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HomeMy WebLinkAboutUrgency Ordinance 3986 - An Interim Ordinance Establishing a CITY OF HUNTINGTON BEACH PROOF O F LEGAL NOTICE URGENCY ORDINANCE NO. PUBLICATION 3990 Adopted by the City Council on SEPTEMBER 16,2013 "AN INTERIM URGENCY( ORDINANCE OF THE CITY. COUNCIL OF THE CITY' STATE OF CALIFORNIA) OF CALIFORNIA,EX BEACH, IFORNI ,EXTENDING' THE `MORATORIUM ON �+�+� THE. CONVERSION OF ANY MOBILEHOME PARK COUNTY ®F ORANGE ) CURRENTLY EXISTING APARK ; THE CITY FROM A PARK i OCCUPIED PRIMARILY OR EXCLUSIVELY BY. RESIDENTS OVER THE' AGE OF 55 YEARSi am a citizen of the United States and a (SENIOR RESIDENTS)TO A MOBILEHOME PARK resident of the County of Los Angeles; I ALLOWING RESIDENTS am over the age of eighteen years, and OF ALL AGES UNTIL i APRIL 30,2014,TO TAKE EFFECT SYNOPSIS:IMMEDIATELY" not a party to or interested in the notice Pursuant t°City Council published. I am a principal clerk of the direction, the City At- torney created Interim i HUNTINGTON BEACH Urgency Ordinance No. 3986 which was adopted INDEPENDENT; which was adjudged a August 5, 2013 estab lishing a temporary mor. newspaper. of general:., circulation on , atorium on the , conversion/change of September 29, 1961, case A6214, and any mobile home park June 11 1963 case A24831 for the City from, park oc ' ' ' currently existing in the cupied primarily or ex- City of Huntington Beach, County of clusively by residents over the age of 55 years Orange, and the State of California. i (Senior Residents) to a mobile-home park allow-j Attached to this Affidavit is a true and ing residents of all ages. State law limits the of-, complete copy as was printed and ! fective period of urgency interim ordinances to 45 published on the following date(s): days from adoption un- less otherwise extended. The City Council ex- tended the urgency in- terim ordinance by adopting Ordinance No. Thursday, September 26, 2013 3990 extending the mor- atorium until April 30, 2014. This extension re- quired a four-fifths vote certify (or declare) under penalty for adoption and'will allow staff additional dy and of perjury that the foregoing is true Iyzetoastregulatonry and correct. framework to address the senior housing is-i sues in Huntington! Beach. PASSED AND ADOPTED by the City Council'of j the City of Huntington Beach at a.regular meet-� Executed on October 2, 2013 ing held September 16, 2013 byr at Los Angeles, California voted°"°wing °" call; AYES: Sullivan, Hardy, Boardman,, Carchio, Shaw,Katapodis NOES:Harper ABSTAIN:None ABSENT:None THE FULL TEXT OF THE ORDINANCEAS" B AVAILABLE IN THE CITY; CLERK'S OFFICE. Signature This,ordinance is effec- tive immediately. CITY OF HUNTINGTON BEACH . 2000 MAIN STREET HUNTINGTON BEACH, CA 92648 714-536-5227 JOAN L.FLYNN,CITY CLERK Published H.B. Indepen-i dent9/26/13 j 1. Dept. ID ca 13-011 Page 1 of 2 ' Meeting Date:9/16/2013 7v A)O) CITY OF HUNTINGTON BEACH � . REQUEST FOR CITY COUNCIL ACTION MEETING DATE: 9/16/2013 SUBMITTED TO: Honorable Mayor and City Council Members SUBMITTED BY: Jennifer McGrath, City Attorney PREPARED BY: Jennifer McGrath, City Attorney SUBJECT: Adopt Ordinance No. 3990, an Interim Urgency Ordinance Extending the Moratorium on the Conversion of Senior Mobile Home Parks (established by Ordinance No. 3986 on August 5, 2013) for an Additional Ten Months and Fifteen Days (Requires 4/5 Vote) Statement of Issue: Pursuant to City Council direction, the City Attorney created Interim Urgency Ordinance No. 3986 which established a temporary moratorium on the conversion/change of any mobile home park currently existing in the City from a park occupied primarily or exclusively by residents over the age of 55 years (Senior Residents)to a mobile home park allowing residents of all ages. State law limits the effective period of urgency interim ordinances to 45 days from adoption unless otherwise extended. The City Council may extend the urgency interim ordinance for an additional 10 months and 15 days after proper public notice and public hearing is provided. This extension requires a four-fifths vote for adoption. The extension of this ordinance will allow staff additional time to study and analyze a regulatory framework to address the senior housing issues in Huntington Beach. Financial Impact: N/A Recommended Action: Adopt Ordinance No. 3990, "An Interim Urgency Ordinance Of The City Council Of The City Of Huntington Beach, California, Extending For Ten Months And Fifteen Days The Moratorium On The Conversion Of Any Mobilehome Park Currently Existing In The City From A Park Occupied Primarily Or Exclusively By Residents Over The Age Of 55 Years (Senior Residents) To A Mobilehome Park Allowing Residents Of All Ages, To Take Effect Immediately." Alternative Action(s): Do Not Adopt Ordinance No. 3990, "An Interim Urgency Ordinance Of The City Council Of The City Of Huntington Beach, California, Extending For Ten Months And Fifteen Days The Moratorium On The Conversion Of Any Mobilehome Park Currently Existing In The City From A Park Occupied Primarily Or Exclusively By Residents Over The Age Of 55 Years (Senior Residents) To A Mobilehome Park Allowing Residents Of All Ages, To Take Effect Immediately" Analysis: A temporary land use regulation (often called a "moratorium") is a mechanism by which a zoning regulation is adopted for a limited period of time without having to go through the normal process of public hearings. State law requires a current and immediate threat to the public health, safety and welfare in order to adopt or extend a moratorium. In this case, the City of Huntington Beach has adopted an urgency ordinance and moratorium that is only in effect for 45 days. In order to continue to preserve the status of mobile home parks operating as senior-only parks, while staff continues to study the effects of regulating senior mobile home parks, the City will need to HB -743- Item 21. - 1 Dept. ID ca 13-011 Page 2 of 2 Meeting Date:9/16/2013 extend Interim-Urgency Ordinance No. 3986 for an additional 10 months and 15 days to preserve the-existing senior.only.mobile home parks. Environmental Status: N/A Strategic Plan Goal: Enhance and maintain public safety Attachment(s): Ordinance No 3990, "An Interim Urgency Ordinance Of The City Council Of The City Of Huntington Beach, California, Extending For Ten Months And Fifteen Days The Moratorium On The Conversion Of Any Mobilehome Park Currently Existing In The City From A Park Occupied Primarily Or Exclusively By Residents Over The Age Of 55 Years (Senior Residents) To A Mobilehome Park Allowing Residents Of All Ages To Take Effect Immediately" Item 21. - 2 xB -744- AT TACHMENT # 1 ORDINANCE NO. 3990 AN INTERIM URGENCY ORDINANCE OF THE CITY COUNCIL OF THE CITY OF HUNTINGTON BEACH, CALIFORNIA, EXTENDING THE MORATORIUM ON THE CON'vBRSION OF ANY MOBILEHOME FARM CURRENTLY EXISTING IN THE CITY FROM A PARK OCCUPIED PRIMARILY OR EXCLUSIVELY BY RESIDENTS OVER THE AGE OF 55 YEARS (SENIOR RESIDENTS)TO A MOBILEHOME PARK ALLOWING RESIDENTS OF ALL AGES UNTIL APRIL 30, 2014, TO TAKE EFFECT IMMEDIATELY The City Council of the City of Huntington Beach does hereby ordain as follows: SECTION 1. FINDINGS. The Ordinance No. 3986, enacted by the City Council of the City of Huntington Beach (the"City") on August 5, 2013 placed a forty-five (45) day moratorium on the conversion of any mobilehome park existing in the City on that date from a park occupied primarily or exclusively by residents over the age of 55 years(senior residents)' to a mobilehome park allowing residents of all ages. In part the moratorium on conversion allows the City time to study whether an amendment to the Mobilehome Park Overlay District to limit or prohibit such conversions is necessary to protect the public, health, safety and welfare by providing adequate affordable local housing for senior citizens, and whether such an ordinance would have any adverse effects on the general housing market in the City; and Section 65858 et.al. of the California Government Code allows an urgency ordinance enacted under the California Government Code to be extended for ten months and fifteen days past the original 45-day urgency period, following a noticed public hearing, in order to further study the immediate health and safety problems identified in Ordinance No. 3986 and At least ten (10) days prior to September 16, 2013, the City Clerk has caused to be published in a newspaper of general circulation a notice advising that on September 16, 2013 at 6:00 p.m. or as soon thereafter, the City Council will conduct a public hearing to consider extending Interim Ordinance 3986; and such public comment and hearing was conducted on September 16, 2013 at the regular City Council meeting. SECTION 2. EXTENSION OF MORATORIUM. The initial forty-five (45) day moratorium on mobilehome park conversions enacted by Ordinance No. 3986, is hereby extended until April 30, 2014 and shall take effect immediately. SECTION 3. DECLARATION OF URGENCY, FINDINGS. Ordinance No. 3990 as well as staff report in support of the Request for Council Action advances the idea that the City of Huntington Beach ("City") does not have enough affordable senior housing options which continues to create problems for seniors that will only increase with the aging population. Mobilehome parks represent one of a few affordable housing options left to senior citizens that 'Housing for Older Persons Act(HOPA)provides that"Senior"is defined as someone 62 years old and over. HOPA defines housing that are restricted to 55+,as"Housing for Older Persons". 13-3865/Interim Mobile Home Park Ordinance.doex Ordinance No. 3990 permit exclusive residence in a detached dwelling by those individuals over the age of 55 years. As set forth in the Housing.Element of the City's General Plan, an important.goal for the City is to preserve the existing senior housing stock' which is represented in part by affordable mobilehome housing. "Converting' . mobilehome parks from a "seniors only" to all ages parks would reduce the number of senior housing units available to those persons 55 years of age and older. There are 18 mobilehome parks in the City, 10 of which are operating as senior mobilehome parks. Thus, converting the `seniors only' mobilehome parks to family parks would result in a significant reduction in the number of affordable housing units available to senior citizens of the community and is irreparably detrimental to them as it creates an immediate threat to their health, safety and welfare. . Further, the announcement that the City is studying this issue and may develop a zoning ordinance restricting the change of seniors only mobilehome parks has resulted in the owner(s) of mobilehome park(s) pursuing conversions to all, age mobilehome parks prior to any such ordinance taking effect.' There is immediate threat to the public health, safety and welfare that would result from allowing the unregulated conversion of senior housing to non-senior housing justifies the extension of the interim urgency ordinance. Based on initial research and analysis, in contrast to other senior housing in the City, mobile home parks afford seniors the ability to live in their own homes rather than in apartments and provide a senior living community in low-rise setting that typically provides a clubhouse for community events and socializing as well as recreation facilities inside the park so that the residents can easily walk to these facilities and event. Many of the seniors living in these senior mobile home parks enjoy having their grandchildren visit them in the parks, but they, like the seniors without grandchildren, purchased mobile homes in a senior park in order to live in a quieter community with others in their own age group and purchased their homes in these parks because they were senior parks that only accepted prospective purchasers'of homes in the park if at least one occupant of the mobile home being purchased was 55 years or older. While senior housing complexes in the -City, other than senior mobile home parks, are generally restricted to senior occupancy by conditions, covenants, and restrictions, that is not the case in senior mobile home parks. The residents of those mobile home parks relied upon the representation of the park management and park owners that only seniors could purchase homes in those parks and obtain tenancies in those parks. These representations were set forth in the leases or rental agreements they were required to sign upon purchasing a mobile home in the parks and moving into the parks and in the rules of those parks, which the residents were also required to sign and acknowledge. Now some owners of senior mobile home parks have indicated that they can, and are already attempting to, change their parks from senior parks to family parks, over the objections of their senior residents, simply by changing park rules using the procedure in Civil Code Section 798.25. 'The two letters to residents of Rancho Huntington mobilehome park residents declaring intent that the mobilehome park no longer restrict housing to older persons(55+)are attached to ordinance no3986. 13-3865/Interim Mobile Home Park Ordinance.docx Ordinance No. 3990 While the seniors now living in senior mobile home parks could remain in a park that changed to a family park, those seniors would no longer enjoy the quiet and companionship of a senior community and the limited supply of senior parks that now exists in the City could be greatly diminished or even eliminated. Since mobile homes are not mobile in any practical sense due to the high cost of moving a home, the risk of damage to the home in moving, the loss of improvements-such as porches, patios, carports, and landscaping, which cannot be moved, and the lack of available rental spaces in senior parks, or in any mobile home park in the City or surrounding areas that will accept re-locating homes, senior residents of a park that becomes a family park would have to sell the homes in which they have lived for many years and in which they have invested both financial and personal resources in order to move to another senior facility. After selling their mobile homes, these seniors may no longer have sufficient funds to purchase a mobile home in another senior park or senior facility. The City of Huntington Beach currently does not have a "senior only" mobilehome park zoning ordinance in place, but such a zoning ordinance may be needed in the immediate future to preserve the few senior only housing options left to our senior citizens. The change from a "senior only" mobilehome park to an "all ages" mobilehome park will reduce the number of housing units available to those persons 55 years of age and older. Based upon the foregoing, the City Council finds that there is a current and immediate threat to the public health,.safety and welfare, and the approval of permits or other entitlements authorizing the conversion of senior mobilehome parks for persons 55 years of age and older to a moblilehome park allowing residents of all ages would result in that threat to the public health, safety and welfare. SECTION 4. EFFECTIVE DATE. The Council finds that public health, safety and welfare require that this ordinance become effective upon its adoption and passage, pursuant to California Government Code Section 65858. SECTION 5. SEVERABILITY. If any section, sentence, clause or phrase of this ordinance is for any reason held to be invalid or unconstitutional by a decision of any court of competent jurisdiction, such decision shall not affect the validity of the remaining portions of this ordinance. The City Council hereby declares that it would have passed this ordinance and adopted this ordinance and each section, sentence, clause or phrase thereof, irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid or unconstitutional. 