Tuesday May 5, 2026 To: Legislative Policy Committee, City of Pasadena Councilmember Steve Madison, City of Pasadena, District 6 Mayor Victor Gordo, City of Pasadena CC: Assemblymember Mike Fong, D49 Senator Sasha Renée Pérez, D25 Assemblymember John Harabedian, D41 Mayor Sheila Rossi, City of South Pasadena City Council, City of South Pasadena Hilda Solis, First District, Los Angeles County Esteemed Committee Members and Public Officials, On the occasion of the City of Pasadena’s consideration of AB2329 (Fong), please see below
a
set
of
legislative
proposals
recommended
by
Caltrans
tenants
in
Pasadena
and
the
wider
710
Corridor.
These proposals respond to specific issues raised by tenants, as well
as
the
input
of
former
state
HCD
staff
and
legislative
staff
with
experience
of
Roberti
Act
sales
successfully
conducted
under
the
direct
supervision
of
David
A.
Roberti.
The first proposal is a straightforward plan to supersede Caltrans with an alternative and better-suited
authority.
The
four
subsequent
sections
highlight
essential
changes
to
the
current
law,
regulations,
and
daily
practices
of
the
program,
which,
on
their
own,
would
represent
a
considerable
improvement
for
current
tenant-purchasers
in
Pasadena,
as
well
as
South
Pasadena
and
El
Sereno.
However,
the
scope
and
detail
of
these
changes
also
serves
to
illustrate
the
underlying
need
for
new
program
leadership,
and
the
crisis
caused
by
allowing
Caltrans
to
administer
the
710
Sales
Program
in
bad
faith.
1 When the Roberti Act was first created in 1979, Caltrans was intentionally excluded from the
Los
Angeles-area
sales
program
that
followed,
which
was
administered
through
a
Department
of
Housing
and
Community
Development
(HCD)
field
office
and
a
local
housing
corporation.
At
the
time,
it
was
simply
assumed
by
the
legislature
and
the
Governor
that
Caltrans
would
not
be
able
to
follow
the
law
as
it
was
written
or
intended.
More
recently,
the
State
Auditor’s
2012
audit
report
called
for
an
inquiry
into
whether
it
would
be
more
effective
for
Caltrans
to
hand
over
management
of
the
710
Corridor
to
a
Joint
Powers
Authority,
or
a
different
State
department.
In
2021,
the
Director
and
Commissioners
of
the
California
Transportation
Commission
openly
debated
the
same
question.
Caltrans
tenants
in
the
710
Corridor
do
not
need
to
debate
this
question:
our
experience
over
the
last
two
years
(and
the
wisdom
of
six
decades)
demands
the
replacement
of
Caltrans,
and
the
return
to
a
trustworthy
process
implemented
by
HCD,
or
a
joint
powers
authority,
with
a
clear
mandate
for
completion.
Caltrans has strenuously opposed the Roberti Act since its creation, and short of declaring
the
statutes
unenforceable
(which
itself
would
be
illegal
under
Article
III
§3.5
of
the
California
Constitution),
the
Department
has
mitigated
its
language
and
obfuscated
its
intent
to
the
point
of
dysfunction.
AB2329
is
an
opportunity
to
confront
this
corrosive
process,
and
finally
put
the
710
Sales
Program
on
the
right
track.
The
experience
of
Caltrans
tenants
has
demonstrated
(and
I
believe
that
the
2026
audit
will
find)
the
necessity
of
the
following
amendments.
Respectfully,
Timothy Ivison Caltrans Tenant, Pasadena Avenue Member, United Caltrans Tenants 2 AB2329 Proposals 1. REMOVE CALTRANS (and possibly CalHFA) - Empower the Department of Housing and Community Development (HCD) — or form a Joint
Powers
Authority
(JPA)
with
the
involvement
of
HCD,
the
cities
of
Pasadena,
South
Pasadena,
and
Los
Angeles
County
District
1 —
to
complete
the
710
corridor
sales
program.
Exclude
Caltrans
from
the
daily
operation
of
the
sales
program.
[Problem:
Caltrans
regulations
and
daily
operations
are
causing
harm
to
tenants
throughout
the
corridor,
every
day.
See
below.]
