Sunnyvale — Mobile Home Park Conversions

District Applicability

No Chapter 19.72 Zoning District Designation

Chapter 19.72 does not establish a separate Sunnyvale zoning district, overlay district, permitted-use table, FAR, height limit, lot coverage limit, or setback schedule for mobile home park conversions. It applies to a qualifying mobile home park conversion regardless of the park’s underlying district designation. § 19.72.030

Accordingly, no R-1, C-N, industrial, mixed-use, or overlay-district standards can be confirmed from the source materials for this chapter. The future use proposed after conversion must be evaluated under the applicable Sunnyvale zoning, Sunnyvale development standards, and potentially Sunnyvale overlay districts requirements.

A proposed replacement development may separately implicate parking, design review, landscaping and screening, and the California Building Standards Code. Those requirements are outside Chapter 19.72 and must be verified with the jurisdiction.

Reduced Occupancy: When a Conversion Is Deemed to Be Underway

A park is deemed to be undergoing conversion by closure or cessation of use when 25% or more of its spaces are uninhabited. An uninhabited space is one that has no mobile home or has a mobile home in which no one resides, unless the condition resulted from a physical disaster or another circumstance outside the park owner’s control. §§ 19.72.020, 19.72.070(a)

At the 25% threshold, the park owner must file a statement explaining known reasons for the reduced occupancy and any intention to change the use. A resident may instead file a reduced-occupancy statement identifying the spaces believed to be uninhabited. § 19.72.070(a)

Park Owner Statement

If the park owner files the statement, the director determines whether it is correct and issues a notice of determination of conversion. No public hearing is required for that owner-filed statement path. § 19.72.070(a)(1)

Resident Statement

If a resident files the statement, the director must determine its correctness at a noticed public hearing. Notice of the hearing’s time and place must go to the park owner, mobile home owners, and residents, and must be posted at every park entrance at least 30 days before the hearing. § 19.72.070(a)(2)–(3)

The director’s determination may be appealed directly to the city council by the park owner, a mobile home owner, or any resident under the appeal procedures referenced in § 19.98.070. The content of those appeal procedures is not found in source materials. § 19.72.070(a)(3)

Notice of Determination and the CIR

After a reduced-occupancy determination, written notice of conversion must be issued to the park owner, mobile home owners, and residents with proof of service. The notice must establish a reasonable period for the park owner to file a CIR. § 19.72.070(b)

“Proof of service” means written evidence that a required recipient received the notice or document. It can include USPS delivery confirmation, certified-mail or signature confirmation, or a recipient-signed statement for personal delivery. § 19.72.020

The CIR is the chapter’s core impact-analysis document. It must adequately define and address the social and economic impacts of the proposed conversion or closure on displaced residents and mobile home owners, except where the director determines that a listed item would not be useful for the particular park. § 19.72.090

Conversion Impact Report Requirements

The CIR must document the park’s residents, homes, realistic relocation options, proposed assistance, and schedule. It is not simply a vacancy survey; it is the evidentiary basis for a site-specific relocation plan. § 19.72.090

Resident and Home Information

The CIR must identify each home’s physical characteristics and accessibility improvements, including ramps, lifts, and grab bars. It must also identify the number of occupants, the household type—such as senior, disabled, low income, individual, or family with minor children—and whether the occupants are mobile home owners, tenants, or another occupancy type. § 19.72.090(a)

The chapter defines a senior household through household members or a primary wage earner/spouse who is at least 62 years old. It separately defines a disabled household through specified household disability circumstances. § 19.72.020

The source materials begin, but do not complete, the definition of a low income household. The applicable income threshold cannot be confirmed from source materials.

Confidential Information Must Be Submitted Separately

Personal resident information is submitted separately from the CIR because it is confidential. The director must maintain that list as a confidential public record and may not disclose it publicly except under a qualifying court judgment, order, or decree under the California Public Records Act. § 19.72.090(b)

The separate list includes resident and owner names, addresses, contact information, occupancy length, current rent, lease terms, and available new addresses for people who have already relocated. § 19.72.090(b)

Comparable Parks and Comparable Housing

A comparable mobile home park is similar to the subject park in amenities and rent, with relevant considerations including transportation and shopping access, the displaced resident’s job market, and school proximity. § 19.72.020

A comparable housing option must meet minimum Uniform Housing Code standards and be similar in rent, size, bedroom and bathroom count, and relevant location factors such as work, amenities, schools, and public transportation. § 19.72.020

The CIR must list vacant spaces in parks within 20 miles and in other California locations desired by mobile home owners. The list must address vacancies, lease rates, acceptance restrictions, amenities, and proximity to transportation, schools, medical care, social and religious services, and grocery stores. § 19.72.090(c)