13-3865/lnterim Mobile Home Park Ordinance.docx Ordinance No. 3990 SECTION 6. PUBLICATION. The City Clerk shall cause this ordinance to be posted in three places designated by City Council pursuant to City Charter Section 500(c) and published by title with a brief summary at least once within fifteen (15) days after its adoption in a newspaper of general circulation, published in the County of Orange and circulated in the City, in accordance with Section 36933 of the California Government Code; shall certify to the adoption of this ordinance and shall cause a certified copy of this ordinance, together with proof of publication,-to be filed in the Office of the Clerk of this City. PASSED AND ADOPTED by the City Council of the City of Huntington Beach at' a regular meeting thereof held on the 16th day of September, 2013. s Mayor ATTEST- A APPROVED AS TO FORM: City Clerk Ci Attorney RE APPROVED- IATED AND APPROVED: t anager ity Attorney 13-3865/Interim Mobile Home Park Ordinance.doex Urgency Ord. No. 3990 STATE OF CALIFORNIA ) COUNTY OF ORANGE ) SS: CITY OF HUNTINGTON BEACH ) I, JOAN L. FLYNN, the duly elected, qualified City Clerk of the City of Huntington Beach, and ex-officio Clerk of the City Council of said City, do hereby certify that the whole number of members of the City Council of the City of Huntington Beach is seven; that the foregoing ordinance was read to said City Council at'a regular meeting thereof held on September 16, 2013 and was passed and adopted by at least five affirmative votes of said City Council. AYES: Sullivan, Hardy, Boardman, Carchio, Shaw,Katapodis NOES: Harper ABSENT: None ABSTAIN: None I,JOAN L.FLYNN,CITY CLERK of the City of Huntington Beach and ex-officio Clerk of the City Council,do hereby certify that a synopsis of this ordinance has been published in the Huntington Beach Fountain Valley Independent on September 26,2013 In accordance with the City Charter of said City City Verk and ex-officio Cl Joan L. Fl n�City Clerk of the City Council of the City Deputy City Clerk of Huntington Beach, California NOTICE OF PUBLIC HEARING CITY OF HUNTINGTON BEACH TO EXTEND FOR TEN MONTHS AND FIFTEEN DAYS THE MORATORIUM ON THE CONVERSION OF ANY MOBILEHOME PARK CURRENTLY EXISTING IN THE CITY FROM A PARK OCCUPIED PRIMARILY OR EXCLUSIVELY BY RESIDENTS 55 YEARS_ OR OLDER (HOUSING FOR OLDER PERSONS) TO A MOBILEHOME PARK ALLOWING RESIDENTS OF ALL AGES NOTICE IS HEREBY GIVEN that a public hearing will be held by the City Council of the City of Huntington Beach in the City Council Chambers of the Civic Center located at 2000 Main Street, Huntington Beach, California, at the hour of 6:00 p.m. or as soon thereafter as possible on September 16, 2013 to extend for ten months and fifteen days the moratorium on the conversion of any mobilehome park currently existing in the city from a park occupied primarily or exclusively by residents 55 years or older (housing for older persons) to a mobilehome park allowing residents of all ages. This proposed extension applies City wide to any existing mobile home parks that have at least eighty percent (80%) of the full-time residents aged fifty-five (55) years or older. If you challenge any of the above in court, you may be limited to raising only those issues you or someone else raised at the public hearing described in this notice, or in written correspondence delivered to the City Clerk at, or prior to the public hearing. All citizens are invited to attend the public hearing and provide the City Council with written and oral comments or ask questions concerning this item. The City of Huntington Beach endeavors to accommodate persons of handicapped status in the admission or access to, or treatment or employment in, City programs, or activities. The City of Huntington Beach is an equal opportunity employer. Dated: September 5, 2013 City of Huntington Beach JOAN FLYNN, City Clerk 2000 Main Street Huntington Beach, CA 92648 Telephone: (714) 536-5227 http://huntingtonbeachca.�,ov/HBPubi]cComments/ 11-3133/public hearing notice mobile homes (2).docx 9/.t113 NOTICE OF PUBLIC HEARING CITY OF HUNTINGTON BEACH TO EXTEND FOR TEN MONTHS AND FIFTEEN DAYS THE MORATORIUM ON THE CONVERSION OF ANY MOBILEHOME PARK CURRENTLY EXISTING IN THE CITY FROM A PARK OCCUPIED PRIMARILY OR EXCLUSIVELY BY RESIDENTS 55 YEARS OR OLDER (HOUSING FOR OLDER PERSONS) TO A MOBILEHOME PARK ALLOWING RESIDENTS OF ALL AGES NOTICE IS HEREBY GIVEN that a public hearing will be held by the City Council of the City of Huntington Beach in the City Council Chambers of the Civic Center located at 2000 Main Street, Huntington Beach, California, at the hour of 6:00 p.m. or as soon thereafter as possible on September 16, 2013 to extend for ten months and fifteen days the moratorium on the conversion of any mobilehome park currently existing in the city from a park occupied primarily or exclusively by residents 55 years or older (housing for older persons) to a mobilehome park allowing residents of all ages. This proposed extension applies City wide to any existing mobile home parks that have at least eighty percent (80%) of the full-time residents aged fifty-five (55) years or older. If you challenge any of the above in court, you may be limited to raising only those issues you or someone else raised at the public hearing described in this notice, or in written correspondence delivered to the City Clerk at, or prior to the public hearing. All citizens are invited to attend the public hearing and provide the City Council with written and oral comments or ask questions concerning this item. The City of Huntington Beach endeavors to accommodate persons of handicapped status in the admission or access to, or treatment or employment in, City programs, or activities. The City of Huntington Beach is an equal opportunity employer. Dated: September 5, 2013 'City of Huntington Beach JOAN FLYNN, City Clerk 2000 Main Street Huntington Beach, CA 92648 Telephone: (714) 536-5227 htt6://huntingtonbeachca.gov/HBPublicComments/ 11-3133/public hearing notice mobile homes (2).docx Printed by:06Q2 Patricia Gamino Aug 28:2013,8:41'am Salesperson: BD$'AriQ�Q6: ,, �'. AAS�1tgt8l8at3`�eS t Phone: Adfi35624631 - �= ��� _,:;�Iccaumttnfocmation=,. _._.. _ p d;tnfdCmatton _ t;. Plhone`fif (714)536-5227 ,'Start date.= 09-05-13 -h ''S¢e 1 x 98.410 uN;arissj City Of Huntington Beach(Parent) 4 S_topYi3a#e.! 09-05-13 1 SIZ9i 0.00 TCN inch !, PO Box 784 i '`nttis+eiti--oris! 1 �:-Kejriiifgrd:� Huntington Beac,CA 92648>t 'Rafe:codej &Legal Huntington Beach ;;`iA'dtype Liner x $ Talcen`by 0602 Patricia Gamin + _ Acct .,C000070479 1 r`: - _- --_r::•.- .� -€ 'Class.• 13000_Legal Notices— :Gross; cfice': �$80.00 ubs:s, TCN HBI $80.00 iet,pnce: 1 Glie > Ci#y Of Huntington Beach-Clerk's O `'Placed tiy; Patty Esparza FeX_#t'i(714)374-1557 ` ': I Ow.MC Oc ksc..ts�j 1l6 1 Ad Copy: NOTICE OF PUBUC HEARING CRY OF HUNTINGTON BEACH TO EXTEND FOR TEN MONTHS AND FIFTEEN DAYS THE MORATO- RIUM ON THE CON- VERSION OF ANY MOBILEHOME PARK CURRENTLY EXISTING IN THE CITY FROM A PARK OCCUPIED PRI- MARILY OR EXCLU- SIVELY BY RESIDENTS 55 YEARS OR OLDER (HOUSING FOR OLDER PERSONS) TO A MO- BILEHOME PARK AL- LOWING RESIDENTS OF ALL AGES NOTICE IS HEREBY GIVEN that a public hearing will be held by the City Council of the City of Huntington Beach in the City Council Chambers of the Civic Center located at 2000 Main Street, Huntington Beach, California, at the hour of 6:00 p.m, or as soon thereafter as possible on September 16, 2013 to extend for ten months and fifteen days the mora- torium on the conver- sion of any mobilehome park currently existing in the city from a park occupied primarily or exclusively by residents 55 years or alder (housing for older persons) to a mobile- home park allowing residents of all ages. This proposed extension applies City wide to any existing mobile home parks that have at least eighty percent (90%) of the full-time residents aged fifty-five(55) years or older. If you challenge any of the above in court, you may be limited to raising only those issues you or someone else raised at --- ad proof pg.1 1 f;. 0 LA.SS.I F:11,E D r r m,== : •.. - Printed by:0602 Patricia Gaffdno Aug 29,2013,8:41 am` j IIpgAlgjC�'tg Salesperson: OUR" Phone: Adit3S624631 the public hearing described in this notice, or in written corre- spondence'delivered to the City Clerk at, or prior to the public hearing. All citizens are invited to attend the public hearing and provide the City Council with written and oral comments or ask questions concern- ing this item. The City of Huntington Beach endeavors to accommodate persons of handicapped status in the admission or access to, or treatment or employment in, City programs, or activities. The City of Huntington Beach is an equal opportunity employer. Dated: September 5, 2013 ' City of Huntington Beach JOAN FLYNN,City Clerk 2000 Main Street Huntington Beach,CA 92648 Telephone:(714)536- 5227 http:// huntingtonbeachca.gov/ HBPublicComments/ --- ad proof pg.2 --- PROOF O F NOT OUR RING QTY OFNUNTINGTNGTON PUBLICATIONFACH BAN TO EXTEND FOR TEN MONTHS AND FIFTEEN D A Y S T H E MORATORIUM ON THE CONVERSION OF ANY MOBILEHOME PARK CURRENTLY ,EXISTING STATE OF CALIFORNIA) IN THE CITY FROM A PARK OCCUPIED PRIMARILY OR )' EXCLUSIVELY BY SS, RESIDENTS 55 YEARS ) OR 'OLDER (HOUSING FOR OLDER PERSONS) COUNTY OF ORANGE TO A MOBILEHOME PARK ALLOWING RESIDENTS OF ALL AGES I am a citizen of the United States and a NOTICE IS HEREBY EN that a public hearing resident of the County of Los Angeles• I will c held by the city r Council of the am over the age of eighteen years r and Beach in city h n Huntington the City Coun- cilnot a art to or interested in the notice Chambers of the Civic party center located at 2000 ppublished. I am a principal clerk..of the Main Street, Huntington p p Beach, California, at the HUNTINGTON -BEACH hour of real er as or as soon thereafter as pos- sible n September 16', INDEPENDENT ,which Was-'adjudged a,: zois to extend for ten months and ..newspaper. of general .circulatiori: on fifteen days the mor- September.'29, 1961,.case A6214,, and. sio�'of any tmob lenome June .11, 1963,,'case..A24831:,,for the the c c ty fromestin a�park City of Huntington Beach County of occupied Primarily or exclusively by residents 55 years or older (hous- Orange, and the State of. to a mobilehome park al- .Attached to this Affidavit is a true and lowing residents of all complete copy as was printed and ages. This proposed ex- tension applies City wide to any existing mobile published on the following date(s): home parks that have at least .eighty ,percent (80%) of the full-time residents aged fifty-five (55)years or older. . If oue any of Thursday, September 5, 2013 he abo eailnncourt, you may be limited to raising only those issues you or someone else raised at the public hearing de- certify (or declare) under penalty scribed in this notice,or corre- spondence written corre- of perjury that the foregoing is true the City delivered to r the City Clerk, at, or prior to the public hear- and correct. All citizens ere invited-to, attend the public hear- ing and provide the City Council with written and oral comments or ask questions concerning Executed on September 11 , 2013 this item. The City of Huntington at Los Angeles, California Beach endeavors commodate personsns Rf of handicapped status in the admission or access to, or treatment or em- ployment in, City pro- grams, or activities.The City of Huntington Beach is an equal er' 5, oppor- tunity employer. Dated: September 2013' SIg118tUC2 C'ty of ton Beach JDAN FLYNN City Clerk 2000 Main Street Huntington Beach,CA 92648 Telephone:(714)536 5227 http:// huntingtonbeachca.gov/ HBPublicComments/ Esparza, Patty From: Surf City Pipeline [noreply@user.govoutreach.com] Sent: Sunday, September 15, 2013 12:13 PM To: CITY COUNCIL; Agenda Alerts Subject: Surf City Pipeline: Comment on an Agenda Item (notification) Request# 15811 from the Government Outreach System has been assigned to Agenda Alerts. Request type: Comment Request area: City Council - Agenda& Public Hearing Comments Citizen name: Mary Jo Baretich Description: Dear Council Members, Regarding Item 21, I urge you to adopt Ordinance No. 3990, the Interim Urgency Ordinance extending the Moratorium on the conversion of any mobilehome park currently existing in the city from a park occupied primarily or exclusively by residents over 55 years (Senior Residents) to a mobilehome park allowing residents of all ages. As you are aware, these seniors moved into their publicized Senior Park to live in an environment set up for Senior living. The amenities, safety, noise level, and total atmosphere are not the same as in an All-Age park. Seniors in their Senior Parks experience a quiet enjoyment of the Jacuzzi and pool without noisy teenagers or small tots jumping in next to them, quiet reading or games in the clubhouse and library, and leisurely walks around the park on roads without the worry of teenage drivers speeding down the street or skateboarders running into them and disabling their wheelchairs or walkers. Living is a Senior Park is similar to living in the Huntington Landmark. Please vote Yes on this Ordinance. Unfortunately, I am currently in Washington State at this time and cannot speak at the September 16th City Council Meeting. Thank you, Mary Jo Baretich State President, Golden State Manufactured-home Owners League (GSMOL) Expected Close Date: 09/16/2013 Click here to access the request Note: This message is for notification purposes only. Please do not reply to this email. Email replies are not monitored and will be ignored. SUPPLEMENTAL COMMUNICATION Meeting Date:-� ( Z/-3 Agenda item No. MHeT Manufactured Housinp,Educational ?a4z�' BOARD OF DIRECTORS September 16, 2013 Errealke Board Sent via E-Mail to j flvn 0ij.surf'cityzhb.org Araident %Wn IlomhurC 1Wh idenl SUPPLEMENTAL &d Art&rwn i'macu , COMMUNICATION1AW Milk Mayor Connie Boardman arr.•relary Mayor Pro Tem Matthew Harper Natwieraaygru Members of the City Council Moo" 9116/'�10 Li `"""'m'il talean CirBiolo City of Huntington Beach &Ath Caw nhivr 2000 Main Street 1o#W&I%m No, L.ImrStan Nl h4till..lr.li.r.hrr Stan Huntington Beach, California 92648 4•uz MnAitiu Bo Br,nd-Y:i Pmrierx Nib Rend RE: City Council Item 21 — OPPOSE EXTENSION OF MORATORIUM duke Faitbndh�r Jx;Gn�•ning Bib 11a ""' Honorable Mayor Boardman and Council Members: Craig lloua.w .h•rry D.Jar•nbson JimJ .4 A° MHET is a non-profit association dedicated to the preservation the manufactured im Martin Dann Panrheri housing lifestyle and to the protection of the property rights of the mobile home park Adrtwry Coneaditer TettyDox•dall business owners who provide housing in the seventeen privately owned mobile home David FYnwoiw A parks in the City of Huntington Beach. !tlt.lanr. D icr Thom, Punresrdears Ed We are opposed to the City enacting any regulations that will restrict the property rights Ed F.�an•. J.It.6'ii,W„<. of the owners of these parks. This includes the enactment of any restrictions by the City W.L.�hiBlrr Riker'Dougher,Sr.drSr• rrrry Doug that will require the private business owner to discriminate against potential customers Pnttl Rncl�iek based on JanrtCBixat age. Specifically, MHET opposes the adoption of any zoning ordinance fluke hrr flrr;rn.l6non.., urgency ordinance or moratorium that would restrict a property owner from renting their a ChrinTra&) Larz ASn.•\don property to any age group they choose. Ja%r Jones &tith rAmnhLws rrai¢11Okinder 11 Rotrat Ohrn We oppose the extension of the moratorium for 10 months. Stan bts 01.Jr. Eile.•n Cirilln LUerrnte Attached are letters from the owners of Huntington Beach mobile home parks urging the _4ward meat City to stay out of regulating how the manage their business. Award Rer•lplenGv Y Y g g Y g Norm bic4d- Jahn Cwan Mkn`v x,,L Additionally the City needs to be aware of the risks involved in going down this path. I E.t LogHrt A.n A.Bs2cs have attached an article which describes the City of American Canyon paying $575,000 HaJ,Trycolden Bam•F liatstrn to a mobile home park owner who sued the City on the issue of regulating the JZ.NlM At rY conversion of parks from senior to all-age facilities. This is not a risk the City of 101A Huntington Beach can afford to take! Ahore and Regond Award Rw:tplrntx A'iliishtdler As previously outlined and communicated with the Council, the following reasons Stan hla;ill Den Jnr,hg support our request to not extend the moratorium and to not move forward with the raw Bmtwirk pp q JC.arelit im Man ��s n adoption of regulations preventing parks from changing from senior to all-age Jartira Junrs communities. CM4u natiiPco luith Cax•nhiw.-r Janlra&Bnuiek Freruttre Director eaW Pa.eeo dr Alicia,Suite 120•Laguna Milts;Cal�i)ruia 9KV•Phoxte:949.&0.3*03•F(m 949.