- Empower the JPA/HCD to conduct household income verification, coordinate city and HUD
inspections,
hire
appraisers
and
contractors,
and
oversee
repairs.
Empower
the
JPA/HCD
to
set
“condition
adjusted
price”
(defined
in
AB2329)
according
to
appraisals,
for
all
occupied
properties.
[Problem: Caltrans has proven that it is not willing or able to effectively
manage
contractors
at
any
stage
of
the
sales
process.] - Empower the JPA/HCD to use existing HCD mortgage products or create a program-specific
mortgage
product,
and
access
the
710
Rehabilitation
fund
to
support
affordable
purchases
and
subsidize
repairs.
Allow
the
“silent
second”
to
be
subordinated
in
such
a
way
to
allow
for
limited
refinancing,
home
improvement
loans,
etc.,
for
tenant
purchasers.
[problem: CalHFA has an interagency agreement with Caltrans to fund affordable
price
sales.
A
new
agreement
could
be
signed
with
HCD
or
a
JPA,
but
HCD
also
has
its
own
loan
products,
and
the
CalHFA
loans
are
so
restrictive,
only
a
single
lender
(now
a
single
person)
in
the
state
of
California
has
been
willing
to
participate,
according
to
CalHFA.
This
suggests
the
need
for
a
review
of
the
CC&Rs.
The
current
“second
deed
of
trust”
is
not
conducive
to
wider
lender
participation
and
does
not
allow
for
later
refinancing
or
home
improvement
loans.]
2. RESOLVE ACCOUNTING DISPUTES - Remove by law or otherwise invalidate regulation §1481(b)(1)(E) regarding “positive dollar
value”
calculations.
Start
over
with
an
independent
income
verification
process.
[problem: Caltrans has illegally disqualified scores of tenants using an invented formula for
pre-screening,
rather
than
verifying
household
income.
Subject
of
current
lawsuit.]
- Establish statutory procedure for resolving disputed and illicit rental debts expediently, before
sales
negotiations.
[Problem: Caltrans has created illicit debts through accounting errors.
Caltrans
has
pursued
illicit
debt
beyond
the
statute
of
limitations,
amounting
to
harassment.
Under
§1481(l),
current
regulations
allow
for
debt
carry-over
in
affordable
price
sales,
meaning
that
some
illicit
debts
will
never
be
resolved.
Furthermore,
Caltrans
determines
which
tenants
are
allowed
to
carry-over,
causing
more
tenants
to
be
disqualified
from
purchase.]
3 3. ENFORCE CODE COMPLIANCE - Impose local code compliance for all occupied properties in the sales program. [Problem:
No
local
code
compliance
for
sales
to
current
tenants
required
under
current
regulations.
Substandard
housing
conditions
are
the
norm.]
- Impose uniform historic standards, and historic inspection/appraisal practices. [Problem:
Caltrans
has
an
alarming
lack
of
expertise
and
concern
for
historic
preservation
standards
in
each
city.
There
are
no
stated
historic
standards
for
inspection,
appraisal,
or
repair
in
either
affordable
or
market
rate
sales,
only
SB580
properties
sold
to
non-profits.]
- Specify that all rent paid by Caltrans tenants in the 710 Corridor should be directed to the
710
special
rehabilitation
fund.
Repairs
should
be
determined
by
either
city
or
HUD
inspectors.
Local
contractors
should
be
selected
by
a
JPA
or
HCD
authority.
[Problem:
Deferred
maintenance
on
the
corridor
requires
additional
resources.
Past
experiences
(and
audits)
make
it
clear
that
those
resources
should
not
be
entrusted
to
Caltrans,
nor
should
they
be
allowed
to
manage
contractors
or
evaluate
repairs.]
- Specify that each city should sign-off on property sales in their city, before Caltrans can bring
the
sale
to
the
CTC
for
final
approval.
[Problem: Caltrans has a habit of bringing
disputed
sales
to
the
CTC
as
“ready
for
approval,”
as
a
means
of
gaining
leverage
and
pushing
the
process
forward.
This
measure
would
provide
an
opportunity
to
resolve
lingering
tenant
disputes,
ensure
code
compliance,
and
to
prevent
illicit
displacement,
before
proceeding
to
CTC
approval.]
