Cotati City Council
Agenda Staff Report
Item type: CONSENT CALENDAR (ACTION)
To: City Council
Subject: SUPPORT OF AB 2596
Date: April 14, 2026
Written by: Damien O'Bid, City Manager
Recommendation
It is recommended that the City Council adopt a motion authorizing the Mayor to send a letter of support for AB 2596 to our state legislators, substantially in the form attached, and authorize the Mayor and City Manager to advocate with Cal Cities and legislators to support this bill.
Background
Mobilehome parks are an important source of housing for Cotati residents, including seniors and households with fixed or lower incomes. State legislation affecting resident protections, park operations, and fees imposed under mobilehome and manufactured housing laws can directly affect housing stability and affordability in Cotati.
Assembly Bill (AB) 25961 (Gipson) would add Civil Code Section 798.14.5, to the Mobilehome Residency Law, to clarify that, if a mobilehome park operator or owner fails to comply with federal law or other federal requirements imposed in connection with a federally approved housing program, the operator or owner must nevertheless ensure ongoing compliance with applicable state laws and local ordinances, including the Mobilehome Residency Law and specified provisions of the Unruh Civil Rights Act2. In other words, the bill would clarify that noncompliance with federal program requirements does not displace otherwise applicable state and local protections.
1 https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202520260AB2596 2 The Unruh Civil Rights Act is a California law that prohibits businesses from engaging in unlawful discrimination against all persons.
Cotati has also adopted a Senior Mobilehome Park Overlay Zone, to preserve a variety and balance of housing types within the city and to provide assurances that existing senior mobilehome parks remain available to seniors. The Overlay applies to the City’s Countryside senior mobilehome park and includes requirements relating to senior occupancy, park identification, ongoing verification and annual certification of compliance, and enforcement through the Cotati Municipal Code. These local requirements reflect the City’s interest in preserving senior mobilehome housing stock and ensuring continued compliance with local protections applicable to those parks.
On April 6, 2026, the City of Petaluma agendized and authorized support for AB 2596. At this time, Cal Cities has a position of ”watch” on this bill.
Analysis/Discussion
AB 2596 would help preserve clarity and continuity in the legal protections that apply within mobilehome parks. The bill would make clear that noncompliance with federal requirements tied to a federally approved housing program does not displace ongoing obligations under California law and local ordinances. This clarification has practical significance for Cotati because the City has adopted a Senior Mobilehome Park Overlay Zone intended to preserve important senior mobilehome housing stock and to help ensure that senior mobilehome parks remain available to seniors. This bill would help clarify that, even where a park operator or owner fails to comply with federal law or other federal requirements imposed in connection with a federally approved housing program, applicable state laws and local ordinances remain in effect and enforceable.
That clarification would reinforce the continued enforceability of local protections such as Cotati’s overlay requirements relating to senior occupancy, identification of senior parks, and compliance verification. The City is currently involved in two lawsuits concerning the Senior Mobilehome Park Overlay Zone, and AB 2596 may help clarify that local ordinances such as Cotati’s remain enforceable notwithstanding noncompliance with federal program requirements.
Financial Considerations
There are no direct financial considerations for sending a letter of support on AB 2596 to Assemblymember Gipson.
Environmental Issues
Where it can be determined with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the activity is not subject to CEQA review.
This general rule can be applied to activities which could be subject to the CEQA process, but which logic dictates should not be subject to CEQA review. Therefore, based on the information provided above, the proposed resolution is exempt from CEQA pursuant to Section 14.03.021 of the CEQA Guidelines in that there is no possibility that the activity may have a significant impact on the environment.