&AS310 Vick1eTa169• EnwO:irlloCa'mh.t.nrp • *hsite:traw.rnhet.org Southern California VHET Serving Orange,Riverside anti.Sala Bernardino Counties since 1982 Page Two • Findings cannot be made that there is a need to preserve the fewer than 1500 mobile home units in Huntington Beach mobile home parks that may be occupied by seni6rs.9 These 1500 units make up only 2%of the total 78,000 total housing units in the Cify`that;are available to seniors city-wide. Additionally, the seniors living in these mobile homes are an extremely small special interest group of only .03% of all of the 47,426 seniors living in the City. And, residency by families and children, per se, cannot'possibly pose a serious or immediate threat to public health and safety. • Prior-to this issue:being raised by the City Council, no mobile home parks in the City were contemplating changing the age rules. As a result of the City Council's action, at least one mobile home park owner has served legal notices to the park residents in order to vest their rights to change from a senior park to an all age park. This park owner has repeatedly stated on the record that they do not want to change to an all age park at this time, but under the circumstances they feel they have not choice but to take action to protect their property rights. • This precipitous action to protect less than .03%of the seniors living in the City is a potentially extremely costly action for a City with far more important and pressing financial challenges and, as previously stated, is completely unnecessary. The City Attorney has already put on the Council's agenda discussions regarding the threat of litigation by mobile home park owners over this issue. • The City should not be in the business of telling property and business owners how to run their business operations when it comes to who they must choose as customers. Would the City adopt a similar ordinance that would require apartment owners, restaurant owners, and other businesses to serve only seniors who make up only 25% of the City's population? • There are many factors for a business to consider when choosing who its customers are. In Huntington Beach the City's mobile home parks are almost evenly split between all-age and senior communities. The free market system is working. The City does not have to "fix" it. Apparently, at this time, there are enough seniors interested in living in a mobile home in Huntington Beach. However, as time changes and demographics change,the owner of a business should be able to modify the business to accommodate the changes. To the case in point, there may be increasing opportunity for seniors regarding housing options in the future and mobile homes may become less desirable for seniors than the other options. In that case, the owners of the mobile home parks that are currently senior would need to consider a change in their business. Page Three • There is no need to force a very small segment of the City's housing providers to provide housing only for seniors. There are currently a significant number of senior housing opportunities in Huntington Beach to provide for the seniors. A quick search for"senior housing in Huntington Beach" resulted in a variety of senior apartments, condominiums, and other facilities. Of course, the vast majority of Huntington Beach seniors live in single family detached housing. • A mobile home park that is designated a"senior"community or, "housing for `older persons' over 55 years of age", are not required to have 100% of the occupants be 55 years of age or older. According to federal law, up to 20% of the residents of the community may be all-ages. Seniors living in the"senior"parks are not now living in communities that are all seniors. The City refers to parks with occupancy by eighty percent older persons; however, there is no mention of qualified parks for "older persons," which requires compliance with a comprehensive litany of requirements and conditions. Mere occupancy is not enough; the City cannot force owners to become"older persons"housing without establishing evidence of compliance with ALL federal requirements of the affected parks. • When a park is a senior park, the mobile home owners who want to sell their homes are restricted to selling to only 25% of the buyers and are not allowed to sell to the other 75% of willing buyers who are not seniors. Countywide the senior population is only 16.5%. Without the senior restriction, the seller has access to 100% of the buyers. This is a dramatic disadvantage to the owners of mobile homes. • Moreover, the elder communities in Huntington Beach parks all appear to be homogenous enclaves of Caucasian residency. Excluding families is to cause a disparate impact of shutting out families. Families are a disproportionately minority (protected classes under federal law). The disparate impact caused by the moratorium results in an unmistakable but clear secondary effect: the denial of housing based on national origin, color and race. • When a park is designated as a senior park homes may only be sold to seniors. If an underage person inherits a mobile home upon the death of a tenant,the underage person may not move into the park and is forced to sell the home. This is only one example of the "unintended consequences" of the City trying to regulate who can and cannot live in mobile home parks. Who will police and enforce the regulations? Conduct required surveys? Qualify new tenants?Defend the park owners in housing discrimination complaints?Advertise housing to conform to zoning as required? Undertake all the requirements of the operation of the parks required of the city when a zoning law is proposed?The City assumes all responsibilities for intent to operate, yet there is no direction,budgeting, or manpower devoted to paying for these new city services. Page Four We urge the City Council to reject the proposal to regulate mobile home park housing and to not adopt a moratorium or other regulations restricting who can live in the City's mobile home parks. Sincerely, Vickie Talley Executive Director cc: Huntington Beach Mobile Home Park Owners Attachments: "American Canyon settles mobile home suit for%575,000" Letters from Scandia Mobile Country Club, Huntington Shorecliffs, Brookside Manor and Del Mar Mobile Estates American Canyon settles mobile home suit for$575,000 http://napavalleyregister.com/news/local/american-canyon-settle... Napa VaIley Regisi erocom American Canyon settles mobile home suit for $575,000 JULY 01,2011 7:48 PM • KERANA TODOROV American Canyon will pay a Roseville-based mobile home park owner $575,000 to settle a federal suit the owner filed last year, saying the city had violated federal fair housing laws, city officials said Friday. The American Canyon City Council voted Tuesday in a special meeting to settle the lawsuit that mobile home park owner Ken Waterhouse filed on May 2010 after the city passed a law to prevent the conversion of senior-restricted mobile home parks into all-age facilities. Waterhouse owns the business that runs Napa Olympia Mobilodge on American Canyon Road, a facility where the vast majority of residents were seniors. In 2006, Waterhouse and his representatives said they would lift the age restriction at the park, whipping a storm of protest from the senior residents. The residents pleaded with city officials to find a way to keep their mobile home park restricted to seniors, saying the facility was not designed for children and that they had moved there because it was an age-restricted facility. The City Council, which wanted to preserve affordable housing, eventually took a series of measures to prevent the conversion of such parks into all-age facilities. In the lawsuit, filed in May 2010 in U.S. District Court for the Northern District of California in San Francisco, Waterhouse's attorney, David Spangenberg, argued that the Napa Olympia Mobilodge had not been a senior-restricted park for years because past owners had not taken a census of the residents' age as required under federal law. On June 6, U.S. District Judge William Alsup granted victory to Waterhouse, saying the city had violated the Fair Housing Act. On Monday, the parties met to discuss a settlement that resulted in Tuesday's vote. Neither City Attorney Bill Ross, Spangenberg or Waterhouse could be reached for comment Friday. 1 of 1 9/12/13 4:28 PM a Brookfield Manor,Inc. Del Mar Mobile Estates, Inc. 9850 Garfield Avenue 19251 Brookhurst Street Huntington Beach,CA 92646 Huntington Beach, CA 92646 September 12,2013 Mayor Connie Boardman Mayor Pro Tem Matthew Harper Members of the City Council City of Huntington Beach 2000 Main Street Huntington Beach,California 92648 RE: City Council Item 21 Oppose Extension of MR Park Moratorium Mayor Connie Boardman and Members of the City Council, I am writing as a Huntington Beach mobile home park owner to urge you to not extend the moratorium and urgency ordinance regulating age restrictions in the city's mobile home parks. The owners of the city's mobile home parks are responsible business operators who offer housing to both seniors and families. We do not need to be regulated. There is no need to have the City become involved in the management of our businesses by regulating who we can or cannot rent to. The free market place provides those business incentives and today the ciry's mobile home parks are almost evenly split between senior and all age housing. t While we have no plans to modify our current business plan,we believe that there is no place for government to step in and tell us how to operate our business. We respectfully request that you do not extend the moratorium on mobile home parks. Sincerely, 1�l i Gregory C. Hexberg President Huntington Shorediff LP 4040 MacArthur Blvd—Suite 300 Newport Beach, CA 92660 949-251-0444 (fax) 949-251-0888 September 12,2013 Mayor Connie Boardman Mayor Pro Tern Matthew Harper Members of the City Council City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: City Council Item 21 Oppose Extension of ME Park Moratorium Mayor Connie Boardman and Members of the City Council, 1 am writing as a Huntington Beach mobile home park owner to urge you to not extend the moratorium and urgency ordinance regulating age restrictions in the city's mobile home parks. The owners of the city's mobile home parks are responsible business operators who offer housing to both seniors and families. We do not need to be regulated. There is no need to have the City ecome mvo v ui a managemen o bmtaLw by regulating who we can or caunot rent to. The free market place provides those business incentives and today the city's mobile home parks are almost evenly split between senior and all age housing. 7 While we have no plans to modify our current business plan,we believe that there is no place for govermnent to step in and tell us how to operate our business. We respectfully request that you do not extend the moratorium on mobile home parks. Sincerely, John R. Saunders Manager Huntington Shorecliffs LP z SKANDIA MOBILE COUNTRY CLUB Division of I.UBBELL FAMILY,LLC 1161 Bryant Road Long Brcb,CA 90815 562.498-2248 FAX 362.597-1958 September 12,2013 Mayor Connie Boardman Mayor Pro Tem Matthew Harper Members of the City Council City of Huntington Beach 2000 Main Street Huntington Beach,California 92648 RE: City Council Item 21 Oppose Extension of MH Park Moratorium Mayor Connie Boardman and Members of the City Council, 1 am writing as a Huntington Beach mobile}tome park owner to urge you to not extend the moratorium and urgency ordinance regulating age restrictions in the city's mobile home parks. The owners of the city's mobile home parks are responsible business operators who offer housing to both seniors and families. We do not need to be regulated, There is no need to have the City become involved in the management of our businesses by regulating who we can or cannot rent to. The free market place provides those business incentives and today the city's mobile home parks are almost evenly split between senior and all age housing. While we have no plans to modify our current business plan,we believe that there is no place for government to step in and tell us how to operate our business. We respectfully request that you do not extend the moratorium on mobile home parks. Sincerely, % Sandra H. Darling Owner, Skandia Mobile Country Club t I Esparza, Patty From: Fikes, Cathy Sent: Monday, September 16, 2013 12:05 PM To: Esparza, Patty Subject: FVV: Vote to preserve Senior Mobile Home Parks From: Martin Van Genderen [mailto:maartienvg@gmail.com] Sent: Friday, September 13, 2013 10:12 PM To: Carchio, Joe Cc: Fikes, Cathy Subject: Vote to preserve Senior Mobile Home Parks Dear Council Member Carchio, Appreciative and mindful of your support in the past vis-a-vis issues affecting Seniors , I now earnestly request your support to extend the moratorium to preserve Senior Mobile Home Parks. Martin Van Genderen Rancho Huntington - Spc 126 Huntington Beach, CA 92646 SUPPLEMENTAL COMMUNICATION Meeting Date: �1 /&Z3 Agenda Item No.— 6?3 z i Esparza, Patty From: Fikes, Cathy Sent: Monday, September 16, 2013 12:05 PM To: Esparza, Patty Subject: FW: Moratorium From: Janice Genelle [mailto:genellejan@socal.rr.com] Sent: Saturday, September 14, 2013 7:06 AM To: Carchio, Joe Cc: Fikes, Cathy Subject: Moratorium Dear Council Member Carchio, Your vote to extend the moratorium to preserve senior mobile home parks is very important. I appreciate your support in the past and look forward to your continued interest and participation in the future. Mr. Carchio, as a resident of Rancho Huntington Mobile Home Estates and as a voter living in Huntington Beach, I ask you to please vote in favor of the moratorium to keep the senior parks in HB senior. The folks, who purchase a home in a Senior Park, do so with the full intent of living in community with other seniors. However, we are now fully aware that the term Senior Park is a loose term that can be altered at any time by the owners of a mobile home park. When a park is reclassified from a Senior Park to a family park, it has the same effect as would any residential area that is re-zoned in the city. If a family would purchase a home in a residential area, planning to live in community with other families, and then find out that the area they live in is to be re-zoned to accommodate a business, this family and other families would be rightly devastated. However, this would not happen on a whim like it has happened in a mobile home park because a residential area is zoned in such a manner as to provide protection for the home owners. Sadly, as seniors, we are aware that there is little protection provided to us, living as we do in a Senior Park. I have supported you with my vote and I would appreciate your vote supporting me and my neighbors at Rancho Huntington. Thank you, Council Member Carchio. Janice Genelle Space#89 SUPPLEMENTAL COMMUNICATION Meeting Date:��LL�,I Agenda Item No. O3 Z i Esparza, Patty From: Fikes, Cathy Sent: Monday, September 16, 2013 12:05 PM To: Esparza, Patty Subject: FW: Moratorium -----Original Message----- From: sparisi@socal.rr.com [mailto:sparisi@socal.rr.com] Sent: Saturday, September 14, 2013 10:43 AM To: Fikes, Cathy Subject: Moratorium Mr. Carchio, as a resident of Rancho Huntington Mobile Home Estates and as a register voter living in Huntington Beach, we ask you to please vote in favor of the moratorium to keep the senior parks in HB SENIOR PARKS. Thank You for your consideration in this matter. Sam F Parisi 714-655-9750 SUPPLEMENTAL COMMUNICATION Meeting Date: __ 2//,/, Agenda item No. Esparza, Patty From: Fikes, Cathy Sent: Monday, September 16, 2013 12:04 PM To: Esparza, Patty Subject: FW: HB Senior Mobile Home Parks SUPPLEMENTAL COMMUNICATION From: Lisa McNeil [mailto:lcmcneil39@gmail.com] Sent: Sunday, September 15, 2013 2:15 PM Meei1V pate: To: Carchio, Joe Cc: Fikes, Cathy Subject: HB Senior Mobile Home Parks Agenda Item No._ Dear Council Member Carchio, I am writing to thank you for your vote on the temporary moratorium, and to ask you to support a long-term moratorium to protect seniors in Huntington Beach mobile home parks. I currently live in Rancho Huntington, as does my mother who will be 87 next month, and my cousin who is in the latter stage of early onset Alzheimer's disease. I am only in my early 50s and planned to continue working full-time until I was at least 67, but I have been diagnosed with an aggressive form of rheumatoid arthritis that has already required several surgeries and that I'm afraid may result in the loss of my job. I have already lost many months of pay in the past two years due to the surgeries. I attended the city council meeting where you said that you thought we could negotiate a solution between Rancho Huntington owners and residents if all parties were sincere in what they want to do. I would like to believe it is possible to work out a reasonable compromise but I've lost all faith in that being feasible. Recently I received a call at work on my emergency-only contact number from Drieta Bronkey, a representative of the management company, who very aggressively tried to convince me to sign the all age lease and to persuade my mother to sign the lease. At that point we had not even seen copies of the newest version of the lease. I mentioned to Ms. Bronkey that many of the residents of these senior parks, like myself and my family, are dealing with serious health issues and/or are quite elderly, and we don't have the resources for the huge rent increase up to $1500 a month or higher within a couple of years that is rumored and that has happened in some other parks. Ms. Bronkey then dismissively said "being elderly or ill has nothing to do with it. My parents are elderly and they are well off financially." I interpreted this to mean that the management company and the owners believe that senior park residents, because we are not wealthy, deserve whatever bad things may happen to us as a result of the park conversions and potential huge rent increases. I am frightened about people like my mother losing much of their life savings that was invested to purchase their homes, and about the limited options ahead that I see for many of us. I don't expect Huntington Beach to be the same small town that my grandparents,parents, and my siblings and cousins and I once lived in, where working class families can thrive and even build or purchase their own homes. At this point all I'm trying to do is keep my mom and myself hanging on here to see my mom through the end of her life in a place she is familiar with, where she still has some surviving friends and family. I know there are many other seniors in these parks who are in similar situations, with modest goals to just live out the rest of their lives in the home that they have invested most of their life savings in. Thank you again for your previous vote, and for taking the time to listen to the concerns of Huntington Beach senior mobile home park residents. Lisa C. McNeil i 19361 Brookhurst St. Space 192 Huntington Beach, CA 92646 lcmcneil39ggmail.com 2 Esparza, Patty From: Fikes, Cathy Sent: Monday, September 16, 2013 12:03 PM To: Esparza, Patty Subject: FW: Thank you for keeping our Senior mobile home parks Senior To all Council From: Jodie Wollman [mailto:jodiewollman@gmail.com] Sent: Sunday, September 15, 2013 7:01 PM To: Boardman, Connie Cc: Fikes, Cathy Subject: Thank you for keeping our Senior mobile home parks Senior Good evening, Mayor Boardman, My name is Jodie, and my husband and I live in Rancho Huntington Mobile Home Estates(RHMHE). I am writing to thank you for all of your support of seniors in Huntington Beach, especially in regard to the ordinance that Councilman Katapodis initiated and the moratorium that you had the foresight to bring to the table,to keep our park a senior community. Thank you, Mayor Boardman! I know that when the City Council votes on Monday, September 16th (Item No. 21 of the Public Hearing portion of the meeting)that you will continue to encourage the entire Council to get this vote right. Thank you. It is imperative that the Council respect and support our senior citizens. Seniors in mobile home parks need you to help us maintain the lifestyle that we voluntarily chose when we purchased our homes—that of a senior community. We need the City Council's assistance to protect us from park owners who want to turn mobile home parks into all-age parks.The senior parks are what our financial situations allow and they afford us the living conditions favorable to seniors,especially those who are frail. Having children and the requisite environment they would produce would make our senior parks much less safe and less hospitable for the elderly. Homeowners in mobile home parks own their individual homes, and we rent the small piece of ground that the home sets on. Even though they are most often known as"mobile homes,"there is nothing "mobile" about these homes. Our current home,for example, is a 2007 triple-wide home with 1,740 square feet of living space. We upgraded from the original 1966, 900-square-foot home that was on the space when we moved into the park in 2000. Even if we were to move our home to another park within Huntington Beach,the cost would be at least$50,000 to dismantle, move and re- set up the home. If the home is moved to Hemet, with mileage alone, I would venture to guess the cost would increase to$100,000. 