Sonoma City Council
April 15, 2026

City Council:

Ron Wellander, Mayor
Sandra Lowe, Vice Mayor
Jack Ding
Patricia Farrar-Rivas
John Gurney

REGULAR MEETING AGENDA

OF THE SONOMA CITY COUNCIL
City Council Chambers, 177 First Street West
Wednesday, April 15, 2026
https://us06web.zoom.us/j/84876986131
6:00 PM Regular Meeting

ACCESSING PUBLIC MEETINGS
As a public service to the community, City Council meetings are held in-person, and viewable through a live webcast on the City’s CivicWeb Portal at https://sonomacity.civicweb.net/Portal/Video.aspx, City of Sonoma YouTube channel at https://www.youtube.com/channel/UChZjUrg2rNLYxTgQHhFy-Tg, and televised on Comcast Cable Channel 27. Members of the public can also view the meeting via ZOOM, at https://us06web.zoom.us/j/84876986131.

If a technical issue arises with Zoom video or the listening phone dial-in option, the City Council meeting will continue unless a Council Member is participating remotely pursuant to the provisions of Government Code Section 54953.8.3.

Members of the public who wish to address the Council by providing public comments during the meeting may do so in-person in the Council Chambers at 177 First Street West, where the meeting is being publicly held. As an alternative, members of the public may also provide written public comment submitted via the City’s online Public Comment form at https://sonomacity.civicweb.net/Portal/CitizenEngagement.aspx or by email to:
[email protected]
PROCESS FOR COMMENTS FROM THE PUBLIC: There will be two opportunities for members of the public to address items not appearing on the agenda. The early public comment period, Agenda Item 1, will be limited to ten speakers. Each speaker will be allowed up to two minutes. Speakers who do not have an opportunity to speak during the first public comment section will be allowed to make their comments during the later public comment period, Agenda Item 10, provided there were more than 10 people in the first public comment section. When the Mayor announces these agenda items, please form a line to speak.

In the event a Council Member participates remotely for just cause Government Code Section 54953.8.3, the City will allow for public comment through the Zoom link.

In accordance with the Americans with Disabilities Act, if you need special assistance to participate in this meeting, please contact the City Clerk (707) 933-2216. Notification 48 hours before the meeting will enable the City to make reasonable arrangements to ensure accessibility to this meeting.

Be Courteous - TURN OFF your cell phones and watches while the meeting is in session.

The City Council may discuss and/or take action on any or all of the items listed on the agenda irrespective of how the items are described.

No new items will begin after 9:00pm unless a majority of the members present vote to allow the items to be heard.

Page

REGULAR MEETING

CONVENE, CALL TO ORDER & PLEDGE OF ALLEGIANCE
ROLL CALL (Gurney, Ding, Farrar-Rivas, Lowe, Wellander)

REPORT ON CLOSED SESSION

APPROVAL OF THE AGENDA

1. COMMENTS FROM THE PUBLIC
At this this time members of the public may address the Council on matters not listed on this agenda, but which are within the subject matter jurisdiction of the Council. This public comment period will be limited to ten speakers. Each speaker will be allowed up to two minutes.

Speakers who do not have an opportunity to speak during the first public comment section will be allowed to make their comments during the later public comment period, Agenda Item 10, provided there were more than 10 people in the first public comment section. When the Mayor announces these agenda items, please form a line to speak.

Under State Law, unless otherwise permitted under the Ralph M. Brown Act, the merits of the matters presented under this item cannot be discussed or acted upon by the City Council at this time. For items appearing on the agenda, the public will be invited to make comments at the time the item comes up for Council consideration. Please begin by stating your name.

2. MEETING DEDICATIONS

3. COUNCILMEMBERS’ REPORTS AND COMMENTS
Committee Reports - Council Members are appointed to various boards and committees - local, county-wide and regional. Any updates from a council member will be shared at this time.

A list of all appointments is available on our City Website for easy reference.

Council Members may also make appointments to city commissions at this time.

4. INTERIM CITY MANAGER COMMENTS AND ANNOUNCEMENTS

5. CITY ATTORNEY COMMENTS

6. PRESENTATIONS

6.1: Proclaiming April 2026 as Parkinson's Disease Awareness Month

7. CONSENT CALENDAR – CITY COUNCIL
All items listed on the Consent Calendar are considered to be routine and will be acted upon by a single motion. There will be no separate discussion of these items unless members of the Council or staff request specific items to be removed for separate action.

7.1: Waive further reading and Authorize Introduction and/or Adoption of Ordinances by Title Only. (Standard procedural action - no backup information provided)

7.2: Accept the Minutes from the Regular Meeting of March 30, 2026 (Monique Saviez Burns, CPMC, CMC, Deputy City Clerk)
RECOMMENDATION: Accept the minutes.

03.30.2026 Regular Meeting Minutes
5 - 7

7.3: Accept the Expenditure Report for the Month of March 2026 (Ryan Kodama, Accounting Manager)
RECOMMENDATION: Accept the report.

Agenda Report - Expenditure Report March 2026 - Pdf
8 - 15

7.4: Adopt a Resolution Authorizing the Interim City Manager to Execute a Contract Amendment to the Contract with GHD, Inc. for the Design of the Citywide 16 - 34

Bicycle and Pedestrian Improvements Project (CIP T-6), In An Amount Not to Exceed $49,857, For a Total Contract Value of $432,287 (Ashley Cotter, PW Admin & Project Manager and Mike Berger, Public Works Director) RECOMMENDATION: Adopt the resolution.

Agenda Report - Go Sonoma Design Contract Amendment - Pdf

7.5: Adopt an Ordinance Amending Sonoma Municipal Code Section 13.20.010 and Finding the Ordinance Exempt from the California Environmental Quality Act (CEQA) Pursuant to Section 15061(b)(3) - General Rule - of the CEQA Guidelines (Ashley Cotter, PW Admin & Project Manager and Mike Berger, Public Works Director)
RECOMMENDATION: Adopt the ordinance.

Agenda Report - Cross Connection Control Ordinance Adoption - Pdf 35 - 39

7.6: Adopt a Resolution Authorizing a Budget Amendment to Increase One Time Expenditures from the Long-Term Building Maintenance Fund by $26,980 for Police Station Maintenance and Repairs (Ashley Cotter, PW Admin & Project Manager and Mike Berger, Public Works Director)
RECOMMENDATION: Adopt the resolution.

Agenda Report - Budget Adjustment for Long-Term Building Maintenance Fund Expenditures - Pdf
40 - 43

7.7: Adopt a Resolution Authorizing a Budget Adjustment to Move Funds from Water Enterprise Fund General Supplies to the Vehicle Replacement Fund for the Purchase of a Backhoe Thumb Attachment (Ashley Cotter, PW Admin & Project Manager and Mike Berger, Public Works Director) RECOMMENDATION: Adopt the resolution.

Agenda Report - Budget Adjustment for Large Equipment Purchase - Pdf 44 - 49

8. PUBLIC HEARING

9. REGULAR CALENDAR – CITY COUNCIL
(Matters requiring discussion and/or action by the City Council)

9.1: Study Session to Discuss Draft Ordinance for Mobilehome Park Closures and Conversions Under the City of Sonoma Municipal Code and Recent Legislative Changes Under AB 2782 and SB 610 (Jennifer Gates, AICP, Community Development Director)
RECOMMENDATION: Provide direction to City staff on ordinance changes.

Agenda Report - Study Session Mobile Home Ordinance - Pdf 50 - 112

10. SECOND PUBLIC COMMENT (ONLY REQUIRED IF EARLIER PUBLIC SPEAKERS

REMAIN)
At this time members of the public who did not have the opportunity to speak during the early comment period may address the Council on matters not listed on this agenda, but which are within the subject matter jurisdiction of the Council. Each speaker will be allowed up to two minutes. Please form a line to speak.

Under State Law, unless otherwise permitted under the Ralph M. Brown Act, the merits of the matters presented under this item cannot be discussed or acted upon by the City Council at this time. For items appearing on the agenda, the public will be invited to make comments at the time the item comes up for Council consideration. Please begin by stating your name.

11. ADJOURNMENT
I do hereby certify that a copy of the foregoing agenda was posted on the City Hall bulletin board as legally required.

Monique Saviez Burns, CPMC, CMC, Deputy City Clerk

Copies of all staff reports and documents subject to disclosure that relate to any item of business referred to on the agenda are normally available for public inspection the Wednesday before each regularly scheduled meeting at City Hall, located at No. 1 The Plaza, Sonoma CA. Any documents subject to disclosure that are provided to all, or a majority of all, of the members of the City Council regarding any item on this agenda after the agenda has been distributed will be made available for inspection at the City Clerk’s office, No. 1 The Plaza, Sonoma CA during regular business hours. If you challenge the action of the City Council in court, you may be limited to raising only those issues you or someone else raised at the public hearing described on the agenda, or in written correspondence delivered to the City Clerk, at or prior to the public hearing.

CLOSED SESSION: If action is taken during a Closed Session meeting and is required to be reported the Council will return to Open Session and report out immediately. However, if they are unable to do so due to time constraints, they will report out at the immediately following Regular Council Meeting under "REPORT ON CLOSED SESSION".

MOTION FOR RECONSIDERATION: A Council Member voting with the majority on any item appearing on this agenda may move for reconsideration of that vote provided the motion is in conformance with the rules adopted by the Council governing such motions.

In accordance with the Americans with Disabilities Act, if you need special assistance to participate in this meeting, please contact the City Clerk (707) 933-2216. Notification 48-hours before the meeting will enable the City to make reasonable arrangements to ensure accessibility to this meeting.

NOTE: Portions of this document may have been drafted with support from AI-based tools, consistent with City of Sonoma policy on use of artificial intelligence. All information represented in this document has been reviewed by City of Sonoma staff.

City Council:

Ron Wellander, Mayor
Sandra Lowe, Vice Mayor
Patricia Farrar-Rivas
John Gurney
Jack Ding

REGULAR MEETING MINUTES

OF THE SONOMA CITY COUNCIL
City Council Chambers
177 First Street West
Monday, March 30, 2026

6:00 PM Regular Meeting
Regular Meeting Minutes, March 30, 2026

REGULAR MEETING

CONVENE, CALL TO ORDER, & PLEDGE OF ALLEGIANCE
Mayor Wellander called the meeting to order at 6:02 p.m.

ROLL CALL:

PRESENT: Mayor Wellander, Vice Mayor Lowe, Council Member Farrar-Rivas, Council Member Gurney, and Council Member Ding

CLOSED SESSION
There was no Closed Session held.

APPROVAL OF AGENDA
Motion by Vice Mayor Lowe, seconded by Council Member Farrar-Rivas, to approve the agenda as presented. Motion carried unanimously by voice vote.

1. COMMENTS FROM THE PUBLIC
None.

2. MEETING DEDICATIONS
None.

3. COUNCILMEMBERS’ REPORTS AND COMMENTS
Council Member Farrar-Rivas reported attending the Special Finance Committee meeting on March 24, 2026, the No Kings March on March 28, 2026, and the North Bay Watershed Association meeting on March 30, 2026. She also recognized and celebrated the “Limit Line.” In addition, she shared that she had her final weekly meeting with outgoing City Manager David Guhin and thanked him for his time and service.

Council Member Ding reported attending the Zero Waste Sonoma meeting on March 19, 2026, the Sonoma County Mayors and Councilmembers Association Legislative Committee meeting on March 20, 2026, the CalCities Policy Committee meeting on March 26, 2026, and the Sonoma Valley Groundwater Sustainability Committee meeting on March 30, 2026.

Mayor Wellander reported participating in the Cemetery Clean Up event on March 21, 2026, the Affordable Housing Roundtable meeting on March 23, 2026, and a Homeless Coalition Board meeting.

4. CITY MANAGER COMMENTS AND ANNOUNCEMENTS
City Manager Guhin thanked the Public Works team for installing ADA ramps throughout the City. He also reminded the public of several upcoming events: Local Fest 2026 on April 1, 2026; the annual Easter Egg Hunt featuring the Easter Bunny at the Plaza on April 3, 2026; and the Treasure Artist Reception on April 16, 2026, at the Amphitheater on the Plaza. In addition, he noted that the Discretionary Funding Application period remains open through April 3, 2026, and that the deadline for the Earth Day Photo Contest is also April 3, 2026. He concluded by thanking the Council and Staff, noting that this was his final meeting as City Manager.

5. CITY ATTORNEY COMMENTS
None.

6. PRESENTATIONS
Item 6.1: Celebrate Sonoma - Presentation in Honor of Tommy Thomsen Public Comment: Steve Page, Karen Collins, Rod Marymoor, Janice King, Ronny Groome, Val Haraszthy, and Dave Aguilar.

7. CONSENT CALENDAR – CITY COUNCIL
Motion by Vice Mayor Lowe, seconded by Council Member Farrar-Rivas, to approve the Consent Calendar as presented. Motion carried unanimously.

Agenda Item #7.2:

Regular Meeting Minutes, March 30, 2026
Item 7.1: Waive further reading and Authorize Introduction and/or Adoption of Ordinances by Title Only. (Standard procedural action - no backup information provided) Item 7.2: Accept the Minutes from the Regular Meeting of March 18, 2026 (Monique Saviez Burns, CPMC, CMC, Deputy City Clerk)
Action: The minutes were accepted.

Item 7.3: Adopt a Resolution Authorizing Temporary Use of City Streets for the July 4th Parade on Friday, July 4, 2026 (Lisa Janson, Senior Management Analyst) Action: Adopted as Resolution 10-2026.

Item 7.4: Adopt a Resolution Authorizing Temporary Use of City Streets by Motiv Servicing for the Napa to Sonoma Wine Country Rosé 5K on Saturday, July 25, 2026, and Half Marathon on Sunday, July 26, 2026 (Lisa Janson, Senior Management Analyst)
Action: Adopted as Resolution 11-2026.

Item 7.5: Introduce an Ordinance Amending Sonoma Municipal Code Section 13.20.010 and Finding the Ordinance Exempt from the California Environmental Quality Act (CEQA) Pursuant to Section 15061(b)(3) - General Rule - of the CEQA Guidelines (Ashley Cotter, PW Admin & Project Manager & Mike Berger, Public Works Director) Action: The ordinance was introduced.

Item 7.6: Adopt a Resolution Approving the Specifications for the Fryer Creek Drive, Pickett Street, and Nash Street Pavement Rehabilitation Project, CIP T-5; Project No. 2601, Accepting Bids, Awarding a Contract to Team Ghilotti and Authorizing the City Manager to Execute a Construction Contract in the Amount of $540,997.00, and Further Authorizing the City Manager to Approve $54,099.70 (10%) in Contingency (Ashley Cotter, PW Admin & Project Manager & Mike Berger, Public Works Director) Action: Adopted as Resolution 12-2026.

Item 7.7: Adopt a Resolution Approving the Second Amendment to the Amended and Restated City Attorney Retainer Agreement (David Guhin, City Manager) Action: Adopted as Resolution 13-2026.

Item 7.8: Adopt a Resolution Authorizing the City Manager to Execute a Professional Services Agreement with Bob Murray & Associates for an Amount Not to Exceed $29,900 to Conduct an Executive Recruitment for the Position of City Manager and Authorize the City Manager to Sign the Agreement (David Guhin, City Manager) Action: Adopted as Resolution 14-2026.

8. PUBLIC HEARING
None.

9. REGULAR CALENDAR – CITY COUNCIL
Item 9.1: Adopt a Resolution Authorizing the City Manager to Execute a Three-Year Contract Amendment with Flock Safety for Automated License Plate Reader (ALPR) Products, In An Amount Not to Exceed $50,500 Annually, as Previously Approved in FY 23/24, 24/25, and 25/26 Budget (Brandon Cutting, Police Chief) Action: Adopted as Resolution 15-2026.

Motion by Vice Mayor Lowe, seconded by Council Member Ding, to Adopt a Resolution Authorizing the City Manager to Execute a Three-Year Contract Amendment with Flock Safety for Automated License Plate Reader (ALPR) Products, In An Amount Not to Exceed $50,500 Annually, as Previously Approved in FY 23/24, 24/25, and 25/26 Budget. Motion carried unanimously.

Item 9.2: Adopt a Resolution Authorizing the City Manager to Execute a Contract with Portola for $194,091.20 for Facility Security Upgrades (CIP BF-11), Authorizing $19,409.12 (10%) in Contingency, and Authorizing a Budget Amendment for $74,250.32 in Additional Expenditures from the Long-Term Building Maintenance Fund (Ashley Cotter, PW Admin & Project Manager & Mike Berger, Public Works Director) Action: Adopted as Resolution 16-2026 and Resolution 17-2026.

Motion by Council Member Ding, seconded by Council Member Farrar-Rivas, to Adopt a Resolution Authorizing the City Manager to Execute a Contract with Portola for $194,091.20 for Facility Security Upgrades (CIP BF-11), Authorizing $19,409.12 (10%) in Contingency, and Authorizing a Budget Amendment for $74,250.32 in Additional Expenditures from the Long-Term Building Maintenance Fund. Motion carried unanimously.

Item 9.3: Adopt a Resolution Approving an Employment Agreement Appointing Cristine Alilovich as Interim City Manager, Effective April 6, 2026, and Authorizing the Mayor to Sign the Agreement (David Guhin, City Manager)
Action: Adopted as Resolution 18-2026.

Agenda Item #7.2:

Regular Meeting Minutes, March 30, 2026
Public Comment: Robert Demler
Motion by Council Ember Farrar-Rivas, seconded by Vice Mayor Lowe, to Adopt a Resolution Approving an Employment Agreement Appointing Cristine Alilovich as Interim City Manager, Effective April 6, 2026, and Authorizing the Mayor to Sign the Agreement. Motion carried unanimously.

10. SECOND PUBLIC COMMENT (ONLY REQUIRED IF PUBLIC SPEAKERS REMAIN FROM ITEM 2.0) None.

11. ADJOURNEMENT
Mayor Wellander adjourned the meeting at 8:18 p.m.

I HEREBY CERTIFY that the foregoing minutes were duly and regularly received at a regular meeting of the Sonoma City Council on the 15th of April 2026.
______________________________________________
Monique Saviez Burns, CPMC, CMC, Deputy City Clerk
Agenda Item #7.2:

City of Sonoma
Agenda Item Summary
Meeting: City Council - 15 Apr 2026
Department
Finance
Staff Contact
Ryan Kodama, Accounting Manager
Agenda Item Title
Accept the Expenditure Report for the Month of March 2026 Summary
The attached report shows disbursements for the month of March 2026.

Fund 630 (Grants Restricted) expended $19,736, which was for the North Bay Water Quality Partnership Project. This project is a partnership with other municipalities and is partially funded by an EPA grant. The City of Sonoma is the intermediate (lead) agency and receives funding from the EPA to disperse to the other agencies in the partnership project as reimbursement for their approved expenses. As this is a pass-through grant, the expense is not budgeted. The city’s participation in the project was authorized by Resolution #83-2024.

A detailed list of disbursements is available at the web site indicated at the bottom of the report.

Recommended Council Action
Accept report.

Alternative Actions
Council discretion.

