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HomeMy WebLinkAbout20 - Ebb Tide Project Relocation Impact Report for Property Located at 1560 Placentia Avenue (PA2014-151)CITY OF NEWPORT BEACH City Council Staff Report January 27, 2015 Agenda Item No. 20 TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL FROM: Kimberly Brandt, Community Development Director — (949) 644 -3226, kbrandt@newportbeachca.gov PREPARED BY: Fern Nueno, Associate Planner PHONE: (949) 644 -3227 TITLE: Ebb Tide Project Relocation Impact Report for property located at 1560 Placentia Avenue(PA2014 -151) ABSTRACT: The property owner seeks to close the Ebb Tide Mobile Home Park located at 1560 Placentia Avenue. Pursuant to California Government Code, the applicant must prepare a Relocation Impact Report ( "RIR ") to document the impact upon the mobile home park residents. The City Council shall review the report to determine if it is sufficient and may require the applicant to take steps to mitigate any adverse impact of the closure on the ability of displaced mobile home park residents to find adequate housing in a mobile home park. RECOMMENDATION: a) Receive public comment; b) Find that the application is not subject to the requirements of the California Environmental Quality Act ( "CEQA ") pursuant to Section 15061.b.3 of the State CEQA Guidelines; and c) Adopt Resolution No. 2015 -8, A Resolution of the City Council of the City of Determining that the Ebb Tide Project Relocation Impact Report is Sufficient Pursuant Code Section 65863.7 for the Closure of the Ebb Tide Mobile Home Park Located at Avenue (PA2014 -151) (Staff Report Attachment No. CC 1). FUNDING REQUIREMENTS: There is no fiscal impact related to this item. Newport Beach to Government 1560 Placentia 20 -1 DISCUSSION: Proiect Setting The Ebb Tide Mobile Home Park is located in the West Newport Mesa area near the intersection of Placentia Avenue and 16th Street, and to the north it borders industrial property in Costa Mesa (Vicinity Map, Attachment No. CC 2). The site is located within the Multiple -Unit Residential (RM) Zoning District and is surrounded by multiple -unit residential, industrial, medical, and commercial uses. The site is 4.7 acres in size and is developed with 73 mobile home spaces, parking areas, and a pool and recreation area. Presently there are 67 spaces occupied by mobile homes and six spaces are vacant. Of the 67 mobile homes, 62 are occupied and five are unoccupied. Of those 62 occupied mobile homes, 52 are owner occupied and ten are renter occupied. These occupancy statistics are summarized in Table 1. Table 1 — Occupancy Statistics Total Mobile Home Spaces 73 Vacant Spaces 6 Mobile Homes 67 Mobile Homes Occupied 62 Owner Occupied 52 Renter Occupied 10 Proiect Description Pursuant to Government Code Section 65863.7, the applicant requested a hearing before the City Council on the sufficiency of the RIR (Attachment No. CC 6). In determining the impact of the closure on the residents, the report addresses the availability of adequate replacement housing in mobile home parks and relocation costs. The Council's responsibility is to review the report for adequacy, and the Council may require the applicant to take steps to mitigate any adverse impact of the closure on the ability of the displaced residents to find adequate housing. Pursuant to Government Code, the mitigation measures shall not exceed the reasonable costs of relocation. It is important to note that Council may not preclude the applicant from closing the mobile home park in accordance with state law. Additionally, the applicant has applied to develop the site with an 83 -unit residential subdivision, which is a separate application from this RIR review, and which will require discretionary City review and approval. Analysis Pursuant to state law, the applicant has the right to terminate mobile home park tenancies as part of a park closure so long as the owner provides the residents with: (1) 6 or 12 months advance notice of the proposed park closure (depending on whether or not the applicant needs discretionary permits /entitlements from the City); (2) a Relocation Impact Report that adequately assesses the impact of the closure of the park on displaced residents by addressing the availability of adequate replacement housing in mobile home parks and relocation costs; and (3) at least 15 days' written notice of the Council hearing on the RIR and a copy of the RIR. Staff retained a consultant to review the adequacy of the RIR and the consultant's report is provided as Attachment No. CC 5. While the term "relocation costs" is undefined, this term has been interpreted to mean the physical costs of moving the mobile home to a new mobile home park, and the consultant's evaluation includes this interpretation. This interpretation is also consistent with the state Mobilehome Residency Law (California Civil Code Section 798 et seq.) intent of providing protection and adequate procedures for the termination of tenancies because of: (1) the high cost of moving mobile homes; (2) the potential for damage resulting from the movement of mobile homes; (3) the requirements relating to the 20 -2 installation of mobile homes; and (4) the cost of landscaping and lot preparation Staff concurs with the consultant's conclusion that the RIR complies with all necessary legal requirements because it sufficiently addresses the impact of the proposed closure on Ebb Tide residents by: (1) identifying alternative sites to which homeowners might relocate their mobile homes, should they choose to do so; (2) identifying other alternative housing options available to the residents; and (3) providing the relocation benefits and assistance to which the residents may be entitled pursuant to applicable law. Furthermore, the consultant believes the RIR provides payments above the reasonable cost of relocation required by state law by including temporary lodging expenses and services of a relocation specialist. In regards to the proposed relocation benefits and assistance, the RIR provides the following mitigation measures (RIR on Pages 9 -11), all of which the applicant has agreed to provide: a) For owners of mobile homes that have the potential to be relocated to a different mobile home park, payment will be provided including the actual cost of relocation (estimated by a professional move specialist to be between $5,500- $15,700 depending on the square footage of the unit), temporary lodging expenses (maximum payment of $125 per night, up to seven nights), moving costs (between $1,100- $1,570 depending on the number of bedrooms determined by the federal fixed move schedule), necessary modifications to accommodate a disabled person, and services of a relocation specialist. b) For owners of mobile homes that do not have the potential to be relocated to a different mobile home park, payment will be provided including a fixed payment (between $9,000 and $15,700 based on the square footage of the unit), moving costs (between $1,100 - $1,570 depending on the number of bedrooms determined by the federal fixed move schedule), and services of a relocation specialist. c) For renters of mobile homes, a fixed payment of $2,000 per unit will be paid to assist with securing replacement housing. Staff received correspondence from Ebb Tide residents (Attachment No. CC 7) that expressed concerns over the process and adequacy of the RIR. Also included in the correspondence are response letters from the applicant. Staff will address the comments in a separate memorandum to the Council. If the Council believes that the proposed measures within the RIR are not sufficient, Council may identify additional measures for the applicant to implement to mitigate the impact of the closure on the displaced residents. Alternatively, the Council could direct the applicant to revise the RIR to incorporate additional supporting information that would make the RIR sufficient, and the revised RIR would be reviewed at a future Council Meeting. ENVIRONMENTAL REVIEW: Staff recommends that the City Council find that the review of the Relocation Impact Report is covered by the general rule that the California Environmental Quality Act ( "CEQA") applies only to projects that have the potential for causing a significant effect on the environment (Section 15061.b.3 of the State CEQA Guidelines). It can be seen with certainty that there is no possibility that this action will have any effect on the environment as it only determines economic mitigation and does not authorize development, and therefore, this action is not subject to CEQA. Furthermore, the project would be exempt pursuant to Section 15268 of Title 14 of the California Code of Regulations, which exempts ministerial projects. The project is ministerial rather than discretionary in nature given the very narrow scope of authority that the Council has pursuant to Government Code Section 65863.7. Future development of the site is not included in this determination and would be reviewed pursuant to CEQA. 20 -3 NOTICING: The property owner has provided proofs of service confirming that all residents have been provided with the requisite 15 -day advance notice of the hearing on the RIR and a copy of the RIR. It is staff's belief that the owner has complied with all necessary noticing requirements. Additionally, the item appeared on the agenda for this meeting, which was posted at City Hall and on the City website. ATTACHMENTS: Description Attachment No. CC 1 - Draft Resolution Attachment No. CC 2 - Vicinity Mao Attachment No. CC 3 - Government Code Section 65863.7 Attachment No. CC 4 - Hearing Notice to Residents Attachment No. CC 5 - Consultant Analysis Report Attachment No. CC 6 - Relocation Impact Report Attachment No. CC 7 - Correspondence Received 9=1 Attachment No. CC 1 Draft Resolution 20 -5 RESOLUTION NO. 2015- A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF NEWPORT BEACH DETERMINING THAT THE EBB TIDE PROJECT RELOCATION IMPACT REPORT IS SUFFICIENT PURSUANT TO GOVERNMENT CODE SECTION 65863.7 FOR THE CLOSURE OF THE EBB TIDE MOBILE HOME PARK LOCATED AT 1560 PLACENTIA AVENUE (PA2014 -151) I I : I * • 11 VA K • I N L [ • 7 I 111111 • ] a I : I ME • ] I rite] 0 i • 1 WIN g • ] :4 ■ :3 4_N ] : I NMI MI :711 : rd 9104 101y_F9 to] I W I ►I T 6� SECTION 1. STATEMENT OF FACTS. An application was filed by Ebb Tide LLC., on behalf of the property owner The Totah Family Partnership, with respect to property located at 1560 Placentia Avenue, and legally described as a Portion of Lot 714 of First Addition to Newport Mesa Tract. 2. The applicant has filed an application requesting that the City determine the sufficiency of a Relocation Impact Report pursuant to Government Code Section 65863.7 for the closure of the Ebb Tide Mobile Home Park. The site is developed with a 73 -space residential mobile home park. As of August 2014, 67 spaces contain mobile homes and six spaces are vacant. Of the 67 mobile homes, 62 are occupied and five are unoccupied. Of those 62 occupied mobile homes, 52 are owner occupied and ten are renter occupied. 3. The Relocation Impact Report, dated November 26, 2014, was prepared by Overland, Pacific & Cutler, Inc. of Irvine, California and includes a discussion of the impact of the closure on the displaced residents. The report includes a summary of the applicable state law requirements, a description of the current park conditions and resident profile, replacement housing and moving cost descriptions and analyses, proposed mitigation measures, and a relocation plan. The report identifies alternative sites to which homeowners might relocate their mobile homes (should they choose to do so), other alternative housing options available for homeowners and renters, and the relocation benefits and assistance that the applicant is offering to mitigate the impact of the closure upon the residents. 4. The subject property is located within the Multiple -Unit Residential (RM) Zoning District and the General Plan Land Use Element category is Multiple -Unit Residential (RM). 5. The subject property is not located within the coastal zone. 6. The applicant has provided proofs of service confirming that the mobile home park residents have been provided with a copy of the referenced Relocation Impact Report and confirming that the mobile home park residents have been provided with the requisite 15 -day advance notice of this hearing. 7. A public hearing was held by the City Council on January 27, 2015, in the City Hall Council Chambers at 100 Civic Center Drive, Newport Beach, California. A notice of 9M. City Council Resolution No. 2015 -_ Pape 2 of 4 time, place and purpose of the meeting was given in accordance with Government Code Section 65863.7(b) and applicable law. Evidence, both written and oral, was presented to, and considered by, the City Council at this hearing. SECTION 2. CALIFORNIA ENVIRONMENTAL QUALITY ACT DETERMINATION. 1. This action is covered by the general rule that the California Environmental Quality Act ( "CEQA ") applies only to projects that have the potential for causing a significant effect on the environment (Section 15061.b.3 of the State CEQA Guidelines). It can be seen with certainty that there is no possibility that this action will have any effect on the environment as it only determines economic mitigation and does not authorize development, and therefore, this action is not subject to CEQA. Furthermore, the project would be exempt pursuant to Section 15268 of Title 14 of the California Code of Regulations, which exempts ministerial projects. The project is ministerial rather than discretionary in nature given the very narrow scope of authority that the Council has pursuant to Government Code Section 65863.7. Future development of the site is not included in this determination and would be reviewed pursuant to CEQA. 2. The City Council finds that judicial challenges to the Ci' CEQA determinations and approvals of land use projects are costly and time consuming. In addition, project opponents often seek an award of attorneys' fees in such challenges. As project applicants are the primary beneficiaries of such approvals, it is appropriate that such applicants should bear the expense of defending against any such judicial challenge, and bear the responsibility for any costs, attorneys' fees, and damages which may be awarded to a successful challenger. SECTION 3. DECISION. NOW, THEREFORE, the City Council of the City of Newport Beach, California, hereby resolves as follows: 1. Based on the aforementioned findings, the Relocation Impact Report, the whole of the administrative record, and the evidence and testimony received during the public hearing, the City Council finds that the applicant has met all the procedural requirements pursuant to Section 65863.7 of the Government Code. The City Council finds that the Relocation Impact Report is sufficient as it adequately identifies alternative sites to which homeowners might relocate their mobile homes, should they choose to do so, other alternative housing options available for homeowners and renters, and the relocation benefits and assistance that the applicant is offering to mitigate the impact of the closure upon the residents, consistent with Section 65863.7(e) of the Government Code. 2. Closure of the park will create an adverse impact to residents, and therefore, the applicant shall implement all of the measures contained within the Ebb Tide Project Relocation Impact Report attached as Exhibit A to mitigate the impact of the closure of Ebb Tide Mobile Home Park upon the residents. 07 -22 -2014 20 -7 City Council Resolution No. 2015 -_ Pape 3 of 4 3. To the fullest extent permitted by law, applicant shall indemnify, defend and hold harmless City, its City Council, its boards and commissions, officials, officers, employees, and agents from and against any and all claims, demands, obligations, damages, actions, causes of action, suits, losses, judgments, fines, penalties, liabilities, costs and expenses (including without limitation, attorney's fees, disbursements and court costs) of every kind and nature whatsoever which may arise from or in any manner relate (directly or indirectly) to City's review of and determination of sufficiency on the Ebb Tide Project Relocation Impact Report including, but not limited to, Planning Activity No. PA2014 -151. This indemnification shall include, but not be limited to, damages awarded against the City, if any, costs of suit, attorneys' fees, and other expenses incurred in connection with such claim, action, causes of action, suit or proceeding whether incurred by applicant, City, and /or the parties initiating or bringing such proceeding. The applicant shall indemnify the City for all of City's costs, attorneys' fees, and damages which City incurs in enforcing the indemnification provisions set forth in this condition. The applicant shall pay to the City upon demand any amount owed to the City pursuant to the indemnification requirements prescribed in this condition. 