1 know that you will vote to help seniors—a group that is often the underdog. Thank you, Mayor Boardman,for continuing to do the right thing and voting for the moratorium to keep our mobile park as a senior community. Jodie SUPPLEMENTAL Pete and Jodie Wollman COMMUNICATION 19361 Brookhurst Street, Space 84 n Huntington Beach, CA 92646-2953 Meeting Date: 7 ZZ6,L�j Agenda Item No. i Esparza, Patty From: Fikes, Cathy Sent: Monday, September 16, 2013 12:03 PM To: Esparza, Patty Subject: FW: Vote to keep Senior Parks Senior From: Billrhb@aol.com [mailto:Billrhb@aol.com] Sent: Sunday, September 15, 2013 7:29 PM To: Boardman, Connie Cc: Fikes, Cathy Subject: Vote to keep Senior Parks Senior Good evening, Mayor Boardman, My name is Bill, and my wife and I live in Rancho Huntington Mobile Home Estates (RHMHE). I am writing to thank you for all of your support of seniors in Huntington Beach, especially in regard to the ordinance that Councilman Katapodis initiated and the moratorium that you had the foresight to bring to the table, to keep our park a senior community. Thank you, Mayor Boardman! I know that when the City Council votes on Monday, September 16th (Item No. 21 of the Public Hearing portion of the meeting) that you will continue to encourage the entire Council to get this vote right. Thank you. It is imperative that the Council respect and support our senior citizens. Seniors in mobile home parks need you to help us maintain the lifestyle that we voluntarily chose when we purchased our homes-that of a senior community. We need the City Council's assistance to protect us from park owners who want to turn mobile home parks into all-age parks. The senior parks are what our financial situations allow and they afford us the living conditions favorable to seniors, especially those who are frail. Having children and the requisite environment they would produce would make our senior parks much less safe and less hospitable for the elderly. Homeowners in mobile home parks own their individual homes, and we rent the small piece of ground that the home sets on. Even though they are most often known as"mobile homes," there is nothing "mobile"about these homes. Our current home, for example, is a 2005 double-wide home with 1,640 square feet of living space. Even if we were to move our home to another park within Huntington Beach, the cost would be at least$50,000 to dismantle, move and re-set up the home. If the home is moved to Hemet, with mileage alone, I would venture to guess the cost would increase to$100,000. SUPPLEMENTAL know that you will vote to help seniors-a group that is often the COMMUNICATION underdog. Meeting Date: Agenda Item No.� pZz Thank you, Mayor Boardman, for continuing to do the right thing and voting for the moratorium to keep our mobile park as a senior community. Bill Bill & Karen Reitz 19361 Brookhurst Street, Space 1 Huntington Beach, CA 92646-2954 M'HeT MuLibmrmi Housing Educatiomi BOARD OF Dinc-ToRs September 16, 2013 Kreejitke Board Sent via E-Mail to iflynnAsurffity-lib.om Prrsidenl W nnldoniburg ke PrrAw".. W41 Awlr,nv)n eq Mill-S Mayor Connie,Boardman &"fary Mayor Pro Tem Matthew-Harper N.WU Members of the City, Council Past prm&ent Elleen Cirillo- City of Huntington Beach.- Keith C:m ahiscr 2000 Main Street LhameNnW,n"m.iJter.r Huntington Beach, California.9 2648S Luz,Nfi,kdw BaardAlombetw Njh RE: City Council Item 21 —City in Violation-of California,Government Code hard A.11311 Hill lt�" Honorable Mayor Boardman and Council Members: Uhle llous,-r Ji,rry D.Jae Wn Cunt LIU Jim 11min We have consulted with.legal counsel regarding the action the Council has taken Deann Panchen regarding the moratorium and the pending extension..of the moratorium. It appears that, Advesory Conwittlev the city has Overstepped its authority and is in violation of the California Government Code, Please note the following: Data Thomxt ,Past Presidents Fd EN1110 Cal.Gov.Code § 65858 is cited,by Huntington Beach as authority for enacting, and J.n.Phflur� W.lAn 3fillhr now extending, the "interimurgency ordinance."' 14)6!rf.01mider St Garry D"aher,Sr. hul 13,.tvick Jima Gl&rt § 65858--allbws.a municipality to adopt an interim ordinance"prohibiting any uses QRrko'FWrl;rotMr PAjyve Jnn,N that may, be in conflict with a . . . zoning proposal that the legislative body,planning ilu rN Uu-z MeAda, commission or the planning department is considering:P.r studying or intends to [with QLwnhL,,er study w.ithin.areasonable.time." (sec. 65658(a)) Cmig IWIwor Ruben.` 11 FRP.Itn CiriflD § 65858(c), however,further states that the.municipality "shall not adopt or extend an interim ordinance. . . unless the ordinance containsdegislative.findings that there A Atrard RwIplents is a current.and immediate threat to the public-health, safety,,or-welfare, and thatthe Norm Mc-Adou J�,hn Crm approval of additional'.subdivisions; use permits,variances, building permits, or R .Braxlf� 9.,JLwrLN:%-j any other applicable entitlement for,use Which.is required in order to comply with Ed E-cam L.,;nn�%_Bogm a.zoning ordinance would result,in that threat to public health, safety., or welfare." J,iry,Gc4d,!n llanT 11 Kamm (emphasis:supplied). J,�. Afiuny MIN WHA It does not appear that the original interim urgency ordinance (#3 986)even includes; 'I bore and BP nd Award&VIP a t,, a finding that the approval of additional entitlements would result in the,threat to public health, safetyor welfare. Min JWAS Paul fl,,-toirk G.Brunt,,_%m,n The proposed extension(#3990)jdoes recite.(in the last paragraph of section 3)that Jim Amain jaln"i.jom!i "the approval of permits or other entitlements-authori z Glwlu Thavinso ing the conversion of senior, Ki"b(;wMI&Ir janwn B.&mUck mobile,home parks-for persons 55 years of age and older to a mobilehome park, Ei,ecutlrp Director ZZ J-Pasvo doAliei4,Suite,120-kquw Hills.California.4.0653 a ftynm 94.1)MQ308•Fax-949.380.3310 vi_rkicTalHn Ewaikivofo@mhet.org - fffbsit&wwrttm&etorg, Souther em 6aliforidd-,VHET Suruing Orange,Rh)ersW atid.San Bernardino Cou n ties-sinc e I.V2 Page Two allowing residents of all ages wouldresult in that threat to the public health, safety and welfare." That finding is spurious unless there is actually a municipal permit or other entitlement that would-be needed for an existing senior mobile.home park to convert to an all ages park. But Ordinance 4.3990, itself(in�the 3d paragraph of section 3) acknowledges that owners of senior mobile-home parks can accomplish that conversion"simply by changing park rules using the procedure in.Civil Code Section 798.25." The City appears to have concluded that conversion can be accomplished by private.action, with no municipal entitlement required. §.65858 authorizes a municipality to impose a moratorium on issuing local land use entitlements where such entitlements would threaten the public health, safety and welfare. It appears that Huntington Beach is attempting to use-that provision to prohibit action that does not need a municipal entitlement in the first place (conversion from senior mobile home park to all-ages-mobile home park).. We respectfully urge the City Council to reject the proposal to regulate mobile home park housing and to not adopt a moratorium based upon the fact that the City does not have the authority to enact such a moratorium. Sincerely, Vickie Talley Executive Director cc: Huntington Beach Mobile Home Park Owners Esparza, Patty From: Fikes, Cathy Sent: Monday, September 23, 2013 11:29 AM To: Esparza, Patty Subject: FW: Thank you for keeping our Senior mobile home parks Senior From: Jodie Wollman [mailto:jodiewollman@gmail.com] Sent: Sunday, September 22, 2013 10:30 AM To: Boardman, Connie Cc: Fikes, Cathy Subject: RE: Thank you for keeping our Senior mobile home parks Senior Hello, Mayor Boardman, This is my first opportunity since Monday night's vote to thank you for voting for the seniors in your constituency by voting for the moratorium. Thank you so much for initiating the moratorium and extending it in the vote on Monday night. I am proud to have you representing me and the rest of the seniors in Huntington Beach. Sincerely, Jodie Pete and Jodie Wollman 19361 Brookhurst Street, Space 84 Huntington Beach, CA 92646-2953 (714)963-2214 home (714) 580-7426 Jodie's cell From: Jodie Wollman [mailto:jodiewollman@gmail.com] Sent: Sunday, September 15, 2013 7:01 PM To: 'Connie.Boardman@surfcity-hb.org' Cc: 'CFikes@surfcity-hb.org' Subject: Thank you for keeping our Senior mobile home parks Senior Good evening, Mayor Boardman, My name is Jodie, and my husband and I live in Rancho Huntington Mobile Home Estates (RHMHE). I am writing to thank you for all of your support of seniors in Huntington Beach, especially in regard to the ordinance that Councilman Katapodis initiated and the moratorium that you had the foresight to bring to the table,to keep our park a senior community. Thank you, Mayor Boardman! I know that when the City Council votes on Monday,September 16`h (Item No. 21 of the Public Hearing portion of the meeting)that you will continue to encourage the entire Council to get this vote right. Thank you. 1 It is imperative that the Council respect and support our senior citizens. Seniors in mobile home parks need you to help us maintain the lifestyle that we voluntarily chose when we purchased our homes—that of a senior community. We need the City Council's assistance to protect us from park owners who want to turn mobile home parks into all-age parks.The senior parks are what our financial situations allow and they afford us the living conditions favorable to seniors,especially those who are frail. Having children and the requisite environment they would produce would make our senior parks much less safe and less hospitable for the elderly. Homeowners in mobile home parks own their individual homes, and we rent the small piece of ground that the home sets on. Even though they are most often known as"mobile homes,"there is nothing "mobile" about these homes. Our current home, for example, is a 2007 triple-wide home with 1,740 square feet of living space. We upgraded from the original 1966, 900-square-foot home that was on the space when we moved into the park in 2000. Even if we were to move our home to another park within Huntington Beach, the cost would be at least$50,000 to dismantle, move and re- set up the home. If the home is moved to Hemet,with mileage alone, I would venture to guess the cost would increase to$100,000. 1 know that you will vote to help seniors—a group that is often the underdog. Thank you, Mayor Boardman, for continuing to do the right thing and voting for the moratorium to keep our mobile park as a senior community. Jodie Pete and Jodie Wollman 19361 Brookhurst Street,Space 84 Huntington Beach, CA 92646-2953 2 H- 1 ORDINANCE NO. 3990 AN INTERIM URGENCY ORDINANCE OF THE CITY COUNCIL OF THE CITY�OF HUNTINGTON BEACH, CALIFORNIA, EXTENDING FOR TEN MONTHS AND FIFTEEN DAYS THE MORATORIUM ON THE CONVERSION OF ANY MOBILEHOME PARK CURRENTLY EXISTING IN THE CITY FROM A PARK OCCUPIED PRD4ARILY OR EXCLUSIVELY BY RESIDENTS OVER THE AGE OF 55 YEARS (SENIO RESIDENTS) TO A MOBILEHOME PARK ALLOWING RESIDENTS OF ALL AGES T TAKE EFFECT IMMEDIATELY The City Council of the City of Huntington Beach does hereby ordain follows- SECTION 1. FINDINGS. The Ordinance No. 3986, en ted by the City Council of the City of Huntington Beach (the"City") on August 5, 2013 pl ed a forty-five(45) day moratorium on the conversion of any mobilehome park existin in the City on that date from a park occupied primarily or exclusively by residents over the ge of 55 years(senior residents)' to a mobilehome park allowing residents of all ages. In part e moratorium on conversion allows the Citv time to study whether an amendment to the Mopilehome Park Overlay District to limit or prohibit such conversions is necessary to protect the public, health, safety and welfare by providing adequate affordable local housing for senior citizens, and whether such an ordinance would have any adverse effects on the general housing market in the City; and Section 65858 et.al. of the California iGovernment Code allows an urgency ordinance enacted under the California Government Code to be extended for ten months and fifteen days past the original 45-day urgency period, following a noticed public hearing, in order to further study the immediate health and safety pro 'lems identified in Ordinance No. 3986 and At -least ten-(10) days -prior -to September -16, 201-3, -the City-Clerk has caused to be published in a newspaper of general circulation a notice advising that on September 16, 2013 at 6:00 p.m. or as soon thereafter, �lie City Council will' conduct a public hearing to consider extending Interim Ordinance 3986; and such public comment and hearing was conducted on September 16, 2013 at the regular-City Council meeting. 7 SECTION 2. EXTENSION OF MORATORIUM. The initial forty-five (45) day moratorium on mobilehome park conversions enacted by Ordinance No. 3986, is hereby extended for an additional ten months and fifteen days and shall take effect immediately. SECTIONi3. DECLARATION OF URGENCY, FINDINGS. Ordinance No. 3990 as well as staff report in support of the Request for Council Action advances the idea that the City of Huntington/Beach ("City") does not have enough affordable senior housing options which continues to/Create problems for seniors that will only increase with the aging population. ' Housing for Older Persons Act(HOPA)provides that"Senior"is defined as someone 62 years old and over. HOPA defines housing that are restricted to 55+,as"Housing for Older Persons". 