17 REVISED
Date: October 13, 2026
To: Honorable Mayor and Members of the City Council
From: Councilwoman Tunua Thrash-Ntuk, Eighth District
Councilwoman Megan Kerr, Fifth District
Subject: Regulation and Enforcement of Unattached Trailers, Oversized Vehicles, Mobile Billboard Trailers, and Trailer-Based Commercial Activity on Public Streets.
RECOMMENDATION
Recommendation to request the City Manager, in collaboration with the City Attorney and relevant City departments, to report back to the City Council within 90 days on legally permissible and operationally feasible options to strengthen the regulation and enforcement of unattached or unhitched trailers, nuisance trailers, oversized vehicles, mobile billboard trailers, and trailer-based commercial activity on public streets, including potential Long Beach Municipal Code amendments, such as to Section 10.18.050 regarding mobile billboard advertising vehicles; traffic engineering and location-based parking restrictions; business licensing, permitting, and compliance mechanisms; administrative citations and progressive enforcement; public nuisance remedies; towing, removal, storage, and release protocols.
DISCUSSION
Trailers and oversized vehicles serve legitimate purposes for residents, contractors, and businesses, and most are used lawfully. When a trailer is left unhitched, stationary, or repeatedly stored on a public street, however, it can convert limited curb space into longterm private or commercial storage, or into a stationary advertising platform. Impacts can include lost curbside parking; reduced sight lines for drivers, bicyclists, and pedestrians; obstructed driveways; interference with street sweeping and utility work; impeded emergency access; and accumulated debris or deteriorating equipment. Enforcement is harder when the owner is difficult to identify or when trailers are moved between nearby Honorable Mayor and City Council
October 13, 2026
spaces to avoid time limits. The policy concern is not trailer ownership or temporary use, but prolonged, recurring, or unlawful use of the public right-of-way.
Long Beach already has relevant tools, but they are spread across different titles of the Municipal Code and are administered by different departments. Title 10 addresses the parking of unattached trailers.1 and restricts oversized vehicles, those exceeding 85 inches high, 80 inches wide, or 22 feet long, on residential streets without a temporary permit.2 Chapter 9.65 authorizes administrative citations, which the Department of Financial Management issues on an escalating fine schedule.3 Chapter 9.37, the Long Beach Nuisance Code, defines as a nuisance “the operation or maintenance of any business, trade or profession in violation of Title 5” and establishes a notice-andabatement process.4 The general business license requirement, however, appears in Title 3.5 The report-back should review how these provisions interact with one another and with applicable zoning, right-of-way, and safety requirements, and identify gaps that arise when a single trailer serves as a vehicle, a storage container, an advertising platform, or a source of recurring nuisance. Staff should determine whether unlicensed activity implicating Title 3 alone falls within Chapter 9.37 as written, without assuming that Chapter 9.37 authorizes every mechanism discussed below.
Trailer-based commercial activity, including advertising, storage, equipment staging, vending, service operations, warrant separate review. The Municipal Code already treats conducting an activity without a required City license or permit as a violation.6 City guidance provides that each day a violation exists constitutes a separate offense.7 Staff should evaluate whether the Code should more clearly identify when trailer-based activity, including the display of advertising in exchange for money, goods, services, or other consideration, requires a business license, a regulatory permit, or both, and which is most appropriate. Advertising trailers also warrant a direct, content-neutral approach. Section 1 Long Beach Municipal Code (LBMC) § 10.24.075 (“Parking of unattached trailers prohibited”). 2 LBMC §§ 10.24.005(B), 10.24.078, and 10.24.080, as added or amended by Ordinance No. ORD-17- 0012 (adopted August 15, 2017).
3 LBMC ch. 9.65 (“Administrative Citations and Penalties”); City of Long Beach, Department of Financial Management, Business License Division, “Administrative Citations” (fines of $100, $200, and $500 for first, second, and subsequent violations); see also Cal. Gov. Code § 53069.4. 4 LBMC § 9.37.090 (“Nuisance defined”); LBMC § 9.37.100 (“Notification of nuisance and abatement thereof”); City of Long Beach, memorandum to the Mayor and City Council, “Nuisance Violation Fine Structure and Opportunities to Expand Code Enforcement” (September 2022). 5 LBMC § 3.80.210 (“License and tax payment required”). Title 5 (“Regulation of Businesses, Trades and Professions”) governs regulatory permits for particular business types. 6 LBMC § 1.32.040 (“Failure to obtain or exceeding limits of license or permit—Grounds for suspension, revocation or denial”).
