sr-112310-3kCity Council Meeting: November 23, 2010
Agenda Item:J"~-
To: Mayor and City Council
From: Eileen Fogarty, Director of Planning & Community Development
Subject: Adoption of a resolution setting forth construction, use, maintenance,
occupancy and design standards for the Mountain View Mobile Home
Park
Recommended Action
Staff recommends that the City Council adopt the attached resolution clarifying that non-
administrative portions of The California Mobile Home Parks Act Regulations (Title 25 of
the California Code of Regulations Sections 1000 et. sec.) will be enforced at the
Mountain View Mobile Home Park which is otherwise exempt from such Regulations
because the mobile home park is currently owned and operated by the City.
Executive Summary
Sections 1000 et. sec. of Title 25 of the California Code of Regulations ("Title 25") is a
comprehensive Code that governs the construction, use, maintenance, occupancy, and
design of mobile home parks throughout the State. In preparing for the installation of 20
new manufactured homes at Mountain View Mobile Home Park (MVMHP), the
applicability of codes governing the proper placement of these new homes was
reviewed. Government-owned mobile home parks are exempt from Title 25. Therefore,
the State building code referred to as Title 24 currently applies to MVMHP. Title 24
covers everything from small sheds to high-rise buildings, but contains no regulations
specific to mobile home parks. In its discretion, the City Council can decide to apply the
non-administrative portions of Title 25 (rather than Title 24) as the appropriate set of
regulations for MVMHP. Title 25 regulates nearly all mobile home parks throughout the
State including the other mobile home park ih the City, Village Trailer Park. The
attached resolution clarifies that the City Building Officer shall apply the non-
administrative provisions of Title 25 at MVMHP.
Background
The City purchased .MVMHP in 2000 and operates it as deed-restricted affordable
housing, with 105 rent controlled spaces. Subsequent to the City acquisition of MVMHP,
a number of improvements have been implemented at the park. Recently, MVMHP
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underwent a complete infrastructure upgrade. The next phase of work involves
replacing 20 older City-owned travel trailers and mobile homes with new manufactured
homes, as approved by City Council on September 28, 2010
Discussion
Pursuant to Health & Safety Code Section 18303, MVMHP automatically became
exempt from the Title 25 when the City acquired the property and assumed operation.
Section 18303 specifically states that Title 25 does not apply to any mobile home park
owned, operated, and maintained by government entities. Title 25 is a comprehensive
code with specifically crafted criteria for mobile home parks. Due to the preparation for
the 20 new homes at MVMHP and the fact that new manufactured homes have not
been installed at MVMHP for years, staff reviewed whether Title 24 or Title 25 should
govern the installation of the new manufactured homes.
Title 25 recognizes that mobilehome parks such as MVMHP, constructed prior to 1961,
require standards that allow such properties to continue to function while maintaining
safety for the occupants. Accordingly, Title 25 establishes different minimum standards
for mobile home parks constructed prior to 1961 compared to mobile home parks
constructed after 1961. Similar to the process that the State uses to update Title 24
(which the City adopts as its Building Code), Title 25 is regularly updated based on
experience and newer technology, continuously improving safety..
Unless the City would add special standards to its building code that would apply to pre-
1961 mobile home parks, Title 24 would require new manufactured housing units
installed at MVMHP to comply with the same standards as traditional buildings, i.e.
single family homes. Applying Title 24 setback and building separation requirements to
MVMHP would require new units to be approximately four feet narrower than would be
permitted under Title 25. The result would be a significant loss of living space for each
unit replaced: The loss of living space reduces the number of bedrooms in each unit;
compromising the ability to house some of the existing families in accordance with
housing regulations regarding the minimum number of bedrooms for larger families.
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Additionally, awnings and covered porches would not be permitted on many of the
smaller lots in the mobile home park, further reducing usable areas.
The new manufactured homes will be built to standards established by the federal
Department of Housing and Urban Development (HUD). The quality and safety of the
new manufactured homes will be superior to the units they will replace. These new
homes will be more energy efficient, have fire resistant siding, modern electrical,
plumbing, and heating systems and be equipped with fire sprinkler systems. Rather
than revise the local building code to include special provisions for mobile home parks
like MVMHP that are exempt from Title 25 due to government ownership, staff
recommends the City apply the non-administrative portions of Title 25 at MVMHP. This
results in a consistent set of regulations applicable to both MVMHP and Village Trailer
Park. The attached resolution clarifies that the City Building Officer shall apply the non-
admihistrative provisions of Title 25 at MVMHP.
Alternative to Title 25
The alternative to Title 25 is applying the City Building Code (which adopts State Title
24) to MVMHP. Title 24 provides safety standards in all types of buildings ranging from
small sheds to high-rise buildings. However, Title 24 contains no specific regulations for
mobile home parks which are unique. Title 25 is specifically designed with safety
standards for mobile home parks.
Environmental Analysis
City Council action oh this matter is not subject to CEQA pursuant to CEQA Guidelines
Section 15060(C)(2), in that the action to clarify the application of safety standards of
Title 25 to all mobile home parks within the City will not result in a direct or reasonably
foreseeable indirect physical change in the environment.
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Financial Impacts & Budget Actions
The recommendation in this report involves clarifying applicable building code
requirements for mobile home parks and does not have any significant budget or fiscal
impact.
Prepared by:
Ron Takiguchi, Building Officer, Building & Safety Division, PCD
Forwarded to Council:
Rod Gould
City Manager
Attachment: Resolution
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Reference Resolution No.
10545 (CCS).