13-3865/101051.doex Mobilehome parks represent one of a few affordable housing options left to senior citizens t t permit exclusive residence in a detached dwelling by those individuals over the age of 55 tears. As set forth in the Housing Element of the City's General Plan, an important goal for thezCity is to preserve the existing senior housing stock which is represented in part by ordable mobilehome housing. "Converting" mobilehome parks from a "seniors only" to al ages parks would reduce the number of senior housing units available to those persons 55 years of age and older. There are 18 mobilehome parks in the City, 10 of which are operating as senior mobilehome parks. Thus, converting the `seniors only' mobilehome park to family parks would result in a significant reduction in the number of affordable housin units available to senior citizens of the community and is irreparably detrimental to them as it creates an immediate threat to their health, safety and welfare. . Further, the annocement that the City is studying this issue and may develop a zoning ordinance restricting the change of seniors only mobilehome parks has resulted in the owners) of mobilehome parkO pursuing conversions to all age mobilehome parks prior to any such ordinance taking effect There is immediate threat to the public health, safety and welfare that would result from allowing the unregulated conversion of senior housing to non-senior housing justifies the extension of the interim urgency ordinance. Based on initial research and analysis, in contras to other senior housing in the City, mobile home parks afford seniors the ability to live in their own homes rather than in apartments and provide a senior living community in low-rise setts g that typically provides a clubhouse for community events and socializing as well as recreation facilities inside the park so that the residents can easily walk to these facilities and event, Many of the seniors living in these senior mobile home parks enjoy having their grandchildren visit them in the parks, but they, like the seniors without grandchildren, purchased mobile homes in a senior park in order to live in a quieter community with others in their own age group and purchased their homes in these parks because they were senior parks that only accepted prospective purchasers of homes in the park if at least one occupant of the mobile home being purchased was 55 years or older. While senior housing complexes yin' the City, other than senior mobile obtle home parks, are generally restricted to senior occupancy by conditions, covenants, and restrictions, that is not the case in senior mobile home parks. /The residents of those mobile-home parks relied upon the representation of the park management and park owners that only seniors could purchase homes in those parks and obtain tenancie/s in those parks. These representations were set forth in the leases or rental agreements they/were required to sign upon purchasing a mobile home in the parks and moving into the parks and in the rules of those parks, which the residents were also required to sign and acknowledge. Now some owners of senior mobile home parks have indicated that they can, and/are already attempting to, change their parks from senior parks to family parks, over the objections of their senior residents, simply by changing park rules using the procedure in Civil Code Section 798.25. 2 The two letters to residents of Rancho Huntington mobilehome park residents declaring intent that the mobilehome park no longer restrict housing to older persons(55+)are attached to ordinance no3986. 13-3865/101051.docx While the seniors now living in senior mobile home parks could remain i�/a park that changed to a family park, those seniors would no longer enjoy the quiet and companionship of a senior community and the limited supply of senior parks that now exists in the City could be greatly diminished or even eliminated. Since mobile homes are not mobile in/any practical sense due to the high cost of moving a home, the risk of damage to the home in moving, the loss of improvements such as porches, patios, carports, and landscaping, which cannot be moved, and the lack of available rental spaces 'in senior parks, or in any mobile4home park in the City or surrounding areas that will accept re-locating homes, senior residents of a park that becomes a family park would have to sell the homes in which they have lived for many years and in which they have invested both financial and personal resources in/order to move to another senior 'facility. After selling their mobile homes, these seniors may no longer have sufficient funds to purchase a mobile home in another senior park or senior facility. The City of Fluntington Beach currently does of have a "senior only" mobilehome park zoning ordinance in place, but such a zoning ordinance may be needed in the immediate future to preserve the few senior only housing options left to our senior citizens. The change from a "senior only" mobilehome park to an "all ages' mobilehome park will reduce the number of housing units available to those persons 55 years of age and older. Based upon the foregoing, the Ci/y Council finds that there is a current and immediate threat to the public health, safety and welfare, and the approval of permits or other entitlements authorizing the conversion of senior 1obilehome parks for persons 55 years of age and older to a moblilehome park allowing reside is of all ages would result in that threat to the public health, safety and welfare. SECTION 4. EFFECTIVE DATE-. The Council' finds that public health, safety and welfare require that this ordinance become effective upon its adoption and passage, pursuant to California Government Code Section 65858. SECTION 5. /SVVERABI]LITY. If any section, sentence, clause or phrase of this ordinance is for an reason held to be invalid or unconstitutional by a decision of any court of competent jurisdic lon, such decision shall not affect the validity of'the remaining portions of this ordinance. T,he City Council hereby declares that it would have passed this ordinance and adopted"this or• inane and' each section, sentence, clause or phrase thereof, irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid or unconstitutional. TA � i 13-3865/101051.docx SECTION 6. PUBLICATION. The City Clerk shall cause this ordinance to be posted,i/r� three places designated by City Council pursuant to City Charter Section 500(c) and published by title with a brief summary at least once within fifteen(15) days after its adoption in a newspaper of general circulation, published in the County of Orange and circulated in'the City, in accordance with Section 36933 of the California Government Code, shall certify/to the adoption of this ordinance and shall cause a certified copy of this ordinance, together with proof of publication, to be filed in the Office of the Clerk of this City. PASSED AND ADOPTED by the City Council of the City of'Huntington Beach at a regular meeting thereof held on the 16th day of September, 2013. /Mayor ATTEST: APPROI D AST FORM: M/ i//', L�- City Clerk C City Attorne. REV ND APPROVED: INITIATED APPROVED: PO4anager %x City A orney =r 1 13-3865/101051.docx PROOF OF PUBLICATION STATE OF CALIFORNIA) SS. PARK OCCUPIED PRI- REPRESENT ONE OF A CITY. RECENTLY, TH ) WOFHUNiINGTON' MARILY DR EXCLUSIVE- FEW, AFFORDABLE NINTH CIRCUIT COUR COUNT OF ORANGE LY BY RESIDENTS OVER HOUSING OPTIONS LEFT 'OF APPEALS ISSUED tN. THE AGE OF 55 YEARS TO SENIOR CITIZENS RULING ' IN PUTNAi LEKNOM " (SENIOR RESIDENTS). THAT PERMIT EXCLU- FAMILY PARTNERSHI UROMCIfW1NMaNO. TO A MOBILEHOME SIVE RESIDENCE IN A V. CITY 'OF YUCAIW PARK ALLOWING RESI- DETACHED DWELLING ("PUTNAM") (2012).67 1 am a citizen Of the United States and a 3986 DENTS' OF ALL. AGES BY THOSE INDIVIDUALS F.3D 920, IN WHICH I �t� AND DECLARING<`THE OVER THE AGE OF 55 DETERMINED THAT CIT resident of the County of Los Angeles; I Adoptedb�tlroUty�oolldl URGENCY THEREOF;TO YEARS. THERE ARE 18 WAS NOT PREEMPTE NIAMYS,2013 TAKE EFFECT,IMMEDI- MOBILE HOME PARKS IN FROM CREATING A am over the age Of eighteen years, and "AW INTERIM ''ORDI. ATELY" THE CITY OF WHICH 10 OVERLAY DISTRIC NANCE OF THE CITY. SYNOPSIS: ARE OPERATING AS THAT RESTRICTED TH not a party to or interested in the notice COUNCIL OF THE"CTY TREK" A LACK -OF SENIOR MOBILE HOME AGE OF CERTAIN M( OF HUNTINGTON BEACH SENIOR HOUSING OP PARKS. THE 10 SENIOR BILE HOME RESIDENT published. I am a principal clerk Of the ESTABLISHING A TEM, TIONS IN AND AROUND MOBILE HOME PARKS TO 55+. IN ADDITIOP PORARY MORATORIUM THE.CITY OF.HUNTING- REPRESENT APPROX- BY CREATING TH HUNTINGTON BEACH ON THE CONVERSION/ TON BEACH THAT WILL IMATELY 1,539 SPACES OVERLAY DISTRICT, TH CHANGE O,F ANY ONLY .INCREASE WITH OUT OF 2,951.SPACES, CITY DID NOT DH INDEPENDENT; which'was adjudged a MOBILEHOME PARK THE AGING POPULATION OR 52.15 PERCENT OF CRIMINATE IN HOUSIN CURRENTLY' EXISTING OF THE', COMMUNITY. ALL. OF THE MOBILE ON THE BASIS OF FI 'newspaper',Of general circulation On IN THE CITY FROM A MOBILE HOME PARKS HOME SPACES IN THE MILIAL STATUS. I September, 29, 1961, case A6214, and LIGHT OF THIS RECEN JUDICIAL DECISION, TH CITY 'June 11, 1963, case A24831,., for the THE`CITTYN TITORNEYTT CREATE AN INTERIM OF City of Huntington Beach,. County Of DINANCE AND A MOF THORIUM TO PRESERV Orange, and the State . Of California.- SENIO THE EXISTING SENIO Attached to this: Affidavit.,is a true and MOBILE HOME PARKS. PASSED .AND ADOPTE complete.: copy �as was printed and the by the Cit of yCof CouncHunting < to Beach at -a regulE published on the following date(s): meeting held August.5, 2013 by 0 following roll call vote: AYES: Sullivan, Hard, Boardman, Carchio Thursday, August 15, 2013 NOES:Harperdis ABSTAIN:None ABSENT:None THE FULL TEXT OF TH ORDINANCE I AVAILABLE IN THE CIT CLERcertify (or declare) under penalty This rdinae a is,, e of perjury that the foregoing is true f CITY OFHUNTINGTOF BEACH and correct. 2000MAINSTREET HUNTINGTON BEACH CA 92648 714-536-5227 JOAN L.FLYNN,CITY CLERK Executed on August 23, 2013 Published H.B. Indepei dent8/15/13 at Los Angeles, California Signature Dept.(D CA 1-3-009-Page 1 of 2 Y. Meeting Date:8/5/2013 CiTY OF HUNTINGTON BEACH REQUEST FORZITY COUNCIL ACTION MEETING DATE: AUgUSt 5, 2013 SUBMITTED TO: Honorable mayor-and City Council Members SUBMITTED-BY: Jennifer McGr ity Attorney PREPARED BY: Jennifer McGr ity Attorney , SUBJECT: Adopt Ordinance No. 3986, An Interim Ordinance Establishing a Moratorium on Conversion of Senior Mobile Home Parks Statement of Issue: There is a lack of senior housing options in and around the City of Huntington Beach that will only increase with the aging population of the community. Mobile home parks represent one of a few affordable housing options left to senior citizens that permit exclusive residence in a detached dwelling by those individuals over the age of 55 years. There are 18 mobile home parks in the City of which 10 are operating as senior mobile home parks. The 10 senior mobile home parks represent approximately 1,539 spaces out of 2,951 spaces, or 52.15 percent of all of the mobile home spaces in the City. Recently, the Ninth Circuit Court of Appeals issued a ruling in Putnam Family Partnership v. City of Yucaipa, ("Putnam") (2012) 673 F.3d 920, in which it determined that City was not preempted from creating a overlay district that restricted the age of certain mobile home residents to 55+. In addition, by creating the overlay district, the City did not discriminate in housing on the basis of familial status. In light of this recent judicial decision, the City council directed the City Attorney to create an interim ordinance and a moratorium to preserve the existing senior mobile home parks. Financiallmpact: N/A Recommended Action: Adopt Ordinance No 3986, "An Interim Ordinance Of The City Council Of The City Of Huntington Beach Establishing A Temporary Moratorium On The Conversion/Change Of Any Mobile Home Park Currently Existing In The City From A Park Occupied Primarily Or Exclusively By Residents Over The Age Of 55 Years (Senior Residents) To A Mobile Home Park Allowing Residents Of All Ages And Declaring The Urgency Thereof, To Take Effect Immediately! Alternative Action(sl: Do Not Adopt Ordinance No 3986, "An Interim Ordinance Of The City Council Of The City Of Huntington Beach Establishing A Temporary Moratorium On The Conversion/Change Of Any Mobile. Home Park Currently Existing In The City From A Park Occupied Primarily Or Exclusively By Residents Over The Age Of 55 Years (Senior Residents)To A Mobile Home Park Allowing Residents Of All Ages And Declaring The Urgency Thereof, To Take Effect Immediately." Item 27. - I HB -678- Dept.1D CA 13-009-Page 2 of 2 Meeting Date:8/5/2013 Analysis: A temporary land use regulation (often called a "moratorium") is a mechanism by which a zoning regulation is adopted for a limited period of time without having to go through the normal process of public hearings. State law requires a current and immediate threat to the public health, safety and welfare in order to adopt a moratorium. In this case, the City of Huntington Beach has a finite amount of housing that is designated as senior only housing and is affordable. One such housing option is mobile homes. After the decision in Putnam, in an effort to protect the City's limited resource of age restricted mobile home parks, the City Council directed staff to look at how this may be accomplished. The announcement that the City is studying this issue and may develop a zoning ordinance restricting the change of seniors only mobile home parks has resulted in the owner(s) of mobile home park(s) pursuing conversions to all age mobile home parks prior to any such ordinance taking effect. In order to preserve the status of mobile home parks operating as senior only parks, the City will need to adopt as an urgency measure an interim ordinance to preserve the existing senior only mobile home park. Environmental Status: N/A Strategic Plan Goal: Enhance and maintain public safety. Attachment(s): 1. Ordinance No 3986,An Interim Ordinance Of The City Council Of The City Of Huntington Beach Establishing A Temporary Moratorium On The Conversion/Change Of Any Mobile Home Park Currently Existing In The City From A Park Occupied Primarily Or Exclusively By Residents Over The Age Of 55 Years(Senior Residents)To A Mobile Home Park Allowing Residents Of All Ages And Declaring The Urgency Thereof,To Take Effect Immediately HB -679- Item 27. - 2 ATTACHMENT # 1 IL- Mein 27. - 3 HB -680- - ORDINANCE NO. 3986 AN INTERIM ORDINANCE OF THE CITY COUNCIL OF THE CITY OF HUNTINGTON BEACH ESTABLISHING A TEMPORARY MORATORIUM ON THE CONVERSION/CHANGE OF ANY MOBILEHOME PARKCURRENTLY EXISTING IN THE CITY FROM A PARK OCCUPIED PRIMARILY OR EXCUSIVELY BY RESIDENTS OVER THE AGE OF 55 YEARS (SENIOR RESIDENTS) TO A MOBILEHOME PARK ALLOWING RESIDENTS OF ALL AGES AND DECLARING THE URGENCY THEREOF, TO TAKE EFFECT IMMEDIATELY WHEREAS, the lack of senior housing options in and around the City of Huntington Beach(the "City") continues to create a serious problem for senior citizens living in the City that will only increase with the aging of the community's population; and Mobilehome parks represent one of a few affordable housing options left to senior citizens that permit exclusive residence in a detached dwelling by those individuals over the age of 55 years; and As set forth in the Housing Element of the City's General Plan, an important goal for the City is to preserve the existing senior housing stock which is represented in part by affordable mobilehome housing; and Mobilehome parks represent four percent of the City's housing stock. "Converting" mobilehome parks from a"seniors only" to all ages parks would reduce the number of senior housing units available to those persons 55 years of age and older; and There are 18 mobilehome parks in the City, 10 of which are operating as senior mobilehome parks; and The 10 senior mobilehome parks represent approximately 1,539 spaces out of 2,951 spaces, or 52.15 percent of all of the mobilehome spaces in the City; and Change from a"senior only" to an"all age" mobilehome park will unduly burden and irreparably harm senior citizens within the community; and The City Council of the City has determined that an urgency ordinance is necessary to protect the public health, safety and welfare of the citizens of the City. 13-3865/100059.doc 1 Ordinance No. 3986 NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF HUNTINGTON BEACH DOES HEREBY ORDAIN AS FOLLOWS: SECTION 1. Declaration of UrEency. The City Council finds and declares: 1. The City's General Plan Housing Element includes policies and goals for the protection of senior housing and development and establishes the City's objective to provide sufficient housing for senior residents. 2. In 2009, the City of Yucaipa, California adopted an Ordinance which amended its land-use plan by creating a Senior Mobilehome Park Overlay District. The Ordinance prohibits any of the 22 mobilehome parks in Yucaipa that currently operate as senior housing (defined as a park in which either 80 percent of the spaces are occupied by or intended for occupancy by at least one person who is age 55 or older or 100 percent of the spaces are occupied by or intended for occupancy by people who are age 62 or older), from converting to all-age housing. Mobilehome park owners sued, alleging that the Ordinance violated the Federal Law (Fair Housing Amendments Act (FHAA) by forcing them to discriminate on the basis of familial status, and by interfering with their ability to "aid[ ] or encourage[ ]" families with children in the enjoyment of fair housing rights, id. § 3617. Plaintiffs also argued that the ordinance was preempted by the FHAA [Federal Law] because it required plaintiff to take action that the FHAA prohibited. 3. In 2012, the Ninth Circuit Court of Appeals issued a ruling in Putnam Family Partnership v. City of Yucaipa, ("Putnam") (2012) 673 F.3d 920, in which it determined that the ordinance was not preempted and that the overlay district did not discriminate in housing on the basis of familial status in violation of FHAA (if the federal senior housing exemption applies (which it did in this case)), since the FHAA's ban on familial status discrimination does not apply to "housing for older persons." 