Financial Impact
Monthly Payables Report, March 2026
Environmental Review Status
Environmental Impact Report
Negative Declaration
Exempt
Not Applicable
Approved/Certified
No Action Required
Action Requested
Attachments
Disbursement Report - March 2026
Resolution 83-2024
Fund Glossary
Alignment with Council Goals:

Agenda Item #7.3:

DISBURSEMENT REPORT MARCH 2026
Year to Date Monthly Year to Date Annual Percent of Fund Fund Revenue Expenditure Expenditure Budget Budget Balance General Fund 30000 18,332,646 29,543,090 62% 13,514,923 City Council 41001 13,523 87,797 150,401 58%
City Clerk 41002 30,249 341,380 463,743 74%
City Manager 41003 57,073 915,597 1,265,317 72%
Finance 41004 25,578 580,919 903,151 64%
City Attorney 41005 3,825 177,740 285,000 62%
Police 42101 513,408 5,138,027 7,778,032 66%
Fire 42201 587,613 6,274,290 8,122,755 77%
Public Works - Admin 43020 42,632 413,224 641,510 64%
Public Works - Streets 43022 123,735 1,112,538 1,498,358 74% Parks & Recreation 43023 88,502 1,157,933 1,869,606 62% Planning 43030 150,111 1,095,114 2,019,937 54%
Building 43040 59,273 715,228 1,221,111 59%
Community Activities 43101 86,726 891,284 1,223,734 73% Successor Agency 43199 3,851 92,913 184,500 50%
Non-Departmental 43200 83,256 619,824 829,040 75%
Emergency Response 43201 4,576 52,862 117,189 45%
Public Information 43203 11,695 137,871 208,492 66%
Transfers 43999 - 1,022,615 1,220,000 84%
Total General Fund Expenditures 1,885,626 20,827,155 30,001,876 69% Other Funds
Public Education & Gov 202 18,668 - 18,318 - 0% (23,663) Strong Motion 203 203 - - - 0% 6,981
Asset Forfeiture 211 398 - - - 0% 17,769
SLESF C.O.P.S Grant 217 111,938 - 120,000 120,000 100% 408,083 Bond Property 220 - - - - 0% (19,144)
Maysonnave Property 221 - - - - 0% (15,195)
Schell Drainage 234 4,833 - - - 0% 73,916
Abandoned Vehicle 240 500 1,342 8,412 15,000 56% (37,900) Streets/Transport/Drain 301 301,748 39,721 205,837 300,000 69% 126,967 Gas Tax 302 223,314 3,726 146,175 414,545 35% 923,395
SB-1Road Maint 303 183,366 - 104,200 204,200 51% 740,353 Parks & Facilities 304 631,665 1,010 80,628 625,000 13% 633,866 Fire Measure H 312 392,841 - 193,104 708,000 27% 199,737 Transportation Measure M 313 116,267 - 200,000 200,000 100% 357,423 Parks-In-Lieu/Quimby Act 314 18,864 - - 225,000 0% 18,864 Parks Measure M 315 93,180 - - 84,999 0% 757,915
Prop 68 Parks 316 - - - - 0% (162,690)
Successor Agency 391 1,310,504 - 1,255,003 2,599,306 48% (17,758,613) CREBS 495 - - - - 0% -
2012 POB 498 29 - - - 0% (5,202)
Cemeteries 501 321,130 19,884 283,580 791,396 36% (2,152,070) Cemetery Replacement 502 - - - - 0% 288,613
Cemetery Endowment 504 30,702 - 47,000 47,000 100% 726,633 Water Utility 510 6,103,074 287,943 4,888,699 7,396,976 66% 10,798,064 Water CIP 512 727,711 40,450 45,622 655,000 7% 1,149,178 Water Equip Replacement 513 16,595 - - - 0% 742,853
EMS Equip Replacement 521 1,947 - - - 0% 86,597
Mgmt Information Srvcs 601 448,123 42,870 406,619 613,288 66% 431,022 Vehicle Replacement 603 788,771 - 433,814 671,985 65% 1,305,878 Insurance 604 1,161 - - - 0% 51,827
Building Maintenance 610 469,464 34,650 235,376 289,915 81% 3,819,922 Computer Loan 614 1,493 - - - 0% 66,540
Hardscape Maint 615 607 - - - 0% 27,031
Admin Hearings 620 196 - - - 0% 1,020
Grants Restricted 630 28,030 19,736 19,736 - 0% 39,839
Culture Fine Art 701 280 - - - 0% 12,606
Tree Trust 702 441 - - - 0% 19,853
Public Art 703 26,512 - 766 35,000 2% 96,603
Pool Scholarship 715 4,891 - 25,000 25,000 100% 184,751 Senior Housing 731 4,635 - 25,454 25,454 100% 195,711
Housing Trust 732 421,138 - 250,000 250,000 100% 2,727,734 IGT 796 1,166,097 - 1,180,400 1,585,968 74% 1,993,782
SVFRA Operations 798 17,223 - - - 0% 610,481
TOTAL 32,321,185 2,376,957 31,000,899 47,884,908 65%
Monthly disbursement detail reports can be found at www.sonomacity.org/financial-documents Agenda Item #7.3:

Agenda Item #7.3:

City of Sonoma

CITY OF SONOMA

FUND DESCRIPTIONS
General Fund (Fund 100): The general operating fund of the City is used to account for all financial resources except those that require accounting in another fund.

Public Education & Government (Fund 202): Special revenue fund accumulates fees from telecommunication operators to support public, educational and government telecommunications, including broadcasting public meetings. Costs associated with acquiring equipment, renovating and constructing PEG-related facilities and broadcasting are paid from this fund.

Strong Motion (Fund 203): Accounts for State of California "strong motion" fees paid by building permit applicants. Funds are paid regularly to State Department of Conservation.

Asset Forfeiture (Fund 211): Accounts for funds received from seizure and forfeiture of assets that represent the proceeds of, or were used to facilitate, crime. Funds are expended according to legal restrictions.

SLESF (Supplemental Law Enforcement Services Fund)/COPS (Citizen Option for Public Safety) (Fund 217): Supplemental law enforcement funding is distributed by the State to the County which passes through the funding to local agencies. These funds have traditionally been used to support the costs of the Community Service Officer staff in the Police Department.

Bond Property (Fund 220): The Bond Property, a six acre parcel located at 19990 Seventh Street, was bequeathed to the city in 1977 by Pauline Bond, for the purpose of “creating and maintaining a public park” and is now home to the Sonoma Garden Center. The parcel is leased to the Sonoma Ecology Center who maintains the property and administers public programs at the site. Not Currently Active Fund Maysonnave Property (Fund 221): The Maysonnave Property, consisting of two parcels of land totaling

1.44 acres located at 291 and 289 First Street East, was bequeathed to the city in 1990 by Henri Maysonave for the purpose of “creating and maintaining a public park”. The parcel at 291 First Street East is leased to the League for Historic Preservation who maintains the property and administers public programs at the site while the parcel identified as 289 First Street East is leased to the Valley of the Moon Petanque Club, which maintains the property and administers public programs at that site. Not Currently Active Fund
Schell Drainage (Fund 234): Accounts for funds used for tracking of mitigation fees for specific projects.

Not Currently Active Fund
Abandoned Vehicle (Fund 240): Accounts for funds received from the Sonoma County Abandoned Vehicle Abatement (SCAVA) program and must be expended in compliance with legal restrictions.

Streets/Transport/Drain (Fund 301): This Capital Improvement Fund represents a transfer of funds from the General Fund to support improvements to the City's streets, sidewalks, bikeways, and storm drainage system.

Agenda Item #7.3:

City of Sonoma
Gas Tax (Fund 302): The State of California imposes per-gallon excise taxes and sales taxes on gasoline and diesel fuel, and registration taxes on motor vehicles with allocations dedicated to transportation purposes. Gas taxes can be used for any street or road purpose; however, it is best practice to focus on maintenance and rehabilitation costs only.

SB-1 Road Maintenance (Fund 303): The Road Repair and Accountability Act of 2017 (SB1) increased pergallon excise taxes and sales taxes on gasoline and diesel fuel, and vehicle registration taxes, stabilized price-based fuel tax rates and provided for inflationary adjustments to rates in future years. Funds may be used for road maintenance and rehabilitation, safety projects, “complete street” components, and traffic control devices.

Parks & Facilities (Fund 304): This Capital Improvement Fund represents a transfer of funds from the General Fund to support improvements to the City's 17 parks encompassing nearly 40 acres, nine play structures, two public restrooms, Class I bike trails, hiking trails, a duck pond, and a rose garden. Park needs that exceed the capacity of City and contract workers are included in this fund.

Fire Measure H (Fund 312): Sonoma County measure uses a ½ cent countywide sales tax to improve fire services.

Transportation Measure M (Fund 313): The Traffic Relief Act for Sonoma County (Measure M) provides for a ¼ cent sales tax that is apportioned to local jurisdictions to maintain their streets, as well as other County-wide street, highway, transit, and safe bicycle and pedestrian routes.

Parks-In-Lieu/Quimby Act (Fund 314): The 1975 Quimby Act (California Government Code §66477) authorized the City to pass ordinances requiring developers set aside land, donate conservation easements, or pay fees, which can only be used for new and rehabilitating existing parks and recreational facilities and cannot be used for the operation and maintenance of park facilities The City currently has a parkland dedication (exaction) requirement as a condition of approval for Tentative Subdivision Maps or Tentative Parcel Maps.

Parks Measure M (Fund 315): Sonoma County Parks Improvement, Water Quality and Fire Safety Measure (Measure M) is a one-eighth cent sales tax that supports Sonoma County’s regional and city parks Prop 68 Parks (Fund 316): Known as the California Clean Water and Safe Parks Act, Proposition 68 allocates funds to construct and rehabilitate parks, implement water improvements for safe drinking water, increase recycling and flood protection, and encourage climate change adaptation projects.

Successor Agency (Fund 391): The City of Sonoma has elected to serve as the Successor Agency to the Sonoma Redevelopment Agency, which was dissolved by the State through the Redevelopment Dissolution Act in 2012. The City as Successor Agency receives pass through revenue when property taxes are remitted to the City by the County via RPTTF (Redevelopment Property Tax Trust Fund). The City then makes authorized payments from Successor Agency for expenses, such as debt service costs, contract services for contracts issued before the dissolution of the development agency, and other expenses, including legal services.

CREBS (Clean Renewable Energy Bonds) (Fund 495): Bonds to pay for solar projects at the Police Station and Corporation Yard. Not Currently Active Fund
Agenda Item #7.3:

City of Sonoma
2012 POB (Pension Obligation Bond) (Fund 498): Bond issued to refund the City’s side fund loan obligations to the California Public Employees’ Retirement System (CalPERS). Not Currently Active Fund Cemeteries (Fund 501): Accounts for funding to support the City’s three cemeteries’ operations and maintenance, including burial and inurnment preparation and coordination, cemetery improvements, tree hazard assessment and abatement, grounds maintenance, mausoleum maintenance, road maintenance, and vandalism abatement.

Cemetery Replacement (Fund 502): Not Currently Active Fund Cemetery Endowment (Fund 504): The Cemetery Endowment Fund was created to record the income received from Cemetery sales that is designated as endowment care. The City’s Municipal Code defines endowment care as the general maintenance of the City’s three cemeteries that is necessitated by natural growth and ordinary wear.

Water Utility (Fund 510): This enterprise fund is responsible for the delivery of high quality, dependable water service for a variety of needs including consumption, irrigation, and fire protection. It operates and maintains 3 active City-owned tanks with a combined storage capacity of 5.5 million gallons, 7 production wells and appurtenant treatment facilities, 2 pump stations with a combined 140 horsepower maximum output, 56 miles of active water main ranging from 8” to 14” in diameter, 513 fire hydrants, and approximately 4,500 active service connections
Water Construction in Progress (CIP) (Fund 512): This Capital Improvement Fund represents a transfer of funds from the Water Utility Fund to support improvements to the City's drinking water infrastructure.

Projects include replacing aging water mains and appurtenances (e.g. tees, crosses, couplers, saddles, valves), neighborhood-scale water service replacement projects, renewing tank coatings and corrosion control systems, replacing well or pump station equipment, replacing Supervisory Control and Data Acquisition (SCADA) systems and equipment, improvements to well and pump station buildings (e.g. replacing roofs or electrical systems).

Water Equipment Replacement (Fund 513): Accounts for costs to replace water equipment. Not Currently Active Fund
EMS Equipment Replacement (Fund 521): Accounts for costs to replace EMS equipment.

Management Information Services (Fund 601): The fund provides a mechanism for funding the operational costs, maintenance, and planned replacement of installed computer systems, equipment, software, telephone systems and other critical electronic office equipment through annual transfers from other City departments and funds.

Vehicle Replacement (Fund 603): Accounts for costs to replace vehicles based on a depreciation schedule.

Costs are distributed among user departments and transferred as approved in the annual budget process.

Insurance (Fund 604): Account from which liability, property, earthquake, vehicle, and other insurance premiums are paid. Funding is transferred from other City departments and funds on a pro rata share.

Not Currently Active Fund
Agenda Item #7.3:

City of Sonoma
Building Maintenance (Fund 610): The fund allows the City to set aside funding received through annual transfers made by other City departments and funds for future replacement or repair of certain items in City owned and maintained facilities.

Computer Loan (Fund 614): Created by the City Council in 2000 and funded by an initial transfer of $50,000 from the Employee Benefit Fund, this fund provides low interest loans to employees for the purchase of computers for both personal and professional use. Loans must be repaid through payroll deductions within two years.

Hardscape Maintenance (Fund 615): Accounts for the City's hardscape maintenance reserve programs.

Not Currently Active Fund
Administrative Hearings (Fund 620): Accounts for all activities of the City's Administrative Hearings as charged to departments. Not Currently Active Fund
Grants Restricted (Fund 630): The purpose of the fund is to separately track grant monies that are received and spent for capital improvement projects.

Culture Fine Art (Fund 701): Accounts for assets held to be used for cultural fine art programs. Not Currently Active Fund
Tree Trust (Fund 702): Accounts for assets held to be used for planting and replacement of trees. Not Currently Active Fund
Public Art (Fund 703): Accounts for assets held to be used for public art displays. Not Currently Active Fund
Pool Scholarship (Fund 715): In 2014, the City entered an agreement with Sonoma Valley Health and Recreation Association to support the construction of a swimming pool within the Sonoma Valley. The City’s financial commitment is for a total of $250,000 to be paid in 10 annual installments of $25,000 for the value of free and reduced-fee services to be provided to Sonoma Valley residents Senior Housing (Fund 731): Sonoma Creek Senior Housing is a thirty-four unit rental apartment complex for very low income senior citizens located on Oregon Street and administered by the Board of Directors of the Sonoma Community Housing Corporation (SCHC), a non-profit housing corporation created by the City’s Community Development Agency (CDA). The Board of the SCHC is comprised of two City Councilmembers, the City Manager, a staff member designated by the City Manager and a public member. The operation of the apartment complex is contracted out to Hank Fisher Properties, a rental management firm, with the resident managers being employed by the firm. All accounting and finance for the complex is handled through the rental management contract. Rental income is used to repay the indebtedness issued for the purchase of the complex and to cover annual maintenance and other operational costs. Not Currently Active Fund
Housing Trust (Fund 732): The fund accumulates and distributes funding in accordance with the City Council’s Affordable Housing Plan. The main source of funding is from General Fund transfers of one percent of the Transient Occupancy Tax.

Agenda Item #7.3:

City of Sonoma
IGT (Intergovernmental Transfer) (Fund 796): State of California program that provides an opportunity to receive federal matching funds to support health services for Medi-Cal Managed Care beneficiaries served by the Fire Department.

SVFRA (Sonoma Valley Fire Rescue Association) Operations (Fund 798): Accounts for operational activities in which revenues and expenses are split between the City and SVFD.

Agenda Item #7.3:

City of Sonoma
Agenda Item Summary
Meeting: City Council - 15 Apr 2026
Department
Parks & Recreation Department
Staff Contact
Ashley Cotter, PW Admin & Project Manager
Agenda Item Title
Adopt a Resolution Authorizing the Interim City Manager to Execute a Contract Amendment to the Contract with GHD, Inc. for the Design of the Citywide Bicycle and Pedestrian Improvements Project (CIP T-6), In An Amount Not to Exceed $49,857, For a Total Contract Value of $432,287
Summary
The City was awarded funding through the Go Sonoma tax program for the Citywide Bicycle and Pedestrian Improvements Project (CIP T-6). City staff initially submitted a funding application in 2021, with the funding awarded in 2024. All items in the project scope also needed to be included in the City's Active Transportation Plan or Comprehensive Transportation Plan.

Recently, the City and Sonoma County Transportation and Climate Authorities (SCTCA) processed an amendment to the project scope of work to remove the Sassarini School Path and replace it with a bike boulevard down Third Street West that would connect the Fryer Creek Bike Path to the Sonoma Bike Path. This amendment proposal was presented at a Special Traffic Safety Committee Meeting on October 7, 2025, linked here. The proposal included a concept only of the proposed bike boulevard, with the full design to be completed after the amendment was approved. The Traffic Safety Committee approved the project amendment at the Special Traffic Safety meeting. Shortly after that, the proposal to remove the Sassarini School Trail and add the Third Street West Bike Boulevard was reviewed and approved by the SCTCA Technical Advisory Committee - an advisory board comprised of city staff from Sonoma County jurisdictions working on transportation projects. After that, the amendment was reviewed and approved by the SCTCA Citizens Advisory Committee (CAC), an advisory board comprised of Sonoma County residents and business owners who provide input on a variety of transportation related projects. After those approvals were received, the proposal went to the Sonoma County Board of Supervisors meeting, where it was ultimately approved and the scope change was finalized.

After the scope change was finalized, staff worked with the design engineer (GHD, Inc.) on a contract amendment for the complete design of the Bike Boulevard. The City required GHD, Inc., to provide a credit for any time and engineering efforts previously unused by the Sassarini School Path (65% design for the Sassarini Path was already completed), and apply it towards the design of the bike boulevard. This resulted in an additional funding required of $49,857.00.

The contract for the project prior to the amendment to remove the trail and replace it with a bike boulevard was $382,430. This additional design effort would bring the total contract value to $432,287.

City Council recently approved a cooperative funding agreement for this project. In order for the City to receive those funds, the scoping and design must be completed, with a complete Agenda Item #7.4:

set of plans and specifications ready for bidding. The project is currently on track to go to construction in September, 2026.

Recommended Council Action
Adopt a Resolution Authorizing the Interim City Manager to Execute a Contract Amendment to the Contract with GHD, Inc. for the Design of the Citywide Bicycle and Pedestrian Improvements Project (CIP T-6), In An Amount Not to Exceed $49,857, For a Total Contract Value of $432,287
Alternative Actions
Council discretion. If approval is not given, it would halt design on this project until scoping is completed, which would delay construction, which is currently estimated for September 2026.

Financial Impact
The Adopted FY25-26 Capital Budget added $100,000 of Gas Tax (Fund 302) to this project.

While additional funds will be needed to fund the City's match share of construction and will be addressed during FY26-27 Budget Development, there is currently enough funding in this project for this increase in design costs.