4. This resolution shall take effect immediately upon its adoption by the City Council, and the City Clerk shall certify the vote adopting the resolution. PASSED, APPROVED, AND ADOPTED THIS 271h DAY OF JANUARY, 2015, BY THE FOLLOWING VOTE, TO -WIT: MA CITY CLERK 07 -22 -2014 AYES, COUNCIL MEMBERS NOES, COUNCIL MEMBERS ABSENT COUNCIL MEMBERS Edward D. Selich NM City Council Resolution No. 2015 -_ Paqe 4 of 4 EXHIBIT A Relocation Impact Report 07 -22 -2014 K Attachment No. CC 2 Vicinity Map 20 -10 Vicinity Map Ebb Tide Project Relocation Impact Report (PA2014 -151) 1560 Placentia Avenue 20 -11 Attachment No. CC 3 Government Code Section 65863.7 20 -12 Government Code Section 65863.7 65863.7. (a) Prior to the conversion of a mobilehome park to another use, except pursuant to the Subdivision Map Act (Division 2 (commencing with Section 66410) of Title 7), or prior to closure of a mobilehome park or cessation of use of the land as a mobilehome park, the person or entity proposing the change in use shall file a report on the impact of the conversion, closure, or cessation of use upon the displaced residents of the mobilehome park to be converted or closed. In determining the impact of the conversion, closure, or cessation of use on displaced mobilehome park residents, the report shall address the availability of adequate replacement housing in mobilehome parks and relocation costs. (b) The person proposing the change in use shall provide a copy of the report to a resident of each mobilehome in the mobilehome park at least 15 days prior to the hearing, if any, on the impact report by the advisory agency, or if there is no advisory agency, by the legislative body. (c) When the impact report is filed prior to the closure or cessation of use, the person or entity proposing the change shall provide a copy of the report to a resident of each mobilehome in the mobilehome park at the same time as the notice of the change is provided to the residents pursuant to paragraph (2) of subdivision (g) of Section 798.56 of the Civil Code. (d) When the impact report is filed prior to the closure or cessation of use, the person or entity filing the report or park resident may request, and shall have a right to, a hearing before the legislative body on the sufficiency of the report. (e) The legislative body, or its delegated advisory agency, shall review the report, prior to any change of use, and may require, as a condition of the change, the person or entity to take steps to mitigate any adverse impact of the conversion, closure, or cessation of use on the ability of displaced mobilehome park residents to find adequate housing in a mobilehome park. The steps required to be taken to mitigate shall not exceed the reasonable costs of relocation. (f) If the closure or cessation of use of a mobilehome park results from the entry of an order for relief in bankruptcy, the provisions of this section shall not be applicable. (g) The legislative body may establish reasonable fees pursuant to Section 66016 to cover any costs incurred by the local agency in implementing this section and Section 65863.8.. Those fees shall be paid by the person or entity proposing the change in use. (h) This section is applicable to charter cities. (i) This section is applicable when the closure, cessation, or change of use is the result of a decision by a local governmental entity or planning agency not to renew a conditional use permit or zoning variance under which the mobilehome park has operated, or as a result of any other zoning or planning decision, action, or inaction. In this case, the local governmental agency is the person proposing the change in use for the purposes of preparing the impact report required by this section and is required to take steps to mitigate the adverse impact of the change as may be required in subdivision (e). (j) This section is applicable when the closure, cessation, or change of use is the result of a decision by an enforcement agency, as defined in Section 18207 of the Health and Safety Code, to suspend the permit to operate the mobilehome park. In this case, the mobilehome park owner is the person proposing the change in use for purposes of preparing the impact report required by this section and is required to take steps to mitigate the adverse impact of the change as may be required in subdivision (e). 20 -13 Attachment No. CC 4 Hearing Notice to Residents 20 -14 Tenant Name: Tenant Address: Space No: NOTICE OF HEARING ON RELOCATION IMPACT REPORT RE: CLOSURE Ebb Tide Mobile Home Park 1560 Placentia Avenue Newport Beach CA 92663 TO MOBILE HOME OWNERS AND TENANTS OF EBB TIDE MOBILE HOME PARK: This Notice is to inform you, pursuant to Civil Code § 798.56(g) and Government Code §§ 65863.7(b) & 65863.7 (c) that there will be a hearing on January 27, 2015 at 7 pm, before the City of Newport Beach ( "City ") City Council, to take place in City Council Chambers, 100 Civic Center Drive, Newport Beach, CA 92660 to consider the adequacy of the proposed Relocation Impact Report regarding the Closure of Ebb Tide Mobile Home Park ( "RIR "). A copy of the proposed RIR is enclosed with this Notice. While an application for change of use is currently pending before the City, this hearing is limited only to consideration of the RIR. The property owner reserves the right to amend, supplement or otherwise modify this Notice, and /or to provide additional notices regarding Park closure as circumstances warrant. Dated: January 9, 2014 Ebb Tide Mobile Home Park By: Totah Family, LLC 38548.001/4844-871 6-9049v. 1 Managing Member 20 -15 Attachment No. CC 5 Consultant Analysis Report 20 -16 11 PARAGON PARTNERS ro December 17, 2014 Fern Nueno Associate Planner, AICP, LEED AP BD +C Community Development Department City of Newport Beach 100 Civic Center Drive Newport Beach, CA 92658 Re: Ebb Tide Project— Review of Draft Relocation Impact Report Dear Ms. Nueno: This evaluation is submitted in response to the City of Newport Beach's request for review of the Draft Relocation Impact Report ( "Draft RIR ") for the Ebb Tide Mobile Home Park (the "Park "), located at 1560 Placentia Avenue. The Draft RIR was prepared by Overland, Pacific and Cutler ( "OPC ") in September 2014 with revisions completed in November 2014. This letter addresses the following issues pertaining to the proposed Park closure: • State of California requirements to change the use of the Park; • The process proposed for the change of use and /or closure; • Analysis of the "Reasonable Cost of Relocation" limit on closure impact mitigation; • The Draft RIR's compliance with state law Scope of Work Paragon Partners, Ltd. ( "Paragon ") was tasked with reviewing the Draft RIR for conformance with California Government Code Section 65863.7 et Seq. and the California Mobile Home Residency Law ( "MRL"). The Draft RIR was reviewed for completeness and conformance with the pertinent laws described above. This review generally included the following: • An analysis of the needs of the displaced households with respect to issues such as household income and special needs • An analysis of replacement housing needs and a determination as to whether or not sufficient housing is available to accommodate the number of displaced households • Personal contact with as many of the occupants as possible • Replacement housing resource survey results • Relocation advisory assistance program • Temporary housing plans and procedures, if applicable • Description of available payment options 5762 Bolsa Avenue, Suite 2oi I Huntington Beach, California 92649 714 379 3376 1 888.89974981 Fax 714373.12341 www.paragon- partners.com 20 -17 I I� PARAGON PARTNERS LTD California Government Code 65863.7 requires that a Park owner take steps to mitigate any adverse impact of the conversion on the ability of displaced mobile home park residents to find adequate housing in a mobile home park. It does not provide any other specific content requirements. However, as a matter of practicality, the items listed below were considered to be pertinent in bolstering the sufficiency of the Draft RIR. • Rent roll with age of each unit, space rental amount, size, homeowner or resident • Project description • Location of all reasonably comparable mobile home parks within a reasonable radius, including vacancies, lease rates, number of units for sale, and age or other restrictions • The availability and cost of standard rental housing of reasonably comparable size and quality within a reasonable radius • Determination of total number of mobile homes to be relocated to another park, and the basis upon which this was determined • Estimated cost of relocating the eligible mobile homes identified above _. • Proposed measures to adequately mitigate the adverse impacts upon each eligible occupant, including a schedule of payments II. Park Description The Ebb Tide Mobile Home Park is a residential mobile home park comprised of 73 spaces on a lot of approximately 4.65 acres. The Park was originally developed approximately 40 to 50 years ago and is in fair condition. There are three general -use buildings on site — an office with laundry facilities, a resident club room and adjacent swimming pool and a resident manager home. For those who reported, the average age of the mobile homes on site is 20 years. The Park is located in an urban setting and is surrounded by industrial, retail and residential uses. III. Important Definitions Homeowner — a person who has a tenancy in a mobile home park under a rental agreement Resident — a homeowner or other person who lawfully occupies a mobile home Tenancy — the right of a homeowner to the use of a site within a mobile home park on which to locate, maintain, and occupy a mobile home, site improvements, and accessory structures, for human habitation, including the use of the services and facilities of the park MRL Section 798.55 — "Also, the legislature finds and declares that, because of the high cost of moving mobile homes, the potential for damage resulting there from, the requirements relating to the installation of the mobile homes and the cost of landscaping or lot preparation, it is necessary that the owners of mobile homes occupied within mobile home parks be provided 20 -18 I I� PARAGON PARTNERS ro with the unique protection from actual or constructive eviction afforded by the provisions of this chapter". The reasonable cost of relocation is limited to the cost to physically move the mobile home to another mobile home park. IV. Requirements to Change the Use of the Park The MRL allows a park owner who desires to change the use of their land to evict their tenants, provided that the steps outlined below are followed. All occupants in the Park must be provided at least 15 days' written notice that the owner will be appearing before a local governmental board, commission or body to request permits for a change of use of a mobile home park. After all required permits requesting a change of use have been approved by the local governmental board, commission or body, the owner shall give the homeowners six (6) months or more written notice of termination of tenancy. If the change of use requires no local governmental permits, then notice shall be given twelve (12) months or more prior to the owner's determination that a change of use will occur. 3. Prior to the conversion of a mobile home park to another use, the person proposing the change in use must file a report on the impact of the conversion, closure, or cessation of use upon the displaced residents of the mobile home park to be converted or closed. In determining the impact of the conversion, closure, or cessation of use on displaced mobile home park residents, the report shall address the availability of adequate replacement housing in mobile home parks and relocation costs. 4. The person proposing the change in use shall provide a copy of the report to a resident of each mobile home in the mobile home park at least 15 days prior to the hearing, if any, on the impact report by the advisory agency, or if there is no advisory agency, by the legislative body. The legislative body, or its delegated advisory agency, shall review the report, prior to any change of use, and may require, as a condition of the change, the person or entity to take steps to mitigate any adverse impact of the conversion, closure, or cessation of use on the ability of displaced mobile home park residents to find adequate housing in a mobile home park. The steps required to be taken to mitigate shall not exceed the reasonable costs of relocation, which has been interpreted to mean the physical cost of moving the mobile home to a new mobile home park. 20 -19 11 PARAGON PARTNERS ro V. Results of Evaluation The Draft RIR was found to be very well written, in plain and understandable language. It was thorough and exhaustive in addressing the current occupants' circumstances, the payment options, relocation possibilities and replacement housing resources. Evaluation Criteria Evaluation Response An analysis of the needs of the displaced Twenty four (24) of the 62 occupied units households with respect to issues such as chose to respond to the survey. Of those who household income and special needs responded, there are 8 senior households and 7 households with a person with a disability. Additionally, 18 households responded to questions regarding income status. Of those households, 6 qualify as Extremely Low, 2 as Very Low, 8 as Low and 2 as Moderate under HUDs' income criteria. An analysis of replacement housing needs and In conjunction with the respondent households a determination as to whether or not sufficient and the rent roll, a summary table of current housing is available to accommodate the housing circumstances was included in the number of displaced households Draft RIR. It concludes that there is an ample supply of both mobile homes for sale and standard housing options. Although it does not summarize the data, it appears that the mobile homes for sale are within an affordable range. While those moving to standard housing will likely experience an increase in monthly rent, there are reasonably affordable units available. Personal contact with as many of the The initial contact letter was not met with a occupants as possible large number of responses. However, a subsequent effort resulted in additional personal interviews. Ultimately, 24 of the 62 occupied units were personally interviewed. There is also an express commitment to complete personal meetings with the remainder of the occupants throughout the entire relocation process. This representation is found on page 6 of the Draft RIR. Replacement housing resource survey results Results are summarized in the "Replacement Housing Resources" section of the report, and tabulated in Tables 1 and 2 and Exhibits F, G and H. 20 -20 PARAGON PARTNERS LTD Evaluation Criteria Evaluation Response Proposed relocation advisory assistance Specific components of the relocation advisory program assistance program are found in the "Relocation Plan / Explanation of Services" section, and details regarding personal assistance are found on page 14. Proposed temporary housing plans and Temporary housing payments are specified in procedures, if applicable the "Proposed Mitigation Measures" section. Description of available payment options All relocation payments are specified in the "Proposed Mitigation Measures" section. Rent roll and for each space: age of unit, This information is detailed in Exhibit D "Park space rental amount, size, homeowner or Resident Data ". resident Project Description A very brief, but adequate, description of the project is included in the Introduction section. Location of all reasonably comparable mobile Results are summarized in the `Replacement home parks within a reasonable radius, Housing Resources" section of the report, and including vacancies, lease rates, number of tabulated in Tables 1 and 2 and Exhibit F. units for sale, and age or other restrictions The availability and cost of standard rental Results are summarized in the "Replacement housing of reasonably comparable size and Housing Resources" section of the report, and quality within a reasonable radius tabulated in Tables 1 and 2 and Exhibits G and H. Determination of total number of mobile It has been concluded that almost all of the homes to be relocated to another park, and units will not be able to be relocated to another the basis upon which this was determined park. This is due to the restriction on age of mobile homes accepted by other parks, and the age of almost all of the owner occupied units. Estimated cost of relocating the eligible mobile Estimated moving costs were provided by a homes identified above professional mover, including the cost to disassemble, move and reassemble the unit. These costs are broken down by size and are detailed in the "Moving Costs" section. Proposed measures to adequately mitigate the Relocation payments are detailed in the adverse impacts upon each eligible occupant, "Proposed Mitigation Measures" section and including a schedule of payments include options for moving a mobile home, renting standard housing and temporary housing, which is not required. 20 -21 I I� PARAGON PARTNERS ro In summary, replacement housing was thoroughly researched, and important factors such as space rent and prohibitions on age and size of mobile homes were included. A plethora of alternative housing was also identified, in the form of various low density and multifamily dwellings. Given the relocation payments available, and the general availability of housing options and price and rental cost ranges, it appears that there is sufficient replacement housing. The Draft RIR is sufficient and meets the requirements of the MRL and California Government Code 65863.7. It is recommended that the Draft RIR be placed on the council agenda for consideration. Should you have any questions or require additional clarification, please contact me at (714) 379 -3376 or via email at prhoad(awfagon- partners.com. Since Peter Rhoa 20 -22 Attachment No. CC 6 Relocation Impact Report 20 -23 RELOCATION IMPACT REPORT Ebb Tide Project Prepared for The Totah Family Partnership 34700 Pacific Coast Hwy, Suite 303 Capistrano Beach, CA 92624 in Overland, Pacific & Cutler, Inc. 1 Jenner, Suite 200 Irvine, CA 92618 (949) 951 -5263 November 26, 2014 20 -24 Table of Contents Introduction..................................................................................... ..............................1 Proposed New Project .................................................................... ..............................2 Mobile Home Park Location and Description ............................... ..............................2 A. Regional Location ........................................................................................... ..............................2 B. Park Site Location .......................................................................................... ............................... 