If a resident cannot be placed in a comparable park within 20 miles, the CIR must address the availability and cost of renting or purchasing comparable housing in Sunnyvale or in another location the resident desires. § 19.72.090(d)

Relocation Plan and Assistance

The CIR must include a relocation plan. That plan must state the minimum relocation assistance the applicant agrees to pay to each eligible resident and mobile home park owner, explain how the amount was determined, identify the proposed replacement-housing type for each resident, and provide an implementation timetable. § 19.72.090(f)

Replacement housing may involve relocation to a comparable park or renting or purchasing other housing. The plan’s timetable must address the physical relocation of mobile homes, implementation of relocation assistance, and park conversion. § 19.72.090(f)(2)–(3)

The CIR also must identify a relocation specialist from the director’s list; moving companies selected by that specialist and approved by the director; and qualified mobile home appraisers from the director’s list. Fee schedules and moving-cost estimates for the mobile home, furniture, and personal belongings are required. § 19.72.090(g)

Chapter 19.72 references a separate relocation-assistance provision and a possible waiver process, but the amount, eligibility rules, and substantive waiver criteria cannot be confirmed from source materials. §§ 19.72.070(c), 19.72.090(a)(3), 19.72.090(f)(1)

Failure to Submit a CIR

Failure to submit a required CIR by the deadline is declared a public nuisance. The ordinance identifies the risk of severe social and economic harm from delaying impact analysis and necessary relocation assistance. § 19.72.070(d)

If the park owner does not prepare the CIR on time, the director must prepare it and bill the park owner. The owner must reimburse the City within 30 days after receiving the bill; otherwise, abatement and collection procedures may begin under the referenced municipal-code provisions. § 19.72.070(d)

Notice to Prospective Residents

Before signing a rental agreement, a park owner must give each prospective new resident written notice that either a development application for conversion has been filed or the park has been determined to be undergoing conversion because of reduced occupancy. The notice must also advise that the new resident may not be entitled to relocation assistance under the chapter’s referenced assistance provision. § 19.72.110

This is a pre-lease disclosure obligation. It applies to a prospective new resident, not only to an existing resident receiving a closure notice. § 19.72.110

For broader renter protections that are not part of this chapter, see Sunnyvale Residential Tenant Protections and California housing laws.

Checklist

• Determine whether the proposal is a change of use, ownership conversion, full or partial closure, cessation of use, or a reduced-occupancy conversion. §§ 19.72.030(a), 19.72.070(a)
• Confirm whether 25% or more of park spaces are uninhabited. § 19.72.070(a)
• If the 25% threshold is met, file the required statement explaining known causes of reduced occupancy and any intended use change. § 19.72.070(a)
• If the director issues a reduced-occupancy conversion determination, track the CIR filing deadline stated in the notice. § 19.72.070(b)
• Prepare a CIR with home, resident, vacancy, comparable-housing, relocation-plan, service-provider, and timetable information. § 19.72.090
• Submit confidential personal resident information separately from the public-facing CIR materials. § 19.72.090(b)
• Evaluate comparable park vacancies within 20 miles and locations elsewhere in California requested by mobile home owners. § 19.72.090(c)
• Include proposed minimum relocation assistance and explain how proposed amounts were determined. § 19.72.090(f)(1)
• Identify the relocation specialist, moving companies, appraisers, fee schedules, and moving estimates required for the CIR. § 19.72.090(g)
• Give prospective new residents written conversion-status notice before executing a rental agreement. § 19.72.110
• Verify the underlying development entitlement path and parcel-specific standards with the jurisdiction. § 19.72.020

Risks & Ambiguities

Plain-English Summary

In Sunnyvale, a mobile home park cannot be treated as an ordinary redevelopment site once conversion or closure is proposed—or once 25% of spaces are uninhabited. The park owner may need to prepare a detailed CIR showing who lives there, whether homes can move, what comparable housing exists, what assistance is proposed, and when relocation will occur. §§ 19.72.070, 19.72.090

Source References

• Sunnyvale Municipal Code, § 19.72.010 — Findings and purpose.
• Sunnyvale Municipal Code, § 19.72.020 — Definitions.
• Sunnyvale Municipal Code, § 19.72.030 — Applicability.
• Sunnyvale Municipal Code, § 19.72.070 — Conversion due to reduced occupancy.
• Sunnyvale Municipal Code, § 19.72.090 — Content of CIR.
• Sunnyvale Municipal Code, § 19.72.110 — Notice to prospective residents.
• Sunnyvale Municipal Code, Chapter 19.72 source: https://ecode360.com/SU5020