Environmental Review Status
Environmental Impact Report
Negative Declaration
Exempt
Not Applicable
Approved/Certified
No Action Required
Action Requested
Attachments
Go Sonoma Design Contract Amendment Resolution
Contract Amendment
Alignment with Council Goals:

Agenda Item #7.4:

City of Sonoma
RESOLUTION # ________- 2026

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SONOMA AUTHORIZING THE

INTERIM CITY MANAGER TO EXECUTE AN AMENDMENT TO THE PROFESSIONAL SERVICES AGREEMENT WITH GHD IN THE AMOUNT OF $49,857 FOR A TOTAL CONTRACT COST OF $432,287 FOR DESIGN OF THE CITYWIDE BICYCLE AND PEDESTRIAN SAFETY IMPROVEMENTS PROJECT, CIP T-6
WHEREAS Sonoma County approved the Sonoma County Traffic Relief Act in 2004 (Measure M), as a ¼ sales tax for transportation; and
WHEREAS, in 2020 voters approved extending Measure M via the Go Sonoma Act without an increase in the existing tax rates; and
WHEREAS, the City of Sonoma currently has $1,610,000 awarded in grant funding via the Go Sonoma Act, and is programmed in the Go Sonoma Strategic Implementation Plan for the construction phase of the City’s Citywide Safety Bicycle and Pedestrian Improvements Project (CIP Project No. T-6); and
WHEREAS, on September 18, 2024, the City executed a contract with GHD, Inc. for the design of the Go Sonoma Project after a successful advertisement of request for proposals; and WHEREAS, recently, the Sonoma County Transportation and Climate Authorities (SCTCA) processed an amendment to the project scope to remove the Sassarini School Path and add in the Third Street West Bike Boulevard; and
WHEREAS, this design change resulted in additional design efforts as the original contract was at 65% design at the time of the amendment process; and WHEREAS, GHD, Inc. provided an amendment proposal for the inclusion of the Third Street West Bike Boulevard, resulting in an increase of $49,857 in the contract amount.

NOW, THEREFORE, BE IT RESOLVED, that the City Council of the City of Sonoma hereby adopts this resolution to authorize the Interim City Manager to execute an amendment to the professional services agreement with GHD, Inc. for $49,857 for a total contract amount of $432,287; and
PASSED, RESOLVED, AND ADOPTED, at a Regular Meeting of the City Council of the City of Sonoma on this 15th day of April, 2026, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
______________________________
Ron Wellander, Mayor
ATTEST:
______________________________
Monique Saviez Burns, CPMC, CMC
Deputy City Clerk
Agenda Item #7.4:

441785.1 Initials: (City) _______ (Consultant) _______

AMENDMENT No. 1 TO PROFESSIONAL SERVICES AGREEMENT
(City of Sonoma and GHD, Inc.)
This Amendment No. 1 (“Amendment”) to Professional Services Agreement (“Agreement”) is made on this 15th day of April, 2026 at Sonoma, California, by and between the City of Sonoma, a municipal corporation, No. 1 The Plaza, Sonoma, CA 95476 (“City”) and GHD, Inc, 2235 Mercury Way, Santa Rosa, CA, a California corporation (“Consultant”).

This Amendment modifies the original Agreement between the City and the Consultant dated September 18, 2024 in the following fashion:

A. City and Consultant desire to amend the Agreement by modifying the total compensation and costs payable to Consultant under this Agreement to a not-to-exceed sum of $432,287.

B. City and Consultant desire to amend the Scope of Services to include the Change of Scope provided by Consultant by letter dated 18 March 2026 to remove the Sassarini School Path and add the Third Street West Bike Boulevard improvements, which Change is Scope is attached hereto and incorporated by this reference.

Unless expressly amended in this Amendment, all provisions, conditions, covenants, and terms of the Agreement shall remain in full force and effect. [Signatures on following page]
Agenda Item #7.4:

Professional Services Agreement
City of Sonoma / GHD, Inc
441785.1 Page
2 of 2
TO EFFECTUATE THIS AGREEMENT, the parties have caused their duly authorized representatives to execute this Agreement on the dates set forth below. “City”
City of Sonoma
By: ______________________________
Cristine Alilovich, Interim City
Manager
Date: _______________
Attest:

By: ______________________________
Rebekah Barr, MMC, City Clerk
Date: _______________
Approved as to form:

By: ______________________________
David J. Ruderman, City Attorney
Date: _______________
“Consultant”
GHD, Inc.

By:______________________________
[Name, Title]
Date: __________________
By:______________________________
[Name, Title]
Date: __________________
Agenda Item #7.4:

The Power of Commitment

2235 Mercury Way, Suite 150
Santa Rosa, CA 95405
USA
www.ghd.com
Our ref: 12637326
18 March 2026
Mr. Mike Berger, Public Works Director
City of Sonoma
Public Works Department
No. 1 The Plaza
Sonoma, CA 95476
RE: Citywide Bicycle and Pedestrian Safety Improvements Project Amendment No. 1 – Change of Scope to Include Third Street West Bike Boulevard
Dear Mike,
The following is a proposed amendment for additional services for the Citywide Bicycle and Pedestrian Safety Improvements Project. This amendment is derived from our work on the Third Street West Bike Boulevard concept and subsequent coordination with the City.

Project Understanding
Background. The City received funding through the Go Sonoma tax program for the Citywide Bicycle and Pedestrian Improvements Project (CIP T-6). City staff applied for funding in 2021, and it was awarded in 2024. All project scope items were required to be included in the City’s Active Transportation Plan or Comprehensive Transportation Plan.

Originally, the project included the Sassarini School Path, listed in the City’s Active Transportation Plan since 2008 and identified as a Safe Routes to School project during prior public meetings. Because the trail would be built on Sonoma Valley Unified School District (SVUSD) property, an easement was required. On March 13, 2025, City staff presented the trail concept to SVUSD Trustees as an informational item.

During design discussions with stakeholders, the City decided to prioritize a different project instead of the Sassarini School Path. Recently, staff identified the Third Street West Bike Boulevard as a potential replacement. City staff met with Sonoma County Transportation and Climate Authorities (SCTCA) to discuss amending the project to remove the Sassarini School Path and add the Bike Boulevard. SCTCA approved moving forward with the amendment process.

The Third Street West Bike Boulevard is listed in the January 2025 Active Transportation Plan as Project Number 191 and ranked as a Tier Three priority (Tier One being the highest). It is part of the Metropolitan Transportation Commission (MTC) Regional Active Transportation Network. This proposed bike boulevard would link the Fryer Creek Trail, starting at Leveroni Road and running along Fryer Creek Drive, crossing West MacArthur Street, and ending at Arroyo Way, to the intersection of Third Street West and West Spain Street at the entrance of General Vallejo's Home, where the Sonoma Bike Path begins.

Bike Boulevard Improvements. Staff believes that the Third Street West Bike Boulevard project provides more value than the Sassarini School Path. The Fryer Creek Trail is heavily traveled and utilized, as is Third Street West as it is a connector to the Sonoma Bike Path. With the designation of Third Street West as a bike boulevard, the attached concept illustrates proposed traffic calming modifications, as the corridor currently lacks any such measures. The proposed traffic calming features include:
• Painted curb extensions on Third Street West at West Napa Street • Speed cushion on Third Street West between West Spain Street and West Napa Street Agenda Item #7.4:

The Power of Commitment
Citywide Bicycle and Pedestrian Safety Improvements Amendment No. 1 – Third Street West Bike Boulevard Page 2 of 6 • Speed cushion on Third Street West between West Napa Street and Robinson Street • Neighborhood traffic calming circle at the intersection of Third Street West and Perkins Street • Painted curb extensions, new crosswalks, and stop control reassignment at Third Street West and Andrieux Street
• Painted curb extensions, new crosswalks, and stop control reassignment at Third Street West and Bettencourt Street
• Signage, striping, and markings designating Third Street West as a bike boulevard These traffic calming additions with the striping of a bike boulevard (edgeline striping and sharrows), will enhance the roadway to make it more bicycle friendly while providing better connectivity between the City’s two main bike paths.

City staff conducted a Traffic Engineering Safety Meeting on October 2, 2025 that included representatives from Sonoma Valley Fire, Sonoma Police Department, and the City Engineer. Representatives from both Police and Fire noted that since Third Street West was not a primary emergency response route, these improvements would be acceptable and would not impact emergency response times.

Community Benefits. This project provides more value to the community, whereas the Sassarini School Path would have primarily served the student population of Sassarini School. The original purpose of this project when submitted in 2021 was to create a high-quality bicycle and pedestrian network, provide a safe and well-maintained transportation infrastructure for pedestrians and bicyclists, focus on strategies that support a walkable community, and prioritize funding for zero-emissions strategies. The Third Street West Bike Boulevard improvements aligns more closely with the goals of the project, as it supports the community as a whole, and provides a much needed connection between two main bike paths in the Sonoma Valley. The bike boulevard improvements would serve more residents, enhance the existing bicycle and pedestrian network, bolster bicycle infrastructure as there are currently no bicycle facilities on Third Street West, and facilitate mode-shift necessary to achieve the goals of zero emissions travel and decrease Vehicles Miles Traveled (VMT). The Fryer Creek trail runs parallel to Broadway up to West MacArthur Street, while Third Street West runs parallel to Fifth Street West, both Fifth Street West and Broadway are major collectors and arterials, so by providing this key connection, residents will have an option to access the historic Sonoma Plaza, West Napa Street, and the Sonoma Bike Path (which starts at Maxwell Village and ends at Fourth Street East), without utilizing these main thoroughfares.

Construction Costs. GHD, Inc. prepared a preliminary construction cost estimate alongside the concept design. The current estimate for the bike boulevard with traffic-calming features is $472,130, compared to the original estimate of $766,700 for the Class I trail at Sassarini School. This represents a decrease of approximately $294,570 to the overall project cost.

The total construction funding for this project is $1,837,000, which includes a grant allocation from SCTCA of $1,610,000, and a city share of $277,000. If additional funding is required, staff can submit a revised capital improvement program request to City Council with additional funding for this project.

Project Approach
With our project understanding, GHD has outlined an approach to advance the Third Street West Bike Boulevard concept and develop it to full design and construction documents, while terminating work on the design of the Sassarini School Trail.

Project Management. GHD’s management approach will be to continue acting as an extension of City staff throughout the project. Through bi-weekly progress meetings and design review meetings after each milestone submittal, GHD will maintain clear and consistent communication with the City as it pertains to project development. The Project Manager will serve as the primary point of contact for the City, streamlining communication and facilitating timely responses to City and/or stakeholder inquiries.

Environmental. In compliance with the California Environmental Quality Act (CEQA), GHD will update and revalidate the environmental review as necessary to address changes introduced by the addition of Third Agenda Item #7.4:

The Power of Commitment
Citywide Bicycle and Pedestrian Safety Improvements Amendment No. 1 – Third Street West Bike Boulevard Page 3 of 6 Street West Bike Boulevard to the project scope. The project is anticipated to quality for a categorical exemption, thus the revalidation will consist of preparing categorical exemption documentation, including the Notice of Exemption (NOE) form and updating the previously submitted CEQA Exemption memo to include the new scope.

Surveying. Topographic survey will be collected at targeted locations along Third Street West to supplement available aerial imagery, which will serve as base mapping for the project. As the improvements along Third Street West primarily consist of striping, signage and traffic calming measures, topographic survey will be limited to specific areas where hardscape surface improvements are planned or where aerial imagery is insufficient or inadequate.

The following location has been designated as requiring additional topographic survey:
• Third Street West and Perkins Street intersection
All improvements are assumed to be within City right-of-way and/or will be confined to existing back of sidewalk limits.

Bike Boulevard Design. Based on the project understanding outlined in the Bike Boulevard Concept, GHD will use aerial imagery and supplemental topographic survey data at the Perkins Street and Third Street West intersection to prepare detailed design and construction documents.

GHD will begin with a field review of Third Street West to document existing conditions, including roadway surface features, utilities, curb lines, pavement conditions, signage, striping, and markings. All signage, striping, and traffic calming treatments—including speed cushions and the traffic circle—will be incorporated into the project plans using aerial or topographic base mapping, as appropriate, and will include all required construction details.

Using information gathered during the field review, GHD will develop plans for the bike boulevard, including geometric layout for a compact neighborhood traffic calming circle at Perkins Street and Third Street West.

Final design documents will follow the City’s standard specification format (Parts I–V) and will reference the City of Sonoma Standard Plans and applicable Caltrans Standard Plans and Specifications.

Right-of-Way and Utility Coordination. All improvements are anticipated to be within City right-of-way and/or to existing back of sidewalk limit, thus no right-of-way acquisition will be required.

Where the project includes hardscape improvements, we anticipate that coordination with utiilty service providers will be required. GHD will contact the following utilities to obtain schematic facility mapping for incorporation into the project base map:
• SCWA – Sanitary sewer and storm drainage
• PG&E – Electric and gas
• AT&T and Cablecom (Comcast) – Communications lines
• City of Sonoma – Water and storm drainage
Sassarini Trail. As part of the original contract, the Sassarini Trail design was advanced to the 95% level, while other elements of the project were developed only to 65%. This difference in design completion was to facilitate right-of-way acquisition, as this was believed to be the critical path for the overall schedule.

Advancing the trail design further allowed the team to better understand potential impacts and right-of-way needs necessary to initiate the acquisition process. Under this amendment, all design scope beyond the completed 95% submittal—as well as other uncompleted scope associated with the Sassarini Trail—is removed, and a credit is provided to the City for the unperformed work.

Where scope tasks developed under the original contract remain applicable and uncompleted, they are reassigned to the Bike Boulevard rather than the Sassarini Trail, including but not limited to project management, bid-phase services, and office engineering support during construction. Because this work will still be performed under the amended scope, no credit is associated with these reassigned tasks.

Agenda Item #7.4:

The Power of Commitment
Citywide Bicycle and Pedestrian Safety Improvements Amendment No. 1 – Third Street West Bike Boulevard Page 4 of 6 Scope of Work – Additional Services
The following describes the added scope of services for the Third Street West Bike Boulevard included in this amendment.

Task 1 - Project Management and Coordination
This task includes project administration, coordination, kick-off and review meetings, and quality control as stated in the following sub-sections:

Task 1.1 Internal Project Management, Coordination and Contract Administration • Budget and schedule tracking
• Provide project and contract oversight
Task 1.2 Project Meetings
• GHD’s Project Manager and/or Assistant Project Manager (as-needed) will attend recurring biweekly Teams (virtual) meetings, which include general coordination, progress, design review and other items requiring discussion. A total of ten (10) meetings are anticipated. These biweekly meetings will include design review meetings after each submittal. Agendas/notes for biweekly meetings will be simple agenda notes style and distributed after meetings. Generally, the meetings will be scheduled for 30-minute durations.
• GHD’s Project Manager, Assistant Project Manager, or Project Engineer, will conduct one (1) field review/site visit to support project coordination, design validation, and preparation of design submittals.

Deliverables: Preparation of meeting agendas, notes, and as-needed progress reports. Meeting notes will be submitted within 5 working days of the meeting.

Task 1.3 Constructability Review and QA/QC
GHD will complete QA/QC and constructability review by a senior civil engineer and construction inspector prior to submitting final plans, specifications, and estimate.

Deliverables: None.

Task 2 – Project Scoping (Task Complete – No Further Work) Task 3 – Stakeholder Engagement (Task Complete – No Further Work) Task 4 – Environmental Documentation
GHD will review the Third Street West Bike Boulevard Project for compliance with the California Environmental Quality Act (CEQA). The findings of this review will be incorporated into the previously prepared CEQA Exemption Memorandum for the Citywide Bicycle and Pedestrian Safety Improvements Project, which will be updated to include the bicycle boulevard project. In addition, GHD will update the previously drafted CEQA Notice of Exemption (NOE) form to include the bicycle boulevard project Deliverables: Draft and Final Notice of Exemption and CEQA Review Memorandum Task 5 – Project Surveys and Geotechnical Investigations Agenda Item #7.4:

The Power of Commitment
Citywide Bicycle and Pedestrian Safety Improvements Amendment No. 1 – Third Street West Bike Boulevard Page 5 of 6 GHD is including subconsultant Cinquini and Passarino to complete the additional survey tasks associated with the bike boulevard improvements.

Task 5.1 Topographic Survey and Right-of-Way Surveys
The topographic survey will be at a drawing scale of 1 inch = 20 feet, unless otherwise requested, with a one foot contour interval. The topographic survey will include the following:
• Topographic survey coverage areas are described as follows:
o Intersection of Third Street West and Perkins Street. (Mapping will extend 25 feet beyond the curb returns on each street)
• Topographic survey will include components and features to produce a topographic basemap, including: building corners and elevations, curb lines, water meters, sewer cleanouts, valves, manholes (including rim, invert and pipe information), utility markings on the pavement, utility poles, driveway and doorway locations, sidewalks, trees four (4) inches and larger, retaining wall or decorative walls, and any other pertinent information that could apply to the project during design. • Right of way lines for the roadways along the corridor will also be shown on the mapping. • Topographic map to horizontally relate to California Coordinate System of Zone 2 and NAVD 1988 Vertical Datum.
• A boundary survey is not a part of this scope of work, as described above.

Deliverables:

Sealed hardcopy of Topographic Survey Map. The Autocad “dwg” used to create the hardcopy can be provided upon request.

Task 5.2 Geotechnical Investigation (No Scope Augmentation Anticipated or Included) Task 5.3 Supplemental Consultation and Plan Review (No Scope Augmentation Anticipated or Included) Task 6 – Design Documents
Project plans will utilize both targeted topographic mapping (where listed in the survey scope) and the City’s existing aerial imagery as the basemap. Topographic information will be utilized to augment the City’s aerial basemap for use in detailed design and preparation of construction documents. Plans will be prepared at a scale of 1”=40’ (1”=80’ half size; unless otherwise approved by the City) using AutoCAD Civil 3D 2025, or later version on GHD title block and CAD Standards.

Design will be in accordance with City of Sonoma Standards and State of California Standards (Caltrans 2018 where applicable. Consistent with past projects, the Specifications will follow the City’s standard for Front End Documents (Parts Nos. 1-4) and Technical Specifications (Part No. 5). Technical specifications will align with Caltrans Standard Specifications Sections. Comments and recommendations provided by the City will be incorporated into each submittal.

For inclusion of the Third Street West Bike Boulevard improvements to the overall Citywide Bicycle and Pedestrian Safety Improvement Project, the following plan sheet additions are anticipated:

Sheet No. Drawing No. Drawing Title
1 G-001 Sheet Title and Drawing Index (augment)
2 G-002 General Notes, Legend and Abbreviations (augment) 3 G-003 Survey Control and Key Map 1 (augment)
4 C-101 Improvement Plan – Third Street West 1
Agenda Item #7.4:

The Power of Commitment
Citywide Bicycle and Pedestrian Safety Improvements Amendment No. 1 – Third Street West Bike Boulevard Page 6 of 6 5 C-102 Improvement Plan – Third Street West 2
6 C-407 Construction Details - Perkins Street Traffic Circle 7 C-501 Civil Details 1
It is assumed that the City will distribute each submittal and return one comment review package. Each submittal will include plans, front-end documents (Part Nos. 1-4), technical specifications (Part No. 5), and an opinion of probable construction costs.

Geotechnical coordination and review is not included.

Task 6.1 Plans, Specifications and Estimate – 65%
Deliverables: Plans – Submit electronic copies 22”x34” (PDF) to the City for review.

Specifications – Submit electronic copies (PDF and Word) of the project specifications to the City for review.

Opinion of Probable Construction Costs – Submit an electronic copy (PDF) to the City for review
Task 6.3 Plans, Specifications and Estimate – 100% (Final/Contract Documents) This task is to complete bid package/construction document preparation.

Deliverables: Final Contract Documents – Deliver an electronic copy of the Contract Documents (PDF) to BPXpress for Bid reproduction. Also deliver one electronic copy (lowresolution PDF) of the Contract Documents to the City for posting on the City’s website.