4. In light of this recent judicial decision, the City intends to develop new zoning regulations relating to the preservation of senior mobilehome parks, which zoning regulations include provisions relating to the location and age restrictions of such parks. 5. Based upon the current state of the law, if a temporary moratorium is not established, existing senior mobilehome parks in the City could be eliminated. 6. There is a current and immediate threat to the public health, safety and welfare arising from the lack of senior housing options for citizens aged 55 and older in and around the City. The change from a"senior only" mobilehome park to an"all ages" mobilehome park will reduce the number of housing units available to those persons 55 years of age and older. Further, the announcement that the City is studying this issue and may develop a zoning ordinance restricting the change of seniors only mobilehome parks has resulted in the owner(s) of 13-3865/100059.doc 2 Ordinance No. 3986 mobilehome park(s) pursuing conversions to all age mobilehome parks prior to any such ordinance taking effect.I 6. Article XI, Section 7 of the California Constitution authorizes cities to adopt local police, sanitary, and other ordinances not in conflict with general laws. 7. The California Legislature has authorized cities to provide zoning for "senior only" mobilehome parks pursuant to Health and Safety Code §18300. 8. As discussed above, in Putnam, the California Court of Appeal has confirmed previous California Attorney General opinion that such senior only zoning does not conflict with the general prohibition against discrimination based upon age contained in California Government Code §65008 (87 Cal. Ops. Atty. Gen. 148 (Oct. 20, 2004)). 9. The City currently does not have a "senior only" mobilehome park zoning ordinance in place, but such a zoning ordinance may be needed in the immediate future to preserve affordable housing options left to the City's senior citizens. 10. The City requires time to study and decide: a. If such an ordinance is necessary to protect the public, health, safety and welfare and provide adequate local senior housing for the community's aging population. b. If such an ordinance would have any adverse effects upon the general housing market and particularly the senior and low-income housing market in the City. Further, whether any potential effects from the removal of a senior housing resource in the City constitute a current and immediate threat to the public safety, health and welfare. C. The extent City may regulate internal operations of mobilehome parks. d. Given the harm to the community by the removal of senior only mobilehome parks, this moratorium is being established to preserve the status quo to provide time to seek clarification of the law, and permit City staff to develop appropriate regulations consistent with the requirements of the law. SECTION 2. Moratorium. In order to protect the public health, safety and welfare and pursuant to the provisions of Government Code §65858, a moratorium is hereby placed prohibiting the"conversion" of any mobilehome park currently in existence in the City from a park where at least eighty percent (80%) of the full-time residents are individuals aged fifty-five (55) years and older (a"senior only" mobilehome park) to a mobilehome park accepting all ages of residents. 'Attached to this ordinance are two letters to residents of Rancho Huntington mobilehome park residents declaring intent that the mobilehome park no longer restrict housing to older persons(55+). 13-3865/100059.doc 3 Ordinance No. 3986 SECTION 3. Exceptions. This ordinance shall not apply to any undeveloped parcels of land or to any mobilehome parks currently operating within the City where the number of full-time residents younger than 55 years of age comprise twenty-one percent (21%) or more of the total number of residents in the mobile home park. SECTION 4. Report. Staff is directed to provide a written report to the City Council at least ten days prior to the expiration of this ordinance, describing the study conducted of the local housing conditions that led to the adoption of this ordinance in accordance with State law. SECTION 5. Effective Date. This ordinance is declared to be an urgency ordinance measure adopted pursuant to the provisions of Government Code Section 65858. As set forth in the findings above, this ordinance is necessary for preserving the public safety, peace, health and welfare of the community. Accordingly, upon adoption by a four-fifths vote of the City Council, this ordinance shall take effect immediately. SECTION 6. Expiration. This moratorium shall be of no further force or effect upon the expiration of forty-five (45) days from the date of adoption, unless extended in accordance with California Goverrunent §65858. SECTION 7. Severability. If any section, sentence, clause or phrase of this ordinance is for any reason held to be invalid or unconstitutional by a decision of any court of competent jurisdiction, such decision shall not affect the validity of the remaining portions of this ordinance. The City Council hereby declares that it would have passed this ordinance and adopted this ordinance and each section, sentence, clause or phrase thereof, irrespective of the fact that any one or more sections, subsections, sentences, clauses or phrases be declared invalid or unconstitutional. Further, the City Council hereby declares that this ordinance neither is intended to nor shall it impair the obligation of existing contracts. SECTION 8. Publication. The City Clerk shall cause this ordinance to be posted in three places designated by City Council pursuant to City Charter Section 500(c) and published by title with a brief summary at least once within fifteen (15) days after its adoption in a newspaper of general circulation, published in the County of Orange and circulated in the City, in accordance with Section 36933 of the California Government Code; shall certify to the adoption of this ordinance and shall cause a certified copy of this ordinance, together with proof of publication, to be filed in the Office of the Clerk of this City. 13-3865/100059.doc 4 Ordinance No. 3986 SECTION 9. CEOA Ezempton. The City Council finds that, regarding the California Environmental Quality Act (CEQA),there is no possibility that the adoption of this ordinance may have a significant adverse effect on the environment (CEQA Guideline 15061 (b)(3)). PASSED AND ADOPTED by the City Council of the City of Huntington Beach at a regular meeting thereof held on the 5 t h day of August , 20� 13 . e Mayor ATTEST: APPROVED AS TO FORM: City Clerk UCitj Attorney `7 3 t3 REVIE . APPROVED: MTIATED AND APPROVED: C WE n a k er Cit Attorney �1 3; J3 13-3865/100059.doc 5 19361 BROOKRURST STREET ...R.m HuNTINGTON BEACH,CALLFORNiA 92646 (714)962,7311 July 26,2013 FINAL NOTICE OF NEW RULES AND REGULATIONS To All Resident(s): - Recenti ,all-residentswere advised-of ascheduled meeti to discussproposed,amendmentte-the-rulesand-re ulations. ursuantio-the Mobilehome-- Y- n9 ' 9 P — Residency Law(Civil Code§§798,et seq.). All residents were provided the opportunity to comment on the proposed change to the rules and regulations.We want-to thank you for your input and comments. The new and final rule amendment is as follows: AMENDMENT TO THE RULES AND REGULATIONS THIS NOTICE IS PROVIDED TO EACH RESIDENT IN ACCORDANCE WITH THE MOBILEHOME RESIDENCY LAW AS A BINDING AMENDMENT TO THE RULESAND REGULATIONS OFTHE PARK.ALL EXISTING RULES REMAIN IN FORCEAND EFFECT EXCEPTWHICH ARE INCONSISTENTWTTH THE FOLLOWING AMENDMENT.THE RULES AND REGULATIONS ARE AMENDED BY ADDITION OFTHE FOLLOWING PARAGRAPH TO READ AS FOLLOWS: ALL-AGE COMMUNITY:Housing provider is an"all age"community and welcomes families with children under the age of eighteen(18).This housing provider has no intent to operate an`older persons"community and will no longer restrict housing to older persons(55+).At least one tenantinust'have.the legal capacity to enter a contract All rules and regulations which mandate or require adult supervision of minors in common facilities,ldsot Lhours of.usage,.orbar access on.the basis of age are rescinded. FAIR HOUSING POLICY(REVISED):WE DO BUSINESS IN ACCORDANCE WITH THE STATE AND FEDERAL FAIR HOUSING • e LAWS. IT IS ILLEGAL TO DISCRIMINATE AGAINST ANY PERSON BECAUSE OF RACE,COLOR,RELIGION,SEX,SEXUAL ORIENTATION OR PREFERENCE,HANDICAP OR DISABILITY,AGE, FAMILIAL STATUS, SOURCE OF INCOME, NATIONAL T ORIGIN, ANCESTRY OR FOR ARBITRARY REASONS UNDER STATE LAW - DISCRIMINATORY ACTIONS OF THE MANAGEMENT,HOMEOWNERS,RESIDENTS, GUESTS OR OTHERS MAY BE REPORTED TO OWNER'S AGENTS,OR THE DEPARTMENT OF FAIR EMPLOYMENT AND HOUSING OR DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT. MANAGEMENT WILL NOT AT ANYTIME UNLAWFULLY ADMINISTER.ENFORCE OR EXPRESS ANY PREFERENCE WITH RESPECT TO EXISTING OR PROSPECTIVE TENANTS,RESIDENTS,OR GUESTS BASED ON ANY PROTECTED CLASS STATUS AS DEFINED UNDER SUCH LAWS.NO SUCH UNLAWFUL ACTIVITY BY OTHER PERSONS WHETHER RESIDING IN OR DOING BUSINESS IN THE COMMUNITY OR OTHERWISE IS PERMITTED; ANYIINLAWFUL DISCRIMINATION KNOWN OR REASONABLY SUSPECTED MAY BE REPORTED TO APPROPRIATE GOVERNMENT AUTHORITIES FOR PROSE.P"ON.. 'Please be advised that all rules and regulations previously in effect and which are consistent with the amendment will continue to be effective and in full force and effect The new rule and regulation amendment will take effect in accordance with the applicable provisions of the Mobilehome Residency Law :(Cvi!Code§§798,-et seq.). If you desire to provide any additional comments or should have any further questions regarding this amendment,you are welcomed„and encouraged to contact the management. Each individual resident has the unwaivable right and power to consent to the new rule and regulations amendment if desired.If you wish to consent ao the new rule and regulation amendment,it becomes effective at such time as you elect to consent to it.If you desire to consent in writing,you may execute this noticeiri the space provided below and return the bottom portion of this notice to the park office.Otherwise,the new rule and regulation amendment takes effect in 180 days(6 monthhs)after service of this notice for homeowners who have not expressly agreed in writing. Again,should thereby any further questions or comments respecting this amendment or any matter regarding the rules or the park,please feel free to contact the management Please feel free to contact management in the event that you desire to ask any additional questions or have any comment: Sinc ly, -Abe Arrr Author1zed.Agen1vtt9,6=er CONSENT To RULE AND RE MMENT I;. space no. .HEREBY CONSENT to the amendment of the rules and regulations set forth above. Please retum this page to the park office for our records.Thank you. Dated; : .. RESIDENT SIGNATURE. Familial Status Protections: • In 1988,Congress enacted the FHAA to proscribe"familial status"discrimination. "Familial status" is defined as"one or more individuals(who have not attained the age of 18 years)being domiciled with ...a parent or another person having legal custody of such individual or individuals." 42 U.S.C.§ 3602(k)(1). Specifically, under the FHAA it is unlawful: • (a)To refuse to sell or rent. . .because of...familial status .... _ .. ... •(b)To discriminate...in the... sale or rental of a dwelling ..because of...familial status. • (c)To make,print,or publish. ._.any preference.... based on ...familial status_.. 42 U.S.C. §3604. Illegal to Interfere with Providing Familial Status Protections: • Section 3617 of the FHAA: `Flit shall be unlawful to coerce, intimidate,threaten, or interfere with any person in the • exercise or enjoyment of, or on account of his having exercised or enjoyed, or on account of his having aided or encouraged any other person in (familial status rights). 42 U.S.C. §3617. No"Interference"ALLOWED in Providing"Familial Status" • U.S.v. Hayward(1992)805 F.Supp.810: Park owner filed HUD complaint. • The United States then filed an action against Hayward. • The Court: Hayward violated the FHAA by coercing and interfering with Park owner's efforts to rescind its "older persons" rules and regulations. Only Owner May Claim Intent To Operate • Once park owner.institutes change to familial status, City cannot interfere. • Hayward attempts to claim the exemption on behalf of the petitioners.This Court concludes that only owners and managers may claim the exemption. . . U.S. v. Mainlands • Homeowners'association did not institute age-verification procedures adequately evidencing intent to provide housing for persons 55 years or older prior to taking action against two homeowners with children, • These six factors are: • (1) written rules and regulations; • (2)the manner in which the housing is described to prospective residents, • (3)the nature of advertising; a (4) age verification procedures; • (5) lease provisions;and • (6)the actual practices of the owner or manager in enforcing relevant lease provisions and relevant rules and regulations. Putnam v.Yucaipa: • The City(cannot) ensure that the Overlay District meets the fairly rigorous statutory requirements of maintaining an • eighty-percent senior population, • publishing and • adhering to policies, and • complying with occupancy verification rules,see 42 U.S.C. §3607(b)(2)(C), and that the Overlay District does so • in advance of engaging in what would otherwise be discriminatory conduct, (i.e. conduct which disqualifies the park from OPH). If Park does not qualify for OPH,cannot enforce: The Act prohibits a housing provider from"coercing,intimidating,threatening or interfering with anyone in the exercise or enjoyment of,or on account of his having exercised or enjoyed any right granted or protected by the Act.42 U.S.C.Sec.3617.The Government asserts that Respondents retaliated against Joyce Vern and Barbara McDermott.. . Yucaipa Does Not Apply to the Facts in R Huntington: • The Park owner desires to and has in fact converted. • The City has Failed to Act in Advance of the Conversion. • It Would Constitute a Violation of§3617 of Federal law to coerce, intimidate or force park owner to discriminate against children. RANCHO HUNTINGTON MOBILE HOME ESTATES 19361 BROOKHURST STREET HUNTINGTON BEACH,CALIFORNIA 92646 (714)962-7311 NOTICE OF AMENDMENT TO RENTAL AGREEMENT July 16,2013 Dear Residents: This letter serves to provide notice of amendment to the rental agreement under which you reside in Rancho Huntington by the addition of the covenant set forth below.You currently reside in the park at space 22 pursuant to a written rental agreement entered into on February 14 , 2005 Management has no further intention of enforcement of"older persons"housing regulations. The rental agreement is amended, by this notice as provided b Civil Code§827 amendment of periodic tenancies),to comply with the federal housing mandate entitled "Federal Fair Housing Amendyments Act of 1988, which guarantees the right of"familial status,"which includes the right of persons of all ages to occupy mobilehomes in the park. This means that all residents are afforded the opportunity to allow the grandchildren to move in, extended families to share housing in these difficult economic.times and allows residents to sell their homes to persons without regard to age restrictions.All persons intending on sale of their homes should make full disclosure of this amendment to all prospective purchasers, AMENDMENT TO THE RENTAL AGREEMENT THIS NOTICE IS PROVIDED IN ACCORDANCE WITH CALIFORNIA LAW AS A BINDING AMENDMENT TO THE RENTAL AGREEMENT. THE RENTAL AGREEMENT IS HEREBY AMENDED BY ADDITION OF THE FOLLOWING PARAGRAPH TO READ AS FOLLOWS: FAIR HOUSING POLICY OF RANCHO HUNTINGTON (REVISED)..IS AS FOLLOWS: WE DO BUSINESS IN ® ACCORDANCE WITH THE STATE AND FEDERAL FAIR HOUSING LAWS. IT IS ILLEGAL TO OPPORTUUNIRM,, DISCRIMINATE AGAINST ANY PERSON BECAUSE OF RACE, COLOR, RELIGION SEX, SEXUAL OPPOTY ORIENTATION OR PREFERENCE HANDICAP OR DISABILITY, FAMILIAL STATUS SOURCE OP-INCOME NATIONAL.ORIGIN, ANCESTRY OR F6R ARBITRARY REASONS UNDER STATE LAW - DISCRIMINATOP ACTIONS OF THE MANAGEMENT, HOMEOWNERS, RESIDENTS, GUESTS OR OTHERS MAY BE REPORTED TO OWNER'S AGENTS, OR THE DEPARTMENT OF FAIR EMPLOYMENT AND HOUSING OR DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT. MANAGEMENT WILL NOT AT ANY TIME UNLAWFULLY ADMINISTER, ENFORCE OR EXPRESS ANY PREFERENCE WITH RESPECT TO EXISTING OR PROSPECTIVE TENANTS, RESIDENTS OR GUESTS BASED ON ANY PROTECTED CLASS STATUS AS DEFINED UNDER SUCH LAWS. NO SUCH UNLAWFUL ACTIVITY BY OTHER PERSONS WHETHER RESIDING IN OR DOING BUSINESS IN THE COMMUNITY OR OTHERWISE IS PERMITTED- ANY UNLAWFUL DISCRIMINATION KNOWN OR REASONABLY SUSPECTED MAY BE REPORTED TO APPROPMATE GOVERNMENT AUTHORITIES FOR PROSECUTION. "ALL-AGE COMMUNITY: Rancho Huntington has no intent to operate as an "older persons" community and