SB 610 requires anyone proposing to convert, close, or cease using land as a mobilehome park to file an impact report that includes a replacement and relocation plan and, when residents cannot be rehoused in another park, to pay the displaced resident the mobilehome’s in‑place market value. The bill makes the person proposing the change responsible for paying for and including a state-certified appraisal and gives residents a right to notice and a hearing on the report’s sufficiency.
For closures tied to disaster damage, the impact report must include a technical service inspection report from the Department of Housing and Community Development. The statute creates a statewide minimum standard, lets local legislative bodies impose mitigation conditions and fees, and exempts closures resulting from bankruptcy proceedings.
At a Glance
What It Does
Requires filers of mobilehome park conversions, closures, or cessations of use to submit an impact report with a replacement/relocation plan; if a displaced resident cannot relocate to another park, the filer must pay the resident the mobilehome’s in‑place market value determined by a state‑certified appraiser. For disaster‑related damage, the report must include an HCD technical service inspection.
Who It Affects
Mobilehome park owners and managers (as defined in Civil Code 798.2), displaced mobilehome residents, state‑certified mobilehome appraisers, local legislative bodies and planning agencies, and the Department of Housing and Community Development.
Why It Matters
The bill sets a uniform baseline across California for how park closures are reviewed and compensated, creates a clear appraisal‑based compensation trigger, and adds procedural protections (notice, hearings, and mitigation authority) that raise the cost and administrative burden of conversions and closures.
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What This Bill Actually Does
SB 610 makes a person or entity proposing to convert, close, or otherwise stop using land as a mobilehome park file an impact report before doing so. That report must include a replacement and relocation plan focused on ensuring displaced residents have the opportunity to move into another mobilehome park.
If the filer cannot reasonably place a resident in another park, the filer must pay the displaced resident the mobilehome’s in‑place market value.
The bill specifies how in‑place market value is calculated: a state‑certified appraiser experienced with mobilehomes must appraise the unit, assuming the mobilehome remains in its current location and the park continues to operate. The filer pays for that appraisal and must include it in the impact report.
However, that payment obligation does not apply when the closure or conversion is the direct result of disaster damage as defined in the Civil Code.For park closures tied to disaster damage, the impact report must also include a technical service inspection report prepared by the Department of Housing and Community Development that describes observed conditions in the park. The statute gives residents the right to receive the report at least 60 days before any hearing on the report and allows the filer or any park resident to request a hearing before the local legislative body on whether the report is sufficient.Local legislative bodies (or their advisory agencies) must review the report, determine whether the proposed conversion would materially contribute to a shortage of housing opportunities for low- and moderate‑income households, and may impose mitigation measures as a condition of approval.
The local body may also set reasonable fees to recover costs of implementing the law. The statute applies to charter cities, to changes stemming from zoning or permit decisions (where the public agency becomes the ‘proposer’), and to enforcement‑driven closures, but excludes closures that result from bankruptcy orders.
The Five Things You Need to Know
The impact report must include a replacement and relocation plan designed to mitigate displaced residents’ ability to find adequate housing in another mobilehome park.
If a displaced resident cannot obtain adequate housing in another park, the filer must pay the resident the mobilehome’s in‑place market value as determined by a state‑certified mobilehome appraiser, and the filer pays for that appraisal.
For closures caused by disaster damage, the report must include a Department of Housing and Community Development technical service inspection identifying observed conditions; the appraisal‑payment rule does not apply in those disaster‑related closures.
The filer must provide each resident a copy of the report at least 60 days before any local hearing (or simultaneously with statutorily required notice if the report is filed earlier), and residents or filers may demand a hearing on the report’s sufficiency.
Local legislative bodies can require mitigation measures as conditions of approval and establish reasonable fees under Government Code section 66016 to cover administrative costs; the statutory standard is a statewide minimum that local agencies may exceed.
Section-by-Section Breakdown
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Mandatory impact report and relocation plan
Before a park conversion, closure, or cessation of use (except conversions under the Subdivision Map Act), the person proposing the change must file an impact report that contains a replacement and relocation plan aimed at mitigating the displacement’s effect on residents’ ability to find adequate housing in another mobilehome park. This provision creates the core procedural obligation that triggers later appraisal, notice, and hearing requirements.
Disaster cases: HCD technical service inspection
When the proposed change follows disaster damage or destruction (per subdivision (k)), the impact report must include a technical service inspection report from the Department of Housing and Community Development identifying observed conditions in the park. This imports HCD’s technical assessment into the local review, potentially slowing timelines and creating a state‑level evidence requirement for disaster‑related closures.