Final Opinion of Probable Construction Costs – Deliver an electronic copy (PDF) of the final opinion of probable construction costs
65% Review Comments Matrix/Response to Comments
Task 7 – Right-of-Way and Utility Coordination
Task 7.3 Utility Coordination
It is anticipated that the following utilities will require coordination:
• (SCWA) Sanitary sewer and storm drainage: adjustment of utility covers to grade • (CableCom for Comcast) Cable Television; adjustment of utility covers to grade. • (AT&T) Telephone; adjustment of utility covers to grade. • (PG&E) Electric; adjustment of utility covers to grade. • (City) adjustment of utility covers to grade.

GHD will prepare Utility "A" letters to request mapping from utility companies. Mapping received from utility companies will be drafted into the design plan basemaps.

Deliverables: Mailing list
Utility "A"Letters
Agenda Item #7.4:

The Power of Commitment
Citywide Bicycle and Pedestrian Safety Improvements Amendment No. 1 – Third Street West Bike Boulevard Page 7 of 6 Scope of Work – Revised Services
The following describes the Sassarini Trail scope of services removed or reassigned to the Third Street West project as part of this amendment, as well as the revised Main Bike Path crossing scope of services.

Task 1 – Project Management and Coordination (Remaining Scope is Reassigned) Task 2 – Project Scoping (Task Complete – No Further Work) Task 3 – Stakeholder Engagement (Remaining Scope is Removed) Task 3.1, which included preparation of graphics to support the City with stakeholder and public engagement efforts, was completed. Task 3.2, which included attendance of up to three (3) stakeholder meetings and up to two (2) public meetings, was partially completed. The remaining effort for Task 3.2 is hereby removed from the scope of work.

Task 3.1 Prepare Graphics for Stakeholder Meetings (Task Complete – No Further Work) Task 3.2 Stakeholder/Public Meetings (Remaining Scope is Removed) Task 4 – Environmental Documentation (Task Complete – No Further Work) Task 5 – Project Surveys and Geotechnical Investigations Task 5.1 Topographic Survey and Right-of-Way Surveys (Task Complete – No Further Work) Task 5.2 Geotechnical Investigation (Task Complete – No Further Work) Task 5.3 Supplemental Consultation and Plan Review (Remaining Scope is Reassigned) Task 6 – Design Documents
Sassarini Trail
Tasks 6.1 and 6.2, which included preparation of the 65% and 95% Plans, Specifications, and Opinion of Probable Construction Costs (PS&E) for the Sassarini Trail, respectively, were completed. Task 6.3, which originally included preparation of the 100% (Final/Contract Documents) PS&E, is hereby removed from the scope of work.

Main Bike Path Crossings
Task 6.1, which included preparation of the 65% PS&E for the Main Bike Path crossings, was completed.

Task 6.2, originally scoped to advance the design from 65% to 95% PS&E, is removed. Task 6.3, originally scoped to advance the design from 95% to 100% PS&E is revised to advance the design from 65% to 100% PS&E.

The City is provided a credit reflecting the reduced level of effort associated with eliminating one (1) round of City comments and preparation of one (1) PS&E submittal package that would have advanced the design from 95% to 100% PS&E.

Task 6.1 Plans, Specifications and Estimate – 65% (Task Complete – No Further Work) Task 6.2 Plans, Specifications and Estimate – 95% (Task Complete – No Further Work) • Sassarini Trail 95% PS&E (Task Complete – No Further Work) Agenda Item #7.4:

The Power of Commitment
Citywide Bicycle and Pedestrian Safety Improvements Amendment No. 1 – Third Street West Bike Boulevard Page 8 of 6 • Main Bike Path 95% PS&E (Scope is Removed)
Task 6.3 Plans, Specifications and Estimate – 100%
• Sassarini Trail 100% PS&E (Scope is Removed)
• Main Bike Path 100% PS&E (Scope is Revised)
Task 7 – Right-of-Way and Utility Coordination
Tasks 7.1 and 7.2, which included preparation of draft and final legal descriptions and plats for the Sassarini Trail, and coordination with the City’s right-of-way agent, respectively, are hereby removed from the scope of work. Task 7.3, which included utility coordination for the Sassarini Trail, was completed.

Task 7.1 Right-of-Way Engineering (Remaining Scope is Removed) Task 7.2 Coordination with the City’s Right-of-Way Agent (Remaining Scope is Removed) Task 7.3 Utility Coordination (Task Complete – No Further Work) Task 8 – Bid Phase Services (Scope is Reassigned)
This task, which originally included bid phase support services for the Sassarini Trail, is hereby reassigned to the Third Street West Bike Boulevard.

Task 9 – Office Engineering Support during Construction (Scope is Reassigned) This task, which originally included office engineering support services for the Sassarini Trail, is hereby reassigned to the Third Street West Bike Boulevard.

Assumptions and Clarification
• Meetings in addition to those included in the scope of work are not required. • Additional geotechnical investigations will not be required for the added Third Street West Bike Boulevard design.
• Existing aerial imagery will be utilized as base mapping for signage, striping, pavement marking upgrades, and curb ramp field fits, where applicable. Topographic mapping and right-of-way will be collected as stated in our scope of work.
• City will furnish most current aerial imagery for use as existing conditions base map in areas where topographic mapping is not required/provided.
• No known cultural resources are anticipated to be identified during the cultural resources record search.
• Environmental documentation is limited to CEQA support services and does not include assistance related to NEPA, regulatory agency permitting, or Phase 1 or 2 environmental site assessments. • The project is anticipated to qualify for CEQA categorical exemptions. If services are required due to a different level of CEQA review, such as an Initial Study/Mitigated Negative Declaration, GHD can assist the City with such services under a task order amendment. • Design of curb ramp and other hardscape improvements not explicitly listed is excluded. Such services can be added as a task order amendment, if needed. • Design of single lane modern roundabouts is excluded. • Design of custom wayfinding and bicycle boulevard signage is excluded, but can be added as a task order amendment, if desired.

Agenda Item #7.4:

The Power of Commitment
Citywide Bicycle and Pedestrian Safety Improvements Amendment No. 1 – Third Street West Bike Boulevard Page 9 of 6 • Consistent with past projects, it is assumed that any yellow thermoplastic stripe removed as part of the project will be considered a hazardous waste with special provisions to accommodate the work, unless directed otherwise by the City.
• It is anticipated that all improvements are within City right-of-way and/or improvements will be confined to existing back of sidewalk limits. No right-of-way acquisition will be required. • No encroachment permit and/or fees will be required to complete project field investigations. The City will waive fees, if required.
• The City will pay all permit and application fees and will handle permit reviews. GHD will provide support in the form of plan and specification preparation and addressing comments from permit reviews, if required.
• Utility relocations, including adjustments to grade, for non-City owned facilities will not be required along Third Street West, thus preparation of conflict maps, Utility “B” and “C” letters are excluded, but can be added as a task order amendment, if required. • Utility relocation design for non-City owned facilities will be provided by the utility owner. The City will complete and file facility relocation applications with the utility owner, as applicable. • Utility relocation design for City owned facilities is excluded, but can be added as a task order amendment, if required.
• Utility potholing is not included in this scope of work. • Design of post-construction storm water quality features (BMPs) is excluded as the project features routine maintenance activities and/or a stand-alone pathway, thus is exempt from these requirements. These services can be provided by GHD through a task order amendment, if required. • It is assumed that dewatering will not be required and specifications will not be developed to require dewatering.
• It is assumed that there are no hazardous materials or contaminated soils in excavated materials.

Testing and/or specifications to provide for hazardous materials or contaminated soils are not included.
• City Staff will perform day-to-day construction management and inspection during construction. • Other services performed or furnished by GHD not otherwise provided in the scope of work are excluded.

Project Schedule
The schedule of the Third Street West Bike Boulevard design will be completed in coordination with City staff to meet project construction advertisement schedule, which is anticipated to be July 2026.

Additional Compensation
This section summarizes the additional compensation for new scope items and the credits associated with Sassarini Trail work that will not be completed. Tasks that remain applicable and are reassigned to the Third Street West Bike Boulevard are not credited, as these services will still be delivered under the amended scope. The resulting additional compensation requested for professional services is $49,857.00, on a not-to-exceed, time-and-materials basis. The fee summary is provided below:

Item Amount
Original Agreement $382,430.00
Amendment No. 1 Additions $90,183.00
Amendment No. 1 Removals (Credit) $(40,326.00)
Total Contract Amount $432,287.00
Agenda Item #7.4:

The Power of Commitment
Citywide Bicycle and Pedestrian Safety Improvements Amendment No. 1 – Third Street West Bike Boulevard Page 10 of 6 Closing
It is assumed that upon agreement of the scope of work for the engineering services for the Citywide Bicycle and Pedestrian Safety Improvements Project, GHD will prepare an amendment to our existing task order agreement consistent with the terms in our Master Agreement with the City. The Notice to Proceed will be the date of written authorization by the City to proceed, which may pre-date City execution of the agreedupon task order.

If you have any questions or comments regarding this proposal, please feel free to call me at 707-303-4853.

Sincerely,
GHD Inc.

Roman Beltran, PE
Project Manager
(707) 303-4853
Attachment: Third Street West Bike Boulevard Concept
Fee Estimate Spreadsheet (Added Services)
Fee Summary (Total Contract Amount)
Agenda Item #7.4:

Third Street West Bicycle Boulevard Project Concept
IntersectionsW. Spain St Church St W. Napa St Banchero St Robinson St• Add painted curb extensions at intersection • Pedestrian curb ramp reconstruction (2 EA) • Add painted curb extensions on 3rd St W legs. • Pedestrian curb ramp reconstruction (2 EA) • Pedestrian curb ramp reconstruction (1 EA)• Add painted medians on W. Spain approaches • Pedestrian curb ramp reconstruction (2 EA) - within Caltrans R/W • Pedestrian curb ramp construction (1 EA) (completed with W. Spain) and potentiall private R/WCooridor W. Spain St to W. Napa St W. Napa St to Arroyo Way• Add right edge lines (Detail 27B) • Add right edge lines (Detail 27B)• Add one speed cushion • Add one speed cushion (between Banchero and Robinson)• Add "Bike Blvd" Markings and "Third Street West Bike Blvd" Custom street name signs. • Add "Bike Blvd" Markings and "Third Street West Bike Blvd" Custom street name signs.

Agenda Item #7.4:

Vigna St Perkins St Andrieux St Bettencourt St Arroyo Way W. MacArthur St • Pedestrian curb ramp reconstruction (2 EA) • Pedestrian curb ramp reconstruction (4 EA) • Move stop control to Andrieux from Third St • Move stop control to Bettencourt from Third St • Reconstruct ramp to Class I path (may not be feasible) • Add W11-2/W16-7p with R1-6 and yield lines • Neighborhood Traffic Circle - needs to be compatible to give priority to cyclist to give priority to cyclist • Consider Solar RRFB at crossing.with bus stop • Add painted curb extensions at intersection • Add painted curb extensions at intersection • Add cross walks • Add cross walks
Arroyo Way to W. MacArthur St• Refresh markings on Class I path.

Agenda Item #7.4:

Cost Proposal for Citywide Bicycle and Pedestrian Safety Improvements Project No. T-6 12637326
Amendment No. 1 - Addition of Third Street West Bike Boulevard Description PD QC Traffic Eng.

PM/Project
Eng. Staff Eng
Senior Env.

Planner PA Total Hours Labor Total CPI Subs Markup Total Subcontractors Cultural Records Search
Other Direct Costs (Travel, Mileage) Disb. Markup Disb. Fee Total Disbursements
Estimated
Project Total
Bill Silva Matt Wargula Frank Penry Roman Beltran
Emmanuel
Ikechi
Brian
Baccarini
Crystal
Prairie
$306 $263 $263 $210 $142 $249 $121
Task1 Project Management and Coordination 2 14 0 26 8 4 8 62 $12,854 $0 $0 $0 $0 $500 $25 $771 $1,296 $14,150 Subtask 1.1 Internal Coordination and Adminstration 2 4 0 6 0 0 8 20 $3,892 $0 $0 $0 $0 $0 $0 $234 $234 $4,126 Subtask 1.2 Project Meetings 0 6 0 20 8 4 0 38 $7,910 $0 $0 $0 $0 $500 $25 $475 $1,000 $8,910 Subtask 1.3 Constructability Review and QA/QC 0 4 0 0 0 0 0 4 $1,052 $0 $0 $0 $0 $0 $0 $63 $63 $1,115 Task4 Environmental Documentation 0 0 0 2 0 8 0 10 $2,412 $0 $0 $0 $500 $0 $25 $145 $670 $3,082 Subtask 4.1 Environmental Documentation 0 0 0 2 0 8 0 10 $2,412 $0 $0 $0 $500 $0 $25 $145 $670 $3,082 Task5 Project Surveys and Geotechnical Investigation 0 0 0 4 0 0 0 4 $840 $6,580 $658 $7,238 $0 $0 $0 $50 $50 $8,128 Subtask 5.1 Topographic Survey and Right-of-Way Surveys 0 0 0 4 0 0 0 4 $840 $6,580 $658 $7,238 $0 $0 $0 $50 $50 $8,128 Task6 Design Documents 0 12 12 92 210 0 12 338 $56,904 $0 $0 $0 $0 $300 $15 $3,414 $3,729 $60,633 Subtask 6.1 Plans, Specifications and Estimate - 65% 0 6 6 52 128 0 0 192 $32,252 $0 $0 $0 $0 $300 $15 $1,935 $2,250 $34,502 Subtask 6.3 Plans, Specifications and Estimate - 100% 0 6 6 40 82 0 12 146 $24,652 $0 $0 $0 $0 $0 $0 $1,479 $1,479 $26,131 Task7 Right-of-Way and Utility Coordination 0 0 0 8 16 0 0 24 $3,952 $0 $0 $0 $0 $0 $0 $237 $237 $4,189 Subtask 7.3 Utility Coordination 0 0 0 8 16 0 0 24 $3,952 $0 $0 $0 $0 $0 $0 $237 $237 $4,189 Total Labor Hours 2 26 12 132 234 12 20 438 $76,962 $6,580 $658 $7,238 $500 $800 $65 $4,618 $5,983 $90,183 x Estimated Project Total $612 $6,838 $3,156 $27,720 $33,228 $2,988 $2,420 438 $76,962 $6,580 $658 $7,238 $500 $800 $65 $4,618 $5,983 $90,183 Notes:1. It is assumed that the hours above will be shifted between Tasks, if needed, to meet actual project needs. Total charges will remain within the total contract amount, unless additional services are requested.2. Rates will be adjusted up to 5% one time per year, each year, on January 1.

Agenda Item #7.4:

FEE SUMMARY
Amendment No. 1

CITY OF SONOMACITYWIDE PEDESTRIAN AND BICYCLE SAFETY IMPROVEMENTS PROJECT GHD Project No. 12637326FEE SUMMARYAMENDMENT NO. 1
Task Task Description
Original Contract
Value
(A)
Amendment No. 1 -
Added Services
(B)
Amendment No. 1 -
Credits for Removed
Services
(C)
Amendment No. 1 -
Additional
Compensation
(D) = (B) + (C)
Amended Contract
Value
(E) = (A) + (D)
01 Project Management and Coordination 35,889.00$ 14,150.00$ -$ 14,150.00$ 50,039.00$ 02 Project Scoping 30,010.00$ -$ -$ -$ 30,010.00$ 03 Public Engagement 27,233.00$ -$ (15,450.00)$ (15,450.00)$ 11,783.00$ 04 Environmental Documentation 10,285.00$ 3,083.00$ -$ 3,083.00$ 13,368.00$ 05 Project Surveys and Geotechnical Investigation 61,928.00$ 8,128.00$ -$ 8,128.00$ 70,056.00$ 06 Design Documents 165,428.00$ 60,633.00$ (19,090.00)$ 41,543.00$ 206,971.00$ 07 Right-of-Way and Utility Coordination 22,076.00$ 4,189.00$ (5,786.00)$ (1,597.00)$ 20,479.00$ 08 Bid Phase Support 6,262.00$ -$ -$ -$ 6,262.00$ 09 Office Engineering Support during Construction 23,319.00$ -$ -$ -$ 23,319.00$ 382,430.00$ 90,183.00$ (40,326.00)$ 49,857.00$ 432,287.00$ TOTAL Fee Summary_12637326_Amendment No. 1_R7.xlsx GHD Inc.

Agenda Item #7.4:

City of Sonoma
Agenda Item Summary
Meeting: City Council - 15 Apr 2026
Department
Public Works
Staff Contact
Ashley Cotter, PW Admin & Project Manager,
Michael Berger, Public Works Director
Agenda Item Title
Adopt an Ordinance Amending Sonoma Municipal Code Section 13.20.010 and Finding the Ordinance Exempt from the California Environmental Quality Act (CEQA) Pursuant to Section 15061(b)(3) - General Rule - of the CEQA Guidelines.

Summary
This ordinance was introduced at the Regular Meeting of March 30, 2026.

Sonoma Municipal Code Chapter 13.02 governs cross-connections and backflow prevention.

Currently, Sonoma Municipal Code Section 13.20.010 states that these regulations are in accordance with the State of California Public Health Administrative Code Title 17. Title 17 has been superseded by the state's newly adopted Cross Connection Control Handbook (CCCPH). For the City's municipal code to be compliant, it must be amended to reflect current rules and regulations. The proposed ordinance will amend the Municipal Code to reflect the following: "This Chapter is adopted in accordance with California Health and Safety Code section 116800 et seq. and the requirements of the State Water Resources Control Board Cross-Connection Control Policy Handbook, adopted December 19, 2023, effective July 1, 2024, revised June 17, 2025, as both may be amended from time to time." Recommended Council Action
Adopt an Ordinance Amending Sonoma Municipal Code Section 13.20.010 and Finding the Ordinance Exempt from Environmental Review under the General Rules in the California Environmental Quality Act (CEQA) Guidelines Section 15061(b)(3).

Alternative Actions

1. Introduce a modified version of the Ordinance.

2. Council's discretion.

Financial Impact
There are no financial impacts at this time.

Environmental Review Status
Environmental Impact Report
Negative Declaration
Exempt
Not Applicable
Approved/Certified
No Action Required
Action Requested
Attachments
Agenda Item #7.5:

Cross Connection Control Plan Update Ordinance
Alignment with Council Goals:

Not Applicable
Agenda Item #7.5:

City of Sonoma
ORDINANCE #_______ - 2026

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF SONOMA AMENDING SONOMA MUNICIPAL CODE SECTION 13.20.010 AND FINDING THIS ORDINANCE

EXEMPT FROM ENVIRONMENTAL REVIEW UNDER THE GENERAL RULE IN

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) GUIDELINES SECTION 15061(b)(3)
THE CITY COUNCIL OF THE CITY OF SONOMA DOES ORDAIN AS FOLLOWS:

SECTION 1: Municipal Code Amendment
Sonoma Municipal Code Section 13.20.010 cross connection and back flow preventions regulations of the Sonoma Municipal Code is hereby amended to read as follows (strikeout is used to denote existing text being deleted; underline is used to denote new text being added):

13.20.010 Purpose
The purpose of these regulations is:

A. To protect the public water supply against actual or potential crossconnections by isolating within the premises contamination or pollution that may occur because of some undiscovered or unauthorized cross-connection on the premises;
B. To eliminate existing connections between drinking water systems and other sources of water that are not approved as safe and potable for human consumption;
C. To eliminate cross-connections between drinking water systems and other sources of water or process water used for any purpose whatsoever which jeopardize the safety of the drinking water supply;
D. To prevent the making of cross-connections in the future.