absent such legal requirement for operation of"older persons housing'can no longer enforce an"older persons" housing restriction.The Park is therefore, by 'law, required toimmediately comply with "familial status" protections of federal and state law. Accordingly, the gpark is an "all-age" mobilehometo enter a contract. ALLrk with no minimum g requirements MAY RESIDE INrTHEnPARKtenancy WITHOUTdRESPECT residence TO least AND NOT CONDITIONED UPON aORaRES) RICTED BY FAMILIAL STATUS OR AGE IN ACCORDANCE WITH THE FEDERAL FAIR HOUSING AMENDMENTS ACT OF 1988. THE FOREGOING AMENDMENT IS FINAL." "Speedy Dispute Resolution: To resolve disputes quickly and inexpensively with lessee or lessor, we agree to arbitrate our differences before an impartial arbiter(per the FAA*)we jointly select from a list supplied from an alternate dispute resolution organization such as the AAA**within 10 days after one side gives written notice of an arbitrable dispute. If a dispute arises with respect to any terms or provisions of tenancy, with the exception of actions in unlawful detainer,forcible detainer,foreclosure, small claims court or injunctive relief, the arbiter will decide all aspects of the dispute, including arbitrability and enforceability of this clause. "Disputes" include rent adjustments or fees, legal compliance in park operation, and park repair and maintenance. AAA** Commercial Rules will apply, and available at www.adrorg,choose"rules and procedures,"choose"rules,"scroll down to"commercial arbitration rules and mediation procedures. ," A copy is also on file in the office, No joinder or consolidation or class actions allowed.Arbiter to decide issues under FAA, shall split costs evenly and decide arbitrability, all within 120 days of selection. Costs to be awarded to the prevailing party; no attorney's fees to either side. Discovery permitted as per Federal Rules of Civil Procedure." "*"FAA" refers to the"Federal Arbitration Act." **."AAA" refers to the"American Arbitration Association,"" Please feel free to contact management in the event that you desire to ask any additional questions or have any comment, Sincerely, Authorized Agent of the Owner RANCHO HUNTINGTON MOBILE HOME ESTATES 19361 BROOKHURST STREET HUNTINGTON BEACH,CALIFORNIA 92646 (714) 962-7311 July 16, 2013 To All Residents at Rancho Huntington Mobile Home Estates, At last night's City Council meeting, the council directed the City Attorney to draft a moratorium to be adopted at the next City Council meeting prohibiting existing senior manufactured home communities from changing to all age communities. While we previously had no intention of changing the current senior status at Rancho Huntington, upon the advice-of our attorney we are now moving forward and providing legal notice that we are changing our status to an all age park to protect our property rights. Please understand that this is not something we desire;however, the actions by the City Council have forced us to take this action to preserve our legal rights as property owners. We will dialogue with you and City representatives at any time, as we stated last night. OFFER OF COMPROMISE: Further,we will be proposing, as an offer of compromise to the City Council, that we consider an agreement to preserve senior status at Rancho Huntington for a fixed period of time while the HOA and management pursue a long term lease with covenants that protect the interests of the residents and management; including a senior community with terms that make sense (in lieu of inflexible terms forced on us by government). This makes any ordinance unnecessary. This proposal is not a release or cancellation of the enclosed notices. We feel that an agreement between residents and management is much more preferable than a long,drawn out legal battle with outsiders making decisions affecting your future. We look forward to meeting with you soon! Sincerely, Authorized Agent of the Owner RANCHO HUNTINGTON MOBILE HOME ESTATES 19361 BROOKHURST STREET HUNTINGTON BEACH,CALIFORNIA 92646 (714)962-7311 July 16, 2013 NOTICE OF AMENDMENT TO RULES AND REGULATIONS Dear Residents: This letter serves to provide notice of a meeting regarding the amendment of the rules and regulations, The amendment provides for a fair housing policy consistent with the Federal Fair Housing Amendments Act of 1988 and implementing regulations. Accordingly, all provisions restricting residency to "older persons" (55 years of age and more) as currently set forth in the rules and regulations are deleted. All residents are entitled to meet and offer their comments to the amendment. You are invited to attend a meeting to discuss the amendment to be held at the clubhouse at 10:00 A.M. o'clock, July 26, 2013. Everyone is invited to comment and ask all questions. Of course, you are not obligated to attend.And, you are free to provide us your written comments at any time, before and after the meeting for your convenience. If the time set forth above is inconvenient and you desire to meet at a different time, please advise so we may informally accommodate you. You are free to consent to the amendment by the terms of the Mobilehome Residency Law (Civil Code §§798, of seq.) ("MRL"), by returning a signed copy of the amendment. We advise you that this amendment is the final text, and is enforceable only as effectuated and defined by the MRL. Please feel free to contact management if you have any questions or comments. AMENDMENT TO THE RULES AND REGULATIONS THIS NOTICE IS PROVIDED TO EACH RESIDENT IN ACCORDANCE WITH THE MOBILEHOME RESIDENCY LAW AS A BINDING AMENDMENT TO THE RULES AND REGULATIONS OF THE PARK. ALL EXISTING RULES REMAIN IN FORCE AND EFFECT EXCEPT WHICH ARE INCONSISTENT WITH THE FOLLOWING AMENDMENT. THE RULES AND REGULATIONS ARE AMENDED BY ADDITION OF THE FOLLOWING PARAGRAPH TO READ AS FOLLOWS: ALL-AGE COMMUNITY: Housing provider is an "all age"community and welcomes families with children under the age of eighteen (18). This housing provider has no intent to operate an "older persons"community and will no longer restrict housing to older persons (55+), At least one tenant must have the legal capacity to enter a contract.All rules and regulations which mandate or require adult supervision of minors in common facilities, restrict hours of usage, or bar access on the basis of age are rescinded. .EFAIR HOUSING POLICY (REVISED): WE.DO BUSINESS IN ACCORDANCE WITH THE STATE AND FEDERAL FAIR =2 HOUSING LAWS. IT IS ILLEGAL TO DISCRIMINATE AGAINST ANY PERSON BECAUSE OF RACE, COLOR, OQUAL PPO"TU M RELIGION, SEX, SEXUAL ORIENTATION OR PREFERENCE, HANDICAP OR DISABILITY, AGE, FAMILIAL STATUS, SOURCE OF INCOME, NATIONAL ORIGIN, ANCESTRY OR FOR ARBITRARY REASONS_ UNDER STATE LAW DISCRIMINATORY ACTIONS OF THE MANAGEMENT, HOMEOWNERS, RESIDENTS, GUESTS OR OTHERS MAY BE REPORTED TO OWNER'S AGENTS, OR THE DEPARTMENT OF FAIR EMPLOYMENT AND HOUSING OR DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT. MANAGEMENT WILL NOT AT ANY TIME UNLAWFULLY ADMINISTER, ENFORCE OR EXPRESS ANY PREFERENCE WITH RESPECT TO EXISTING OR PROSPECTIVE TENANTS, RESIDENTS, OR GUESTS BASED ON ANY PROTECTED CLASS STATUS AS DEFINED UNDER SUCH LAWS. NO SUCH UNLAWFUL ACTIVITY BY OTHER PERSONS WHETHER RESIDING IN OR DOING BUSINESS IN THE COMMUNITY OR OTHERWISE IS PERMITTED; ANY UNLAWFUL DISCRIMINATION. KNOWN OR REASONABLY SUSPECTED MAY BE REPORTED TO APPROPRIATE GOVERNMENT AUTHORITIES FOR PROSECUTION. Please feel free to contact management in the event that you desire to ask any'additional questions or have any comment. Sincerely, Authorized Agent of the Owner Urgency Ord. No. 3986 STATE OF CALIFORNIA ) COUNTY OF ORANGE ) ss: CITY OF HUNTINGTON BEACH ) I, JOAN L. FLYNN, the duly elected, qualified City Clerk of the City of Huntington Beach, and ex-officio Clerk of the City Council of said City, do hereby certify that the whole number of members of the City Council of the City of Huntington Beach is seven; that the foregoing ordinance was read to said City Council at a regular meeting thereof held on August 5, 2013 and was passed and adopted by at least five affirmative votes of said City Council. AYES: Sullivan, Hardy, Boardman, Carchio, Shaw Katapodis NOES:. Harper ABSENT: None ABSTAIN: None I;JOAN L.FLYNN,CITY CLERK of the City of Huntington Beach and ex-officio Clerk of the City Council,do hereby certify that a synopsis of this ordinance has been published in the Huntington Beach Fountain Valley Independent on e F August 22,2013 hi accordance with the City Charter of said City Cl Clerk and ex-officio Urk Joan L. Flynn, City Clerk of the City Council of the City Deputy City Clerk of Huntington Beach, California CITY OF HUNTINGTONEACH City Council Interoffice Communication To: Honorable Mayor and City Council Members From: Jim Katapodis, City Council Member Date: July 8, 2013 Subject: CITY COUNCIL MEMBER ITEM FOR THE JULY 15, 2013, CITY COUNCIL MEETING— RESTRICTING SENIOR MOBILE HOME PARKS FROM BECOMING FAMILY PARKS STATEMENT OF ISSUE: In February 2013, the United States Court of Appeals, Ninth Circuit, determined that a city may establish protections for senior mobile home parks under both federal and state law. Specifically, the case establishes the ability for a city to adopt a Senior Mobile Home Park Overlay District to restrict the ability of a senior mobile home park from becoming a family park. RECOMMENDED ACTION: Direct the Planning and Building Director and City Attorney to draft the Senior Mobile Home Park Overlay District for consideration by the Planning Commission and the City Council. xc: Fred Wilson, City Manager Bob Hall, Deputy City Manager Joan Flynn, City Clerk Scott Hess, Director of Planning and Building Jennifer McGrath, City Attorney Western Manufactured Housing Communities Ihon RECEIVED FROM � MEETINGAS PUBLIC RECORD FO OF July 15, 2013 CITY CLERIC JOAN L FLYNN,CITY CLERK The Honorable Connie Boardman c-'aV Mayor,City of Huntington Beach 2000 Main Street, Huntington Beach,CA 92648 Re: Item#21 Restricting Senior Mobile Home Parks From Becoming Family Parks Dear Mayor Boardman: I am writing asking for you and your fellow council members to refer item#21 on tonight's agenda Restricting Senior Mobile Home Parks From Becoming Family Parks to the City's Mobile Home Advisory Board and possibility the city's Planning Commission for review and advisory action. It is my understanding that it is Council Member Katapodis' desire to mirror the City of Yucaipa's action of senior overlay zones of these communities.This was done in Yucaipa by changing the zoning of a park owners' property sometimes against their wishes with very little input from the property owner. It led to long and lengthy litigation which was very costly to the City of Yucaipa and very divisive amongst residents and management. I request that park owners and residents use the resources the city has made available to them to work on these important issues. Perhaps a consensus can be reached outside city council chambers that doesn't require regulation or expensive litigation? It would'seem to me this is exactly why the city decided to keep the Mobile Home Advisory Board when it was threaten to be dismantled not too long ago. It was important to the past council to have a forum for residents and owners to work on mutual interest concerns and issues and certainly this issue would be appropriate to be assigned to for review. Thank you for your thoughtful consideration of my request and my association and members look forward to working with you on this issue in the near future. Sincerely, Jul' Paule tegional Representative 40335 Winchester Road,#E-165 !Temecula,CA 92591 phone 951.926.0631 1 fax 951.926.8770 email julietapauleconsulting.com 1 web www.wma.org RECEIVED FROM d44 AS PUBLIC RECORD R M IL�9EETING SENIOR VS. ALL-AGE PARKS CITY CLERK OFF Presentation: October 121", 2005 MM u FLY'CITY CLERK Prepared for the McDonald Family, Azul Pacifico cc: Clint Lau, Les Frame Inc. Prepared by Robin Holland FACTORS: Tahitian Terrace is a senior mobile home park located in Pacific Palisades. The owners of the Park are considering changing the designation of the Park from to senior all-age. The following research outlines the possible ramifications of that change according to specialists in the fields of mobile homes, mobile home law, mobile home insurance and mobile home park management. The final and strongest paragraphs are from the organization to which park owners themselves belong. My statement to the entities with which I spoke as to the possible reason for the change was "... the owners are concerned about legal problems they have now or may encounter re: discrimination against families. The owners feel that even though they win the cases because the law is clear, the effort, threat and possible legal fees would be removed if the owners changed the Park's designation from senior to all age." Breakdown: The comment I heard repeatedly was that the only reason the attorneys (who had represented both park owners and park residents), representatives of the various companies and organizations and managers with whom I spoke could see for changing to an all-age park was if the park was plagued with vacancies and those vacancies could not be filled in any other way. And I was repeatedly told it would probably be a bad move both financially and with regards to increased maintenance problems. A sampling of 18 Insurance companies contacted. Manning and Nozick: Jay Zandman w/c wed w/figures 53 Perimeter Center, #120, Atlanta, GA 30346 800-211-0468 - Synopsis of comments: "Why would the owners change? The only reason to change is too many vacancies." The change in premiums 1 would be negligible at first but as claims came in, of course premiums would increase. Alliance - Lewis 602-494-6761. "Insurance charges wouldn't change at first but a change to family park usually leads to more claims. A kid hurt by a vehicle coming up or down the hill would be a major impact insurance-wise. There also appears to be other 'built-in' dangers in this park. If you are having trouble with people claiming they've been discriminated due to being younger, Alliance offers a stand-alone policy EPLI/TD (employment practices liability/tenant discrimination) which will cover that problem as well as several others and it's a much cheaper and more efficient way to go. It's about $1,700 for $1 Million coverage. It also will cover the holder on other commercial ventures on the same policy. Statistically, senior parks are a much better risk (translation: lower premiums due to fewer and lesser claims) than all-age parks." Mobile Insurance, 2203 Timberloch, #110, The Woodlands, TX 77380 281-367-9266 xt-17. They no longer offer MHP insurance in Florida due to the losses they've incurred from the Florida weather. I was told, however, that they were incredulous that any owner of a mobile home park would want to change from senior to all-age due to the likely financial losses that would entail. The person with whom I spoke said, "Owners usually want to try to figure out how to go the other way (all-age to senior) because of the savings in upkeep and management." As an aside, it was strongly suggested that traffic signage should be clear and very visible and that any increase in auto accidents would probably be covered initially by the individual's car insurance if it the signage was reasonable and easily visible. If someone wanted to sue the Park for an accident claiming it was partially or fully due to the layout of the road, the signs would possibly help the Park mitigate at least some of the claim. For other road problems, it would probably depend on park streets and the park's idiosyncrasies. CSIE- (Cal. Southwestern Ins.) 800-352-0393 Greg - "Insurers prefer senior parks because they usually have far fewer claims." Bikes, cars, (rolling toys,) etc., increase risk dramatically and increase the workload of the park staff. Senior parks have much lower maintenance, lower work load and have a reduced number of claims. With family parks, the overall Park quality goes down and maintenance intensifies markedly. The wear and tear go up. 2 Synopsis of the rest of the organizations and attorneys contacted: Insurance companies, management companies, attorneys and park managers who were called had similar opinions. None thought the change would save money. They seemed to agree that the initial change in just the premiums would be lateral but that the real costs would escalate fairly rapidly with the change-over to younger people in the park. The density of people per household increases in all-age parks, traffic goes up and the maintenance and associated costs rapidly increase for even minimum park maintenance and infrastructure repair. Additionally, often round-the-clock and/or on-site security are necessary. -Many of them had, in their own words, "horror stories". The only reason any of them could see for this change would be if the vacancy rate in a park was high. In the case of Tahitian Terrace where vacancy is nil, none of them could come up with any reason to change that would make it financially feasible or logical. Further, when the layout of the Park (steep hill entry & exit with blind corners, fire road, hillsides, Pacific Coast Highway) was described to several insuring entities after their initial comments, they then felt the claims would be even greater than they first thought. Although any auto-involved accidents would be covered to some extent by the offending party's car insurance or the homeowners' policy, the deep pockets of the Park ownership would very likely be involved because of that layout which could be construed with little difficulty to be at fault. -Because there are no play areas, yards or park areas and there are inadequate facilities for kids, possible loss of coverage and liability risk is increased. -Emergency access is limited now and will be even more limited due to excessive cars parking as the number of persons per household increases. -The fire road would be an expanded liability especially if there is nowhere else to play. -Crime goes up. For example, domestic abuse cases, teenage fighting, speeding cars, loud noise at night, theft, etc., increase dramatically. - In giving quotes, all-age parks tend to have much more careful examinations by the agent and later, if a claim is lodged, by the adjuster. Rates escalate with claims and all-age parks tend to have more claims. - Many carriers will estimate senior but not all age parks as they are more leery of writing all-age parks. 