7 City of Long Beach, Department of Financial Management, “Administrative Citations” (“Each day a violation exists constitutes a separate and distinct offense.”).
Honorable Mayor and City Council
October 13, 2026
10.18.050, adopted in 2009, prohibits stopping, standing, or parking mobile billboard advertising on any street, defined to include any vehicle or wheeled conveyance that carries a sign for the primary purpose of advertising.15 Beginning in 2010, State law defined mobile billboard advertising displays as including signs carried on nonmotorized vehicles and authorized local ordinances regulating them. State law also allows cities to give notice by warning citation instead of posted signs and to remove a display after a prior warning.16 The Ninth Circuit has since upheld ordinances barring these displays from public streets as content-neutral and has separately addressed an ordinance with vehiclebased exemptions.17 Staff and the City Attorney should evaluate whether Section
10.18.050 should be updated accordingly, including its definitions, exemptions, notice and removal procedures, and penalties, so that enforcement turns on use of the public rightof-way rather than the message displayed.
Staff should also evaluate how documented compliance history may be considered in issuing, renewing, conditioning, suspending, denying, or revoking a business license.
Unlicensed operation may already be a ground for denying a license for that activity.18 Chapter 3.80 directs Financial Management to refer applications to City departments, prohibits issuance of a license where a department determines that the business or its proposed location will not comply with applicable laws, and authorizes suspension or revocation, after notice and a hearing, when a licensee fails to comply with the Municipal Code.19 Title 5 separately governs regulatory permits.20 The City Attorney should advise how these provisions apply to trailer-based businesses, including whether a business 15 LBMC § 10.18.050 (“Mobile billboard advertising vehicle prohibited”), subsections (C) and (D); Ordinance No. ORD-09-0021, § 31 (2009).
16 Cal. Veh. Code § 395.5 (defining a “mobile billboard advertising display” as “an advertising display that is attached to a mobile, nonmotorized vehicle, device, or bicycle, that carries, pulls, or transports a sign or billboard, and is for the primary purpose of advertising”); § 21100 (authorizing local ordinances regulating mobile billboard advertising displays); § 22651(v) (notice by warning citation in lieu of posted signs; removal after a prior warning citation); Assem. Bill No. 2756 (2009–2010 Reg. Sess.), Stats. 2010, ch. 615. Subdivision designations within § 21100 have been renumbered over time and should be confirmed by the City Attorney.
17 Lone Star Security & Video, Inc. v. City of Los Angeles, 831 F.3d 1192 (9th Cir. 2016) (upholding ordinances prohibiting the parking of nonmotorized mobile billboard advertising displays on public streets as content-neutral time, place, and manner regulations); Boyer v. City of Simi Valley, 978 F.3d 618 (9th Cir. 2020) (applying strict scrutiny to a mobile billboard parking ordinance that exempted certain vehicle types).
18 LBMC § 1.32.040.
19 LBMC §§ 3.80.421.1; 3.80.421.5 (the Director of Financial Management “shall not issue such license” where a department rejects an application because the business or its proposed location “will not so comply with applicable laws and ordinances”); 3.80.429.1 (suspension or revocation after ten days’ written notice and hearing).
20 LBMC § 5.06.020 (grounds for suspension or revocation; written notice and hearing; one-year bar on reapplication following revocation or denial).
Honorable Mayor and City Council
October 13, 2026
proposing to operate in violation of Title 10 may be denied a license on that basis, and whether objective criteria, such as repeated trailer parking, mobile billboard, or oversizedvehicle violations or unpaid citations, should be codified to guide these decisions. No prior violation should be presumed to require an adverse action. Any licensing consequence should be evaluated for notice, opportunity to cure, hearing and appeal rights, evidentiary standards, and proportionality. Licensing standards that apply to expressive activity must rest on objective criteria rather than official discretion.27 For businesses with a documented pattern of serious or repeated violations, staff should evaluate whether a probationary, conditional, or limited-term license would be an appropriate tool. Components may include a shorter term, such as six months; periodic compliance reviews and inspections where authorized; conditions requiring compliance with Title 10 parking provisions and limiting commercial storage on public streets; and progressive consequences, from temporary suspension to revocation after an established pattern of serious noncompliance, with a reasonable waiting period before reapplication where legally justified. The City’s tobacco retail, sidewalk vending, and cannabis permit frameworks offer procedural reference points,28 but only as analogies; each rest on its own legal basis, and the City Attorney should determine whether any comparable mechanism is permissible for trailer-based businesses.