4. CLARIFY DEFINITIONS AND PRIORITIES - The law should clarify the order of sales so that current occupants have priority over vacant
property.
Homes
currently
in
escrow
should
be
resolved
on
a
clear
and
reasonable
timeline.
[Problem: Caltrans is creating the mere appearance of progress by prioritizing
empty
lots
and
vacant
properties.
This
disguises
the
fact
that
there
are
substantive
disputes
over
nearly
every
single
occupied
property.
Tenant-purchasers
have
been
informed
that
they
will
be
waiting
between
2-7
years
in
escrow
.]
- Provide ironclad, standard definition of “single-family residence.” Delete superfluous and deviant
definition
in
the
regulations
under
§1476(a)(23).
Instruct
Caltrans
to
correct
their
internal
database
and/or
split
parcels
to
provide
as
many
affordable
purchase
opportunities
for
current
occupants
as
possible.
[Problem: Caltrans is exploiting
non-standard
interpretations
of
what
is,
and
is
not,
a
single
family
residence,
in
an
effort
to
disqualify
tenants
from
purchase.
They
are
also
cynically
claiming
that
they
must
do
this
in
order
to
provide
affordable
housing
(because
selling
to
the
city
triggers
the
3-unit
affordable
housing
clause).]
- Abolish regulation §1476(a)(17) (the “net equity maturity date”) by law (or abolish Caltrans
sales
regulations
and
replace
with
JPA/HCD
regulations).
[Problem: the
4 “maturity date” is a new regulation that effectively reverses the affordability goals of the program,
threatening
to
turn
a
sale
into
a
long-term
lease.
Caltrans
is
prominently
highlighting
the
"net
equity
to
be
returned"
in
each
of
the
affordable
parcels
being
presented
to
the
CTC,
as
if
to
brag
about
all
the
money
that
they
are
saving
the
state
(when
in
fact
they
are
only
able
to
do
this
by
stealing
housing
security
from
low
income
families).
This
regulation
should
be
removed
from
all
contracts,
now
and
in
the
future.]
- Clarify priority to purchase for multifamily occupants. Correct the contradictory statutory priorities
in
Pasadena
and
South
Pasadena
and
delete
copy/pasted
language
of
SB51’s
54239.1.
(a)
into
Pasadena's
54239.5
(a)
and
South
Pasadena’s
54239.6(a).
[Problem:
Portantino
imported
language
from
Durazo’s
SB51
into
his
amendments
for
both
Pasadenas
(SB381
&
SB959).
This
created
a
confusing
situation
where
individual
households
in
multifamily
dwellings
are
offered
the
entire
parcel
(duplex,
triplex,
apartment
complex,
etc)
at
fair
market
value,
ignoring
(and
contradicting)
the
tenant’s
preexisting
legal
right
under
54237(d)(A)(ii)
to
determine
the
feasibility
of
forming
a
limited
equity
cooperative
(support
for
which
is
not
provided).]
5. PROVIDE ADVOCACY & REPRESENTATION - Transfer control of the program to a JPA/HCD, or provide legal and/or real estate advocates
from
other
State
or
City
agencies
to
represent
tenant
purchasers.
[Problem:
Caltrans
deleted
legal
aid
provisions
from
their
regulations
in
“phase
II.”
Caltrans
also
hired
Veterans
Realty
Group,
which
claims
to
represent
tenants
interests
and
will
collect
the
buyer’s
fee,
but
in
practice,
they
defer
directly
to
Caltrans
on
any
substantive
issues.]
- Empower JPA/HCD to work with the California Center for Cooperative Development or similar
agency
to
provide
counseling
and
resources
for
cooperatives,
or
viable
alternatives
for
occupants
of
multifamily
housing.
[Problem: Cooperative development is
the
primary
mechanism
for
providing
multifamily
occupants
with
ownership
rights
commensurate
with
single
family
home
purchasers
under
the
Roberti
Act.
There
is
currently
no
guidance
on
co-op
formation.
Originally,
the
Roberti
Act
led
to
the
creation
of
a
dedicated
HRE,
The
Route
2 Community
Housing
Corporation
(RT2CHC),
staffed
by
HCD
and
local
stakeholders,
which
provided
this
service,
leading
to
no
less
than
four
successful
co-ops
in
Echo
Park
and
Silver
Lake.]
5