BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 1542
                                                                  Page  1

          Date of Hearing:  April 25, 2007

                       ASSEMBLY COMMITTEE ON LOCAL GOVERNMENT
                             Anna Marie Caballero, Chair
                 AB 1542 (Evans) - As Introduced:  February 23, 2007
           
          SUBJECT  :  Mobilehome parks: conversions.

           SUMMARY  :  Repeals provisions of the Subdivision Map Act that  
          exempt the conversion of rental mobilehome parks to resident  
          ownership from local government approval and conditions.   
          Specifically,  this bill  :

          1)Repeals the provision of the Subdivision Map Act (Map Act)  
            that exempts the conversion of rental mobilehome parks to  
            resident ownership from local government approval and  
            conditions.

          2)Repeals the provisions of the Map Act that provide procedures  
            for subdividers to address the economic displacement of  
            nonpurchasing residents of a mobilehome park that is being  
            converted to resident ownership.

           EXISTING LAW  :

          1)Allows the local legislative body authorized to approve or  
            disapprove a tentative or parcel map for the conversion of a  
            rental mobilehome park to another use to require the  
            subdivider to take steps to mitigate any adverse impact on the  
            ability of displaced mobilehome park residents from finding  
            adequate space in a mobilehome park, but exempts the  
            conversion of rental mobilehome parks to resident ownership  
            from this provision.

          2)Requires, in lieu of local government approval and conditions,  
            that a subdivider offer residents of a mobilehome park that is  
            converted to ownership the option to purchase their   
            subdivided unit or to continue residency in the park if they  
            decide not to purchase their lot.

          3)Requires the subdivider to file a report on the impact of the  
            conversion upon residents of the park and to make the report  
            available to all residents 15 days prior to the hearing on the  
            tentative or parcel map before the local legislative body.









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          4)Requires the subdivider to conduct a survey of support of the  
            residents of the park for the proposed conversion.

          5)Limits the scope of the hearing of the legislative body on the  
            tentative or parcel map to the subdivider's compliance with  
            the procedures to avoid the economic displacement of   
            non-purchasing residents.

          6)Establishes the following method for avoiding the economic  
            displacement of non-purchasing residents:

             a)   Allows the monthly rent for non-purchasing residents who  
               are not low-income to increase from the preconversion rent  
               to market rents as defined in an appraisal conducted in  
               accordance with nationally recognized professional  
               appraisal standards in equal annual  increases over four  
               years;

             b)   Allows the monthly rent for non-purchasing, low-income  
               residents to increase from the preconversion rent by an  
               amount equal to the average monthly increase in rent in the  
               four years immediately preceding the conversion except that  
               in no event may the monthly rent be increased by an amount  
               greater than the average monthly percentage increase in the  
               Consumer Price Index for the most recently reported period.  
                

           FISCAL EFFECT  :  Unknown

           COMMENTS  :

          1)There are approximately 4,800 mobilehome parks and  
            manufactured communities in California with an estimated  
            700,000 residents.  In the majority of parks, residents own  
            their homes but rent the land on which their homes are  
            installed from the park on a month-to-month or long-term lease  
            agreement.  According to a recent background paper published  
            by the Senate Select Committee on Mobile and Manufactured  
            Homes (Select Committee), most of the parks in the state are  
            privately owned by investor groups or owner/operators, and an  
            estimated 150 are owned by resident organizations or  
            non-profit organizations.

          2)According to the Select Committee, in the mid-1980s, as a  
            result of increasing park rents for low- and moderate-income  








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            residents and the closure of some parks and displacement of  
            residents, the concept of resident-owned parks (ROP), in which  
            residents form a homeowners association to purchase a park for  
            sale and convert it to a mobilehome subdivision, condominium,  
            stock co-operative, or non-profit ownership, gained  
            popularity.  As a result of this shift between 1984 and 1996,  
            a number of laws were enacted to encourage ROP conversions.

          3)Conversions of mobilehome parks to other uses are considered  
            to be a subdivision pursuant to the Map Act.  Prior to 1991,  
            the Map Act required a subdivision map to be filed and  
            approved by the local jurisdiction before individual lots in a  
            park could be sold and converted to a resident-owned  
            subdivision or condominium, and allowed the local government  
            to impose its own conditions on the map, such as steps to  
            mitigate economic displacement of non-purchasing residents or  
            inclusion of a method to ensure that a majority of residents  
            supported the conversion.  In 1991 the Legislature exempted  
            ROP conversions from Map Act requirements when two-thirds of  
            the owners approved the conversion,  Then in 1995, in response  
            to further complaints from some resident groups and conversion  
            consultants, the Legislature restricted the power of local  
            governments to regulate the conversion of parks to  
            resident-owned condominiums or subdivisions with the enactment  
            of Government Code Section 66427.5, which provided a minimum  
            state standard for mitigation of non-purchasing residents  
            through a "state-rent control formula" for low-income  
            residents who did not purchase their lots. 