3 C. Mobile Home Park Description ........................................................................ ..............................4 Mobile Home Park Resident Profile ............................................... ..............................5 Replacement Housing Resources ................................................ ............................... 6 A. Mobile Home Park Space ............................................................................... ..............................6 B. Mobile Homes For Sale ................... ........................ ....... ................. ....... ........................ ,.............. 7 C. Rental Housing ............... ................. ....... ......................................... ........................ .............7 MovingCosts ................................................................................... ..............................8 Proposed Mitigation Measures ..................................................... ............................... 9 A. Impacts to Mobile Home Owners .................................................................... ..............................9 B. Relocation Mitigation Measures ...................................................................... ..............................9 Relocation Plan / Explanation of Services ................................... .............................11 Conclusion...................................................................................... .............................15 Listof Exhibits: ........................................................................................................... 16 20 -25 Introduction The Ebb Tide Mobile Home Park is a 73 space residential mobile home park ( "Park ") situated on real property located in Newport Beach, CA. The property is currently owned and operated by The Totah Family Partnership, a California limited partnership ( "Owner ") and is being acquired by Ebb Tide LLC ( "Developer ") for proposed development of a new well designed 83 detached single family residence project. The proposed project will replace the Park's existing 73 spaces, site improvements and mobile homes. As a result, the current property owner ( "Owner ") is required to prepare a Closure Impact Report in accordance with the State of California Government Code and Mobile Home Residency Law; the purpose of which is to report on the impact of the proposed Park closure and to address measures to be taken to mitigate adverse effects of the proposed closure upon the residents of the Park who would be displaced by the closure. In 1978, the California Legislature enacted the Mobile Home Residency Law (Civil Code Section 798 et seq.) ( "MRL ") which provides a comprehensive statewide regulatory scheme governing the use and closure of mobile home parks (Civil Code sections 798 et seq. and Government Code sections 65863.7- 65863.8.) In anticipation of the need to prepare for closure of the Park, Overland, Pacific & Cutler, Inc. (OPC) has been contracted to prepare a Relocation Impact Report or Closure Impact Report (Report) as required by the MRL and the Government Code. The purpose of this Report is to explain the protections afforded those owners of mobile homes within the park. Among the mandates of Code Section 65863.7 are the requirements to "...report on the impact of the conversion, closure or cessation of use upon the displaced residents of the mobile home park to be converted or closed" and ...'address the availability of adequate replacement housing in mobile home parks and relocation costs. "The measures required to mitigate the adverse impact of the park closure on the displaced mobile home park residents shall not exceed the reasonable costs of relocation, pursuant to Section 65863.7. In addition, the Owner must notify residents of the Park of the proposed change in use, in accordance with Section 65863.8. Prior to the closure of the Park, the Owner and all residents of the Park shall have the right to, and the availability of, a public hearing before the legislative body on the sufficiency of the Report and the proposed relocation assistance described in Section 20 -26 65863.7. This Report will address all homeowners and occupants of the Park as of August 2014. In order to prepare this Report, OPC reviewed resident data that was provided by the residents and the Owner and performed a comprehensive study of mobile home park resources and other housing resources within Orange County. Consistent with Mobile Home Residency Law and Government Code Section 65863.7, this Report presents recommendations concerning the mitigation of relocation impacts associated with the closure of the Park. Proposed New Project The proposed project will be 83 well designed for -sale small -lot, single - family detached homes ranging from approximately 1,600 to 2,100 square feet. The new project's conceptual design is provided in Exhibit A. Mobile Home Park Location and Description A. Regional Location The Park is a residential mobile home park situated on the real property located at 1560 Placentia Avenue, Newport Beach, within Orange County. (See Figure 1: Regional Mobile Home Park Location.) E 20 -27 w,ll, tiowney .. „�Cynvrglad 1d 14ahra F.nrc�l..3.:..��r ie'ij �, xmmt La Miiada Grea!-�I fw, S' (_; Norwalk fw. •: ?! Ccanplon �n.a+Hlvi �Inle rrF 2 "'U n a. Yo16a Leda w $j��, DeIN r - xq I � A po }ulkflon kJ nL..oae[ I. eV[IPad q J GHrlka9 - _ `} iv lalllwgl}Q �r -'�'�d r Mdl!PIrtI HQIy ~�'� t .Q a I• 11 k.�H:,n.:r b�:, ,. laheim - �` rYVrcxx v .r. r .r a IF A, aJnY lll'i�� t /f�jJem »r r�urrx gIy. 34Y: L. Lanp fleaUl r,l.nr., Gerden G`oo= , ...m Wealminstm r ` teal rrrxn \\ Santa Ana 'uslin _. LI p Li+FSllmeranp.'r. Foualarn Yelley �. /- Hnponn'vel,l ;onn ror.r a -1n ' 6:IIle'1- Imp.o ll. n:n Hurnl- r.�iun Bew_h - z53a1 imnwocaln, !- Loki-F-presk kiiil:h.SilitU M.ry, 15W plH "ie A. Sly}j b4.rvils >a•. �n ers�r 13 11 y VA'-kr._ I Irxw Mlf9lpn rilpl0 urlu(N CU. Incnor, — xn Figure 1: Regional Mobile Home Park Location B. Park Site Location The Park, situated on approximately 4.65 acres, is bounded by W. 16th Street to the north, Superior Avenue to the east and south, and Placentia Avenue to the west. (See Figure 2: Mobile Home Site Location.) The legal description of the Park property is found in Exhibit B. c 20 -28 ,. YF C. Mobile Home Park Description The Park contains 73 mobile home spaces total. Sixty -seven spaces contain mobile homes, and six spaces are vacant. Of the 67 mobile homes currently in the Park, 62 are occupied and five are vacant. The Park has been in existence for approximately 40 — 50 years and contains three fixed structure amenities: a central business office and laundry room with three coin - operated washers and dryers, a resident club room with adjacent swimming pool, and a home occupied by the Park manager. The internal roadway is paved with asphalt. Approximately 21 unreserved parking stalls are located on the north edge of the property, and three stalls are located near the business office. Additionally, residents are able to park a maximum of two vehicles in front of their mobile home. The landscaping of the park is in fair condition. Placentia Avenue, the western border of the park, provides the only two vehicular entrances to Ebb Tide. A chain link fence separates Ebb Tide from the industrial site to M 20 -29 the north and commercial site to the east. A 5' block wall separates Ebb Tide from residential sites to the south. Utilities are provided via overhead and underground services. Each space has independent gas and electric meters, and tenants are responsible for gas and electricity payments directly to the public utility. Gas meters are located at each space, while individual electricity meters reside in a centralized location. Currently, the park is not served by a cable TV provider. Water, sewer, and trash service to each mobile home is included in the monthly rent. Lastly, mailboxes are located at the central business office. A map of the park is presented in Exhibit B of this report. The average age of the homes in the Park is unknown at this time, although most of the units are at least 30+ years old. A few of the units are approximately 10 -15 years old. Most of the homes have one or more types of improvements such as covered porches, covered patios, enclosed patios, tip -outs, and a covered carport. Mobile Home Park Resident Profile This Report is being prepared based on the known occupants of the Park as of November 2014. Resident surveys were mailed to all occupants in early August 2014 to collect data on affected owners and occupants of the Park, and 19 responses were received. We were also provided limited information regarding each of the known occupants by the Owner. All residents and owners were then invited to a community meeting held on October 15, 2014, where they were encouraged to schedule personal meetings with relocation personnel to provide information about the Project's effects on their households and their relocation needs. Letters to all residents were also mailed on October 4, 2014 requesting interviews due to the lack of response to the surveys. After the letters and the community meeting, five additional households agreed to interview with relocation personnel and provided information about their circumstances. (Thirteen households, who had previously returned surveys, also personally interviewed with relocation staff.) Mobile homes in the Park are either owned by the occupant /resident or owned by the Park and rented to the occupant/renter. Based upon our review of the information provided, there are 10 mobile homes that are occupied by renters and 52 mobile homes that are occupied by owners of the mobile home. 20 -30 A summary of available Park resident data is provided in Exhibit D. We do not have complete household data due to the lack of response to multiple survey and interview requests. However, prior to actual displacements, personal interviews with all households will be conducted to ascertain relocation needs. Of the 24 respondent households, 19 were owner- occupants and five were tenant households, comprised of a total of 50 adults and 12 children. Eight households reported senior members (62 years of age of age or older), and seven households reported at least one member with a disability. Eighteen of the 24 respondent households reported gross household income, and the results are as follows: six households qualify as Extremely Low Income (30% or less than area median income); two households qualify as Very Low Income (31% - 50% AMI); eight households qualify as Low Income (51% - 80% AMI); and two households qualify as Moderate Income (81% - 120% AMI). Six respondent households declined to provide information regarding household income. Four of the respondent households reported existing mortgages on their homes ranging from $15,000 - $99,500. The mobile homes within the Park are one - bedroom, two - bedroom and three bed -room units. Of the respondent households, three reported owning double -wide dwellings. Bedroom count and size of units is reported in Exhibit D. Representative photographs of Park coaches are presented as Exhibit E. Replacement Housing Resources One of the impacts of the proposed closure will be the availability of replacement sites to which a mobile home could be moved, as well as other replacement housing resources. Following is information on the availability of replacement sites in mobile home parks within the County of Orange and within 20 miles of the Park; mobile homes for sale; and availability of all types of rental housing within 15 miles of the Park. A. Mobile Home Park Space There are 28 mobile home parks located within 20 miles of the Park and a search was conducted to determine the availability of vacant mobile home spaces or pads. The original search in May 2014 included both family and senior parks within Newport Beach and surrounding communities. The search was updated in September 2014. A complete L 20 -31 updated list of the parks with the number of available spaces and conditions, and the reported type of mobile homes and residents accepted, is presented in Exhibit F. Based on the survey of mobile home parks and of those parks where a representative was available to answer questions, 52 available spaces were identified. Space rents for these parks range from $685 to $1,900 per month, depending on the size and location. Typically, a park will only consider accepting mobile homes, if they are brand new or in very good condition and are ten years old or newer. Although some of the mobile homes within the Park are in fair to good condition, there are other limitations to moving them to another park. Generally accepted standards and practices among mobile home park operators allow homes to be moved into the park if they are less than five years old and deny homes that are more than ten years old. While some park operators may allow homes in excess of 10 years, they are generally not accepted and would have to be approved on an individual basis. Only one of the existing homes within the Park meets the ten year age standard based on information provided that may be considered for acceptance by another park in the immediate vicinity. Therefore, under the above generally accepted standards and practices, it is a reasonable assumption that only a very limited number of mobile homes with associated fixed accessory equipment may be relocated to a comparable mobile home park within the immediate vicinity. B. Mobile Homes For Sale A survey of for -sale mobile homes currently on the market identified approximately 76 mobile homes for sale within a 20 mile radius, with prices ranging from $27,000 to $459,000. Mobile homes with higher sale prices may include the land, making it very much like single family residences or condominium units with common area maintenance monthly dues instead of space rents. Higher prices also indicate more park amenities and newer manufactured homes or mobile homes than exist at the Park. The available mobile homes for sale that were surveyed can also be found in Exhibit F. C. Rental Housing A mobile home within another park would be considered the most comparable dwelling to what the residents currently occupy. A rental survey was performed in May 2014 to identify the availability of one - bedroom, two - bedroom and three - bedroom mobile homes for rent within 15 miles from the Park. However, no mobile homes were identified for 7 20 -32 TABLE 1: Availability and Cost of Low Density Rental Housing Bedroom Size One Two Three No. Found 2 21 15 Rent Range $1,300 - $1,795 $1,500 - $3,100 $1,825 - $3,695 TABLE 2: Availability and Cost of Other Rental Housing Bedroom Size One Two Three No. Found 61 44 10 Rent Range $1,200 - $3,009 $1,445 - $5,500 $2,400 - $4,050 rent within other mobile home parks in the area. An updated survey was conducted in September 2014 with the same results. Due to the lack of availability of mobile homes for rent in the area, a search of other types of available rental housing was conducted. The next most comparable type of unit would be a low density unit such as a single family dwelling, condo, townhome, or a duplex, triplex or quad -plex unit. Additional rental housing (not low density) was also identified. Tables 1 and 2 show a summary of the availability of all types of rental units within a 15- mile radius. Specific listings for low- density rental units can be found in Exhibit G and listings for available units within apartment complexes of higher density can be found in Exhibit H. Movinq Costs A list of professional moving companies specializing in the relocation of mobile homes was compiled and is provided in Exhibit I. Estimated move costs associated with the relocation of the mobile homes within the Park to another mobile home park within 20 miles (assuming the mobile home could be moved and there was an available location) were provided by one of the move specialists. The cost estimated to disassemble an existing mobile home and all appurtenances in the Park, and to transport, and reassemble the mobile home in another mobile home park was broken down as follows: 1) For units 540 SF or less, the estimated cost ranges from $5,500 - $9,000. 2) For units 600 SF -912 SF, the estimated cost ranges from $13,500 - $14,500. 