Appraisal‑based compensation when relocation fails
If a displaced resident cannot obtain adequate housing in another mobilehome park, the filer must pay the resident the unit’s in‑place market value. The statute requires a state‑certified appraiser experienced with mobilehomes to base the appraisal on the home’s current in‑place location and assume the park continues to operate; the filer pays for the appraisal and includes it in the impact report. The payment rule expressly excludes disaster‑related closures as defined in the Civil Code.
Notice and hearing rights for residents
The filer must provide each resident a copy of the impact report at least 60 days before any hearing by the advisory agency or legislative body, or concurrently with the notice required under Civil Code section 798.56(g) if the report is filed earlier. Either the filer or a park resident can request a hearing before the legislative body on whether the report is sufficient, embedding a formal opportunity to challenge the adequacy of mitigation plans or valuations.
Local review, findings on housing impacts, and mitigation authority
The local legislative body or its advisory agency must review the report and decide whether the proposed change will materially contribute to a shortage of housing options for low‑ and moderate‑income households. The local body may impose mitigation steps as conditions of approval to address adverse impacts on displaced residents’ ability to secure housing in another park, providing a direct lever for local governments to shape remedies.
Scope, exceptions, and who counts as the proposer
The law does not apply to park closures that result from a bankruptcy order. The statute applies to charter cities and to decisions by local agencies not to renew permits or zoning variances—where the public agency is treated as the entity proposing the change—and to closures prompted by permit suspensions, where the park owner is the proposer. These rules assign responsibility for preparing the impact report depending on the source of the closure.
Fees, state minimum standard, and applicability
Local jurisdictions may adopt reasonable fees under Government Code section 66016 to recover costs of implementing the statute (including Section 65863.8). The statute is expressly a statewide minimum; local agencies may impose more stringent rules. That creates both uniform baseline obligations and local flexibility to demand stronger mitigation or higher developer fees.
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Displaced mobilehome residents — receive a formal relocation plan, advanced notice and the right to a hearing; if they cannot relocate into another park they are entitled to an appraisal‑based payment for the in‑place value of their unit.
- Residents impacted by disaster damage — gain an independent technical inspection from HCD included in the impact report, which documents conditions and supports claims for mitigation or assistance.
- Local governments and planning agencies — gain a standardized process and evidentiary basis to assess how a closure or conversion will affect low‑ and moderate‑income housing supply and to condition approvals on mitigation.
- Tenant advocacy groups and legal services — obtain clearer procedural hooks (notice, hearings, appraisal reports) to challenge inadequate relocation plans or valuations on behalf of residents.
Who Bears the Cost
- Park owners or proposers (including managers or local agencies acting as proposers) — must prepare the impact report, pay for state‑certified appraisals, and potentially pay relocation compensation and local fees when residents cannot be rehoused.
- Department of Housing and Community Development — will shoulder technical service inspection workload for disaster cases and may need additional resources to meet demand and deadlines.
- Local agencies — must review reports, make housing‑impact findings, hold hearings, and may face increased administrative workload and potential litigation defending their findings.
- Developers and prospective converters — face higher transactional costs, possible mitigation requirements, and delays from the added reporting, appraisal, and hearing process that can affect project schedules and feasibility.
Key Issues
The Core Tension
The bill forces a trade‑off: it strengthens protections for mobilehome residents by requiring relocation planning, notice, hearings, and appraisal‑backed compensation when relocation fails, but those protections increase costs, administrative burdens, and delay for property owners and public agencies—creating pressure that could slow or deter redevelopment and shift costs onto local governments, state agencies, or developers with no single clean solution.
The statute threads a fine line between protecting long‑term mobilehome residents and preserving the ability of property owners and local governments to repurpose land. Valuation design — requiring an appraisal that assumes the park continues to operate and that the unit remains in place — aims to capture the value of site‑dependent units, but it leaves open disputes about comparable sales, depreciation for needed site repairs, and interpretive variance among appraisers.
The disaster carve‑out for payment obligations further complicates the picture: disaster closures still require HCD inspection reports, but the absence of a payment mandate in those cases may leave residents without compensation even when their homes lose substantial value.
Implementation raises logistical and fiscal questions. HCD’s role in providing technical service inspections creates a single authoritative source of park condition information but also concentrates workload at a state agency without an express funding mechanism in the text; local agencies may use fees under section 66016 to recover costs, but fee levels and whether they fully cover state inspection or litigation expenses is uncertain.
The bankruptcy exception creates a clear escape valve for filers in financial distress but also a potential strategic pathway to avoid obligations. Finally, the statute leaves key terms—such as what constitutes “adequate housing in a mobilehome park” and the standards for determining when relocation efforts are “adequate”—to local interpretation, which will likely generate litigation and uneven application across jurisdictions.
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