Additional tools may be needed when the same trailer, business, or block repeatedly generates violations. State law permits local authorities to restrict parking on designated streets once adequate signs are posted,29 but otherwise limits local regulation of matters the Vehicle Code covers.30 Within those limits, staff should evaluate location- and timebased restrictions grounded in objective criteria such as roadway width, vehicle dimensions, sight distance, driveway and emergency access, and documented recurring nuisance activity. Staff should assess how Chapter 9.37 may apply to recurring trailer conditions and which remedies are available; assessments or liens should be considered only where independently authorized by law.31 Staff should separately evaluate whether a location-based licensing restriction could be legally permissible where illegal trailerbased commercial activity recurs at one location, drawing on the City’s cannabis framework only for procedural concepts and subject to City Attorney analysis of property 27 City of Lakewood v. Plain Dealer Publishing Co., 486 U.S. 750 (1988). 28 LBMC ch. 5.81 (“Tobacco Retail Permit”); LBMC ch. 5.73 (Sidewalk Vending); LBMC chs. 5.90 and
5.92 (cannabis businesses); Cal. Gov. Code §§ 51038–51039. 29 Cal. Veh. Code § 22507(a).
30 Cal. Veh. Code § 21(a) (local authorities may not enact or enforce ordinances on matters covered by the Vehicle Code unless expressly authorized).
31 See, e.g., Cal. Gov. Code §§ 38773.1, 38773.5 (nuisance abatement costs as special assessments or liens against a parcel). Whether any such mechanism can attach to conditions arising on the public rightof-way requires City Attorney review.
Honorable Mayor and City Council
October 13, 2026
rights, due process, proportionality, State law, and effects on subsequent owners and tenants. Finally, staff should recommend towing protocols covering grounds for removal, notice, signage, waiting periods, opportunities to cure, immediate hazards, abandoned or unregistered trailers, costs, and release, consistent with State removal and post-storage hearing requirements and constitutional limits on vehicle seizures.37 Effective regulation will require coordinated enforcement rather than reliance on one department or code section. The report-back should identify a lead department; the existing authority of departments responsible for business licensing, parking, traffic engineering, code enforcement, public safety, towing, collections, and legal review, potentially including Financial Management, Public Works, Community Development, and the Police Department; overlaps and gaps; complaint routing; repeat-violation tracking; escalation criteria; staffing and technology needs; and recommended Municipal Code amendments. The report-back should also include available citywide data on trailerrelated complaints, citations, and tows to establish a factual record for any Code amendment. The privilege of doing business in Long Beach should be connected to compliance with City law, and enforcement should fairly distinguish lawful temporary trailer use from chronic street storage, nuisance conditions, or unlawful commercial activity. The intended result is a clear, coordinated, and legally defensible framework that protects neighborhood quality of life, preserves public access to curb space, improves traffic safety, supports legitimate businesses, provides fair notice and due process, and gives staff practical tools to address repeat violations.
This matter has been reviewed by Budget Manager Rebecca Bernstorff on October 7, 2026.
FISCAL IMPACT
This recommendation requests City Manager, City Attorney, and relevant departments to report back in 90 days on legally permissible and operationally feasible options to strengthen the regulation and enforcement of unattached or unhitched trailers, nuisance trailers, oversized vehicles, mobile billboard trailers, and other trailer-based commercial activities. This recommendation to provide a feasibility analysis and present options back to City Council is anticipated to have a moderate impact on staff hours beyond the normal budgeted scope of duties and is in line with existing City Council priorities. There is no local job impact associated with this recommendation.
37 Cal. Veh. Code § 22651 (enumerated circumstances for vehicle removal); § 22852 (post-storage hearing); Brewster v. Beck, 859 F.3d 1194 (9th Cir. 2017); Miranda v. City of Cornelius, 429 F.3d 858 (9th Cir. 2005).
Honorable Mayor and City Council
October 13, 2026
SUGGESTED ACTION
Approve recommendation.
Respectfully submitted,
Tunua Thrash-Ntuk, Councilwoman, Eighth District
Megan Kerr, Councilwoman, Fifth District