At its meeting beginning at 6pm on December 3, 2025, Sonoma’s City Council will hold a study session on proposed changes to the city’s Mobilehome Ordinance. Modification of state law and concerns raised by mobilehome owners and residents have prompted the review. There are approximately 6-700 residents in mobile home parks within the City of Sonoma. No formal action is taken during study sessions.
Key Areas for Discussion
1. Mandatory Relocation Impact Report (RIR)
Provide more specificity on what is contained in the RIR and the relocation plan?
Any person applying to change the use, close, or cease operations of a mobilehome park must file a comprehensive Mobilehome Relocation Impact Report (RIR). Applications will not be considered complete until this report is filed and approved. The Tri-Park Committee ordinance contains more specificity regarding what is required in the RIR and the required relocation plan. The example ordinances provide a range of level of specificity.
2. Notification and Timeline
Require additional, or extend timing of noticing requirements pre or post application submittal?
The City’s current notice to provide the mobilehome owners and residents the RIR 15 days before the hearing will change to at least 60 days in compliance with the state law. The City can modify other deadlines and noticing periods including if a noticing must be sent to mobilehome owners before application submittal. The example cities provided a variety of noticing timelines for pre-application, before public hearing, and post hearing.
Change City Manager to Director of Community Development?
Currently the City Manager is identified as the lead, however most jurisdictions identify the Planning or Community Development Director as the lead to process the applications.
Add an approval expiration and extension procedure.
The City’s code does not currently have a period of time for the permit to be executed before expiring and an extension procedure. The standard period for development permits in Sonoma is 2 years.
3. Relocation and Payments
Clarify components of the relocation plan to determine and identify appropriate relocation assistance?
State law provides a “replacement and relocation plan that adequately mitigates the impact upon the ability of the displaced residents of the mobilehome park to be converted or closed to
find adequate housing in a mobilehome park” is to be provided with the RIR. Some jurisdictions provide more detail on what is to be included in the relocation plan provided as part of the RIR.
Require a housing specialist to be identified to assist?
The City currently requires the RIR include a list of potential housing specialists to assist park residents with relocation. Some jurisdictions and the Sonoma Tri-Park Committee ordinance require the owner to pay for a housing specialist to help prepare the relocation plan and assist the homeowners and residents.
Clarify timing when the payments shall be made?
The Tri-Park Committee ordinance requires the payments be made not less than 90 days before the date to vacate the mobilehome park.
Identify provision of additional relocation assistance for low income households and/or disabled households?
Some jurisdictions provide specific types of relocation assistance for low-income and/or disabled households that could be included in the relocation plan.
Expand comparable parks to include those within a certain radius of the City and/or other counties?
The Tri-Park Committee ordinance identifies comparable parks to be up to a distance of 20 miles or in Sonoma or Napa Counties and of similar Cal EPA’s CalEnviroScreen score. Currently, the City’s code states comparable parks are only those in Sonoma County.
4. Valuation / Appraisal
Appraiser selected and managed by the City or approved list provided to select from? Currently the City has the consultant preparing the RIR to complete or have the appraisal completed for the “fair market value” of each mobilehome. The state law just requires that the “in-place market value” must be appraised by a state certified appraiser and submitted as part of the RIR.
Should the scope of the appraisal include the park?
The proposed ordinance from the Tri-Park Committee includes an appraisal for the mobilehome park to be included in the RIR comparing values. Two of the four example jurisdictions require this.
5. Review Procedures and Findings
Planning Commission or City Council to approve? Allow for appeals to Council?
Currently the City requires approval by City Council along with most jurisdictions. However, the City Council can identify the Planning Commission as the approval body. This would allow for an appeal process to City Council.
How to involve mobilehome owners and residents in the process?
Currently the City only requires standard noticing and public hearing. The Tri-Park Committee ordinance provides for additional opportunity during the public hearing for residents so it is equal to the applicant.
Should development be reviewed concurrently with a closure/conversion?
Currently the City states an RIR is to be provided with a change of use request. The Tri-Park Committee ordinance requires a special use permit to be considered concurrent with the required development approvals or an additional finding is required in the instance that no development is concurrently proposed. The example jurisdictions provide a variety of treatments from development must be heard after the closure request to allowing development agreements concurrently with the closure request.
Should decision be made at the public hearing or time given for consideration after close of the public hearing?
A few jurisdictions and the Tri-Park Committee ordinance allow for a decision to be made after the close of the public hearing, but within 60 – 90 days.
Should conditions necessary to mitigate impacts be required?
The City’s current wording is that conditions may be necessary. The Tri-Park Committee ordinance requires conditions to mitigate while other example ordinances state findings should include conditions necessary to mitigate.
6. Consistency Findings (Housing Element/RHNA/ lower income housing availability)
Should language be strengthened to require denial if housing availability negatively impacted or require conditions to mitigate impact.
State law requires that the a finding shall be made as to whether a closure will result in or materially contribute to a shortage of housing opportunities and choices for low- and moderate income households. The Tri-Park Committee ordinance proposes a finding that the closure will not reduce affordable housing stock to the extent that the closure/conversion would be inconsistent with the Housing Element.
7. Resident Purchase / Right of First Refusal (ROFR)
Add ROFR to the RIR information if being provided? Add ROFR as a potential relocation assistance option?
The City currently requires the Council to make a finding regarding if ROFR is provided. However, the codes does not specify in the RIR or the relocation plan any information to be submitted.
8. Public Outreach
Require resident/mobilehome owner questionnaire to be included in the RIR?
The RIR requires information on each mobilehome, its owner, and its occupants to be provided. Most of the example jurisdictions and the Tri-Park Committee ordinance require questionnaires be completed by the mobilehome owner and occupant households and provided with the RIR.
Require an informational meeting held by the applicant for the affected mobilehome owners and residents before the public hearing?
The Tri-Park Committee ordinance proposes to require a community meeting be held by the applicant at least 30 days before the public hearing and attended by City staff.
9. Enforcement Tools
Require recordation of agreement and/or require affidavit of compliance completeness before issuance of building permit?
The City currently requires a written agreement to ensure compliance, but it is not required to be recorded nor does the ordinance clearly state when the compliance need to be completed by. The Tri-Park Committee ordinance provides that the mitigation measures are to be completed before issuance of building permits. The example jurisdictions also tie the completion of mitigation before construction and some require recorded or written letters stating that they have complied.
10. Reconsideration
Include a revocation process?
Most jurisdictions and the Tri-Park Committee ordinance include a revocation process.
11. Other
Add provision for exemption from relocation assistance requirements based on reasonable use or economic value? The Tri-Park Committee ordinance and a couple example ordinances allow for an exemption from relocation assistance. State law requires an exemption for bankruptcy.
Add additional finding for closure not heard concurrently with a change of use? The Tri-Park Committee ordinance requires an additional finding be made if a change of use in not heard concurrently.
Next Steps
Staff is requesting direction and any further questions or requests for additional information. We will take the direction provided and present a draft ordinance in the early 2026. City staff will continue to work with residents and park owners through the process to ensure everyone has the time and forum to provide input before a public hearing.
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