These regulations are in accordance with the state of California Department of Public Health Administrative Code, Title 17, entitled “Regulations Relating to Cross-Connections”. This Chapter is adopted in accordance with California Health and Safety Code section 116800 et seq. and the requirements of the State Water Resources Control Board Cross-Connection Control Policy Handbook, adopted December 19, 2023, effective July 1, 2024, revised June 17, 2025, as both may be amended from time to time.

It is the intent of these regulations to recognize that there are varying degrees of hazards and to apply the principle that the degree of protection should be commensurate with the degree of hazard.

SECTION 2. CEQA
Agenda Item #7.5:

This Ordinance has been assessed in accordance with the authority and criteria contained in the California Environmental Quality Act (CEQA), the State CEQA Guidelines, and the environmental regulations of the city. City Staff has determined that the adoption and implementation of the Ordinance is exempt from further environmental review under the general rule in California Environmental Quality Act (CEQA) Guidelines Section 15061(b)(3) that CEQA only applies to projects that have the potential for causing a significant effect on the environment. The City Council concurs in these findings and adopts them as its own. The City Council, therefore, directs that a Notice of Exemption be filed with the County Clerk of the County of Sonoma in accordance with CEQA Guidelines.

SECTION 3. Severability.

If any section, subsection, subdivision, sentence, clause, phrase, or portion of this Ordinance for any reason is held to be invalid or unconstitutional by the decision of any court of competent jurisdiction, such decision shall not affect the validity of the remaining portions of this Ordinance.

The City Council hereby declares that it would have adopted this Ordinance, and each section, subsection, subdivision, sentence, clause, phrase, or portion thereof, irrespective of the fact that any one or more sections, subsections, subdivisions, sentences, clauses, phrases, or portions thereof be declared invalid or unconstitutional.

SECTION 4. Effective Date.

This ordinance shall take effect thirty (30) days after passage thereof.

SECTION 5. Publication.

This ordinance shall be published in accordance with the provisions of Government Code section 36933, subdivision (c)(1).

SECTION 6. This Ordinance Prevails Where There is Conflict.

To the extent that this Ordinance conflicts with any other provision in the Sonoma Municipal Code or city ordinance (urgency or otherwise), policy or regulation, this Ordinance will control.

Introduced and first read at a Regular Meeting of the City Council on the 30th of March 2026.

PASSED, RESOLVED, AND ADOPTED, at a Regular Council Meeting of the City Council of the City of Sonoma held on the 15th day of April 2026, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
___________________________________
Ron Wellander, Mayor
ATTEST:
_______
Monique Saviez Burns, CPMC, CMC
Deputy City Clerk
___________________________________
Date
Agenda Item #7.5:

I HEREBY CERTIFY that the foregoing ordinance was duly and regularly adopted by the City Council of the City of Sonoma, Sonoma County, California, at a meeting thereof, held on the 15th day of April 2026, by the following vote:

AYES:

NOES:

ABSTAIN:

ABSENT:
_______
Monique Saviez Burns, CPMC, CMC
Deputy City Clerk
Agenda Item #7.5:

City of Sonoma
Agenda Item Summary
Meeting: City Council - 15 Apr 2026
Department
Public Works
Staff Contact
Ashley Cotter, PW Admin & Project Manager
Agenda Item Title
Adopt a Resolution Authorizing a Budget Amendment to Increase One Time Expenditures from the Long-Term Building Maintenance Fund by $26,980 for Police Station Maintenance and Repairs
Summary
Staff at the Police Department notified Public Works of several issues at the Police Department Building. While the City contracts with the Sheriff's Department for law enforcement services, the building is a city-owned facility that is maintained by the City.

Issues reported to Public Works included water leaking from the fire sprinklers, as well as the All-Guard alarm sounding due to required system updates not being installed.

Public Works staff contacted Peterson Mechanical to investigate the water leak issue. The water intrusion stemmed from a defective drain pan installed with the HVAC system. Staff also contacted North Counties Drywall to investigate damage done to the ceiling from the water.

The total cost for these repairs is as follows:
 $9,040 for drain pan repair (contracted through Peterson Mechanical)  $2,900 for refrigerant leak check for the installed HVAC unit (contracted through Peterson Mechanical)
 $5,300 for replacement of insulation, drywall, and texture finish for ceiling (contracted through North Counties Drywall, Inc)
 $3,740 for All Guard alarm replacement (provided by All-Guard). The existing alarm is too old to upload current updates, and the system needs a new alarm.  Contingency - $6,000 - this high amount is due to not being able to visualize the water damage done to the wall, if the water leak was not isolated to the ceiling, a similar scope of work (replacement of insulation, drywall, and texture finish) will be required for the wall as well. If damage to the wall is not observed, and no other changed conditions in the field require additional funding, this will not be utilized.

This constitutes a total of $26,980 required for repairs to the police station. Staff determined that increasing expenditures from the Long-Term Building Maintenance Fund (LTBM) would be the most appropriate as the nature of these unplanned repairs are to ensure the long-term care and maintenance of the facility.

Contracts for the necessary repairs will be approved in accordance with the City's purchasing ordinance (SMC 3.04.080) and the Uniform Construction Cost Accounting Act, which allows projects costing $75,000 or less to be performed by employees of a public agency by force account, by negotiated contract, or by purchase order.

Recommended Council Action
Agenda Item #7.6:

Adopt a Resolution Authorizing a Budget Amendment to Increase One Time Expenditures from the Long-Term Building Maintenance Fund by $26,980 for Police Station Maintenance and Repairs.

Alternative Actions
Direct staff to investigate alternative funding methods, such as Parks Repair and Maintenance, Police Repair and Maintenance, or Non-Departmental Repair and Maintenance.

This is not recommended at this time as it is a relatively large expenditure, which was not budgeted for during FY25-26 budget development. Paying for these services out of these operational accounts could impact staff's ability to conduct planned operations and projects as it would reduce available funding.

Financial Impact
This budget adjustment would increase the Long-Term Building Maintenance Construction/Materials expenditures by $26,980. The LTBM fund has sufficient funding to support this effort. This fund functions as an internal service fund, with each department contributing towards facilities maintenance annually during budget adoption.

Environmental Review Status
Environmental Impact Report
Negative Declaration
Exempt
Not Applicable
Approved/Certified
No Action Required
Action Requested
Attachments
LTBM Resolution
Budget Adjustment Form
Alignment with Council Goals:

Agenda Item #7.6:

City of Sonoma
RESOLUTION # _______ - 2026

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SONOMA AMENDING THE FISCAL YEAR 2025-26 ADOPTED BUDGET
WHEREAS, on June 18, 2025, the City Council of the City of Sonoma adopted Resolution 37-2025, adopting the budget for Fiscal Year 2025-26 and WHEREAS, the changes in anticipated revenues and/or expenditures of the City of Sonoma necessitate amendments to the appropriations for Fiscal Year 2025-26; and WHEREAS, the budgeted expenditures do not exceed anticipated revenue and available fund balance; and
WHEREAS, the City Council has reviewed the proposed Fiscal Year 2025-26 budget amendment; and
NOW, THEREFORE, BE IT RESOLVED, that the City Council of the City of Sonoma hereby adopts the budget amendment for Fiscal Year 2025-26 as contained in Exhibit A to this resolution.

PASSED, RESOLVED, AND ADOPTED, at a Regular meeting of the City Council of the City of Sonoma on this 15th day of April 2026, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
__________________________________
Ron Wellander, Mayor
ATTEST:
__________________________________
Monique Saviez Burns, CPMC, CMC
Deputy City Clerk
Agenda Item #7.6:

Batch ID#:

Entered By:

Date:

Request Date: 4/6/2026 Fiscal Year: 2025-26
Requesting Department: Public Works
Adjustment Description: Adjustment for Repair and Maintenance for Police Station Requestor: Ashley Cotter, PW Admin/Project Manager
Department Head Approval: Mike Berger, Director of Public Works Date: 4/6/2026 Finance Review: Ryan Kodama, Accounting Manager Date: 4/6/2026 City Manager Approval (if required)*: Cristine Alilovich, Interim City Manager Date:

Net Adjustment:

Justification:

City Clerk Signature (if required)**: Date:

Budget Adjustment Form
Account Description of Adjustment Increase / (Decrease) Finance Department Use Only
Total Revenue Adjustments:

Account Description of Adjustment
610-64250-011-70703
Increase of LTBM Expenditurese in Construction and Materials for repairs required at the Police Station
Total Expenditure Adjustments: 26,980.00
26,980.00
* City Manager Approval required for transfers between departments within the same fund, any changes to salary/benefit budgets, or matching increases to revenue and expense budgets.
** City Clerk Signature indicates that the requested Budget Adjustment was approved by Council. -
Increase / (Decrease)
26,980.00
26,980.00

TOTAL DEBIT
The Police Department has several repairs needed due to a leak from the HVAC equipment - this includes repairs to the existing asset, leak check, and repairs to the ceiling and possibly the wall depending on the level of damage done by the water intrusion.
-

TOTAL CREDIT
Agenda Item #7.6:

City of Sonoma
Agenda Item Summary
Meeting: City Council - 15 Apr 2026
Department
Public Works
Staff Contact
Ashley Cotter, PW Admin & Project Manager
Agenda Item Title
Adopt a Resolution Authorizing a Budget Adjustment to Move Funds from Water Enterprise Fund General Supplies to the Vehicle Replacement Fund for the Purchase of a Backhoe Thumb Attachment
Summary
Public Works Water Enterprise would like to purchase a backhoe thumb attachment (quote attached). Currently, the mini excavator is shared by Streets, Parks, and Water. Due to limited equipment, work can be delayed. Purchasing the thumb would add a lot of utility to the Water Department's backhoe. Additionally, this would increase departmental efficiency by maximizing the utility of the backhoe and reducing time spent coordinating shared resources.

This purchase has been approved by the Public Works Director and the City Manager (City Manager approval attached), who are authorized to approve a purchase of this value under the City's purchasing policy.

While staff did not budget for this purchase, there is sufficient funding in Water Enterprise Fund's General Supplies Line Item. The cost of this attachment is $18,742.50. Freight was quoted at $900, and including sales tax, the total cost for this attachment is $21,563.61. The Water Enterprise Fund General Supplies line item has sufficient funding for this purchase. In order to correctly record this purchase as a capital asset, staff has recommended that Public Works process a budget amendment to move the funding from the Water Enterprise Fund General Supplies to the Vehicle Replacement Fund (VRF) line item for equipment purchases.

After this budget amendment has been approved, this purchase will be paid out of the Vehicle Replacement Fund for the full value of the asset and acquired in conformance with the City's purchasing policy.

Recommended Council Action
Adopt a Resolution Authorizing a Budget Adjustment to Move Funds from Water Enterprise Fund General Supplies to the Vehicle Replacement Fund for the Purchase of a Backhoe Thumb Attachment
Alternative Actions
Council discretion.

Financial Impact
The funding is currently available in the Water Enterprise Fund General Supplies line item to purchase the thumb attachment; however, to accurately capture the value of the fixed asset being purchased. The funding that is currently in the Water Enterprise Fund will be moved to the Vehicle Replacement Fund (VRF). After this, the equipment will be paid for out of the VRF.

Agenda Item #7.7:

Environmental Review Status
Environmental Impact Report
Negative Declaration
Exempt
Not Applicable
Approved/Certified
No Action Required
Action Requested
Attachments
Amulet Thumb Quote
CM Approval
VRF Resolution
Budget Adjustment Form
Alignment with Council Goals:

Not Applicable
Agenda Item #7.7:

CUSTOMER: ESTIMATE#
ADDRESS: DATE:

LOCATION: WORKORDER:

CONTACT: PHONE:

PHONE: MODEL: SERIAL:

E-MAIL: HOURS: UNIT
X
X
1 $ 9,125.00 $ 8,725.00 $ 17,850.00
$ -
2 $ -
$ -
3 $ -
$ -
4 $ -
$ -
5 $ -
$ -
6 $ -
$ -
7 $ -
$ -
8 $ -
$ -
9 $ -
$ -
10 $ -
$ -
11 $ -
$ -
12 $ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ 9,125.00 $ 8,725.00 $ 17,850.00
NOTE: PARTS $ 9,125.00
* THIS ESTIMATE ASSUMES ALL CORES MEET CORE ACCEPTANCE. DOES NOT INCLUDE ANY OTHER LABOR $ 8,725.00 MACHINING, FABRICATION OR WELDING NOT SPECIFICALLY LISTED ABOVE. THE CUSTOMER WILL BE TRAVEL CONTACTED FOR APPROVAL ON ANY EXTRA WORK. ALL REUSED PARTS MUST MEET REUSABILITY FREIGHT GUIDELINES BY INSTALLER. ALL PARTS WILL BE ORDERED STOCK ORDER TERMS. NO FREIGHT, TAX OR MISC $ 892.50 SPECIAL SERVICE CHARGES ARE INCLUDED IN THE ESTIMATE. FEES MAY INCLUDE ENVIRONMENTAL FEES, TAX WELDING FEES, OR SHOP SUPPLIES, OR MISC. SERVICE SUPPLIES IF APPLICABLE. TOTAL * $ 18,742.50

ESTIMATE VALID UNTIL
CUSTOMER AUTHORIZATION: DATE:

Please call with any questions regarding your account status.

DESCRIPTION OF REPAIRS PARTS LABOR TOTAL
account limits are considered COD. Cash, check, or credit card will be required before machine PAPE MACHINERY, INC.

City of Sonoma
Pape R/P shop
3/31/2026
Product Support Estimate
Estimate
5380 Commerce Blvd ~ Rohnert Park, CA 94928 ~ (707) 584-9161 Bob Meade Pape Machinery 707 584-9161
310L
**** all non stock parts are subject to a 20% restocking fee **** Install 17"Amulet thumb, lines kit, and 6th function valve kit with pedal actuator and reliefs Fabricate hoses and set aux. hydraulic pressures.
707 694-8194
[email protected]
Tommy
1T0310LXCKF368126
The lines kit and 6th function kit have lead times that I will get when I order the parts. can be released. Workorders will require a 50% down payment / deposit.

SEG
SHOP

FIELD ESTIMATE
QUOTE
Repairs performed from approved estimates for cash customers or customers that exceed their This estimate is subject to a 10% variance.
> > > T O T A L S > > >
****All nonstock parts are subject to a 20% restock fee**** THANK YOU FOR YOUR BUSINESS!
Agenda Item #7.7:

From: David Guhin
To: Ashley Cotter; Ryan Kodama
Cc: Mike Berger; MacLean Meyn; Terrence Erickson
Subject: RE: Water Backhoe Thumb Purchase
Date: Tuesday, March 31, 2026 4:34:03 PM
Attachments: city of sonoma 310L amulet thumb.pdf
Approved
David
From: Ashley Cotter <[email protected]>
Sent: Tuesday, March 31, 2026 4:31 PM
To: David Guhin <[email protected]>; Ryan Kodama <[email protected]> Cc: Mike Berger <[email protected]>; MacLean Meyn <[email protected]>; Terrence Erickson <[email protected]>
Subject: Water Backhoe Thumb Purchase
Hi David and Ryan,
The water department would like to purchase a thumb for our backhoe. Currently, streets and water share the mini excavator, which can delay work. By purchasing the thumb, we are adding a lot of utility to our backhoe, and would go a long way towards increasing efficiencies as it would reduce sharing/coordinating equipment use. David, while this is in your signing authority, and we need your approval to move forward with the purchase, it does need to go to council for a budget adjustment to move the funds from General Supplies to the VRF to capture this as an asset and capitalize it.

Ryan – I’ll work with you to get the BA in place, this is going to be a copy/paste of what we did previously for the flail mower attachment.

Please don’t hesitate to reach out if you have any questions! Ashley Cotter
Public Works Administrative and Project Manager
City of Sonoma
707-933-2233
City of Sonoma records, including emails, are subject to the California Public Records Act. Unless exemptions apply, this email, any attachments and any replies are subject to disclosure on request, and neither the sender nor any recipients should have any expectation of privacy regarding the contents of such communications.

Agenda Item #7.7:

City of Sonoma
RESOLUTION # _______ - 2026

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SONOMA AMENDING THE FISCAL YEAR 2025-26 ADOPTED BUDGET
WHEREAS, on June 18, 2025, the City Council of the City of Sonoma adopted Resolution 37-2025 adopting the budget for Fiscal Year 2025-26 and WHEREAS, the changes in anticipated revenues and/or expenditures of the City of Sonoma necessitate amendments to the appropriations for Fiscal Year 2025-26; and WHEREAS, the budgeted expenditures do not exceed anticipated revenue and available fund balance; and
WHEREAS, the City Council has reviewed the proposed Fiscal Year 2025-26 budget amendment; and
NOW, THEREFORE, BE IT RESOLVED, that the City Council of the City of Sonoma hereby adopts the budget amendment for Fiscal Year 2025-26 as contained in Exhibit A to this resolution.

PASSED, RESOLVED, AND ADOPTED, at a Regular meeting of the City Council of the City of Sonoma on this 15th day of April 2026, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
________________________________
Ron Wellander, Mayor
ATTEST:
________________________________
Monique Saviez Burns, CPMC, CMC
Deputy City Clerk
Agenda Item #7.7:

Batch ID#:

Entered By:

Date:

Request Date: 4/6/2026 Fiscal Year: 2025-26
Requesting Department: Public Works
Adjustment Description: Adjustment for Purchse of Backhoe Thumb Attachment Requestor: Ashley Cotter, PW Admin/Project Manager
Department Head Approval: Mike Berger, Director of Public Works Date: 4/6/2026 Finance Review: Ryan Kodama, Accounting Manager Date: 4/6/2026 City Manager Approval (if required)*: Cristine Alilovich, Interim City Manager Date:

Net Adjustment:

Justification:

City Clerk Signature (if required)**: Date:
* City Manager Approval required for transfers between departments within the same fund, any changes to salary/benefit budgets, or matching increases to revenue and expense budgets.
** City Clerk Signature indicates that the requested Budget Adjustment was approved by Council. -
Increase / (Decrease)
(21,563.61)
21,563.61

TOTAL DEBIT
The Water Department would like to purchase a thumb attachment for the backhoe. This was not budgeted through the VRF, but the Water Fund General Supplies line item has sufficient funding for this purchase. However, this will not accurately capture the fixed asset. In order to do that, the funding will be transferred to the Vehicle Replacement Fund, and after the transfer, the equipment will be paid for out of this fund.
-

TOTAL CREDIT
Total Expenditure Adjustments: -
-
603-64510-604-70604
Funding from Water Enterprise Fund General Supplies for purchase of Thumb Attachment
Total Revenue Adjustments:

Account Description of Adjustment
510-62001-501-70501
Funding from Water Enterprise Fund General Supplies for purchase of Thumb Attachment
Budget Adjustment Form
Account Description of Adjustment Increase / (Decrease) Finance Department Use Only
Agenda Item #7.7:

City of Sonoma
Agenda Item Summary
Meeting: City Council - 15 Apr 2026
Department
Community Development
Department
Staff Contact
Jennifer Gates, AICP, Community Development
Director
Agenda Item Title
Study Session to Discuss Draft Ordinance for Mobilehome Park Closures and Conversions Under the City of Sonoma Municipal Code and Recent Legislative Changes Under AB 2782 and SB 610.

Summary
Background
On November 5, 2025, the City Council held a Study Session (Link to Agenda, Report, and Video) to discuss legal and procedural requirements for mobilehome park closures and conversions under the City of Sonoma Municipal Code and recent legislative changes under AB 2782 and SB 610. At that meeting staff provided the requirements under Sonoma Municipal Code Chapter 9.82, the existing closure/conversion process, and the updates needed to comply with state law.

