From: Frederick Allebach
To: CityCouncilListPublic; Osburn, Gabe; Jones, Jessica Subject: [EXTERNAL] Public comment for Santa Rosa City Council 7/26/26 TOC (Transit Oriented Communities) policy Study Session
Date: Friday, July 24, 2026 7:39:19 AM
Fred Allebach
7/23/26
820 words, five minutes
Public comment for Santa Rosa City Council 7/26/26 TOC (Transit Oriented Communities) policy Study Session
With a national attack on DEI (diversity, equity and inclusion) and as Santa Rosa-SoCo NAACP Housing Committee Co-Chair I am working locally to advance housing equity ideals and programs. In this TOC grant program study session item, I will zero in on housing equity applications as they apply to mobile home parks (MHP) which are cited by staff as meeting the City’s scoring requirements for a TOC grant.
Housing has Three Ps: production, preservation, and protection. Few if any new mobile home parks are now being produced and otherwise, 100% AH (affordable housing) production is currently in a major downturn.
What is left for the City policy-wise on housing now is preservation and protections (1).
As
noted in the TOC study session staff report, the City administers a state mobile home rehab loan program for low-income unit owners. This is good. MHP protections are covered by the City MHP rent stabilization ordinance (RSO). The RSO has some issues that could be improved but not here.
For AH preservation, the City has a MHP Closure and Conversion Ordinance (CCO) for which staff is claiming full preservation value for TOC grant scoring. My opinion, the CCO only partially covers the preservation angle for TOC grant scoring because the City has discretion to strengthen it. The current CCO is a weaker tea policy. Also, the study session staff report does not specify if the City CCO is citing state law provisions or the City’s own CCO ordinance for:
tenant relocation assistance plan, tenant protections, and benefits and relocation payments? Some questions here by Council members and/or explanation by staff would be good.
An angle
State law AB 2782 (2020) for MHP CCOs does not spell out details and local gov’t has the discretion to do local detail work about what is included in a CCO. Lack of details leaves the City and MHP residents open to legal challenges. I suggest consulting with Legal Aid and requiring that five points be updated and strengthened in the City’s MHP CCO: 1 relocation plan, 2 closure impact report, 3 accurate assessment of resident’s income, 4 in-place value assessment of units done by a gov’t chosen consultant, 5 a finding on availability of affordable housing appropriate to income levels within the greater Santa Rosa area.
In the TOC staff report, limited staff time and funds are cited as reasons why the City can’t do much to strengthen AH policies and programs.
If MTC (Metropolitan Transportation Commission) TOC funds are in the offing, earmark 25% of these to fund staff time to directly benefit City anti-displacement strategy for MHPs with a stronger CCO ordinance. The Council can direct this earmarking.
The only study session action on AH equity for TOC grant purposes is a by-right ministerial housing ordinance. This is passive and contingent on waiting for a development application and the only likely AH would be a 15% AH inclusion in a market rate project. (2) This TOC study session’s purpose is to receive information and provide policy direction. An updated CCO is a policy item not cited by staff and one that would provide tangible equity benefits in affected TOC areas and for all City MHPs, for example in the South Santa Rosa Specific Plan (SSRSP). The Council can direct this and direct that a portion of potential TOC funds received be allocated to doing the CCO update.
The city is looking to cash in on the benefits of having MHP dense-housing within a half mile of a train stop. MHPs are cited as AH. MHPs are under attack by unscrupulous speculators in Santa Rosa and the Santa Rosa immediate area. MHP naturally-occurring AH status is under active and objective threat (3). Let’s have the City CCO ordinance beefed up through this TOC process so MHP residents are not just pawns to get a grant but the residents are inherently valued as core community members needing City protection and get updated benefits that respond to the times.
(1) Part of City housing protections is stated in the AH and Anti-Displacement Strategy which calls for specific safeguards and targeted actions: “These challenges must be addressed (in the SSRSP) to ensure that community members can remain in their homes and that new residents can find housing options at the appropriate level of affordability.”
(2)
For this by-right ministerial housing ordinance, the inclusion could be bumped up to 20% or 25%. Sonoma has a 25% inclusionary ordinance and it has objectively not deterred developers. The main deterrents are too much red tape, too many fees, NIMBYs, and CEQA.
(3)
See CCO court cases in Petaluma and Windsor. It’s not acceptable for Santa Rosa to treat these as test cases with a wait and see strategy while Santa Rosa and SSRSP MHPs are under the same exact threat now.
"We don't know where we're going but we have to stick together in case somebody gets there." Ken Kesey