3) For units 960 SF -1,344 SF, the estimated cost ranges from $14,500 - $15,700. e 20 -33 If the mobile home could not be moved, the cost to tear down and discard the mobile homes, including awnings, decks, etc. was quoted at $3,000 - $4,000 per mobile home. Costs to relocate personal property within the mobile home are based on the federal fixed move schedule for the state of California and include utility transfer fees. Payment amounts include $1,100 for a one - bedroom unit, $1,295 for a two - bedroom unit, and $1,570 for a three - bedroom unit. Proposed Mitigation Measures The Report is to propose measures which will adequately mitigate the adverse impact of the closure on the Park residents. The relevant statutory law for the closure of a mobile home park and specific requirements for mitigation are California Government Code Section 65863.7 and Civil Code Section 798.56(8), which indicate the City prior to closure will review the steps taken by the Park Owner to mitigate any adverse impact of the closure on the ability of the displaced mobile home owners to find adequate housing. The steps required to be taken to mitigate, "shall not exceed the reasonable costs of relocation ". Given the linkage between mitigation and reasonable relocation costs, the Owner is obligated to determine what elements should be considered in determining "reasonable costs of relocation." The scarcity of available mobile home park space and the difficulty or impossibility anticipated in the actual moving and set -up of the existing mobile homes in the Park provides for a financial allowance to mitigate the physical moves. A. Impacts to Mobile Home Owners The most immediate impact of a possible Park closure is the effect on the mobile home resident owners, most of who may have been at the Park for significant periods of time. All residents face the issue of the disposition of their mobile home and relocation to a replacement dwelling. Physical relocation to another mobile home park is likely not an option for many of the mobile home owners desiring to stay in the immediate vicinity. Finding available alternative space, particularly for older mobile homes, will be a challenge, if not impossible. B. Relocation Mitigation Measures As stated above, this report is to propose measures to mitigate the adverse impact of the closure of the Park. While the requirements that may be imposed "to mitigate" are stated in the California Government Code, there are no clear guidelines to determine what is required to mitigate any adverse impact. Section 65863.7 does not require a E 20 -34 local government to impose any mitigation measures, but clearly limits any measures imposed to the reasonable cost of relocation. It is the intent of the Owner to meet the above conditions as well as additional assistance to further mitigate the impacts of the Park closure. The following physical move costs and relocation assistance will be offered to the mobile home owners and renters. Relocation Assistance for Resident Owners of Mobile Homes a) In situations where it is feasible to relocate a mobile home, payment will be provided as follows: 1. Reimburse the actual cost to relocate the mobile home, including without limitation, to disassemble, transport and reassemble the mobile home and all legal accessory structures to another mobile home park provided the mobile home owner signs a cooperation agreement that terminates any tenancy /occupancy and permanently vacates the Park. 2. Payment of temporary lodging expenses, if the mobile home relocation results in the homeowner being displaced over one or more nights, up to the maximum of $125 /night, and up to 7 nights; 3. Payment of moving costs associated with moving all personal property, allowance to be determined based on the most current federal fixed move schedule for the State of California and the size of the mobile home; a. Payment for necessary modifications to a replacement dwelling to accommodate a handicapped or disabled person; and 5. Services of a relocation specialist to assist owners through all aspects of the relocation to include, but not be limited to, explaining options and relocation assistance program details, identifying replacement units, coordinate moving arrangements and payment of benefits. 10 20 -35 b) In situations where it is not feasible to relocate the mobile home, payment will be provided as follows: 1. A fixed payment to the mobile home owner to abandon the unit in place, or remove the mobile home at their own cost, provided the mobile home owner signs a cooperation agreement that terminates any tenancy /occupancy and permanently vacates the Park. Payments to be made as follows: - For units 540 SF or less, a payment of $9,000 - For units 600 SF -912 SF, a payment of $14,500 - For units 960 SF -1,344 SF, a payment of $15,700 2. Payment of moving costs associated with moving all personal property, allowance to be determined based on the most current federal fixed move schedule for the state of California and the size of the mobile home; 3. Services of a relocation specialist to assist residents through aspects of the relocation to include, but not be limited to, explaining options and relocation assistance program details, identifying replacement units, coordinating moving arrangements and payment of benefits. Relocation Assistance for Renters of Mobile Homes A fixed payment of $2,000 will be paid to the renter to assist the renter with securing replacement housing provided the renter and all other occupants sign a cooperation agreement and permanently vacate the Park. Relocation Plan / Explanation of Services It is not known at the time of this Report, how long the actual physical moves of mobile homes would take, nor how many homes will be able to be moved at all. It is the opinion of the author that no mobile home manufactured in 2000 or older will be able to be accepted at any of the mobile home parks within the County of Orange. There is ample available housing in Newport Beach and other nearby communities for the residents of the Park. While no two communities are alike, the residents undoubtedly have quality, well- maintained mobile home park communities and other 11 20 -36 comparable alternatives available for their consideration as housing options. If the objective of Park residents were to continue owning a mobile home for residential purposes, resident owners could be assisted to move their mobile home or purchase a replacement mobile home. We have concluded that it will be challenging to move existing mobile homes to another park in the immediate vicinity. If purchasing a replacement mobile home is considered an option, buyers will find an adequate inventory of for -sale mobile homes in good parks throughout Orange County. In the event it is unfeasible to move the mobile home, the rental housing market in Newport Beach and Orange County offers another option to residents. An adequate supply of available housing options exists in the market for the existing residents to consider. The recommendation of this Report is to offer alternate relocation payments and assistance to the residents as outlined in this Report. Any relocation assistance payments will be conditioned on the completion of actual arrangements to move a mobile home and improvements, or the rental /purchase of replacement housing and removal of the existing mobile home and upon the resident permanently vacating the Park on a date certain. The recipients must also enter into a voluntary relocation agreement (cooperation agreement), which specifies relocation benefits in accordance with this report. Requests for funds will be timely processed in a reasonable manner and signed acknowledgments of receipt of payments will be maintained in individual relocation files. Mobile home owners will be offered the assistance of a relocation counselor to assist in identifying replacement dwellings and to coordinate moving arrangements and the payment of relocation assistance. Current Park residents would have to select in writing their choice of a relocation assistance option no later than sixty (60) days from the date the City Council adopts a resolution or ordinance or takes other affirmative action that finds under applicable law that this Report is adequate and sufficient. Notwithstanding that resident(s) does not timely or otherwise select a relocation assistance option, resident(s) will be required to vacate the Park no sooner than six months from the date the City Council adopts a resolution or ordinance or takes other affirmative action that finds under applicable law that this Report is adequate and sufficient. The Owner anticipates the Park closing in July 2015. 12 20 -37 It is not within the scope of this Report to address any disputed issues that may have been raised in the process of exploring the Park's closure. The recommendations which have been made however do provide an equitable basis for determining relocation assistance under current regulatory standards. Under the level of proposed assistance, it is anticipated that there is the opportunity for all residents to maintain a residence within or in proximity to Newport Beach and the surrounding communities. It is proposed that relocation assistance payments will be managed by the selected relocation assistance specialist through a funded trust. Claim forms or agreements will be provided and payments made based on the option selected within the timeframe specified above. The relocation assistance payments will be based on the mitigation measure option chosen. Upon proof of need, adequate advance payments may be made to assist residents with securing their replacement housing and final payments will be made after the resident has vacated the Park. In situations where it is not feasible to move the mobile home, any mobile home owner that is eligible to receive a relocation payment as a resident owner will need to provide a valid Department of Motor Vehicles or Department of Housing and Community Development title to confirm ownership. Any title issues will need to be resolved by the unit owner prior to release of funds. The mobile home will ultimately need to be removed from the park, and the process for removal will need to be finalized. The procedures for claiming benefits are to be as follows: 1. Claimants will provide all reasonable and necessary documentation to substantiate eligibility for assistance; 2. Assistance amounts will be determined; 3. Required claim forms and relocation agreements will be prepared by relocation personnel in conjunction with claimants. Signed claims, cooperation agreements, and supporting documentation will be submitted by relocation personnel to the Owner; 4. The Owner will review and if in conformance with the selected relocation program, will reply with concurrence and approval for processing the payment, or request additional information; 13 20 -38 5. The relocation specialist will issue benefit checks, which will be available at their offices for pick -up, delivered personally or mailed, depending on circumstances; 6. A final payment will be issued after confirmation that the resident has completely vacated the Park; 7. Receipts of payment will be obtained and maintained in the relocation case file. Throughout the entire relocation process, a relocation specialist will be available to assist owners with their relocation assistance needs including the following: A. Be available to provide an explanation of benefits, so residents have a full understanding of the issues related to the closure of the mobile home park. B. Providing assistance as needed and requested to lessen hardships by working with real estate agents, property managers, lenders, health care providers and others. C. Provide relocation assistance information and counseling in the primary language of the displaced occupants, in order to assure that all displaced occupants obtain a complete understanding of the relocation program and eligible benefits. D. Search for available replacement dwellings within and outside of Newport Beach or in the area desired by the displacee. E. Provide assistance in claiming relocation assistance funds from the Owner. F. Other individual assistance that may be required on a case by case basis. 14 20 -39 Conclusion It is the Owner's intent to adhere to all state law and local ordinance requirements in consideration of the Park closure. Additionally, as discussed in this Report the Owner is offering assistance beyond the minimum requirements of the law to lessen the impact of closing the Park by providing the relocation assistance services of a relocation professional to assist the residents and by providing financial assistance to renters not required by State law. 15 20 -40 List of Exhibits: Exhibit A — Proposed Project Plans Exhibit B — Legal Description of the Park Exhibit C — Existing Park Map Exhibit D — Park Resident Data Exhibit E — Photos of Park Mobile Homes Exhibit F — Available Mobile Home Spaces and Units for Rent /Purchase Exhibit G — Low - Density Available Rental Housing Exhibit H — Apartment Complex Rental Housing Availability Exhibit I — Professional Mobile Home Movers 16 20 -41 Exhibit A — Proposed Project Plans Conceptual Lot Study A 17 x-_ �. ZI- 20 -42 Exhibit B — Legal Description of the Park The land referred to herein is situated in the State of California, County of Orange, City of Newport Beach, and is described as follows: LOT 714 OF FIRST ADDITION OF NEWPORT MESA TRACT, AS SHOWN ON A MAP THEREOF RECORDED IN BOOK 8, PAGE 61 OF MISCELLANEOUS MAPS, RECORDS OF ORANGE COUNTY, CALIFORNIA. EXCEPT ONE -HALF OF ALL OIL AND OTHER HYDROCARBON SUBSTANCES, AS GRANTED TO HAZEL S. GREGG, BY DEED RECORDED JULY 14, 1953 IN BOOK 2537, PAGE 609, OFFICIAL RECORDS. ALSO EXCEPT ONE- QUARTER OF ALL OIL OR OTHER HYDROCARBON SUBSTANCES AS RESERVED IN THE DEED FROM FRANK STEM AND SIDONIA STEM, HUSBAND AND WIFE, RECORDED SEPTEMBER 10,1959, IN BOOK 4873, PAGE 433, OFFICIAL RECORDS. ALSO EXCEPT THE WESTERLY 10 FEET OF SAID LAND AS CONDEMNED BY THE CITY IF NEWPORT BEACH UNDER SUPERIOR COURT CASE NO. 203614. lu 20 -43 Exhibit C — Existing Park Map 19 20 -44 51TE EVACUATION PLAN EBB WA MOBILE HOME PA-1. RIWP 1RT BEACH. CA - v ! PARAIN6 A! A3 AO AS At 7 AS A4 A30 7 _ — _ _ el I—" C- i -- 61 67 M , B$ '\ 66 87 !! di 6iC Gil 62 I cm HME /tie 6i ROM cl Ira €l / u`• C4 €6 c7 c6 a ctl. z W � n GS ` 01 O7 D3 OA 03 96 Erb 66 0110 all i, � at E! E3 N ES E6 17 u E9 10. Ell Ell E73 E14 67 Fl R FS F6 N 69 F10 Fll Fl! F13 F36 F15 T16 Ip F17 at SECTION ONE r SECTION IHREE 19 20 -44 Exhibit D — Park Resident Data SPACE # NAME Monthly Rent Ownership Status # BRs / #BAs SF Age of Unit A -02 Novotny, Bill (Gary Lender) 825.00 OWNER 3BR A -03 Eakins, Paut/Reta 800.00 OWNER 2BR A -04 Hacket, Evelyn 800.00 OWNER 2BR A -05 Nunez, Esau/Cesiah (Park Rental) 1,200.00 TENANT 2BR A -06 Hurst, Gary 850.00 OWNER 2/1 720 34 A -07 Long,Hope 800.00 OWNER 2BR A -08 Sturniolo, Chris 800.00 OWNER 2/1 600 35 A -09 Wolfe, Dan 900.00 OWNER 211 1240 28 A -10 Beat, Jeff 82500 OWNER 2BR B -01 Kawamura, Daniel J. 740.00 OWNER 2BR B -02 Eifler, Jim 890.00 OWNER 2/2 740 15 B -03 Cutts, Antonio 800.00 OWNER 2BR B -04 Wooden,Denice 80000 OWNER 2BR B -05 Jackson, Sonja B. (Gary Rental) 90000 TENANT 2BR B -06 Cline, Chuck and Ippun 800.00 OWNER 2/2 720 31 B -07 IVACANTSPACE - I VACANT B -08 Velez, Mireya Minbel 1,00000 OWNER 2BR B -09 Thomas, Janine 850.00 OWNER 2/2 800 39 B -10 Jones, Harry Bell 1,200.00 TENANT 3BR WA N/A B -11 VACANT SPACE - 3BR C -01 Jones, Cliff & Maier, June 80000 OWNER 1/1 450 56 C -03 Russell, Francis 850.00 OWNER 1/1 576 27 C -05 Nematzaden , Mohamed & Roberta (Park Rental) 1,000.00 TENANT 2/1 N/A WA C -06 Pelayo, Ramon 81000 OWNER 2BR C -07 Baiza, Bobby and Caryn 820.00 OWNER 2/2 1056 30 C -08 Crowe, Jose and Blanca 810.00 OWNER 2/1 400 35 C -09 Ferrari, Nikki 800.00 OWNER 2BR C -10 Koepke, William 81000 OWNER 2BR C -11 Esparza, Gary and Abrego Diana 850.00 OWNER 2/1 1160 54 D -01 Toste , Ray (Park Owned SFR) 982.00 TENANT 2BR D -02 Rodolfo, Lerri 800.00 OWNER 2BR D -03 VACANT MOBILE HOME - VACANT 2BR D -04 Price, Steve 810.00 OWNER 2/1 360 35 D -05 VACANT MOBILE HOME - VACANT 2BR D -06 Talmo, Mark & Hart, Dawn (Park Owned Rental) 900.00 TENANT 2BR D -08 Hrehniy, Adeline 850.00 OWNER 2/1 600 48 D -09 Wolfe, Jeff 825.00 OWNER 2BR D -10 VACANT MOBILE HOME - VACANT 2BR D -11 Abrego, Enrique 81000 OWNER .2BR E -02 Mcshane, Timothy 900.00 OWNER 2BR E -03 Noeggerath, Osbaldo /Beatriz 820.00 OWNER 2BR E -04 Gonzales, Lidia 1,000.00 OWNER 2BR E -05 Reyes, Myriam 815.00 OWNER 2BR 20 -45 Exhibit D — Park Resident Data SPACE # NAME Monthly Rent Ownership Status # BRs / #BAs SF Age of Unit E -06 Novotny, William M & Casiday, Monique (Park Rental 1,200.00 TENANT 2BR 1 E -07 Jimenez, Rigoberto and Rosa 876.00 OWNER 2/1 620 29 E -08 VACANT MOBILE HOME - VACANT 2BR E -09 Tinoco, Jose /Gloria (Gary Rental) 80000 TENANT 2BR E -10 Sullivan, Mark 80000 OWNER 2BR E -11 Ramirez, Javier and Marina 1300.00 TENANT 2/? N/A N/A E -12 Elder, David /Jeri 82000 OWNER 2/2 880 9 E -13 Lea, Alicia 800.00 OWNER 2BR E -14 Long, Don 810.00 OWNER 2BR F -03 Strader, Scott and Patricia 810.00 OWNER 3/2 480 15 F -04 Rodriguez, Teresa 810.00 OWNER 2BR F -05 Fierro, Andrea 810.00 OWNER 2BR F -06 Courter, Eric /Rachel 810.00 OWNER 2BR F -08 Killian, Tanya et al 970.00 OWNER 3/2 N/A 10 F -09 VACANT MOBILE HOME - VACANT 2BR F -10 Martin, Cassandra 800.00 OWNER 2BR F -11 Mezones, Mario /Maribel 935.00 OWNER 2BR F -12 Macias, Bertha 825.00 OWNER 2BR F -13 Moore, Christopher G.Nioleta 1,000.00 OWNER 213R F -14 VACANT SPACE - VACANT F -15 Rodriguez, Maria (Park Owned Rental) 1,250.00 TENANT 2BR N/A N/A F -16 VACANT SPACE - VACANT F -17 Ryan, Mike 830.00 OWNER 2BR G -01 Brown, Marie 825.00 OWNER 2/2 880 37 G -02 Orozco, Martin 825.00 OWNER 2BR G -03 VACANT SPACE 1,000.00 VACANT 3BR G -04 Roses, Rafael & Bandilla, Maria 825.00 OWNER 2BR G -05 VACANT SPACE VACANT G -06 Szecse, David and Marie Bucayan 825.00 OWNER 212 800 35 G -07 Tirado, Maria 825.00 OWNER 2BR G -08 Garrison, Claude, Fleuret, Beth, Garrison, Dylan 1,400.00 TENANT 2/2 N/A 39 SUMMARY Resident Owned Mobile Home 52 Park Owned Mobile Home - Vacant 5 Park Owned Home - Renter Occupied 10 Structure - Managers House 1 Vacant Space 6 21 20 -46 Exhibit E — Photos of Park Mobile Homes n.A r i T� 22 :- 20 -47 Exhibit E - Photos of Park Mobile Homes 23 W-3 Exhibit F — Available Mobile Home Spaces /Units for Rent /Purchase — w /in 20 Mile Radius of 1560 Placentia, NB 24 20 -49 AVAIL AVAIL UTILITIES ACCEPTS TOTAL PUS AGE PARK NAME ADDRESS FOR RENT LEASE FOR PORCH AVAIL SPACE TYPE OF MH ALLOWED - -- -- DATE PAID BY TRAVEL UNITS CT RESTRICTION TYPE (55 +, COMMENTS IAMEN RENT TERM PUROH PADS RENT AVAIL TENANT TRAILERS 50., etc) PROP PROP Single &Double Witle, must Exc�p1 wale[ 2 heated pools, 2jacuzzies, a pruete Baysitle Village 300 East Coast Hwy 0 _ _ 6 $68,900- 1 $1'900'00 submit l for home, the (949) Plow s rand No 2]0 Peta ok Family No beach gym, 2 clubhouses and NewpoM1 Beach $259,000 home can not take up mom can not 1331 1 track me ask. Only bmndnew mobile homes than 75% of the property will be allowed in me park. Lido Mobile Home 710 Lido Park DAe 0 0 0 - 0 $1'625.0 Single S Double Wide (G49) 673 Nine armor trash No 214 2uump {refs Family No Priwte beach, clubhouse. Park Newport Beach and up 6030 8 sewer allowed Regal Estates 1545 Mo mina Avenue 0 - - 3 $27'000 0 $92500 Single 8 Double Wide (Ng) 545- Now Gas, electric, No 94 Pets ok 55+ 55+ Na, clubhouse, library. Mobile Home Park Costa Mesa $62,500 8703 Ads, &Sewer Mariner6. Pat am 19350 WaN Street 0 2 a1n.5oo 0 $895.00 Single 8 Double Wide (714) 955- blow Gas, eledflo, No 93 1indoor small 56+ 55+ Heated Pool &Spa. Clubhouse Mobile Home Huntington Beach - - - 0820 water & sewer pats 20 pound. $194,500 Bay Harbor Mobl le 396 E 21st Street 0 - - 0 - 1 $875.00 Single S Double Wide (714) 321 Now Gas S Y. 28 Small pet Family No O^relle Laundry Facility, Travel- Valler Home Park Costa Mae. 0122 Electric a RV ishass ble- Sfarllte Village 2060 Nei BIW, k4 0 - - 2 $69,900 0 $675.00 Single &Double Wide (949)54& Ni Gas, electric No 55 1 pet, under Family No Pool, clubhouae. Mobile Park Costa Mass 1312 S water 301to Rancho Huntington 19361 Bmckl mat St 0 5 $291900. 