On December 3, 2025, the City Council held a Study Session (Link to Agenda, Report, and Video) to provide direction to staff on revisions to the closure and conversion ordinance allowed under state law for inclusion in an updated draft ordinance to be considered and adopted in early 2026. AB 2782 amended Government Code section 65863.7, which provides the minimum requirements for mobilehome park conversions and states:

This section establishes a minimum standard for local regulation of the conversion of a mobilehome park to another use, the closure of a mobilehome park, and the cessation of use of the land as a mobilehome park and shall not prevent a local agency from enacting more stringent measures.[1]
To assist the discussion, staff prepared two matrices:

1. Compliance Options – provides current code, state law, proposed ordinance provided by the mobilehome owners and residents (Tri-Park Committee ordinance), and options for consideration to begin the discussion (further discussed below).

2. Jurisdiction Examples – Examples from four cities comparing key components of their mobilehome conversion and closure ordinance. The codes from each jurisdiction are also attached.

Staff separated the discussion into key areas with questions to assist in the dialogue. At that meeting staff received direction and some questions for further discussion. The City Attorney’s office and staff updated the existing ordinance based on the direction received, which is attached in strikeout and underline format. Staff also summarized the direction in the updated Compliance Options Matrix attached. Further discussion on changes made and the areas for further discussion is provided below.

Agenda Item #9.1:

Chapter 9.82 - Mobilehome Park Conversions
Chapter 9.82 of the Municipal Code, titled "Mobilehome Park Conversions," establishes the rules and processes required when a property owner proposes to close or convert an existing mobilehome park to a different use. The conversion or closure of mobilehome parks can have a substantial adverse effect on residents due to the high cost of relocation, the difficulty of finding similar, affordable replacement housing, and the scarcity of comparable mobilehome spaces in the area.

Key Areas for Discussion

1. Mandatory Relocation Impact Report (RIR)
Any person applying to change the use, close, or cease operations of a mobilehome park must file a comprehensive Mobilehome Relocation Impact Report (RIR). Applications will not be considered complete until this report is filed. SMC Section 9.82.035was updated with clarifying language and dates and incorporates additional changes including the use of a state certified appraiser and a relocation housing specialist.

2. Notification and Timeline
The City’s current notice requirement that mobilehome park owners provide the mobilehome owners and residents the RIR is being extended from 15 days before the hearing to at least 60 days before the hearing in compliance with AB 2782. The draft ordinance includes a requirement that mobilehome park owners provide all residents at least 30 days notice of their intent to convert or close the park before submitting an initial application. Additionally, a closure or conversion approval will expire after two years with a one year extension available.

Staff has prepared a timeline as an attachment highlighting critical dates.

3. Relocation and Payments
State law requires the RIR to include a “replacement and relocation plan that adequately mitigates the impact upon the ability of the displaced residents of the mobilehome park to be converted or closed to find adequate housing in a mobilehome park.” Draft SMC Section

9.82.035(C)(14) contains examples of what can be included.This section of the SMC also includes a requirement that a relocation housing specialist will assist with the development of the relocation plan.

Additional changes include relocation assistance options specific to low-income households and households with persons with disabilities and that any relocation payments be made not less than 90 days before the date to vacate the mobilehome park.

A question that City Council wanted to further discuss was the definition of comparable mobilehome parks in the creation of the relocation impact report. The Tri-Park Committee ordinance identifies comparable parks to be up to a distance of 20 miles or in Sonoma or Napa Counties and of similar Cal EPA’s CalEnviroScreen score and not in a disadvantaged community. Currently, the City’s code states comparable parks are only those in Sonoma County. The use of the Tri-Park Committee ordinance definition would limit the parks reviewed in the RIR. Staff has provided further information in an attachment.

4. Valuation / Appraisal
The draft ordinance has been updated to reflect state law that the “in-place market value” must be appraised by a state certified appraiser and submitted as part of the RIR.

During the study session, City Council wanted to better understand why a jurisdiction would Agenda Item #9.1:

include the park in the appraisal. The proposed ordinance from the Tri-Park Committee includes an appraisal for the mobilehome park with its current and future values to be included in the RIR. Staff believes the reason behind including the appraisal of the park’s value is to better determine the ability of the park to pay for the relocation assistance. Staff has added this requirement if the applicant requests an exemption from providing relocation assistance (SMC Section 9.82.070(C)(4)).

5. Review Procedures and Findings
The draft ordinance continues with the City Council as the approval body of a newly created “Conversion Permit.” This permit shall be considered concurrently with any required planning permit(s) if the applicant is proposing the conversion to a new use. SMC Section 9.82.065 Relocation assistance has been updated with additional means to mitigate impacts specific for lower income households and residents with disabilities.

6. Consistency Findings (Housing Element/RHNA/lower income housing availability) The findings to be made by the City Council have been updated to comply with state law including addition of a finding regarding potential impact on shortage of housing opportunities for lower-income households.

7. Resident Purchase / Right of First Refusal (ROFR)
The City currently requires the Council to make a finding regarding if ROFR is provided and the draft ordinance further details what types of ROFRs may be provided as options for relocation assistance.

8. Public Outreach
A new SMC Section 9.82.040 has been added to require the completion of resident/ mobilehome owner questionnaires to be used in preparing the RIR. In addition, an information meeting held by the applicant for the mobilehome owners and residents is now required before the public hearing before the City Council.

9. Enforcement Tools
The ordinance has been updated to require a written agreement to be recorded against the mobilehome park within 30 days after approval of the permit to ensure compliance.

10. Revocation
A revocation process has been added in draft SMC Section 9.82.075(C) for non-compliance with the Conversion Permit or any other enforceable permit, condition, or legal provision.

11. Other
State law requires an exemption for bankruptcy which has been maintained. A provision has been added in SMC Section 9.82.070 allowing for an exemption from relocation assistance requirements based on a reasonable use or economic value.

Public Comments
Comments have been received from representatives for the mobilehome owners and the mobilehome park owners that are attached to this report.

Next Steps
Staff is requesting further direction and questions or requests for additional information. We will take the direction provided and return to introduce the final draft ordinance, unless an additional study session is requested. City staff will continue to work with residents and park Agenda Item #9.1:

owners through the process to ensure everyone has the time and forum to provide input before a public hearing.
[1] Gov. Code, § 65863.7, subd. (l).

Recommended Council Action
Provide direction to City staff on ordinance changes.

Alternative Actions
Council discretion.

Financial Impact
Not applicable.

Environmental Review Status
Environmental Impact Report
Negative Declaration
Exempt
Not Applicable
Approved/Certified
No Action Required
Action Requested
Attachments
Chapter 9.82 redline 03182026
MH Direction Matrix 04092026
MH Important Dates
MH Comparable Parks
Mobilehome Owners Comment Letter
Mobilehome Park Owners Comment Letter
Alignment with Council Goals:

Agenda Item #9.1:

1 Chapter 9.82

MOBILEHOME PARK CONVERSIONS
Sections:

9.82.010 Purpose and intent.

9.82.015 Definitions.

9.82.020 Applicability.

9.82.025 Disclosure of notification requirements.

9.82.030 Relocation impact report required.

9.82.035 Notice and distribution of relocation impact report.

9.82.040 Notice to new residents.

9.82.045 Hearing on relocation impact report.

9.82.050 Findings.

9.82.055 Relocation assistance.

9.82.060 Bankruptcy exemption.

9.82.065 Administration fee.

9.82.010 Purpose and intent.

9.82.015 Definitions.

9.82.020 Applicability.

9.82.025 Application for conversion permit.

9.82.030 Notice of intent to residents.

9.82.035 Relocation impact report required.

9.82.040 Resident questionnaire required.

9.82.045 Notice of relocation impact report and hearing on conversion permit application.

9.82.050 Notice to prospective residents.

9.82.055 Hearing on relocation impact report.

9.82.060 Findings.

9.82.065 Relocation assistance.

9.82.070 Exemption from relocation assistance obligations.

9.82.075 Written agreement.

9.82.080 Expiration of approval.

9.82.085 Bankruptcy exemption.

9.82.090 Administration fee.

9.82.010 Purpose and intent.

A. Where a person proposes to convert an existing mobilehome park to another use or to close a mobilehome park or to cease using land as a mobilehome park, current provisions of state law, as set forth in Government Code Section 65863.7 and Civil Code Section 798.56, authorize the city to require the person proposing the change of Agenda Item #9.1:

2 use to file and distribute a report on the impact of such change and further authorize the city to require measures to be undertaken to mitigate the adverse effects of the change of use upon the tenantsresidents of the mobilehome park who would be displaced by such change.

B. The city council finds and determines that unless mitigation measures are undertaken, the conversion, closure or cessation of use of mobilehome parks could have a substantial adverse effect upon park residents in terms of cost of relocation, scarcity of similar comparable housing within a reasonable proximity to the city, and the significantly higher costs of other types of housing in the immediate area if park residents cannot relocate to other mobilehome parks.

C. It is the intent and purpose of the city council in adopting this chapter to ensure that the social and fiscal impacts of a proposed conversion, closure, or cessation of use of a mobilehome park are adequately defined prior to consideration of a proposed change of use; to establish reasonable rules and regulations in accordance with the authority granted by state law to mitigate the adverse effects of relocationdisplacement upon mobilehome park residents who are confronted with a proposed changeconversion, closure, or cessation of use forof their mobilehome park or portions of the park; and so that the owners and occupants of mobilehomes and theresidents and owners of mobilehome parks understand their rights and responsibilities in such situations.

9.82.015. Definitions.
“Applicant” means the person(s), firm(s), entity(ies) or corporation(s) applying for any application for the purposeconversion, closure, or cessation of converting, changing to another use, closing, or ceasing to use land as of a mobilehome park or any portion thereof. If the owner of the controlling interest in a mobilehome park is not the applicant, then the applicant must provide evidence of the controlling owner’s consent to the filing of the application.
“Cessation of use of land as a mobilehome park” means a decision by the owner(s) of a mobilehome park to discontinue the park’s discontinuation of use of property as a mobilehome park, which is not an adjudication of bankruptcy. “Closure of a mobilehome park” means one of the following:

A. A. A closure of a mobilehome park occurs when less than 75 percent of the occupiable spaces are leased by qualified homeowners as defined in the Mobile-Home Residency Law (Civil Code Section 798 et seq.). However, upon application of a mobilehome park owner, the city council may, in its absolute discretion and upon a finding of good cause, determine that a closure of a mobilehome park is not occurring, notwithstanding that less than 75 percent of the occupiable spaces are leased. Any such application by the mobilehome park owner shall be accompanied by an estimate of a qualified appraiser as to the fair market value of the mobilehome(s) and all associated Agenda Item #9.1:

3 fixed property for which the foregoing exemption is requested. The appraiser’s estimate shall conform to the requirements of SMC 9.82.030(C)(12).9.82.035(C)(12).

B. B. Notwithstanding the provisions set forth in subsection A of this definition, a closure of a mobilehome park occurs when the city council, in its absolute discretion and upon a finding of good cause, determines that the mobilehome park owner has acted and/or has failed to act in a manner whichowner’s actions or omissions would cause a reasonable person to conclude that the mobilehome park owner intends to eliminate or reduce mobilehome spaces available for rent to the general public. Such acts or omissionsconduct may include, but are not limited towithout limitation, the withholding of available mobilehome spaces under the control of the mobilehome park owner, and statements by authorized agents and representatives of the mobilehome park owner to prospective buyers of the mobilehome park that the mobilehome park is being closed by the mobilehome park owner.
“Comparable housing” means housing which is comparable in floor area andsize, number of bedrooms, bathrooms, amenities, and other rooms to the mobilehome to which comparison is being made, which housing meets the minimum standards of the Uniform Housing Code...
“Comparable mobilehome park” means any other mobilehome park within Sonoma County, substantially equal in terms of park amenities, rent and proximity to services. “Conversion of a mobilehome park” means changing the use of a mobilehome park or a portion thereof for a purpose other than the rental, or the holding out for rent, of two or more mobilehome sites to accommodate mobilehomes used for human habitation. A conversion shall include, but not be limited to, a change of any existing mobilehome park or any portion thereof to condominium, stock cooperative, planned unit development, or any form of ownership wherein spaces within the mobilehome park are to be sold, or the. Conversion includes cessation of use of all or a portion of the park as a mobilehome park, whether immediately or on a gradual basis, or theand closure of a park.
“. Conversion of a mobilehome park” shall not include a conversion of a mobilehome park to resident ownership.
“Conversion of a mobilehome park to resident ownership” means a sale, transfer or assignment of a mobilehome park either directly or indirectly in whole or in part to mobilehome park’s homeowners and prospective homeowners for the benefit of the mobilehome park’s homeowners and prospective homeowners. A conversion of a mobilehome park to resident ownership may include but not be limited to, conversion of the community to a subdivision, condominiums, planned development, community apartments, stock cooperative, other form of corporate ownership, or by a nonprofit organization qualified pursuant to Internal Revenue Code Section 501(c)(3) for the homeowners’ or prospective homeowners’ benefit. Notwithstanding any provision in this Agenda Item #9.1:

4 chapter to the contrary, in the event the conversion of a mobilehome park to resident ownership is by a nonprofit corporation qualified under Internal Revenue Code Section 501(c)(3),501(c)(3), homeowners may or may not have the right to participate through direct ownership of the mobilehome park and the nonprofit shall not be required to make an offer of participation to the homeowners.
“Department” shall mean the community development department of the city of Sonoma.
“Director” shall mean the director of the department.
“Resident with disabilities” means a resident with a physical or mental disability, as defined under the Federal Fair Housing Amendments Act of 1988 and the California Fair Employment and Housing Act, as amended from time to time. “Homeowner” means the owner(s) of a mobilehome.
“Impact report” means a report required by California Government Code Sections 65863.7 and 66427.4, as applicable, and containing the information set forth in SMC

9.82.030(C). “Impact report” does not include the impact required by Government Code Section 66427.5(b) for conversion to resident ownership. “Long-term lot” means anya mobilehome lot that has been occupied by the same mobilehome for at least nine of the 12 months prior to the adoption of this chapterpark. “Low-income household” means a household with an annual income less than 80 percent of the area median income of households in Sonoma County, as defined by the California Housing and Community Development Department. “Mobilehome” means a vehicle designed or used for human habitation and shall include camping trailers, motorhomes, slide-in campers and trailers, when used as the occupant’s principal place of residence, and mobilehomesstructure as defined in Health and SafetyCalifornia Civil Code Section 18211.798.3.
“Mobilehome lot” means any area or tract of land, or portion thereof, occupied or held out for occupancy by one mobilehome that is not owned by the park owner. “Mobilehome park” means anyan area or tract of land where 10two or more mobilehome lotssites are rented or leased, or held out for rent or lease, to accommodate mobilehomes used for human habitation.
“Moderate-income household” means a household with an annual income less than 120 percent of the area median income of households in Sonoma County, as defined by the California Housing and Community Development Department. “Relocation impact report” means a report required by Government Code Sections 65863.7 and 66427.4, as applicable, and containing the information set forth in SMC Agenda Item #9.1:

5 9.82.035(C). Relocation impact report does not include the impact required by Government Code Section 66427.5(b) for conversion to resident ownership. “Resident” meansincludes a homeowner or tenant.
“Tenant” means a personand all persons who occupieslawfully occupy a mobilehome within a mobilehome park pursuant to a bona fide lease or rental agreement and who, during his or her tenancy, is not the owner or member of the immediate household of the owner of the mobilehome. .

9.82.020 Applicability.

A. For applications involving the redevelopment, closure, or conversion, or cessation of use of a mobilehome park that include a subdivision map, the provisions of Chapter 9.849.84 SMC shall apply. The provisions of this chapter shall not apply to such applications, except as specifically referenced in Chapter 9.84 SMC.

9.82.025 Disclosure of notification requirements.

B. When anAn application has been made to the city for the redevelopment, closure or, conversion, or cessation of use of a mobilehome park, the city shall be considered concurrently with, and as a necessary prerequisite to, any required planning permit(s) or approval(s) for the new intended use, if any, of the mobilehome park, with review being the responsibility of the higher decision-making body.

9.82.025 Application for conversion permit.

No conversion of a mobilehome park is allowed except upon issuance and in compliance with a conversion permit issued by the city council under this chapter. An applicant desiring to close, convert, or cease the use of a mobilehome park or a portion thereof shall apply for a conversion permit, in addition to any necessary discretionary land use permit and development applications, as follows:

A. The applicant shall submit an initial application that includes, at a minimum, the following:

1. A detailed narrative description of the proposed use to which the mobilehome park or a portion thereof is to be converted or the reason for the closure or cessation of use of the mobilehome park or a portion thereof.

2. The proposed timeline for closure, conversion, or cessation of use.

3. Evidence of compliance with the notice requirements of SMC 9.82.030 regarding notification of homeowners and residents of the applicant’s intent to apply for closure.

Agenda Item #9.1:

6 When an initial application for a conversion permit has been submitted, the director shall inform the applicant, in writing, of local regulations regarding notifications to residents and mobilehome owners within the affected park, as well as the notification requirements set forth in Section 798.56798.56 of the Civil Code. This disclosure shall be made at least 30 days prior to any hearing on the application or the relocation impact report. No hearing on the application shall be held or any other action on the application taken until the applicant has satisfactorily verified that required notices have been provided to residents.

B. A final application shall include, at a minimum, the following:

1. The relocation impact report required under SMC 9.82.035 and Government Code Section 65863.7, as amended from time to time.

2. The resident questionnaires required under SMC 9.82.040.

Within 30 days after an applicant submits their final application to the department, the director shall review the initial and final applications for completeness and shall notify the applicant in writing that their application is complete or incomplete. After the applicant submits a complete application to the department, the director shall forward the application to the city council for final action. No conversion permit application shall be deemed complete, and processing for consideration will not commence, until the initial application and final application have been reviewed and approved as to their completeness by the director and all applicable application fees have been paid.

9.82.030 Notice of intent to residents.

At least 30 days prior to filing the conversion permit initial application with the department, the applicant shall give written notice to residents in the affected mobilehome park, in the manner prescribed by Section 1162 of the Code of Civil Procedure, of the applicant’s intent to convert the mobilehome park.

9.82.035 Relocation impact report required.

A. A. Any person who files an final application with the city for a general plan amendment or for a rezoning of land use type or density, or for approval of a conditional useconversion permit or any other application for the purpose of converting a mobilehome park to another use, close a mobilehome park or cease to use land as a mobilehome park, shall concurrently file with the city a mobilehomeinclude a relocation impact report that complies with this section. No such applications shall be considered or deemed complete or processed for consideration or approved unless and until such relocation impact report is filed and approved in accordance with this chapter.Government Code Section 65863.7, as amended from time to time.

B. B. At any time at which the occupancy of a mobilehome park is such that it meets the definition of “closure” as set forth in this chapter, the owner shall immediately provide written notification to the city of the event and shall either file a request for the Agenda Item #9.1:

7 preparation of a relocation impact report or shall petition the city council to make a finding that a closure is not occurring as set forth in SMC 9.82.015(A).9.82.015(A).

C. C. The Within 90 days of an applicant’s filing of an initial application, the city shall select one or more consultants, each of whom may retain subconsultants as necessary, including a consultantstate-certified appraiser with experience establishing the value of mobilehomes, and a housing relocation specialist with expertise in the fields of housing and relocation of persons displaced from housing to performprepare the relocation impact report within 90 days of a written request from the applicant.. The applicant shall be noticednotified in writing of the estimated cost of the relocation impact report and shall deposit that sum with the city prior to commencement of any work on the relocation impact report. The city will then contract with athe consultant(s) for the preparation of the relocation impact report. Once an application is filed, the residents of the mobilehome park shall be notified by the city that an application has been filed and that the preparation of a relocation impact report will be required. The relocation impact report shall contain, but need not be limited toat a minimum, the following information:

1. 1. A legal description of the property.