          4)The creation of a state rent control formula preempted local  
            rent control ordinances, raising concerns among local  
            jurisdictions who had no means of enforcing the state rent  
            control.  Additionally, moderate-income residents who do not  
            purchase their mobilehome have their lot rents increase to  
            market rate in four years, which has led to concerns about the  
            loss of affordable housing.

          5)In response to an appellate court decision (El Dorado Palm  
            Springs, Ltd. v. City of Palm Springs et al.), the Legislature  
            passed AB 930 (Keeley) Chapter 1143, Statutes of 2002, to  
            allow local governments to require park owners as part of the  
            Subdivision Map Act process to provide the city with a survey  
            of support indicating resident support for a proposed ROP  
            conversion, and included un-codified language stating the bill  
            was intended to assure such conversions were "bona-fide."








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          6)According to the Select Committee, within the last year and a  
            half a number of mobilehome parks have either notified their  
            residents of the park's intention to convert or have actually  
            applied to local governments for a map to convert their rental  
            parks to a park condominium. Media reports indicated there may  
            be between 12 and 30 park-owner initiated ROP conversions  
            taking place in, among other locations, Buellton, Carson,  
            Ojai, Vallejo, Santa Rosa, Healdsburg, Rohnert Park, and  
            unincorporated areas of Sonoma and San Luis Obispo Counties.

          7)At a recent hearing of the Select Committee, representatives  
            of local governments expressed concern that the existing  
            process for converting mobilehome parks to resident ownership  
            does not give them the authority to enforce rent control  
            protections and reduces their affordable housing supply.   
            Cities and counties are required to maintain and produce a  
            specified amount of affordable housing each year, and the  
            conversion of rental mobilehome parks to resident ownership,  
            which allows mobilehomes that are not purchased by the  
            resident to go to market rate after four years, reduces the  
            supply of affordable housing in the community.

          8)Under existing law, a local governing body has the authority  
            to approve a tentative subdivision map for a mobilehome park  
            conversion to other uses and to impose conditions on that  
            approval to mitigate the impact of the conversion on  
            residents' ability to find adequate housing in other  
            mobilehome parks.  The standard is a minimum and does not  
            prohibit the local legislative body from enacting more  
            stringent provisions.  However, the law specifically exempts  
            ROP conversions from local control. AB 1542 removes this  
            exemption. 

          9)The Committee may wish to consider two basic questions  
            concerning AB 1542:

             a)   Is it appropriate that the state should substitute its  
               judgment for that of a local government for this one narrow  
               category of land use decision, particularly if doing so  
               makes it harder for local governments to satisfy other  
               state-imposed requirements for the provision of affordable  
               housing?

             b)   Given that conversion of mobilehome parks to resident  








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               ownership may provide lower- income households with unique  
               opportunities to achieve true, equity-building home  
               ownership, should local governments be allowed to place  
               additional hurdles in the way of such conversions?  Does AB  
               1542 provide protections to one class of lower-income  
               household at the expense of another?

          10)This bill was heard by the Assembly Housing and Community  
            Development Committee on April 11, 2007, where it passed with  
            a 5-2 vote.
                     
           

          REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          City of Santa Rosa [CO-SPONSOR]
          County of Sonoma [CO-SPONSOR]
          American Planning Association, CA Chapter
          CA Alliance for Retired Americans
          CA Rural Legal Assistance Foundation
          CA State Association of Counties
          Cities of Carson and Santa Rosa
          County of Ventura
          El Sereno Estates
          Golden State Manufactured-Home Owners League
          Mayors and Councilmembers Association of Sonoma County
          Western Center on Law and Poverty
          Individual letters (90)
          Petition signatories (580)

           Opposition 
           
          Californians for Resident Ownership
          CA Mobilehome Parkowners Alliance
          Western Manufactured Communities Housing Association
          Individual letter (1) 

           Analysis Prepared by  :    J. Stacey Sullivan / L. GOV. / (916)  
          319-3958