0 $1,250.00 Single & Double Wide (714) 962 Ni All No 194 1 Indoor pet Family 55+ Fleeted Pad & Spa, Clubhouse, Mobile Park Huntington Beach $157,900 7311 less than 201bs & Sonia Game mom. Two Club Houses with kitchens, Huntington 20701 Beach BIW. 0 8 $39,000- 0 $1,725.00 Single & Double Wide (714)5. Now Al Ne 304 Bread & waght Family No laundry facilities, library, heated Shoreclifla Huntington Beach $399000 4417 reaMCtions pools 8 spas, billiard mom, cant mom, BBOareas. Los Amigos Mobile 18601 Newland Street 0 - 5 $79,900 0 $900.00 Single S Double Wide (714)962 Now All No 145 2Pat. max, 20. 55+ 55+ Pad S Spa, Clubhouse, Fulham Rm, Home Park Huntngton Beach $249,900 7422 fi s now Dal Mar Mobile 19251 Bmokhuref SL 0 6 $84,920- 0 $925.00 Single B Double Wide (714)96& 56w All No 142 Y. no Isis 55+ 55+ Pleated Pad & Spa, Clubhouse, -RV Estates Huntington Beach $18%900 0484 breeds Storage. Clubhouse, Pool, Jaaazi and Sauna, Huntington Harbour 16,100 Saybrook Ln. 0 - - 1 $459,000 0 - Double wide an y (714) 646- Now All No 130 Pets N 55+ $$+ BBq Entertaining Area, Putting Village Huntington Beach 1010 Green, Exercise Roam, Billiard and Cam Room, Community Gordon. Gables Mobile 4801 W 1st St. M&i 0 - - 0 - 0 $975.00 Double wide only (714) 554- Now Gas, electric No 12fi 2 pets, under Family No Pod antl Jacuzzi. Clubhouse (not Estates Santa Ana spin donate, wind currently In use). Ce,waan station. Country Club Mobile 518 S Sulliten St 0 - - 1 $53,000 - $1,145.00 Single &Double Wide (714) 543- Ni All No 114 2 pets ok Family No Pod, spa 8 clubhouse, Home Santa Ana 7080 Bel Prase Mobile 8200 But.. A.m. 0 - - 2 $53,400 0 $1,200 and up Single &Double Wide (714)891 - Now All No 169. Pets ok Family No Pooh spa & clubhouse. Home Park Midway qty 0604 Double Wide (Single. Plaza Mobile Ee18le8 3101 S F.i,. St Remmetl; Doubles Preterred) (714)646 - Paol &spa. clubhouae wl Billartls. aka Plaza Vlllege Santa And 0 - - 1 $39,007 22 $1,098.00 2005 or newer', need to submit pictures for ap shed (45,95 is 42f16 Now Ga. isal is No 237 Pets ok Family No Playgmuntl. Cnborderot Sanla Ana, Costa Mass, and Newport Beach. aVne, space size) 24 20 -49 Exhibit F — Available Mobile Home Spaces /Units for Rent /Purchase — w /in 20 Mile Radius of 1560 Placentia, NB 25 20 -50 AVAIL AVAIL UTILITIES ACCEPTS TOTAL PUS I AGE PARK NAME ADDRESS FOR RENT LEASE FOR PURCH AVAIL SPACE TYPE OF MH ALLOWED CONTACT DATE PAID BY TRAVEL UNITS TRICT RESTRICTION TYPE (5A, COMMENTS (AMENITIES RENT TERM PURCH PLACE PADS RENT PHONE AVAIL TENANT TRAILERS 5 W., etc) PROP Beachview Mobile Park 17261 GOthard Street $3],000. (714)847 - aka Beach View Huntington Beach 0 - - 2 ]� 0 $]B5 00 Single &Double Wide 4444 Now All No 81 t small pet 55+ 55s Pod and 2 Laundry Rooms. Community 8241 & 6301 Warner All, (Thash & Sea A. Mobile Arenas D - - 5 $90'0. 0 $1,134.00 Single & Double Wide (]14) 84] Now Sewer addd No 331 1 small pet Family No 2 Pools, 2 Spas, 2 Gubhousea, ECads $169.900 1121 $20 onto Laundry Room. Huntington Beach Spane Rant) Pool, Spa, GUbM1OUSe, Erce¢ise Brookfleltl Manor 9850 Comeld Ate 9 - - 5 $159,900. 0 $92500 Double wild only (714) 966- Now All No 139 i pet, under 55' Sys Room, Billam Room, 2 Saunas, Huntington Beach $239995 0484 Mae HorseShce Gaming Area, Putting Green, and Lbhury. Single & Double Wide, must Single Green L antern 14352 Beach Blvd, - - 1 $]4,900 4 $90000 be brand new, dealer must (714) 897- Now All No 130 i Pep under Family No Pool, Spa, Gublouse, Laundry Village & Mobile Westminster 3001 late Room. RV paking$75.00 per month. come to take measurements Bola Vertle Estatee 9350 Balsa Ays 0 - - 0 - 0 $9W.00 Single & Double Wide (714) 897 How All No 85 Pete ok Family No Pool, spa, clubli Near Little Westminster 4447 Saigon. Sea Breeze Mobile 5200 Hell Aware $]T 500- Single & Double Wide, 24x44, (71 °)846- 1 small pet Pool,leuntlry Room, Recreation Hall, Estates; Huntington Beach 0 - - 2 $89,500 1 $82500 brand new home perared car 3885 Naw All N, 65 under ISlhsa 55+ 55, and Library , submit pictures fa approvel. 15inches New homes, unable was, Town &Coon" 3929 W 5Th Street $685.00- space for 2 -Cab C. homes (]14)554- Pets ok, under Pool, Spa, and Lei Room,, Car Villas Santa Ana 0 - - 5 $55,000* 3 $]5000 older model, l -24x42 apace 2768 Now All No fig 29bs 85* Wv Wash, and Clubhouse, newer home pereards Warren Park MHE 1500 Warren Street 0 - - D - 0 $840.00 Single 8 Double Wide 014) 54] Now Touch. gas & No 203 Pete ok Family No Gym, pod, and, clubhouse . Sas Are n 0421 water pa, a use, po s a Coach Royal Mobile 215 S Sullivan Smeat D - - 1 $52,000 0 $1,14500 Single is Double Wide (714) 941 Now All No 328. 1 small pet Family No (half-basketball wart), Computer Ham. Park Santa And 2124 Room and Llbrery. Gym, Laundry 2Small Pets Haated PddJSpa Billiards, Rancho La Skies 181948usherd Street 0 _ _ 5 Sbi' $W,g00. 1 $900'00 Double Wide (pty)g8p- Now All No 181 Okay , under 551 55, Community Garden, RV Storage, Res Mobile Home Fountain Valley 0 3841 39bs Room with Monthly Potlucks) $159,995 1 small Pat Villa Valencia 14092 Browning Ale. 0 - - 2 - 0 $9W.00 Newhomes, doublawide 014) 544 How All No 157 under 2011da or, Family No Pool, Spa Clubhouse, Billed! Room, Mobile Ealale Tustin $179,995 0311 20 inches LauMry Room, His & Has Sauna. Double Wide, 24x55 wdh Pets ok; Indoor 23301 Ridge Route Drite $38'900 (949) W10- only. No Laguna Hills Estates Laguna Hills 0 - - 3 $140,995 1 is-2 $1,2W.W small game & must be brand 3900 Now All No 252 eize/weight Family No Pod, Spa, Gubra.... (hardly raetl). I laudations, bin Single & Double Wide (Mcatly Gym, Pool & Spa, Clubhouse, Orange Mobile 1931 E Meats A a, 0 - - 1 SPUD 00 18 $1,22/. W Double), homes mual be in 714- 283,6151 Now All No 1T9 Pe[s ok (1 Her Family No Playgarurrd' Game Room, end 860 Home Park Orange gootl condition. family an Area. 25 20 -50 txmon U - Low-uens TV Avauame Kentai nousin APPROX. SIZE OF SECURITY LEASE DISTANCE DATE UTILITIES WASHER PETS PARKING ADDRESS UNITTYPE B R BA UNIT (SF) RENT DEPOSIT TYPE FROM AVAIL PAID BY /DRYER ALLOWED INCLUDED AMENITIES SITE IN TENANT MILES ■ New extariorlinsrior paint, 12382 Ranchwood Rd. SFR 3 2 2291 $3,300 $4,950 12 Months 13.6 1111114 All Hook -ups Pets ok Garage new carpet &renovated Tustin wbhen Grants counter bps, 14841 Canterbury Ave. SFR 3 2 1972 $3,300 $3,300 12 Months 106 1111114 All Hook -ups Pets ok Garage hardwood floors& Tustin asmdafion pees. Newer grants kikhen,buift- 3120 Taft Way SFR 3 3 1750 $3,200 $3,500 12 Months 13.3 9115114 All Hook -ups Pets ok Garage in wine rack, new tie /carpet Tustin pa9c with cover. 1752 Green Meadow Wall neinkined, patio with Ave. SFR 3 2 1685 $2,795 $3,000 12 Months 104 9115114 All Hook-ups Pets ok Garage large yard, community pool Tustin and spa. Conan bounders, mry, 143 N. "C' St. SFR 3 2 1700 $2,785 $2,785 12 Months 111 10115114 All Hookups Pets ok Garage fireplace, recessed lighting Tustin & large l Community pool, walking All except 834 Main St. Condo 2 2 952 $1,750 $1,750 M -M 11. 1 10115114 water Hook -ups None Carport distance b old low, Tustin. Tustin trash One level made with bur nit on lot Mole house remodeled, 1910 Baker SI. SFR 2 1 1291 $3,100 $3,100 12 Months 4.2 1111114 All Hook -ups Small pet Garage new plumbing, new Santa Ana skinless all applknces. New exarior & interior 1230 W.18th SL Pain( new mu , SFR 2 2 1901 $2,999 $2,999 12 Month Months 152 11115114 All Hook -ups Small pet Garage Santa Ana new skinless steteel e/ appliances. en me es gar ener, 1220 W. 14th SL SFR 3 3 1700 $2,250 $2,300 12 Mantra 144 10115114 All Hook -ups Pets ok Garage new interior paint garden Santa Ana window & stainless seal pot Laminasllle (boring, 1245 Cabrillo Park SFR 2 2 1127 $2,200 $3,500 12 Menthe 121 9123114 All Hook -ups Pets ok Garage spacious breakfast nook, Santa Ana private yard. 2160 W. Wellington Ceiling fans, Showed Ave. SFR 2 2 1471 $2,100 $2,200 12 Months 11.2 9122114 All Hook -ups Pets ok Garage yard, sun room &walking Santa Ana distance b restaurant. n ergroun ga 3039th St. #404 Condo 1 1 897 $1,300 $1,500 12 Months 12.8 9122114 All On-sia None Garage parking, spacious balcony, Santa Ana space walking distance to Huge yard for 213 Nobel Ave. SFR 3 1 1289 $2,295 $2,000 12 Months 7.2 9122114 All Hook -ups None Garage enarfainni close Santa Ana space freeways. Rent ed. Community, pool, spa, huge 3710 S. Bear St. #89 Condo 2 2 1093 $2,250 $2,000 12 Months 6 9115114 weer& Hook -ups Pets ok Garage doses, newer cabinets and Santa Are trash munsrbps. Single level, renovabd 3925 S. Ross St. #A SFR 3 2 900 $2,150 $2,200 12 Months 7.5 9115114 All Hookups None Garage hardwood floors, grants Santa Ana munsrs and tocasd S. Coast meto area. Gaad community, new 3685 S. Bear St. #K Condo 2 2 1144 $1,795 $1,800 12 Months 83 1011114 All Hookups None Carport ceiling has, dishwasher& Santa Ana walking . distance b schools. 19431 Surrey Ln, Rent ind. #102, Huntington Condo 2 2 1225 $2,700 $5,000 12 Months 7.1 9122114 waar & Ini None Garage Single Level, 3 pools within Beach trash community, clubhouse. All. Rent Huge yard for 6621 Lennox Dr. SFR 3 1 1306 $2,500 $3,150 12 Months 113 9122114 includes Hookups Pets ok Garage entsrbinal close Huntington Beach Gardener teeways. 5142 Warner Ave. Pet deposit $500, goad #111, Huntington Condo 2 2 1253 $2,300 $2,300 12 Months 11.6 9119114 Trash Hook -ups Pets ok Garage mm unity, swinal pool Beach induded &jacum M. 20 -51 Exhibit G - Low - Densitv Available Rental Housing 27 20 -52 APPROX. SIZEOF SECURITY LEASE DISTANCE DATE UTILITIES WASHER PETS PARKING ADDRESS UNIT TYPE B R BA UNIT (SF) RENT DEPOSIT TYPE FROM AVAIL PAID BY (DRYER ALLOWED INCLUDED AMENITIES SITE IN TENANT MILES 7672 Timber Cr. #4, Water and Fenced yard, dose to Townhouse 2 2 1060 $1,750 $2,500 12 Mantis 7.2 1011114 Trash Hook -ups None Garage Huntington Beach dining and shopping. included Water and Gated community, granite 411 Coral Reef Dr. kiChen counters, wood #33, Huntington Condo 2 2 7042 $2,250 $2,300 12 Mantis s fi 0/1114 In -UnR None Carport dues Scoring, shopping center Beach included nearby. Association Gated community, central 8142 Centimeters Dr, SFR 3 3 2430 $3,695 $3,800 12 Mantis 5.7 9123114 dues Hook -ups None Garage A/C, hardwood flooring, Huntington Beach included large yard. All, Rent a eposi e 8322ington SFR 3 2 1027 $2,695 $2,700 12 Mantis 5.5 9123114 includes Hook -ups Pe6ok Garage flooring, large back yard, Bar, Huntington Beach Gardener large drive way, near unlike and rental. Water and Enclosed privet pro, 8932ingonBeac04q Condo 3 2 1287 $2,600 $2,600 12 Mantis 53 9123114 Trash Ini Pet ok Garage single level, swimming pool Huntington Beach included and clubhouse whine crionernow Water and Batton floor unit dose to 20062 Bayfront Ln. Trash and downtewn, shops & #101, Huntington Condo 2 2 1228 $2,550 $3,000 6 Months 61 9/1114 association Ini None Garage Beach dues restaurants, gated included community. Water and 7351 Clay Ave. Townhouse 2 2 7150 $2,500 $5,000 12 Monbs 77 9123174 Trash Hook -ups None Garage 2 Car garage, upgraded Huntington Beach cerpet eodosed man pate. included Water and Petdeposit$500, single 2321 Florida St. #B, Condo 2 1 1100 $1,875 $1,875 '12 Months fib 9123114 Trash On -site Pe6ok Garage stery large unit community Huntington Beach induced laundry, high ceilings. Recently upgraded with 5000 Neptune Ave, Duplex 1 15 800 $1,795 $1,795 12 Mantis 1.2 9123114 All Ornsite None Carport new carpel, paint Close to Newport Beach dining and shops. 204 Adams St, Water and Clow b dining and shops, Newport Beach, CA Duplex 3 2 1250 $2,490 $2,500 12 Mantis 33 9123114 Trash On -site None Garage very dose to beach. 92661 included 16892 Sol. Chi. Water, trash Detached garage, dose to St., #203, Huntington 4 -Plex 2 2 880 $1,500 $1,500 12 Months 11.8 9123114 &gardener On-site None Garage parks and schools. Beach indudetl 17752 Paseo Circle, Duplex 2 2 1000 $1,575 $1,575 12 Months 79 9123114 All On -site None Garage Large patio, huge walk in Huntington Beach close6, dose b shopping. 16684 Arbor Cir, 2 Car garage, upgraded #110C, Huntington Condo 2 1 835 $1,595 $200 12 Mantis 94 9123114 Al In -Und None Garage carpet paint jax4 riles Beach tam beach. 2656 Orange Ave., 00, Townhouse 2 1 1000 $1,650 $L650 12 Mantis 45 9123114 All Hook -ups Peeok Street Enclosed patio, gas Costa Mesa fireplace, Ole flooring. 2447 Elden, #2, Costa Townhouse 2 1,5 1050 $1,695 $1,400 12 Monte 36 1011114 All Hook -ups None Garage Two story unit fire place, Mesa small yard reached. 873 Bear Crk, Costa Townhouse 3 2 1325 $1,825 $1,825 12 Months 6 9123114 All Hook -ups Pe6ok Garage leca@d near dining and Mesa shopping, grid community. 229 W Wilson St, #e, 2 Car garage under the Townhouse 2 2 1005 $1,995 $2,300 12 Mantis 3.1 9123114 All lai None Garage unk large pact, does le Costa Mesa dining and shops. Water and 284 Cabrillo St, #B, Condo 2 1.5 1065 $1,850 $1,850 12 Mantis 15 1011114 Trash Hookups None Garage Small frontpafio & large Costa Mesa beck paid, tiled tooring. included 2314 Santa Ana, Water and Large pal fireplace, Townhouse 3 2 1600 $2,495 $1,000 12 Mantis 3.1 9123114 Trash Hookups None Garage galled counity, swimming Costa Mesa included pool. 27 20 -52 Exhibit H - Apartment Complexes - Rental Housing Availability 20 -53 Distance Utilities Complex Name Address Phone from Site ca m m SEC. DEP. Pets l Dep.(ea) Included (Miles) Wksthay Apartment 825 Center Street Costa Mean 949- 642 -1424 0.8 $1,350 N/A $700 None None Eadide Apartlnent 126 E. 18th Street Cosh Mesa 855 -857 -5272 1.3 $1,890 $1,000 Calsonty None Sundance West 1996 Maple Avenue, Cosh Mesa 949- 642 -4593 1.7 $1,575 $525 Cats only None Coronado at Newport $1,437- $1,943- Up In 3 Pets. No South 880 Irvine Avenue, Newport Beach 949 - 371.8437 2.0 $3,176 $4249 N/A $600 -$700 Weight Rest. Only None Breed Ram. Parsons ApartrnenLS 2000 Parsons Street2, Casa Mean 855 - 685 -6528 2.0 $1,750 $700 Pet ok None Mariner Square 1244 Irvine Avenue, Newport Beach 866- 280 -2871 2.1 $2,210 $2,500 +1 - $700 Pet ok (Up t 18 None inches) Maditrranean Village 2400 Harbor Boulevard, Costa Mesa 714-557 -8020 2.8 $1'530 $1,930 N/A $600 -$800 Cat only (Dogs in None $1,675 Certain Unit) Promontory Point 200 Promontory Drive West Newport 866- 293.3148 3.7 $2,885 $1,000 Fees & Deposits None Bch Missions at Bad Bay 1330 Bristol Street Cosh Mesa 657 -622 -0923 4.4 $1,661- $1,806- N/A $500 -$600 Up In 2 rat/dags None $1,806 $2,103 w/ Breed Rest. The Colony 5100 Colony Plaza, Newport Beach 866- 311 -2614 5.0 $3,150- $3,355- N/A Varies Deposits &Pet None $3,435 $3,530 Rent $1,475- $1,890- Cat &Birds Only South Point 655 Baker Street Cosa Mesa 714662.3222 5.1 $1,630 $2,100 $650. $850 wl Deposit & Pet None Rent $1,920- $2,130- The Bays 1 Baywood Drive, Newport Beach 866-306 -9255 6.0 $2785 $700 Fees &Deposits None $1,960 $2,360 Carlyle at Golan Plaza 18880 Douglas, Irvine 855 -564 -9125 6.3 NIA $2.665- $3,500- $500 -$750 Fees & Deposits None $3,485 $3,700 Avenue of the Art 3400 Avenue of the Art, Costa 714 -881 -1795 6.4 $2.099- $2,339- NIA $800- $2,000 Fees &Deposit None Apartments $2,771 $3,641 Aspen Village 3600 Aspen Village Way, Cosh Mesa 714-751 -1332 6.4 $1,650 $2,000 N/A $600 -$650 Cat Only None Peartree Apartment Homes 3401 S. Plaza Drive, Sant Ana 714 -557 -1234 6.5 $1,475 $550+ None None Baypoinh 2500 Baypoinh Drive, Newport 866- 269.6524 6.5 $2'080 $2,460 N/A $700 Fees & Deposit None Beach $2,300 $1,760- $2,000- Newport North 2 Milano Drive, Newport Beach 866 - 286.9360 6.7 NIA $2,000 Pets ok None $1,830 $2,320 Pinnace atMacArthur 31 E. MacArthur Crescent Santa Ana 866 - 673.8849 7.0 $1'759 $1'964 NIA $400 -$500 Pets ok None Place $2,946 $3,088 Skyline at MacAMur Place 15 MacArthur Place, Santa Ana 714.557.4444 7,1 $3,009- $3,200- NIA $1,500 Pets ok Gas $3,298 $5,500 $2.485- $3,030- Newport Bluffs 100 Viaggio, Newport Beach 866 -286-7291 7.5 Varies Fees &Deposit None $2,725 $4,050 The Palm, Santa Ana 1331 W. Central Avenue, Sunni Ana 714 - 979 -2994 7.6 $1,445 $500 None None San Marm Villa 101 Venetia Drive, Irvine 866-286-7328 8.2 $1,550+ $3,500+ $4,500 $600 - $800 Fees & Deposit None San Marino 403 San Marino, Irvine 949 -553 -1662 9.9 $1,795 $99 Fees & Deposits None Woodbridge Pae 115 Pineshne, Irvine 949 -733 -0414 10.4 $1,740 $2,000+ $3,190 Varies Fees & Deposit None Cross Creek 22 Creek Road 41, Irvine 949- 733 -0414 10.6 $2,400+ $2,000 Fees &Deposits None Newport Ridge 1 Whita Cap Lane, Newport Beach 866-288 -0255 10.6 $2,030 $2,195- $1,000- Fees &Deposits None $2,525 $2,030 Turtle Rod Canyon 100 SanedlRe Aisle, Irvine 866- 319 -0424 10.9 $2,195 $2,965 $1,000 Dog -24 inches None Wndwood Knoll 2 Flagsthne, Irvine 949 - 551.3258 11.2 $1,700+ $1,800+ $2,400 $600 -$800 Fees & Deposits None Rancho Maderes 13408 Heritage Way, Tustin 866 - 297.7878 13.0 $1,955 $700 Pets ok None 20 -53 Exhibit H - Apartment Complexes - Rental Housing Availabilitv I 20 -54 Distance Complex Name Address Phone from Site m m m SEC. DEP. Pets l Dep.