2. 2. A map and a detailed description of the condition of the mobilehome park, including the nature and location of structures, landscaping, easements, utilities and other on-site features and amenities.

3. 3. The names and addresses of all mobilehome owners within the parkresidents (including absentee mobilehome owners), as shown on the rental agreement for the mobilehome park spaces, homeowners owners and the names and addresses of allpersons who physically occupy a mobilehome tenants within the park) as of the date of the application.

4. 4. The characteristics of each mobilehome within the park, listed by space number and address, including the date of manufacture, type, width, living area, and number of bedrooms.

5. 5. The number of spaces within the park, length of occupancy by the current occupantresidents of each space and the current lease rate for each space.

6. 6. The total number of mobilehome residents, listed by space identifying owner or renter occupancy, principal or second home occupancy, and the number of residents who are physically disabled, including the chronically illwith disabilities.

7. 7. A description of the proposed new use and all discretionary approvals necessary therefor, if any.

8. 8. The proposed timetable for conversion, closure, or cessation of use of the land as a mobilehome park and for obtaining other discretionary approvals for the proposed use, if any.

Agenda Item #9.1:

8 9. 9. The location of all comparable mobilehome parks within Sonoma County, including the park name, number of mobilehome lots, number of vacancies, lease rates and terms, policies and restrictions on the type of mobilehomes and residents accepted, amenities offered and proximity to services (bus stops, grocery stores, hospitals, etc.).

10.10. A determination based on the information provided in subsections (C)(4), (5)(C)(4), (5) and (9)(9) of this section of the total number of mobilehome units that are eligible to be relocated to a comparable mobilehome park.

11.11. The estimated cost of relocating the mobilehomes identified in subsection (C)(10)(C)(10) of this section to available mobilehome lots in mobilehome parks within the study area. The cost of relocating shall include the costs of dismantling, packing, moving, reassembling, rebuilding and unpacking, as necessary, the mobilehome, all personal property, skirting, tie-downs and all other associated structures and property.

12.12. An estimate of the fair market value of each mobilehome and all associated fixed property that cannot be relocated to a comparable mobilehome park. In determining fair market value, the consultantappraisal shall considerbe based upon the mobilehomes in their current locations assumingin-place location of the mobile home and shall assume the continuation of the mobilehome park in a safe, sanitary and well maintained condition with competitive lease rates. The consultant shall specify the basis for a conclusion that any mobilehome cannot be relocated to a mobilehome park and the basis for determining the value of the mobilehome. The estimated fair market value shall be completed by a state-certified appraiser with experience establishing the value of mobilehomes. This subsection 12 shall not apply if the proposed closure, cessation, or change of use is related to damage or destruction by a disaster, as defined in Civil Code Section 798.64, as amended from time to time.

13.13. The availability and cost of rental housing of comparable size and qualityhousing in the city of Sonoma for each resident living in a mobilehome in the mobilehome park tenant..

14.14. A replacement and relocation plan, prepared with the assistance of a relocation housing specialist, to assist the residents in finding and moving to relocation mobilehome lots and comparable housing. The plans shall propose measures to mitigate the adverse impacts of the conversion on the residents in the park that will include a timetable for physically relocating the mobilehomes, or payment of relocation assistance, and additional options for assistance available to residents deemed necessary to mitigate impacts.

15.15. Proposed measures to mitigate the adverse impacts of the conversion upon each park resident based on SMC 9.82.055.9.82.065.

Agenda Item #9.1:

9 16. A list of persons, firms and organizations with proven expertise in the fields of housing and relocation of persons displaced from housing. This list shall include the names, addresses, telephone numbers, and fee schedules of persons who are qualified as mobilehome movers and appraisers of mobilehomes. The information shall include an explanation of the services that the housing specialists can provide.

16.17. A technical service inspection report from the Department of Housing and Community Development that identifies the observed conditions within the mobilehome park if the closure, cessation, or change of use is related to damage or destruction by a disaster, as defined in Civil Code Section 798.64, as amended from time to time.

16.17. Any information which the city managerdirector determines is necessary to address the specific issues raised by the application or the impact study and any information that may be necessary to implement the provisions of this chapter or Government Code Section 65863.7, as amended from time to time.

9.82.035 Notice and distribution of relocation impact report.

D. After completing the relocation impact report, the consultant(s) shall promptly file the complete report with the department together with the resident questionnaires required under SMC 9.82.040.

E. Any unused portion of the deposit required under this section shall first be applied to any outstanding conversion permit application fees established by the city council. Any remaining unused funds shall be returned to the applicant.

9.82.040 Resident questionnaire required.

A. A confidential resident questionnaire shall be sent to each park resident on a form provided by the city or its consultant(s) within 30 days of the applicant paying the deposit required under SMC 9.82.035. The questionnaires shall be kept separately from the rest of the application materials and shall not be included in the relocation impact report sent to each resident. The identity of each resident and his or her responses shall be kept confidential and used only to determine the relocation assistance to be provided to a particular resident. If a questionnaire contains insufficient information, the city or its consultant(s) may seek the information directly from the resident. . The questionnaire shall require the following information for each mobilehome space in the park:

1. The registered owner and legal owner of the mobilehome;

2. The identity, ages, number and any disabilities of the residents occupying the mobilehome;
Agenda Item #9.1:

10 3. The date of manufacture of the mobilehome, the name of the manufacturer, the size of the mobilehome, the number of bedrooms in the mobilehome, any special amenities in the home, including, but not limited to, equipment needed because of the medical condition, age, or disability of any resident in the home;

4. Any improvements or renovations to the mobilehome or improvements to the mobilehome lot made by the current resident, including, but not limited to, a new roof, porches, patios, awnings, siding, carports, pop-out rooms, recreational equipment, barbecue equipment, landscaping, etc., whether such improvements are movable and the cost of such improvements;

5. The purchase price paid by the current homeowner of the mobilehome and the amount and terms of any remaining mortgage or loan on the home;

6. Any special circumstance that would limit the area to which the resident or tenant is able to relocate;

7. Whether the residents receive Supplemental Social Security Income or qualify as moderate- or low-income household;

8. A notice that the identity of the resident and his or her responses shall be kept confidential and used only to determine the relocation assistance to be provided; and

9. A notice that the acceptance of relocation assistance from the applicant may limit or waive their rights to any assistance as provided by this chapter.

B. Any affected resident may decline to provide any information requested, but the cty’s determination of the reasonableness of the level of relocation assistance proposed in the relocation impact report will be based on information provided in response to the questionnaire, and the level of assistance deemed reasonable in an individual case may be limited, or the relocation assistance requirement may be eliminated, based on the owner's or resident's verified refusal to provide information necessary to make such a determination.

9.82.045 Notice of relocation impact report and hearing on conversion permit application.

A. Not less than 1560 days prior to a scheduled hearing before the city council, the park ownerapplicant shall transmitgive to the owner or occupant of each resident of a mobilehome occupying a sitemobilehome lot within the mobilehome park and to, including all other persons described in SMC 9.82.030(C)(3),9.82.035(C)(3), in the manner prescribed by Section 1162 of the Code of Civil Procedure, a copy of the relocation impact report, a copy of this chapter, and notices of the dates, times and places of the public hearings or any informational meetings. The copies provided shall be free of charge. Proof of service of distribution of the impact report to each resident must be filed by the applicant with the city managerdirector at least seven days prior to the hearing and shall be signed under penalty of perjury.

Agenda Item #9.1:

11 B. Not less than 30 days before the scheduled hearing before the city council applicant shall hold an informational meeting for the affected residents.

C. At least 20 days before the hearing, the director shall mail notice to the applicant and to the residents at the addresses identified report of the date, time and place of the hearing. At least 20 days before the hearing, the director shall cause the property to be posted with a notice of the date, time and place of the hearing. The notice of the hearing shall contain a general explanation of the matters to be considered by the city council.

9.82.040050 Notice to newprospective residents.

WhenAfter an application for a change of use and/or closure of a mobilehome park conversion permit has been filed with the citydepartment, the park owner shall advise each prospective new resident who proposes to occupy a mobilehome or mobilehome lot within such park after the filing of such application, in writing, that such application has been filed prior to the execution of a rental agreement or commencement of such occupancy, whichever occurs first, that such application has been filed..

9.82.045055 Hearing on relocation impact report.

A. A. When an application has been filed for a general plan amendment, rezoning, or conditional use permit for the proposed change of use and/or closure ofBefore approving a mobilehome parkconversion permit, the city managercouncil shall scheduleconduct a public hearing onto consider the conversion permit application. At the public hearing, the city council shall review the relocation impact report beforeand any additional relevant documentation provided to the city council within 30 days of receivingat the relocation impact reporthearing. The city council, in considering the relocation impact report and the application, shall make written findings based on evidence regarding the factors outlined in SMC 9.82.050.9.82.060. The city council may continue the public hearing from time to time.

B. B. At the public hearing, all interested parties will be allowed to present evidence to the city council on any aspect of the application., including the sufficiency of the relocation impact report. The evidence may include, but is not limited to, justification for the payment of relocation costs, including the fair market value of any mobilehome, evidence why a mobilehome cannot be relocated to a comparable mobilehome park, and similar information.

C. C. If the city council is unable to make findings consistent with SMC

9.82.0509.82.060 and is unable to impose reasonable measures as provided in SMC

9.82.0559.82.065 to mitigate the adverse impact(s) of relocationconversion, the city council shall deny the application for a conversion permit, unless the proposed conversion, closure or cessation of use.city council makes the finding under SMC

9.82.070(D). No other permit or approval shall be granted in furtherance of the proposed conversion, and no conversion, including change of use, including cessation or closure, shall occur unless a relocation impact reportconversion permit has been approved.

Agenda Item #9.1:

12 9.82.050060 Findings.

The city council, in considering the relocation impact report and conversion permit application, shall accept and hear evidence, shall consider such evidence, and shall make written findings based on such evidence regarding each of the following factors and any other factors as it deems appropriate:

A. A. That the relocation impact report provides the information required by state law and this chapter and that it provides the city council with adequate information on the impacts of the park conversion in terms of disruption to and displacement of affected residents and the methods available for addressing relocation needs.

B. B. ThatWhether there will exist, at the time of conversion, closure or cessation of use available mobilehome lots within Sonoma County to accommodate the mobilehomes to be displaced.

C. C. That adequate options are available forto adequately mitigate the impact on residents who would be disrupteddisplaced by the conversion.

D. D. That the relocation plan provides for reasonable costs of relocation based on the findings of the relocation impact report.

E. E. If the proposed conversion is to another residential use, whether the residents of the mobilehome park will have an opportunitythe right of first refusal to purchase, if for sale, or rent the new units, and whether the construction schedule will result in unreasonably long-term displacements.

F. F. That the proposed conversion will not be detrimental to the public health, safety and general welfare.

G. G. Whether, taking into consideration, both the relocation impact report as a whole and the overall housing availability within the local jurisdiction, the conversion will result in or materially contribute to a shortage of housing opportunities and choices for low- and moderate-income households within the city.

G.H. That all reports and notices required by law have been properly prepared and properly served.

9.82.055065 Relocation assistance.

In approving a relocation impact report an application for a conversion permit, the city council may attach reasonable conditions to the permit in order to mitigate the impacts associated with the conversion, closure or cessation of use. The specific conditions of approval of a particular application shall be determined on an application-by-application basis with regard to the actsfacts and circumstances of the application and the relocation impact report, but shall not exceed the reasonable cost of relocation, as documented in the relocation impact report. The city council shall require the applicant to enter into a written agreement with the city to ensure compliance with and fulfillment Agenda Item #9.1:

13 of the conditions of approval, whichas described in SMC 9.82.075. The conditions of approval may include but are not limited to the following matters:

A. A. Payment of relocation assistance to each resident who resided in the mobilehome park as of and after the date the application is filed or the date a closure, conversion or cessation of use is deemed by the city council to have commenced. If relocation assistance requires payment to a displaced resident of the mobilehome park, such payment shall be made not less than 90 days before the date that the resident is required to vacate the mobilehome park.

B. B. Payment to a homeowner whose mobilehome is being relocated to a mobilehome park of the:

1. The cost of physically moving the mobilehome to a new sitemobilehome lot, including teardown and setup of movable improvements such as patios, carports and porches; packing, moving and unpacking all personal property; and in-transit costs for meals, lodging and gas.

2. C. Payment of aA lump sum to compensate for payment of the first and last month rent and any security deposit at the new mobilehome park.

3. D. A lump sum to compensate for any differential between rental rates at the closing mobilehome park and the new mobilehome park during the first year of the new tenancy.

C. For non-homeowner residents:

1. The costs of all reasonable expenses incurred in moving to comparable housing, up to a maximum distance of 50 miles.

2. A lump sum to compensate for payment of the first and last month rent and any security deposit at the replacement rental housing.

1.3. Payment of a lump sum to compensate for any differential between rental rates at the closing mobilehome park and the new mobilehome parkreplacement rental housing during the first year of the new tenancy.

E. For tenants the costs may include all reasonable expenses incurred in moving to a new location, up to a maximum distance of 50 miles.

B.D. F. For homeowners who are unable to reasonably relocate their mobilehome to a comparable mobilehome park within Sonoma County, payment of in-place, fair market value for their mobilehome, based on information contained in the approved relocation impact report, and the costs of all reasonable expenses incurred in moving to comparable housing, up to a maximum distance of 50 miles.

C.E. G. Setting aside a certain number of affordable units for the residents of the park, if the park is to be converted to another residential use; or providing a certain Agenda Item #9.1:

14 number of affordable units on-site or off-site, if the park is to be converted to a use other than residential.

F. H. Providing the residents of mobilehomes a right of first refusal for new residential units, if the park is to be converted to another residential use. Income-eligible residents may have first priority to purchase or rent any below market rate (BMR) units which may be constructed on the park site, if they meet all eligibility requirements for the BMR housing program. To receive priority for BMR units, interested residents shall file a request with the director before vacating the park.

G. For low-income and/or residents with disabilities, payment of a rent subsidy of up to 36 months if needed to offset increased housing costs and secure comparable housing. The rent subsidy is the difference of rent paid by the resident in the mobilehome park and any higher rent for either a space at another park if the mobilehome is relocated, or rent for comparable housing if the resident moves to other rental housing. Mobilehome owners who are eligible to sell their mobilehome to the applicant at its in-place value may only receive the rent subsidy if the selling price is inadequate to secure comparable replacement housing for at least 36 months.

H. For residents with disabilities, an additional payment toward the cost of obtaining any assistance needed to enable the resident to move or to make reasonable modifications necessary for them to fully use and enjoy their replacement housing.

D.I. In order to facilitate a proposed conversion, closure, or cessation of use of a mobilehome park the residents and applicant may agree to mutually satisfactory conditions. To be valid, such an agreement shall be in writing, shall include a provision stating that the resident is aware of the provisions of this chapter, shall include a copy of this chapter as an attachment, shall include a provision in at least ten-point type which clearly informs the resident of the right to seek advice of an attorney prior to signing the agreement with regard to the resident’s rights under such agreement, and shall be drafted in the form and content otherwise required by applicable state law.

J. 9.82.060That the applicant, mobilehome park owner (if the applicant is not the mobilehome park owner), and the mobilehome park owner’s successors in interest shall comply with the requirements of the Housing Crisis Act of 2019 (Government Code Sections 66300 to 66300.6.5), as amended from time to time.

9.82.070 Exemption from relocation assistance obligations.

If the applicant believes that providing the relocation assistance identified in the relocation impact report would impose an unreasonable financial hardship, is not economically feasible, or would eliminate substantially all reasonable use or economic value, the applicant may request total or partial exemption from relocation assistance obligations in accordance with this section.

A. The request shall be filed with the department at least 60 days before the city’s public hearing on the conversion permit application.

Agenda Item #9.1:

15 B. The applicant shall notify residents of the request for exemption from relocation assistance obligations by including the request with the relocation impact report that the applicant serves on residents under SMC 9.82.045.

C. To justify the basis for the request of exemption from relocation assistance obligations, the applicant shall provide the following information with the relocation impact report:

1. Statements of profit and loss from the operations of the park for the most recent five-year period before the date of the application or request, audited by a certified public accountant;

2. A statement made under penalty of perjury by a state licensed general contractor that repairs and improvements are necessary to maintain the park in a decent, safe and sanitary condition and to continue the use of the property as a mobilehome park. The statement shall include an itemized list of the necessary repairs and improvements, their costs, and the minimum period of time they shall be made. The applicant shall also submit a statement audited by a certified public accountant on the necessary increase in rental rates of mobilehome spaces within the park within the next five years necessary to pay for such repairs or improvements. At the director’s discretion, the applicant may be required to hire another licensed general contractor selected by the director to analyze the submitted information from another licensed general contractor selected by the director;

3. The estimated total cost of relocation assistance based on SMC 9.82.065 and as determined by a relocation specialist;

4. A comparison by an appraiser from the director’s list of the estimated values of the property if it were to continue as a mobilehome park, and if the park were developed according to the proposed conversion of the park; and

5. Other information the applicant believes to be pertinent, or which may be required by the director.

D. Where an exemption from relocation assistance obligations has been requested, the city council shall make an additional finding to exempt, in whole or in part, the relocation assistance if substantial evidence has been provided that the obligation would impose an unreasonable financial hardship, is not economically feasible, or would eliminate substantially all reasonable use or economic value.

9.82.075 Written agreement.

A. A. Subsequent to the approval of a conversion permit, the applicant and the mobilehome park owner, or their successor in interest, shall enter into a written agreement with the city to ensure compliance with the provisions of this chapter and any conditions, mitigation, or relocation assistance approved by the city.

Agenda Item #9.1:

16 B. The agreement shall bind the applicant, mobilehome park owner, and their successors in interest, and shall be recorded within 30 days of approval of the conversion permit and before issuance of any permit in connection with the approved conversion permit to constitute legal notice to any prospective buyers of the property or successors in interest.

C. The agreement shall provide that the conversion permit may be revoked for noncompliance with any term or condition thereof, or any enforceable permit, permit condition or legal provision applicable to the mobilehome park.

1. When the director finds reason to believe that grounds for conversion permit revocation exist, the director shall send written notice by certified U.S. mail, return receipt requested, to the applicant that states the nature of the noncompliance as grounds for approval revocation. The applicant shall have a reasonable time from the date of the notice, but no more than 30 days unless authorized by the director, to cure the noncompliance or show that no noncompliance ever occurred.

2. If, after notice and opportunity to show that noncompliance did not occur or to cure the noncompliance, the applicant fails to cure the noncompliance, the city council shall conduct a noticed public hearing to determine whether to revoke the conversion permit for uncured noncompliance. The applicant shall be afforded an opportunity to be heard and may speak and submit written materials to the city council. After the noticed public hearing, the city council may revoke or suspend the conversion permit when it finds that the applicant had notice of the noncompliance and remained in noncompliance with any term or condition of the conversion permit and its related agreement, an enforceable permit, permit condition or law applicable to the mobilehome park. Written notice of the city council’s determination and the reasons therefor shall be served by certified U.S. mail, return receipt requested, to the applicant’s address as provided in the agreement.

Upon revocation of approval, the city council may take any legally permissible action or combination of actions necessary to protect public health, safety, and welfare.