3 - The location of the park and its track record will (obviously) affect the premiums. - "Now (at the beginning of the process of going from senior to all age) there may be no change in premiums but losses will show up and premiums will go up, too." - "In thinking about this change, you should err on the side of caution. Senior parks are safer and less work, as a rule. They also use much less management time and have many fewer claims or damage." - Enforcement of pertinent rules would be taken into consideration when premiums and claims are looked at. In an all-age park, more rules have to be made and management must be more diligent at following them. -"Nuisance value (factor) both to the residents of the park and the owner seem to be much greater in parks where teenagers and children live." - "You'll probably have many more headaches and heartaches with all- age." - "In an all-age park, you'll have to have strict rules and strong management, and enforce eviction procedures. Otherwise you open yourself up to legal problems. Amend rules correctly and enforce them. (You) must have an energetic manager who works effectively." - A few comments from other agencies around the country and in California ran something like, 'Go from a senior park to an open park??? Who's telling them it would be cheaper/better/easier/etc.?' or 'They should get better advice.' or 'I wish more of the parks we insured were senior!' and 'I'd rather write a whole (senior) park than a small park with one teenaged boy and his pals.' -Spaces are not worth as much in a family park because they are not as desirable. The overall value of the park would actually decrease. (Robin comments: This one surprised me; I'm not sure I believe it.) -To refinance or sell the park, lenders look at senior parks as more stable so they are more desirable. They cannot discriminate technically and legally but in reality, all-age parks come under more of a microscope. - "Most owners would like to crawl BACK to the safety of the womb, (laughs) not the other way 'round." '"Living in a senior park is usually a lifestyle-choice and social activities are usually adult oriented and not child friendly." -"Living in an all-age park is usually a necessity because the people can't afford to live anywhere else and they can't afford the upkeep of their mobile home the way it should be kept up. The whole place suffers." 4 -Because all-age or family parks have a higher density, costs go up whether you're discussing maintenance or security or management. You have to factor in patching, painting, destruction of plants, physical disputes, security costs, possible additional employees because the staff is stretched too thin and can no longer handle the ordinary or main projects due to the increase in jobs to be done. -Senior parks are not considered 'trailer trash' because the impact on the facilities and grounds are light but family parks can be considered 'trailer trash' because maintenance cost goes up which makes the cash flow to maintain the extra wear and tear go up. It's not cheap so profits go down and things are let go. - "It is more difficult to keep liability costs down in all-age parks with most new (court) cases being decided against the park owners." Additional Findings of Specific Interest Western Manufactured Housing Association (park owners' ass in) - shari@wma.org, phone: 916-448-7002. Shari Gray will be happy to discuss the conversion to an all-age with you. Her quote: "If you think you had legal problems before (while designated a senior park), just wait till you have some teenagers move in." Some examples given by Ms. Gray: "I can tell you horror stories - I do this (job) all day long and I hear them ...drugs, undesirable friends, vandalism, kids bored in the summer when school's out so they trash facilities like the laundry room, kids who go out at night and put soap in the pool so you eventually have to hire security all the time. Then the kids wait till the guard is gone and then defecate in the pool or dump bleach on things. They'll put Clorox on the grass and plants." In answer to the question 'why do they want to change?' and the answer, age lawsuits from younger people, etc, she stated, "You may have one set of problems but - wait till you see what you will have when you change! They (all-age parks' younger residents) have no respect for the property, frequently tag homes and property. Parents are working and the kids are left alone. In the summer, the kids are really a problem. They get bored and get into trouble (showing off for each other)." She had no idea why anyone would want to change from senior to all age due to the dramatically increased expense of maintenance, management and possibly increased liability on many legal fronts to the owner. 5 Case Law: Clint and I discussed a couple of recent cases that should also be considered, especially on fault and liability. Further, Mobilaire Estates and the case in Imperial County are of interest. cc: Clint Lau (John and Mary McDonald copies given to Desmond McDonald) During presentation, we discussed 'quiet enjoyment' liability. Addendum: July 15t", 2013 Emergency Services. According to the records kept by publicly supported emergency service of the Police and Fire Department, calls from all-age mobilehome parks are drastically higher than the number of calls from senior parks. Further, the local community appears to suffer losses both due to increased funding necessary for those services and to vandalism. An annotated study is being prepared but is not ready at this time. Robin Holland, Mobile Home Park Task Force, City of Los Angeles, California 6 August 5, 2013 Sent via E-Mail to jflynn(j�surfcity-hb.org August 2, 2013 The Honorable Connie Boardman Mayor, City of Huntington Beach The Honorable Matthew Harper Mayor Pro Tem, City of Huntington Beach Members of the City Council 2000 Main Street Huntington Beach, CA 92648 Subject: Proposed Mobile Home Park Senior Age Restriction Overlay Zone Dear Mayor Boardman: As President of the Orange County Association of REALTORS®, I am writing to express concern with Council Member Katapodis's proposal to impose zoning restrictions on existing senior mobile home park communities to prevent park owners from changing the age status of the community. In general, our association advocates for the protection of private property rights, however, we are also aware that there are circumstances whereby the rights of a protected class need to be elevated. In this case, we are not aware that such evidence exists that would require the city to subordinate the rights of park owners by forcing them to serve only seniors. We would encourage the city to consider and exhaust all other options before imposing such a drastic and not uncontroversial zoning scheme. Sincerely, SUPPLEMENTAL Len Herman COMMUNICATION President N4eetft®ale: A*enda Item No.� 1 MH '.4fanufactuml Housine OT August 4, 2013 BOARD OF 1)IRFcrORS Sent via E-Mail to jflynn&surfcity-hb.org ,csiMa Board Aresideia SUPPLEMENTAL Vice Hsideiag COMMUNICATION Rod t�,rson Mayor Connie Boardman Rod Anderson 7ieaswrr Mayor Pro Tem Matthew Harper Im:Miller Members of the City Council Meetkv Date:Secretary Natalie caaagBo City of Huntington Beach Natalie Pad Praioh t 2000 Main Street Apnde Item No. 4� Eileen Cirillo Keith Casenhiser Huntington Beach, California.92648 Lauren Fischer Stan Magill,Jr. Lan McAdoo RE: City Council Item 27-.OPPOSE Board Members Bob Bottdetti Adopt Ordinance No. 3986, an Interim Ordinance Establishing a Clarke "n'�nther e Jay Greening Moratorium on Conversion of Senior Mobile Home Parks Richard A.Hall Rill Hanks Craig Rouser Jerry D.Jscobs:m J Honorable Mayor Boardman and Council Members: Clint Lau Jim Martin eana D Panchen eereorgContmtttee MHET is a non-profit association dedicated to the preservation the manufactured AdvisTerryDoadall housing lifestyle and to the protection of the property rights of the mobile home park Waft ne business owners who provide housing in the seventeen privately owned mobile home Dave Thomas Past Presidents parks in the City of Huntington Beach. Ed Evans J.R.Phillips RobertOiand We are opposed to the City enacting any regulations that will restrict the property rights Rnbert0landerSr. Gerryostwick of the owners of these parks. This includes the enactment of any restrictions by the City Janet Gilbert Clarke Fairbroiher that will require the private business owner to discriminate against potential customers Clrk ` elu Tenea Cheln rnqeso based on age. Specifically MHET opposes the adoption of any zoning ordinance, m`esJone urgency ordinance or moratorium that would restrict a property owner from renting their Keith Casenhiser Craig Uom,rtoascr 0{andar It property to any a eg_groW they choose. Sian Magill,J. Eileen Cirillo Ltre.ttme We further oppose the adoption of Ordinance 3986 based on the following: Achievement Award Recipients Norm Minn • Findings cannot be made that there is a need to preserve the fewer than 1500 mobile John Rob Robert N. s home units in Huntington Beach mobile home parks that may be occupied by Rrbert N.Rast. [A�A.Beggs seniors. These 1500 units make up only 2%of the total 78,000 total housing units in Jerry Golden Harry E.Karsten the City that are available to seniors city-wide. Additionally, the seniors living in Jess CMPAiey these mobile homes are an extremely small special interest group of only .03%of all W`LA Abode and Beyond of the 47,426 seniors living in the City. And, residency by families and children,per Award Rectptents se, cannot possibly pose a serious or immediate threat to public health and safety. Willis Miller Stan Magill Dan Bostwrobick • Prior to this issue being raised by the City Council, no mobile home parks in the City C.Rrent.Svanson Jim Martin were contemplating changing the age rules. As a result of the City Council's action, James Jones Carlo Travmw at least one mobile home park owner has served legal notices to the park residents in Keith Casenhiser James It Bostick order to vest their rights to change from a senior park to an all age park. This park Execrattae&rector owner has repeatedly stated on the record that they do not want to change to an all Vickie Tellep 25241 Paseo de Alicia,Suite 120•Laguna Hats,Cahfoi is 92653•Phone:949.380.3303•Far:949.340.3310 Email:hjfoCmhet.org • Mbsite:wYwwmhet.org Southern California MHET S,-n4uy Orawge.,Riverside anti San Bernardino Counties shave 1982 Page Two age park at this time, but under the circumstances they feel they have not choice but to take action to protect their property rights. • This precipitous action to protect less than.03% of the seniors living in the City is a potentially extremely costly action for a City with far more important and pressing financial challenges and, as previously stated,is completely unnecessary. The City Attorney has already put on the Council's agenda discussions regarding the threat of litigation by mobile home park owners over this issue. • The City should not be in the business of telling property and business owners how to run their business operations when it comes to who they must choose as customers. Would the City adopt a similar ordinance that would require apartment owners, restaurant owners, and other businesses to serve only seniors who make up only 25% of the City's population? • There are many factors for a business to consider when choosing who its customers are. In Huntington Beach the City's mobile home parks are almost evenly split between all-age and senior communities. The free market system is working. The City does not have to"fix" it. Apparently, at this time, there are enough seniors interested in living in a mobile home in Huntington Beach. However, as time changes and demographics change, the owner of a business should be able to modify the business to accommodate the changes. To the case in point, there may be increasing opportunity for seniors regarding housing options in the future and mobile homes may become less desirable for seniors than the other options. In that case,the owners of the mobile home parks that are currently senior would need to consider a change in their business. • There is no need to force a very small segment of the City's housing providers to provide housing only for seniors. There are currently a significant number of senior housing opportunities in Huntington Beach to provide for the seniors. A quick search for"senior housing in Huntington Beach"resulted in a variety of senior apartments, condominiums, and other facilities. Of course, the vast majority of Huntington Beach seniors live in single family detached housing. • A mobile home park that is designated a"senior" community or, "housing for `older persons' over 55 years of age", are not required to have 100% of the occupants be 55 years of age or older. According to federal law,up to 20% of the residents of the community may be all-ages. Seniors living in the"senior"parks are not now living in communities that are all seniors. The City refers to parks with occupancy by eighty percent older persons; however, there is no mention of qualified parks for "older persons,"which requires compliance with a comprehensive litany of requirements and conditions. Mere occupancy is not enough; the City cannot force 25241 Paster the A£ivifi.Suite 120-Luquna Hltls,Gaf#bruia 926&Y•Ptioue:949..t89.8303•Far.049.u.Stf.8,4t9 Errr�zit trtj�(Q>rth t.rrg • Wehsite:unvu. tzhet.rsrq Southern Ca iforniax HHETServing Orange,Riverside rind Barr BervarLino Counties since 198,E a Page Three owners to become"older persons"housing without establishing evidence of compliance with ALL federal requirements of the affected parks. • When a park is a senior park, the mobile home owners who want to sell their homes are restricted to selling to only 25% of the buyers and are not allowed to sell to the other 75% of willing buyers who are not seniors. Countywide the senior population is only 16.5%. Without the senior restriction, the seller has access to 100% of the buyers. This is a dramatic disadvantage to the owners of mobile homes. • Moreover, the elder communities in Huntington Beach parks all appear to be homogenous enclaves of Caucasian residency. Excluding families is to cause a disparate impact of shutting out families. Families are a disproportionately minority (protected classes under federal law). The disparate impact caused by the moratorium results in an unmistakable but clear secondary effect: the denial of housing based on national origin, color and race. • When a park is designated as a senior park homes may only be sold to seniors. If an underage person inherits a mobile home upon the death of a tenant, the underage person may not move into the park and is forced to sell the home. This is only one example of the "unintended consequences"of the City trying to regulate who can and cannot live in mobile home parks. Who will police and enforce the regulations? Conduct required surveys? Qualify new tenants?Defend the park owners in housing discrimination complaints?Advertise housing to conform to zoning as required? Undertake all the requirements of the operation of the parks required of the city when a zoning law is proposed?The City assumes all responsibilities for intent to operate,yet there is no direction,budgeting, or manpower devoted to paying for these new city services. We urge the City Council to reject the proposal to regulate mobile home park housing and to not adopt a moratorium or other regulations restricting who can live in the City's mobile home parks. Sincerely, Vickie Talley Executive Director cc: Huntington Beach Mobile Home Park Owners 2MV Paseo A,Alicia,Suite 120•Laguna Hills,Cali or7da 92853•Phone:949.380.330.3•Fax:90 380.3310 Email:infoOnhet.org • Kftite:wu;wmMet.org &Qtthern California/11HET Serving Orange,Riverside and San Bernardino Counties since 1982