(ea) Utilities (Miles) Included Northwood Place 1300 Hayes, Irvine 949- 857 -4100 13,4 $1,550 $1,645 $2,445 $600-$800 Fees & Deposits None Promontory Point 200 Promontory Drive West, Newport 866- 293 -3148 3.8 $2,990 $2,900 Yes None Beach Coronado at Newport 880 Irvine Avenue, Newport Beach 949- 371 -8437 2.0 $1,365- $1,871- N/A $600 -$700 Yes None South $2,264 $3,048 Turle Rock Vista 3 Rockview Drive, Irvine 866 -319 -0439 9.4 $1,775 $1,775 Yes None Harbor at Mesa Verde 2700 Peterson Place, China Mesa 714 -546 -0370 3fi $1,471 $1,471 Yes None San MI Villa 101 Veneto, Irvine 866- 286 -7328 8.2 $1,575 $1,575 Yes None Woodbridge Villas 10 Thunder Run, Irvine 949- 786 -5110 10.1 $1,755 $2,145 $1'755 Yes None $2,145 Courtyards at South Coast 3800 S. Flower, Santa Ana 714 556 -7960 7.8 $1,414 $1,414 Yes None Kelvin Court 1 2552 Kelvin Avenue, Irvine 949- 797 -0003 81 $1,865 $1,865 Yes None Wndwood Knoll 2 Flagstone, Irvine 949 -551 -3258 12,1 $1,600 $1,600 Yes None Murano 100 Grand Canal, Irvine 866 -941 -7075 13.7 $1,675 $1,675 Yes None Northwood Place 1300 Hayes, Irvine 949 -857 -4100 15.1 $1,555 $1,555 Yes None Core Bella Apartment 9580 El Rey, Fountain Valley 714 - 968 -6545 7.3 $1,496 $1,496 Yes None Sendero Apartment Homes 8945 Riverbend Drive, Huntington 714842 -7368 10.8 $1,445 $1,445 Yes None Beach Huntington Parkside 16211 Parkside Lane, Huntingtoo 714 -847 -5441 127 $1,300 $1,300 Yes None Beach The Huntington Apartments 8400 Edinger Avenue, Huntington 714-947-9605 12.7 $1,455 $1,455 Yes None Beach El Pasco Apartment Homes 14901 Newport Avenue, Tustln 714 -544 -9090 9.5 $1,425 $1,425 Yes None Estrella Apartment Homes 15742 Wtiiams Street, Tustin 714 -547 -0401 10.1 $1,302 $500 Yes None Rancho Mariposa 13211 Mytord Road, Tustin 866- 306 -0327 13.1 $1,695 $1,695 Yes None Las Palmas 100 La Palmas, Irvine B66- 280 -1732 133 $1,630 $1,630 Yes None Rancho Alisal 13800 Parkeentor Lane, Tustin 866- 297 -5653 11.9 $1,590 $1,590 Yes None Solana 100 Monk) Vista, Irvine 714- 389 -4444 13.3 $1,880 $1,880 Yes None Parkside Court 4200 Wasl lstStree( Santa Ana 866- 673 -8792 10.8 $1,196 $1,196 Yes None Renaissance at Uptown 3063 W Chapman Avenue, Orange 866- 674 -1229 14.9 $1,718 $1,718 Yes None Camden Martinryue 2855 Pinecreek Drive, Newport 714540 -5500 4,5 $1,200 $300 No All Beach The Bays i Baywood Dr", Newport Beach 866- 306 -9255 6.0 $1,875 $1,875 Yes Gas utilities included Newport North 2 Milano Drive, Newport Beach 866- 286 -9360 6.7 $1,705 $1,705 Cate None Newport Bluffs 100 Vilaggio, Newport Beach 866 - 286 -7291 7.4 $2,300 $2,300 Yes None Mariner Square 12441n•ine Avenue, Newport Beach 866- 280 -2871 21 $2,145 $2,145 Yes None Baypoinle Apartnente 2500 Baypotnp Drive, Newport 866- 269 -6524 6.5 $2,135 $2,135 Yes None Beach I 20 -54 Exhibit I — Professional Mobile Home Movers Name /Address Phone Contact Comments BH Manufactured Specializes in tear downs and rebuilds, Homes 1731 Pacific Coast 310 - 534 -1750 Brad remodels and transporting. Hwy., Lomita, CA 90717 Go Transport 27548 Specializes in transporting, parking, tear Vanilla Ct Menifee, CA 760- 475 -3586 Edgar down and set up. 92585 Ron Hannah Trucking PO Only licensed for the transporting of BOX 24 Moreno Valley, CA 951 - 924 -7114 Ron mobile homes. 92552 Compass Mobile Home Movers 234 Jacobs Piland 843- 906 -2568 Tim Services nationwide, specializes in set Rd., Moncks Corner, SC ups and tear downs and transporting. 29461 RBK Transport, Inc. 1315 Services all of California, only licensed N Murray St, Banning, CA 951- 849 -5940 Marge for the transporting of mobile homes. 92220 Bennet Truck Transport 1444 S. Willow 909- 875 -8008 Cali Services all of California, only licensed Ave., Rialto, CA 92376 for the transporting of mobile homes. Golden State Home Services all of California and Transport 11212 Lander 209 - 656 -8000 Cherli specializes in transporting, parking, tear Ave., Turlock, CA 95380 down and set up. Baxter Mobile Home Services all of California and Services 2540 Burlwood 209 - 544 -8212 Rachel specializes in transporting, parking, tear Dr., Modesto, CA 95355 down and set up. BENT Level Services all of California and provide Construction PO BOX 503 - 650 -5883 Angie mobile home and modular setup, tear 264 Oregon City, OR down, and transport with a remote 97045 parking machine. Sav On Moving & 800- 675 -2956, Goes through a tow company with Storage 341 Bonnie Circle, cell 714 -299- Shannon Landow and only takes for disposal not Suite 103 Corona, CA 7539 set up for relo. 92880 30 20 -55 Attachment No. CC 7 Correspondence Received 20 -56 January 13, 2015 Re: Relocation Impact Report Ebb Tide Project November 26, 2014 PA — 2014 -151 To the City Council of Newport Beach: �.�GEIVEQ 9}. CO-M . UNITY JAN I • 2915 n� QEVELOAf;�EN7 1. G OFN%<WPORS As a homeowner in the Ebbtide Mobile Home Park (Park), this will serve as my submission and rebuttal to both the November 26, 2014 Relocation Impact Report (RJR) for the Ebb Title Project as well as the December 17, 2014 Review of the RJR by Paragon Partners, Ltd. (Paragon). For ease of reference and to facilitate your analysis, I have categorized some of the more predominant issues and problems in the RJR into separate issues. ISSUE 1 Page 12 of the RIR states: "The owner anticipates the Park closing in July 2015." Excerpt from December 17, 2014 Paragon report on its review of Draft RIR for the Ebb Tide Project (MRL 798.56 (g) (2)- Exhibit C)): After all required permits requesting a change of use have been approved by the local governmental board, commission or body, the owner shall give the homeowners six (6) months or more written notice of termination of tenancy, If the change of use requires no local governmental permits, then notice shall be given twelve (12) months or more prior to the owner's determination that a change of use will occur. Please see Notice of Incomplete Filing (Exhibit A) dated October 22, 2014 from the City of Newport Beach Coimnunity Development Department. The second to the last paragraph states: "Please note that the City will retain a consultant, at the applicant's expense, to conduct the enviromnental review of the proposed project and the Traffic Study. Staff remains concerned about the overall plan related to the amount of open spaces provided, excessive building height, and the number and location of guest parking spaces. We have provided guidance in an effort to enhance the project; however, efforts to address staff's concerns have been insufficient and may lead to staff to recommend against the proposal as currently proposed." Since October 22, 2014, there has been no update to PA — 2014 — 110 by the applicant, and the filing is expected to remain incomplete as of January 27, 2015 and also January 31, 2015. I have been informed that the initial Study Sessions by the Planning Department of the Traffic Study and/or the Environmental review of the proposed project have not even been tentatively scheduled yet, and the soonest they could occur might be sometimE in February 2015. 20 -57 I assert that the only legal means to close the park in "July 2015" would require that all of the permits to have been granted no later than January 31, 2015 (i.e. 6 months prior to July 31, 2015). Since the file (PA 2014 -110) and related application are expected to be incomplete on January 31, 2015, how is it legally possible to close the park in July 2015, since it is impossible for the permits to be granted by January 31, 2015? I assert that the draft RIR dated November 26, 2014, as submitted to the City Council and mailed to the Ebbtide Homeowners on January 12, 2015 is not sufficient and has not met the requirements of the MRL, since the July 2015 anticipated Park closure date is in not in accordance with MRL Section 798.56 (g) (2). One possible alternative might be for a future draft RIR to read "The Owner anticipates the Park closing on the later of [a] July 27, 2015, or [b] six months after all required permits requesting a change of use have been approved by the local governmental board, commission, or body, including the required land use permits /entitlement approvals from the City" rather than "The Owner anticipates the Park closing in July 2015." Language based upon Costa Mesa (Anchor Park) 2013 RIR excerpt below: 2.3 Park Closure As discussed throughout the Report, the Park will cease operating as a mobilelrome /recreational vehicle Park. Under applicable state laws, the earliest date that the Park can officially close is the date that is six (6) mouths after the Proposed Owner has obtained the required land use approvals from the City of Costa Mesa for the proposed prgioct on the site. The Proposed Owner commits that the Park closure date will be the, lgig of (1) august 24, 2013 or (ii) six (6) months after obtaining the required laud use permiWantitleanont approvals from the City ( "Closure Date "), which date is the final date all residents must vacate the Park. It is esthnated that the date that is xix (6) mouths after the Proposed Owner received its land use approvals may occur before August 24,2013; however„ the Proposed Owner has committed that the Closure Date will not be sooner than August 24, 2013, Upon receipt of the approvals for the change of use iiom ilia City of Costa Mesa, the Proposed Owner will send each resident household, within the Park a formal notice of the actual Closure Date and a notice of termination of tenancy pursuant to California Civil Code Section 798, et seq., which is commonly known as the Mobilehome Residency Law (`1^ARV), ISSUE 2 Excerpt from December 17, 2014 Paragon report on its review of Draft RIR for the Ebb Tide Project In summary, replacement housing was thoroughly researched, and important factors such as space rent and prohibitions on age and size of mobile homes were included, A plethora of alternative housing was also identified, in the form of various low density and multifamily dwellings. Given the relocation payments available, and the general availability of housing options and price and rental cost ranges, it appears that there is su icient replacement housing, The Draft RIR is sufficient and meets the requirements of the KARLI land California Government 20 -58 Assuming the City Council agrees with my assertion in ISSUE 1, I respectfully propose that Paragon be terminated by the Planning Department as the Expert Consultant with respect to further reviews of future draft RIRs. Since Paragon concluded that "The Draft RIR is sufficient and meets the requirements of the MRL... ", and that conclusion is upheld as incorrect, how could any further reviews of future draft RIRs by Paragon be expected to have integrity, and being worthy of the Planning Department and the City Council placing reliance on this Expert Consultant and any future reports issued by such Consultant? ISSUE 3 Page 12 of the RIR states: "The recipients must also enter into a voluntary relocation agreement (cooperation agreement), which specifies relocation benefits in accordance with this report." Page 3 of the VOLUNTARY RELOCATION AGREEMENT (Exhibit B) states: "In the event (i) the RIR submitted to the City is found sufficient without material changes in the relocation benefits provided thereunder, and (ii) all material components of the residential subdivision project described in the RIR submitted to the City ( "Entitlements ") are approved either unconditionally or with the conditions acceptable to Owner and a conforming final ordinance or resolution is adopted by the City prior to May 31, 2015, then in consideration for Resident (i) terminating and vacating his or her tenancy before the Termination date pursuant to paragraphs 1 and 2 above, (ii) permanently vacating the Homesite and Park, and (iii) removing the Mobilehome from the Homesite and the Park on or before the Termination Date, subject to _ Section 3 of this Agreement, Resident shall receive a payment in the sum of $20,000, within 10 business days after permanently vacating the Homesite and Park." Mr. Sunti Kumjim has presented Exhibit B, along with the draft RIR dated November 26, 2014, as the only two options that I have. Black's Law Dictionary defines coercion as: "Compulsion; constraint; compelling by force or arms or threat. It may be actual, direct, or positive, as where physical force is used to compel act against one's will, or implied, legal or constructive, as where one party is constrained by subjugation to other to do what his free will would refuse. As used in testamentary law, any pressure by which testator's action is restrained against his free will in the execution of his testament. "Coercion" that vitiates confession can be mental as well as physical, and question is whether accused was deprived of his free choice to admit, deny, or refuse to answer." 20 -59 Black's Law Dictionary defines duress as: "..." "A condition where one is induced by wrongful act or threat of another to make contract under circumstances which deprive him of exercise of his free will: 'Includes any conduct which overpowers will and coerces or constrains performance of an act which otherwise would not have been performed. "... "One who, under the pressure of an unlawful threat from another human being to harm him (or to harm a third person), commits what would otherwise be a crime may, under some circumstances, be justified in doing what he did and thus not be guilty of the crime in question." I assert that Mr. Kumjim has used coercive tactics in an attempt to compel me to agree to enter into the agreement (memorialized as Exhibit B) wider duress by presenting a non - compliant (please see ISSUE 1) draft RJR dated November 26, 2014 as my only other alternative. I have pointed out the non- compliance of the RIR to Mr. Kumjim numerous times, and requested him to provide me with a compliant RIR before I make a decision, and he has refused my numerous requests. My only hope is to humbly and respectfully beg the City Council to consider my rebuttals. ISSUE 4 Page 11 of the RIR states: b) In situations where it is not feasible to relocate the mobile home, payment will be provided as follows: 1. A fixed payment to the mobile home owner to abandon the unit in place, or remove the mobile home at their own cost, provided the mobile home owner signs a cooperation agreement that terminates any tenancy /occupancy and permanently vacates the Park. Payments to be made as follows: - For units 540 SF or less, a. payment of $9,000 - For units 600 SF -912 SF, a payment of $14,500 For units 960 SF -1,344 SF, a payment of $15,700 From speaking with various Homeowners, it is my understanding that certain Homeowners are being offered a VOLUNTARY RELOCATION AGREEMENT which differs significantly and materially from the VOLUNTARY RELOCATION AGREEMENT presented as Exhibit B. 20 -60 There is no transparency provided in the RIR to explain why certain homeowners are compensated with as much as $50,000 to $99,500 each, while the vast majority are compensated with $29,000 to $35,700 each. If the differences are based upon appraisals and/or in -place value provided to certain Homeowners, why can't the appraisals and any other applicable criteria used and explanations be included within the RIR to provide transparency to the City Council to have all facts reasonably available in making the review and decision? I assert that by keeping each of the 52 VOLUNTARY RELOCATION AGREEMENTS details excluded from the RIR, the applicant is not providing adequate transparency to allow the City Council to determine if all of the homeowners are being treated equally with respect to the compensation required by page 11 of the 11111, which is based upon square footage of the home... period. If there are other attributes being considered in determining reasonable and appropriate compensation, these attributes should be documented within the RIR to provide transparency for the review process by the City Council, in order to determine if these attributes have been measured and applied consistently and fairly for all of the Homeowners. I propose that the applicant be compelled to include all 52 Homeowners' VOLUNTARY RELOCATION AGREEMENTS within the RIR to allow adequate transparency to allow the City Council to malce an appropriate review of the RIR, since the reference on page 12 of the RIR incorporates this document as a material component of the RIR by usage of the word "must ", implying there is no alternative or other option. ISSUE 5 The payment schedule on page 11 of the RIR does not contain a timeline of the payment dates. There is no transparency provided with respect to the dates that the homeowners can expect to receive the compensation that they have been promised. The language infers that the homeowner must fulfill requirements of the RIR in exchange for an IOU and a promise that the check will be in the mail if and when we decide we will issue the payment. Page 12 of the RIR states "Requests for funds will be timely processed in a reasonable manner and signed aclumowledgements of receipt of payments will be maintained in individual relocation files." No meaningful details are provided with respect to actual dates that the homeowners can expect to receive the compensation they have been promised, and the language is vague and subject to interpretation. 20 -61 Page 14 of the RIR states: 5. The relocation specialist will issue benefit checks, which will be available at their offices for pick -up, delivered personally or mailed, depending on circumstances; 6. A final payment will be issued after confirmation that the resident has completely vacated the Park; 7. Receipts of payment will! be obtained and maintained in the relocation case file. There is no mention of any specific dates that the Homeowner can expect to receive compensation from the applicant, and the language used is vague with respect to the timing and the expected dates of actual payment to the homeowner. I propose that a transparent payment timeline be memorialized, including details of dates and timeline specifications, within the RIR to allow City Council to review the appropriateness, reasonableness and conformity of such with the law. Please see excerpts below from the Anchor Park closure (City of Costa Mesa during 2013) in which specific dates and timetables are established in order to provide reasonable transparency for the City Council to review for appropriateness and conformity with the law. To summarize the Eligible Residents' paymants and the timing, see below chart. ' Prior to Colnmoneement Date" �t7 Days Prior to Eligible Resident's Move Out Date 26 7 On Move Out Date Relocation Benefits Not Paid; /, ofFUND Amount Remaining'fi of FUND Amount; Option 1 Eligible Resident meats per Diem; Personal Property with Relocation Assistant moving costs (if select to do to review Relocation directly). All third party costs paid Options directly to company(ies) handling I I service. _ _ :Ctelocatinn Benefits Not Paid; /s of FUND Amount Remaining % of FUND An oust; Option 2 Eligible Resident meets Cash equivalent of Residential with Relocation Assistant Structure Moving Costs; Per Dican . to review Relocation _ Arttount; Salvage Value of ___ 20 -62 ISSUE 6 I have been informed by Mr. Kumjim that some or all of the voluntary relocation agreements (please see page 12 of RJR) will be still in draft stage as of January 27, 2015. How could the City Council be expected to make a determination of the compliance of the RIR with State Law if a material component of the RIR is still under draft on January 27, 2015? I propose that the applicant be compelled to complete its drafting of the voluntary relocation agreements which are required (usage of the word must) by the RIR and reach a final issuance stage to be incorporated into a future version of the applicant's RIR, and include each of the final documents as Exhibits, rather than keeping the City Council, Ebbtide Homeowners and the general public in the dark by providing absolutely nothing in writing with respect to the voluntary relocation agreements which must be entered into by the Homeowners per the November 26, 2014 draft RIR page 12. Please note that this submission is not exhaustive and I expressly reserve my right to challenge any other deficiencies within the RIR that are not mentioned herein. I also reserve any and all administrative, legal and equitable rights and remedies to challenge any subsequent decisions of the City with regards to the change of use and /or closure of the Park. I do appreciate your time and respectfully request your detailed consideration of these issues:: Thank you. Respectfully Submitted, David A. Szecsei David A. Szecsei, Homeowner in the Park Enclosures 20 -63 Options _ Residential Struct n•e based nn hida )endent company's schedule Relocation Benefits Not Paid; /20t FUND Amount Remaining'' /. of FUND Amount; Option 3 lligible Resident meets Per Diem; appraisal value of with lelocation Assistant to review Relocation O tions Residential Structure Non - Eligible .Residents Benefits Not:Paid '/, of Moving Stipend. Remausing'4a of Moving Stipend ISSUE 6 I have been informed by Mr. Kumjim that some or all of the voluntary relocation agreements (please see page 12 of RJR) will be still in draft stage as of January 27, 2015. How could the City Council be expected to make a determination of the compliance of the RIR with State Law if a material component of the RIR is still under draft on January 27, 2015? I propose that the applicant be compelled to complete its drafting of the voluntary relocation agreements which are required (usage of the word must) by the RIR and reach a final issuance stage to be incorporated into a future version of the applicant's RIR, and include each of the final documents as Exhibits, rather than keeping the City Council, Ebbtide Homeowners and the general public in the dark by providing absolutely nothing in writing with respect to the voluntary relocation agreements which must be entered into by the Homeowners per the November 26, 2014 draft RIR page 12. Please note that this submission is not exhaustive and I expressly reserve my right to challenge any other deficiencies within the RIR that are not mentioned herein. I also reserve any and all administrative, legal and equitable rights and remedies to challenge any subsequent decisions of the City with regards to the change of use and /or closure of the Park. I do appreciate your time and respectfully request your detailed consideration of these issues:: Thank you. Respectfully Submitted, David A. Szecsei David A. Szecsei, Homeowner in the Park Enclosures 20 -63 EXHIBIT "A" 20 -64 COMMUNITY DEVELOPMENT DEPARTMENT PLANNING DIVISION 100 Civic Center Drive, 13,0. Box 1768, Newport Beach, CA 92658 -8915 (949) 644 -3200 Pax: (949) 644 -3229 www.newportbeachea.gov NOTICE OF II NCOIVI LETS FILING October 22, 2014 Ebb Tide, LLC Attn: Sunti Kumjim PO Box 19583 Irvine, CA 92623 skumjim @ebbtidelic.com VIA EMAIL as 1/712015 (per Fern, signer of this letter) and expected to be current as of 1/27/2015 Application No. PA2014 -110 Tentative Tract Map No. NT2014 -002 • Site Development Review No. SD2014 -004 • Traffic Study No. 732014.007 • Planned.Comm unity Development Plan No. PC2014 -003 • Zoning Code Amendment No. CA2014 -006 Address 1560 Placentia Avenue In response to a Notice of Incomplete Filing dated July 18, 2014, you submitted additional information on September 24, 2014. Please be advised that after review of this information, the submittal was only partially responsive and It has been determined that further information Is required and your application remains incomplete. Please be advised that in the July 181h incomplete letter and in previous discussions, staff expressed concerns regarding height, design, parking, and open space. While your proposed Planned Community Development Plan attempts to address height, design, and lot size, staff still has concerns about the project and the process. The project does not meet the intent of the Planned Community District Procedures as established by Zoning Code Chapter 20.56 of providing for the classification and development of land as coordinated, comprehensive projects in order to take advantage of the superior environment resulting from large -scale community planning; allowing diversification of uses as they relate to each other in a physical and environmental arrangement while ensuring substantial compliance with the spirit, intent, and provisions of this Zoning Code; and inclusion of various types of uses, consistent with the General Plan through the adoption of a development plan and text materials that identify land use relationships and associated development standards. ' The following documentation is required to complete the application: 1 1. Revise the project description to include creation of a Planned Community District. J Include a narrative in support for waiving the minimum acreage requirement and how the proposed project meets the purpose of Chapter 20.56 (Planned Community District Procedures) (described above). 20 -65 2. In order to approve the proposed Tentative Tract Map and Site Development Review, certain findings must first be made. Revise the project description to include a narrative • supporting the required findings (Municipal Code Sections 19:12.070, 20:52.080; and 20.30.060) and justifying the additional height requested. 3. Include within the project description the intended creation of a Homeowners Association;. applicable Covenants, Conditions, and Restrictions; and any easements such as landscaping and parking. 4. Provide a Materials Board. 5. Submit the alternate design previously discussed that provides a driveway and landscape buffer to the abutting industrial property in the City of Costa Mesa. Provide a description and analysis of why the proposed design is superior to the alternative design and why the alternative plan was rejected. 6. Submit a drainage analysis for review for the proposed storm drain. The proposed storm drain on Placentia Avenue must be constructed per City Standards. The storm drain on -site must be privately maintained. Catch basins will likely be located at the intersection of the entry street and Placentia Avenue. Please note that the City will retain a consultant, at the applicant's expense, to conduct the environmental review of the proposed project and the Traffic Study. Staff remains concerned about the overall plan related to the amount of open space provided, excessive building height, and the number and location of guest parking spaces. We have. provided guidance in an effort to enhance the project; however, efforts to address staffs concerns have been insufficient and may lead staff to recommend against the proposal as currentl proposed. Upon verification of completion, the application will continue to be processed and will be tentatively scheduled for a Planning Commission Meeting. Should you have any questions regarding submittal requirements, please contact Fern Nueno, Associate Planner at (949) 644 -3227, fnueno @newportbeachea.gov. Thank you. 0J ono, Assoo o e PIAMor c: The Totah Family Partnership 34700 Pacific Coast Highway, 303 Capistrano Beach, CA 92624 ffp_mgmt @yahoo.com October 22, 2014 Page 2 20 -66 EXHIBIT "B" Not provided 20 -67 EXHIBIT 44U" See Attachment No. CC 6 Erin S. Guzman, Esq. G U ZMAN LAW FIR Of Counsel: erin @guzmanfirm com Y� 1\ItlA Telephone (760) 650 -1077 Facsimile (760) 477 -6044 www.guzmanfirm.com A PROFESSIONAL CORPORATION P.O. Box 1407 San Marcos, California 92079 January 16, 2015 City of Newport Beach Attn: City Council & City Plamling Staff 333 W. Ocean Blvd Long Beach, CA 90802 Re: PA- 2014 - 151 1Comment letter re: RJR for Ebb Tide To City Council and City Planning Staff Mark D. Alpert, Esq. malpert@guzmanfirm.com Daniel T. Rudderow, Esq. drudderow@guzmanfirm.com I represent Ebb Tide LLC in conjunction with the closure of Ebb Tide Mobile Home Park ( "Ebb Tide "). I have been asked to address comments in a letter to the City, dated January 13, 2015 by David Szecsei ( "Szecsei letter ") regarding the Relocation Impact Report ( "RIR ") for Ebb Tide. For the past 14 years, my legal practice has focused on the manufactured housing industry, including the closure and conversion of mobile home parks to other uses. As you may know, the purpose of an RIR and the local government's role in reviewing an RIR is described in Government Code § 65863.7. This section specifies the party seeking closure "... shall file a report on the impact of the conversion, closure, or cessation of use upon the displaced residents of the mobilehome park to be converted or closed. In determining the impact of the conversion, closure, or cessation of use on displaced mobilehome park residents, the report shall address the availability of adequate replacement housing in mobilehome parks and relocation costs." (§65863.7(a)) The City's role under this section is to review the report for the purpose of determining what it " .. . may require, as a condition of the change, the person or entity to take steps to mitigate any adverse impact of the conversion, closure, or cessation of use on the ability of displaced mobilehome park residents to find adequate housing in a mobilehome park. (65863.7(e)) However, "The steps required to be taken to mitigate shall not exceed the reasonable costs of relocation." Id. The Szecsei letter raises concerns which are not material to the City's role in assessing the RIR and determining the appropriate relocation benefits. Most of his comments either directly or indirectly rely on his assertion that the RIR is not adequate because it included the comment that "The owner anticipates the Park closing in July 2015." On its face, this statement was merely the owner's rough estimate of the closing date. The comment is simply irrelevant to whether the RIR adequately reports the impacts of the closure on the residents or whether the relocation benefits are adequate. The inclusion of this language is in no way inconsistent with the notice requirements under Civil Code § 798.56(g)(2). The statement does not purport to give residents statutory notice of closure. The residents will receive the statutorily required notice prior to 20 -69 Friday, January 16, 2014 PA- 2014 - 151 /Comment letlerre: 212jor Ebb l "ide any closure and the RIR does not purport to serve as such notice. As a result, there is no merit to the argument, which is the basis for issues I. 2 & 3. Exhibit B to the Szescei letter is not a 'cooperation agreement" referenced in the RIR. The "cooperation agreement" will include terms that are the same as those specified in the RIR, which can be finalized after such time as the RIR is approved. Any other relocation agreements that have been entered into between the owner and residents are private agreements by residents who have chosen to accept those relocation benefits instead of those to be ultimately provided in the RIR. Thus, the assertion of "issue 4" that these private agreements should be part of the RIR is mistaken. Similarly, issue 6 raised by the letter has no merit because the actual cooperation agreements contemplated by the RIR will duplicate the relocation benefits as the RIR and thus will have no impact on the benefits received, the cooperation agreement cannot now be finalize and no purpose is served by requiring it to be appended to the RIR. The Szescei letter takes issue with the fact that there are no exact deadlines for payment of relocation benefits. In this case, the relocation is being managed by Overland, Pacific, & Cutler, Inc., which is perhaps the most well -known and widely used in the industry. They can be relied upon to efficiently process requests for relocation benefits. In our view, it is unwise to specify exact dates because payments can be delayed by the failure of residents to timely provide necessary or adequate documentation and other issues outside the control of the park owner. The RIR is sufficient in noting that relocation payments will be completed after the resident has vacated the Park. It is notable that none of the comments raised in the Szessei letter address whether the relocation benefits set forth in the RIR adequately mitigate the impact of closure under the limitation that relocation benefits shall not exceed the reasonable cost of relocation. In other words, the comments are not relevant to the City's role in reviewing the RIR. If staff or the City Council has any questions regarding these matters, please feel free to contact me. Sincerely, ?z7 Mark . At , Esq. GUZMAN LAW FIRM- APC On Behalf of Ebb Tide, LLC M DA /kl cc: Sunti KUlDpin Page 1 2 20 -70 January 16, 2015 To: Fern Nueno, Newport Beach Planning Commission And Newport Beach City Council From: June C. Maier Ebb Tide Mobile Home Park HOA Secretary Gifted and Talented Specialist (retired) Our Lady Queen of Angels R.0 Church parishioner and member of three ministries Grandmother of seven Members of the Commission and the City Council; My personal background in Ebb Tide MHP: In 2008 1 retired from teaching in Las Vegas, NV, to move to Newport Beach because my daughter, Laura Zublin, (resident of the Port Streets) needed my help after the birth of the fourth child in the family. After looking for years to purchase a mobile home, I located my single -wide 1958 Rod n' Reel "trailer" Space C1 in Ebb Tide MHP. It was 400 sq ft with a small yard next to the pool, across from the entrance and the manager. It was all I had looked for; security, independence, gardening, exercise, and room for my Westie and cats, all wrapped up in mid - century charm! And the price was right, fitting my small teacher's pension. More background on Ebb Tide closure: In July 2014 the manager came to me asking what I could find out about the rumors people were asking him. He said that people were saying our park was sold, we would all be evicted, and new homes were going in here. I told him to call Joe La Barbera, the son in law of Ray Totah, the owner and ask him. This he declined to do. So I went to the woman who started the rumors and got Fern's name and called her. She confirmed the basic facts. In Augusta Homeowners' Association was formed and registered with NB City Clerk as a legal entity. Many meetings were held and the residents were able to vent their own situations, feelings, and exchange ideas. The rest is a history of more rumors, lies from Joe, some information from Fern which was all we had to go on, and a couple of vague and misleading letters from Sunti Kumjim who represented "Ebb Tide LLC ". There was one public meeting in October with OPC explaining how this would transpire. Residents were upset due to the information that not only would they be forced to move, they would be given a pittance in comparison to the equity they had put into their homes, some over decades. 20-79 My comments on the RIR and the events of the park closure: • Totally unprofessional treatment of the situation on the part of the Totah Family Partnership and the developer MDK Irvine and their employee Sunti • Lack of information forthcoming from owner TFP, including Joe L. telling residents bold -faced lies about the sale of the park • The first RIR offering residents 10 -15k for homes worth way more was iaughable as well as insulting • Belief that because the majority of residents were low and moderate income, some seniors, some Spanish speaking, some deaf, some living from paycheck to paycheck, that they were not smart enough or interested enough to be dealt with as NB citizens in other parts of town would be treated • Telling residents at a public meeting that they would be dealing with the OPC employees as was standard operating procedure in a park closure, but then Sunti walking around the park, speaking to people without an appointment, offering secret deal verbally if they would move out by Jan. 1, 2015 • This coercive deal was never in writing, but served to further infuriate the residents because it was an additional 20k, double the pittance, but still not enough to purchase a new mobile or even pay off a mortgage • When asked why the settlement couldn't be 60k to 100k to reflect "in place value" Sunti said because then developer would not make profit since he was paying Totah Family so much for land- rumored to be 40M My comments on what needs to happen for this RIR to be more acceptable: • to help mitigate the impact on the residents who are losing their homes that they have invested in over the years, they need to receive an independently done appraised "FAIR MARKET VALUE" so they could go to a nearby MHP and have a large enough down payment to purchase a similar home • most space rents will be higher so an additional period of "rent relief' reflecting the difference should be paid • a timeline which clearly states when and how the settlement is distributed so no possible misunderstanding is possible • all documents, including the RIR, need to be in Spanish for the 10 households that need them, or a representative of OPC verbally translate each page and explain it • remove wording like "a voluntary relocation agreement MUST be signed..." • More communication, communication, communication... Respectfully submitted by June C. Maier 0111612015 20 -72 January 15, 2015 Dear Ms. Nueno: I am writing to request that a very important issue be added to my original letter containing 6 issues as the 7`h issue. I am enclosing a copy of State of California Department of Consumer Affairs Legal Guide K -4 FOREIGH LANGUAGE TRANSLATION OF CONSUMER CONTRACT dated May 2012 (the "Legal Guide ") which states (following 5 paragraphs extracted from the enclosure): A person in a trade or business, who negotiated primarily in the Spanish, Chinese, Tagalog, Vietnamese, or Korean language in the course of entering into a contract with a consumer, must give the consumer a written translation of the proposed contract in the language of the negotiations (California Civil Code section 1632). The purpose of the law is to insure that Californians who speak a language other than English have a genuine opportunity to read the foreign - language translation of any proposed contract that has been negotiated primarily in that language, and to consult with other, before the contract is signed. It is never sufficient for the seller or creditor to give the foreign - language- speaking person the translation after he or she has executed (signed) the contract. The law requiring translation of contracts negotiated in a language other than English applies to: Contracts for the rental, lease or sublease of apartments or other dwellings (including mobile homes) for period longer than one month. The foreign - language translation need not be given in the following kinds of transactions: ...Contracts in which the foreign language- speaking consumer has negotiated the contract through his or her own interpreter (with limitations, see below). However, the last exception applies only if the consumer's interpreter is able to speak fluently and read with full understanding both the English and the foreign language. In addition, the interpreter cannot be a minor (under 18 years of age). Nor may the interpreter be employed or made available by or through the person engaged in the trade or business. 20 -73 Beginning with the initial letter from the developer announcing the initial outreach meeting, no communications have ever been provided in Spanish, including the RIR nor the 15 day advance notice to the residents about the City Council meeting on January 27, 2015. According to June Maier, Secretary of the Ebbtide Mobile Homeowners Association, there are approximately 10 households which are English as a second language with the primary language being Spanish. June is compiling a list of the applicable space numbers to have for you Monday morning and also at the January 27 City Council meeting. This is a by- product from her research which led her to print Homeowners Association notices to residences in both English and Spanish on a routine basis. I believe that many of the translators for the English as a second language adult residents, both homeowners and renters, have been minors. Since the RIR terminates the rental of tenancy of residents who have resided at Ebbtide Mobile Home Park on a long -term basis for a minimum of one year and as long as 25 years or more, I assert that the attachment is be relevant to the RIR, and any related legally required communications. I respectfully request that this letter and enclosure be added to my previously submitted "6 issue" letter and Enclosures. Thank you for your time and attention to this matter. Sincerely, David Szecsei, one of the Ebbtide Homeowners Enclosure 20 -74 6TATE AND CONSUMER BERV CE6 AGENCY • GOVERNOR EDMUND G. BROWN JR. Legal Affairs - 1525 North Market Blvd., Suite S 309, Sacramento, CA 95834 �°' o[v�nu[n, www.dca.ra.goV Legal Guide K -4 FOREIGN LANGUAGE TRANSLATION OF CONSUMER CONTRACTS May 2012 A person in a trade or business, who negotiates primarily in the Spanish, Chinese, Tagalog, Vietnamese, or Korean language in the course of entering into a contract with a consumer, must give the consumer a written translation of the proposed contract in the language of the neeotiationEThe translation must be an accurate translation of every term and condition in the contract or agreement. This requirement of California law applies whether the negotiations are conducted orally or in writing. This section does not apply to contracts negotiated in any of the above languages if the consumer has an interpreter.2 The foreign language translation must be given to the consumer before the consumer signs the contract. The seller or creditor must give the consumer the foreign- language translation whether or not the consumer requests it. The foreign - language translation must include the proposed contract terms, such as purchase price, finance charges, payment amount, etc. The purpose of the law is to insure that Californians who speak a language other than English have a genuine opportunity to read the foreign - language translation of any proposed contract that has been negotiated primarily in that language, and to consult with others, before the contract is signed. It is never sufficient for the seller or creditor to give the foreign-language - speaking person the translation after he or she has executed (signed) the contract. If a trade or business that is required to provide a foreign - language translation fails to do so, the consumer can rescind (cancel) the contract or agreement, in which event the law governing cancellation of contracts will apply.3 The consumer can cancel the contract even if it has been assigned to a financial institution; but in that event, the consumer must look to the original trade or business for a return of the amounts he or she has paid. If the consumer received any goods, the goods must be returned to the original trade or business. If a consumer rescinds, the consumer need not pay the financial institution that has received an assignment of the contract. Instead, the financial institution is entitled to return the contract to the original trade or business, and to recover from the original trade or business anything it has paid to the trade or business. The law requiring translation of contracts negotiated in a language other than English applies to: Credit sale contracts involving consumer goods and services of all kinds, including automobile purchases and leases; 20 -75 • Virtually all loans or other extensions of credit for use primarily for personal, family or household purposes, except loans secured by real property; Consumer loans secured by real property, if arranged by a real estate loan broker, or made by a personal finance company; • Contracts for the rental, lease or sublease of apartments or other dwellings (including mobile homes) for a period longer than one month. (Month -to -month and week -to- week rental contracts are not covered); Contracts involving the payment of fees or charges for legal services furnished by lawyers; • Reverse mortgages; and • Mortgage foreclosure consulting contracts. The foreign - language translation need not be given in the following kinds of transactions: • Home improvement contracts. • Contracts involving a seller who is not engaged in a trade or business. • Contracts in which the foreign language- speaking consumer has negotiated the contract through his or her own interpreter (with limitations, see below). However, the last exception applies only if the consumer's interpreter is able to speak fluently and read with full understanding both the English and the foreign language. In addition, the interpreter cannot be a minor (under 18 years of age). Nor may the interpreter be employed or made available by or through the person engaged in the trade or business. At the same time and place where any contract is entered into following negotiations primarily in one of the foreign languages listed above, a notice of the consumer's rights must be displayed. This notice must be written in the language of the negotiation and must be conspicuously displayed. The notice must inform consumers of their rights under this law. This notice need only be displayed at those locations where the foreign language is used. (The notice is not required to be given by providers of legal services or those who make or arrange loans secured by real property.) The business must give the consumer a foreign - language translation of the original contract and any subsequent documents that modify the original contract or substantially change the rights and obligations of the parties. A notice of repossession and deficiency under Civil Code section 2983.2 is a document that substantially affects a consumer's rights under an automobile financing contract. However, the law does not require a foreign - language translation for any later documents authorized by or expected to be made under the original contract or its modifications. Examples of those documents which need not be translated include periodic statements, sales slips, 20 -76 invoices, add -on sales, or refinancings that are provided by or made pursuant to the original contract. If the contract involves a loan made by a "supervised financial organization" such as a bank, savings association, credit union or personal finance company, the organization need only provide a foreign - language translation of the credit disclosures required by the federal Truth in Lending Act. A foreign - language translation of the remainder of the contract need not be provided. Thus, the foreign - language translation need only include the amount financed, the annual percentage rate, the amount and due dates of the payments and other relevant credit information — the most relevant details that the average consumer would be likely to consider before signing a contract. The rule is different in the case of preprinted automobile lease contracts provided to dealers by prospective assignees, such as banks or leasing companies. The prospective assignee must provide a Spanish - language translation of the entire lease contract to the dealer upon the dealer's request.' The dealer then provides this translation to the Spanish - speaking customer. In interpreting a contract subject to the foreign - language translation law, the signed English contract determines the rights and duties of the parties. However, if there is a substantial difference between the English contract and the foreign- language translation, the law states that this may show that no contract was ever entered into. All cosigners of consumer credit contracts must receive notice of their obligations in English and Spanish and/or the language in which the consumer contract is written (if not in English or Spanish) prior to them becoming obligated under the contract.6 The same is true for cosigners on vehicle leases .7 NOTE: This does not apply if the cosigner is married to the individual for who he /she is cosigning. A Patients' Bill of Rights translated into Spanish, Chinese, and certain other languages must be made available to all patients speaking those languages living in long -term health care facilities, including skilled nursing facilities, intermediate care facilities, and nursing facilities.s The provisions relating to verification of Spanish - language translations of contracts by the Department of Consumer Affairs were repealed in 2001.9 NOTICE: We attempt to make our legal guides accurate as of the date of publication, but they are only guidelines and not definitive statements of the law. Questions about the law's application to particular cases should be directed to a specialist. This document is available on the department's website at www.dca.ca.gov. This document may be copied if all of the following conditions are met: the meaning of the copied text is not changed; credit is given to the Department of Consumer Affairs; and all copies are distributed free of charge. Prepared by: Richard A. Elbrecht, Supervising Attorney, Marla L. Scharf, Staff Counsel, Legal Services Unit. Last updated May 2012 by Claire Yazigi, Attorney. 20 -77 ENDNOTES 1. Civil Code section 1632. 2. Civil Code section 1632(h). 3. Civil Code sections 1688 et seq. 4. Reyes v. Superior Court (1981) 118 Cal.App. 3d 159, 162 [173 Cal.Rptr. 267, 268]. 5. Civil Code section 2991. 6. Civil Code section 1799.91 (a), (b). 7. Civil Code section 1799.91(d). 8. Health & Safety Code section 1599.61. 9. Statutes 2001, chapter 306 (AB 446). 20 -78 Erin S. Guzman, Esq. erin@guzmanfirm.com GUZMAN LAW FIRM A PROFESSIONAL CORPORATION Telephone (760) 650 -1077 Facsimile (760) 477 -6044 P.O. BOX 1407 www.guzmanfirm.com San Marcos, California 92079 January 20, 2015 City of Newport Beach Attn: City Council & City Planning Staff 333 W. Ocean Blvd Long Beach, CA 90802 Re: P.4- 2014 - 151 /Comment letter re: RIR jor Ebb Tide To City Council and City Planning Staff, Of Counsel: Mark D. Alpert, Esq. malpert@guzmanfirm.com Daniel T. Rudderow, Esq. drudderow@3uzmanfirm.com As you know, I represent Ebb Tide LLC in conjunction with the closure of Ebb Tide Mobile Home Park ('Ebb Tide "). I am writing to address a second letter to the City, dated January 15, 2015 by David Szecsei regarding the Relocation Impact Report ( "RIR ") for Ebb Tide. The letter raises a seventh issue, the claim that the RIR and /or related notices should have been provided to Spanish speaking tenants in Spanish. The letter is not accurate and raises an issue which is not relevant for at least three separate reasons. First, the cited code section, Civil Code § 1632 only applies to contracts with consumers. The RIR is not a contract with a consumer or a contract of any kind. It is a report on the impact of closure and mitigation measures proposed by the park owner, which has been submitted to the City of Newport Beach for approval. Second, even assuming the RIR were a contract, the statute only applies if the contract was primarily negotiated in the foreign language. (§ 1632 (a)) There is no indication any residents negotiated their leases primarily in Spanish any language other than English. Third, the RIR does not terminate the tenancy resident. It is merely a proposal for relocation benefits to be paid to be reviewed by the City of Newport Beach. The tenancies would be terminated by a separate legal notice to the residents. If staff or the City Council has any questions regarding these matters, please feel free to contact me. On Behalf of Ebb Tide, LLC MDA /kl cc: Sunti Kumjim 20 -79