9.82.080 Expiration of approval.

Unless the conditions of approval establish a different time limit, any conversion permit granted under this chapter shall expire two years after city council approval. The applicant may be granted no more than one extension for a one-year period. The director may grant a request for an extension based upon a showing that good faith progress has been made toward fulfilling the conditions of approval or some intervening event not the fault of the park owner has prevented timely compliance with the conditions of approval. The applicant may appeal the denial of a request for an extension to the city council.

9.82.085 Bankruptcy exemption.

The provisions of this chapter shall not apply if it is determined that the closure of a mobilehome park or cessation of use of the land as a mobilehome park results from an Agenda Item #9.1:

17 adjudication of bankruptcy. The applicant shall have the burden to produce substantial evidence that a court of competent jurisdiction has determined in connection with a proceeding in bankruptcy that the closure or cessation of use of the affected park as a mobilehome park is necessary. The documentation shall include the title, case number and court in which the bankruptcy proceedings were held and certified copies of all pertinent judgments, orders and decrees of the court.

9.82.065090 Administration fee.

The city council may establish by resolution reasonable fees to cover any costs incurred by the city in implementing this chapter. Such costs include, but are not limited to, the reasonable costs to the city to process and review the conversion permit application, including, without limitation, the costs of the relocation impact report consultant(s), the costs of preparing and procuring resident questionnaires, and staff time to process and review the conversion permit application. Such fees shall be paid by the park owner or applicant subject to the provisions of this chapter, in accordance with the limitations of Section 65863.7(g) of the Government Code.

Agenda Item #9.1:

Mobilehome Park Conversion AB 2782 Compliance Matrix UPDATED April 9, 2026 433348.4
Category Sonoma Municipal Code Chapter 9.82
(Mobilehome Park Conversions) Adopted 2004
AB 2782 & Other State Law Requirements Directions from CC 12/3/2025 and Proposed Updates
Relocation Impact Report (RIR) SMC Section 9.82.030: City selects consultant to prepare; Paid by applicant; Includes the replacement
information and relocation plan prepared by the
consultant.

RIR submitted by applicant; must demonstrate
adequate mitigation
Draft SMC Section 9.82.035
• Updated to incorporate direction provided by other
sections below.
• Subsection C(17) provides a catch all and should
remain.
• Provide minimum amount of information and data
needed to make the findings.
• Section was updated with clarifying language and
dates.
• Subsection C(16) added and (C)12 amended to
comply with SB 610.

Notice & Timeline • City to select a consultant to perform the RIR within 90 days of written request from applicant;
• City manager shall schedule a public hearing on
the relocation impact report before the city council
within 30 days of receiving the relocation impact
report;
• City shall notify applicant at least 30 days prior to any hearing of the notification requirements for
owners/residents;
• Notice of the hearing to be sent to each
mobilehome owner and resident in the affected
park at least 30 days prior to the hearing by the
applicant;
• RIR to be provided to each mobilehome owner and
resident in the affected park at least 15 days prior
to the hearing by the applicant;
• No expiration.
• RIR provided to the residents and mobilehome
owners at least 60 days prior to the hearing;
• After all required permits are obtained the
management shall give the homeowners six
months’ or more written notice of termination of
tenancy; if change of use requires no permits,
notice of change of use shall be 12 months.
• See timeline diagram. Attachment A
• Add a notice of intent to close 30 days prior to
application. Draft SMC Section 9.82.030
• Comply with state law for notice 60 days prior to
hearing. Draft SMC Section 9.82.045(A)
• Change from City Manager to Director of
Community Development throughout draft
• Add that an approval expires after two years with a
process for one year extension consistent with
development code SMC § 19.56.040. Draft SMC
Section 9.82.080.

Relocation and Payments Shall not exceed the reasonable cost of relocation; RIR to include comparable parks and replacement
housing in Sonoma County; relocation costs up to
maximum distance of 50 miles; list of housing
specialists to be provided in RIR; relocation
assistance to be paid as of or after application is filed or date of closure.

In-place market-value compensation for homes that
can’t relocate.
• Relocation plan to be expanded to include more
than just the timeline (subsection C(14)) but keep
general, examples of but not required. Draft SMC
Section 9.82.035(C)(14).
• City shall hire housing specialist to assist with the relocation plan. Draft SMC Section

9.82.035(C)(14).
• Additional assistance for low-income and disabled
for consideration. Draft SMC Section 9.82.065(EH).
• Add the 90 days payment requirement. Draft SMC
Section 9.82.065(A).
• Staff to provide comparable mobilehome parks
options. Attachment B
Agenda Item #9.1:

Mobilehome Park Conversion AB 2782 Compliance Matrix UPDATED April 9, 2026 433348.4
Category Sonoma Municipal Code Chapter 9.82
(Mobilehome Park Conversions) Adopted 2004
AB 2782 & Other State Law Requirements Directions from CC 12/3/2025 and Proposed Updates
Valuation / Appraisal Consultant preparing RIR to provide appraisal in RIR; Estimate of the fair market value of each
mobilehome and all associated fixed property that
cannot be relocated to a comparable mobilehome
park
In-place market value shall be determined by a
state-certified appraiser with experience establishing
the value of mobilehomes; submitted as part of the
RIR; paid for by the applicant
• State certified housing appraisers to be used for
appraisal. Draft SMC Section 9.82.035(C)(12).
• Changed to state “in-place market value.” Draft
SMC Section 9.82.065(D).
• Staff to provide more information on why the scope
of the appraisal include the future use of the park.

Appraisal of park required if requesting exemption
from providing relocation assistance. Draft SMC
Section 9.82.070(C)(4).

Review Procedures and Findings Standard findings; Final decision by City Council; All interested parties allowed to present evidence; May
include conditions necessary to mitigate; RIR
required to be filed concurrently with a permit
application that modifies use of a MHP; may include
conditions necessary to mitigate impacts.

Approval by the legislative body or delegated
advisory agency required.
• City Council to approve. Draft SMC Section

9.82.055.
• Proposed new development to be reviewed
concurrently with a closure/conversion. Draft SMC
Section 9.82.020.
• Decisions made at the public hearing.
• Conditions necessary to mitigate impacts – staff to
provide examples of options. See Draft SMC
Section 9.82.065 for possible conditions.

Consistency Findings (Housing Element / RHNA/
lower income housing availability)
Not Included Finding on whether a closure will result in or materially contribute to a shortage of housing
opportunities and choices for low- and moderateincome households within the local jurisdiction. • Add state law finding. Draft SMC Section

9.82.060(G).
• Staff to look into more around how the findings can
be made and the state law implications.

Resident Purchase / Right of First Refusal
(ROFR)
Finding as to whether units are made available for
purchase or rent on or offsite.

Not required. Option for ROFR may be provided
when subdivision map is applied for.
• Add ROFR as a potential relocation assistance
option. Draft SMC Section 9.82.065(F).

Affordable Housing In-Lieu Fees / Preservation Relocation assistance option - setting aside a certain number of affordable units for the residents of the
park, if the park is to be converted to another
residential use; or providing a certain number of
affordable units on-site or off-site, if the park is to be converted to a use other than residential.

Not required. • Keep set aside of affordable units. Draft SMC Section 9.82.065(E).

Public Outreach Nothing in addition to noticing and public hearing One public hearing required. • Require resident/mobilehome owner questionnaire to be included in the RIR. Draft SMC Section

9.82.040.
• Require an informational meeting held by the
applicant for the affected mobilehome owners and
residents prior to the public hearing. Draft SMC
Section 9.82.045(B).

Agenda Item #9.1:

Mobilehome Park Conversion AB 2782 Compliance Matrix UPDATED April 9, 2026 433348.4
Category Sonoma Municipal Code Chapter 9.82
(Mobilehome Park Conversions) Adopted 2004
AB 2782 & Other State Law Requirements Directions from CC 12/3/2025 and Proposed Updates
Enforcement Tools Written agreement with the City to ensure compliance
Not specified. • Require recordation of agreement (current code requirements) within 30 days of approval. Draft
SMC Section 9.82.075.
• Include a revocation process. Draft SMC Section

9.82.075(C).

Appeal / Reconsideration Not specified. Not specified. None—City Council decision final Other Bankruptcy Exemption; Identifies option of setting aside affordable units on or offsite.

Bankruptcy exemption; Specific requirements apply
when a subdivision map is processed prior to
closure.
• Add provision for exemption from relocation
assistance requirements based on reasonable use
or economic value. Draft SMC Section 9.82.070.
• Ordinance requires concurrent processing if a
project is known. Draft SMC Section 9.82.020(B).
• A bankruptcy exemption is still an option. Draft
SMC Section 9.82.085.

Administrative Cost Recovery City cost-recovery fees; administration fees. Reasonable fees may be established. Updated. Draft SMC Section 9.82.090.

Agenda Item #9.1:

Mobilehome Park Conversion/Closure Important Dates
Notice of Intent
•30 days prior to
application the
applicant shall give
written notice to the
residents
•Proof of notice
provided with
application for
closure or conversion
filed with Community
Development
Director with initial
application
Application and
RIR
•Initial Application
submitted to Director
•RIR Consultant(s)
selected within 90
days of receipt of
initial application
•Questionnaire
circulated to
residents within 30
days of consultant
selection
•RIR completed
•Completeness
review of Final
Application within 30
days of receipt of
completed RIR
•Director determines
completeness, if
complete, schedules
a hearing.

Notice and
Hearing
•Applicant provides
RIR to residents and
home owners at
least 60 days prior
to hearing
•Applicant holds
community meeting
at least 30 days
prior to hearing
•City sends public
notice 20 days
before hearing
•Applicant submits
proof of service of
RIR 7 days before
hearing
•Hearing by City
Council
Post Hearing
•Written agreement
recorded within 30
days of approval of a
conversion/closure
permit
•Relocation payment
to be paid 90 days
before final date to
vacate
•Expiration is two
years from approval
date, one extension
for one year is
possible
Agenda Item #9.1:

Comparable Mobilehome Park Options
Current Code Definition:
“Comparable mobilehome park” means any other mobilehome park within Sonoma County, substantially equal in terms of park amenities, rent and proximity to services.

TriPark Proposed Definition:
“Comparable mobilehome park” is one that meets all of the following requirements:
(1) It must be substantially similar to the mobilehome park proposed to be converted or closed in terms of its rent, amenities, proximity to services, proximity to the homeowner’s place of employment, its overall condition, and quality, including the condition and quality of its infrastructure.
(2) Its California Environmental Protection Agency’s “CalEnviroScreen” score must not be higher than the score of the census tract in which the mobilehome park proposed for conversion or closure is located.
(3) It must be in Sonoma County, Napa County, or within twenty (20) miles of the mobilehome park proposed to be converted or closed.
(4) A mobilehome park that is located in a census tract that has been designated by the California Department of Environmental Protection as a “disadvantaged community” based on its CalEnviroScreen cannot be listed or considered under this Chapter as a comparable mobilehome park unless it is demonstrated, through clear and convincing evidence, that the conditions in the census tract, upon which the designation is based, do not occur in the section of the census tract in which the mobilehome park is located.

What is a CalEnviroScreen?
“CalEnviroScreen is a mapping tool that identifies communities most impacted by pollution.

CalEnviroScreen uses environmental, health, and socioeconomic information to compare pollution burden and community vulnerability for census tracts across the state.” See Technical Report for more details on the methodology. See CalEnviroScreen 5.0 (Draft) Map.

What is a “disadvantage community”?
“Disadvantaged communities in California are specifically targeted for investment of proceeds from the state’s Cap-and-Trade Program. These investments are aimed at improving public health, quality of life and economic opportunity in California’s most burdened communities, and at the same time, reducing pollution that causes climate change.” See Disadvantaged Communities Map.

How does this impact “comparable mobilehome list”?
The relocation report requires the location and details of all “comparable parks” to determine if there are spaces available to move the mobilehomes to. While the City’s current regulations allow Agenda Item #9.1:

for any mobilehome park with similar amenities and proximity to services in Sonoma County to be used, the TriPark recommended ordinance would also include Napa County, it would remove mobilehome parks that have a CalEnviroScreen Score higher than the park being converted or closed and exclude those in a disadvantaged community.

As an example, currently two of the mobilehome parks have a CalEnviroScreen 5.0 (Draft) scores of

24.78 and one with 23.18. Sonoma is in the lower percentile as seen in the map below.

For comparison purposes, staff looked at the map for Santa Rosa along with the location of mobile home parks in and around Santa Rosa. The mobilehome parks located along Hwy 101 would not meet the Enviroscreen Score requirement (yellowish green and orange), while those in the darker green would.

Agenda Item #9.1:

William J. Constantine, Attorney
303 Potrero Street, Building # 29, Suite 107
Santa Cruz, California 95060
Mailing Address
P.O. Box 3683April
Santa Cruz, California 95063
(831) 420-1238
Fax: (831) 480-5934
[email protected]
April 7, 2026
Honorable Mayor Ronald Wellander and City Council Members Interim City Manager Cristine Alilovich
and Community Development Department Director Jennifer Gates Sent via Email to: [email protected]
Re: Sonoma Mobilehome Owners’ Response and Suggested Modifications to The City of Sonoma’s March 19, 2026 Draft Amendments to Sonoma’s Mobile Home Parks Conversions Ordinance
Dear Honorable Mayor Ronald Wellander, City Council Members, Interim City Manager Cristine Alilovich and Community Development Department Director Jennifer Gates:

My office represents the Mobilehome Park Homeowners’Associations of the three mobilehome parks in the City of Sonoma, who have asked me to analyze and provide their comments and suggestions regarding the draft proposed amendments to the City's Mobile Home Parks Conversions Ordinance (the Ordinance), which the City made available to them on March 19, 2026.

Below are our comments and suggestions for important modifications, along with explanations of why they are required under the state statutes that control mobilehome park conversions and closures.

I. Introduction and Summary of Modifications Needed
A. Introduction
The City’s March 19, 2026, proposed amendments did a good job of stating that compliance with the new applicable requirements of Government Code Section 65863.7 and the Housing Crisis Act of 2019 is now required, but they do not adequately modify the operative provisions of the Agenda Item #9.1:

Honorable Mayor and City Council Members
Interim City Manager and
Community Development Director
City of Sonoma
April 7, 2026

Ordinance to ensure consistency throughout the Ordinance in conformity with them. 1 This has
resulted in more than a dozen of the Ordinance’s provisions remaining inconsistent with these two statutes’ mandatory requirements and, therefore, preempted by them and unlawful.

Fortunately, the amendments only need small but critical modifications.

Specifically, the new provisions of Government Code Section 65863.7 and the Housing Crisis Act of 2019 now expand their mandatory mitigation measures to include not only those needed to enable displaced mobilehome owners to relocate their mobilehomes into other mobilehome parks but also now include new reporting and replacement requirements to preserve or replace the current stock of low-income affordable housing located in a mobilehome park that will be lost to a conversion. They also contain new mandatory provisions that require displaced mobilehome owners to be provided with sufficient compensation to purchase other housing when it is determined that their mobilehomes cannot be relocated to other parks.

B. Summary of Modifications Needed
To provide consistency and full compliance with the new requirements of Government Code Section 65863.7 and the Housing Crisis Act of 2019, the following modifications are needed:

1. Subsection J of Section 9.82.065 Clarification that Section 9.82.065’s subsection J, which requires compliance with the applicable provisions of the Housing Crisis Act of 2019, is mandatory since amended Section 9.82.065 makes its list of relocation benefits optional through its use of the term “may.” Remove the limitation in Section 9.82.065 that its mitigation measures “shall not exceed the reasonable costs of relocation” since that limitation was removed by the Legislature from Government Code 65863.7 and now both it and the Housing Crisis Act of 2019 contain mandatory requirements, requiring the replacement of lost low income housing and compensation to mobilehomes owners when their mobilehomes cannot be relocated, which do not fall under that old limitation. (See Sections II C, D (1) and E (1) through (3) below)

2. Subsection A of Section 9.82.020 Subsection A of Section 9.82.020 “Applicability” should be corrected to clarify that the provisions of the Ordinance not only apply to conversions and closures mobile parks under Government Code Section 65863.7 but also to conversions of mobilehome parks to other uses requiring subdivision approval under Government Code Section 66427.4 but not to conversions to resident ownership requiring subdivision approval under Government Code Section 66427.5. (See Section II A below) 1 See the attached November 18, 2024 California Housing and Community Development Department (HCD) Mobile Home Parks - Protection from Conversion - Letter of Technical Assistance Agenda Item #9.1:

Honorable Mayor and City Council Members
Interim City Manager and
Community Development Director
City of Sonoma
April 7, 2026

3. Subsection B of Section 9.82.020 Subsection B of Section 9.82.020, which requires conversion and closure applications to be considered concurrently with, and as a necessary prerequisite to, any required planning permit(s) or approval(s) for the new intended use, should have a provision added to it that provides a mechanism for ensuring a park owner does not circumvent this requirement by claiming they are simply closing their park without an intended new use. (See Section II B below)

4. The Ordinance’s definitions of “Comparable housing” and “Comparable mobilehome park,” in Section 9.82.015 The Ordinance’s definitions of “Comparable housing” and “Comparable mobilehome park” in Section 9.82.015“Definitions” should be expanded to also require that comparable housing and mobilehome parks must also be “decent, safe, and sanitary, and located in areas not subject to unreasonable adverse environmental conditions” in order to comply with Government Code Section 65863.7 and the Housing Crisis Act of 2019. (See Section II D (3) below)

5. The Ordinance’s definition of “closure” in Section 9.82.015 5. The Ordinance’s definition of “closure” in Section 9.82.015 must be expanded to cover the broader definition of “closure” intended in Government Code Section 65863.7. (See Section II D (2) below) II. The Reasoning and Controlling Law on the Modifications Needed to Bring the City’s Proposed Amendments into Compliance with the New Requirements of Government Code Section 65863.7 and the Housing Crisis Act of 2019.

A. Subsection A of Section 9.82.020 (Applicability)
Although it appears to be unintentional, Section 9.82.020 “Applicability” excludes all conversions “that include a subdivision map,” thereby improperly excluding all conversions to other uses under Government Code Section 66427.4 that require a subdivision map. It then states that Chapter 9.84 of the Sonoma Municipal Code applies to them instead:
“9.82.020A Applicability.

A. For applications involving the closure, conversion, or cessation of use of a mobilehome park that include a subdivision map, the provisions of Chapter 9.84 SMC shall apply. The provisions of this chapter shall not apply to such applications, except as specifically referenced in Chapter 9.84 SMC.”
The mistake here is that its language fails to distinguish between conversions of mobilehome parks to a resident owned subdivision, which require subdivision map approvals under Government Code 66427.5, and which are properly covered by Chapter 9.84 of Sonoma’s Municipal Code, and mobilehome park conversions to another use under Government Code Agenda Item #9.1:

Honorable Mayor and City Council Members
Interim City Manager and
Community Development Director
City of Sonoma
April 7, 2026

66427.4, which also require subdivision map approval (for example conversions to mixed housing subdivisions), and which are not covered by Chapter 9.84 of Sonoma’s Municipal Code.

The reason this appears to be an unintentional mistake is that, just a few lines above this Section,” is the Ordinance’s definition of “Relocation impact report,” which properly states that its “impact report” requirements apply to conversions under both Government Code Sections 65863.7 and 66427.4 but not to conversions to resident ownership covered by Government Code Section 66427.5. (See the definition of “Relocation impact report under “Section 9.82.015 Definitions” of the proposed Ordinance)
The text of Government Code Section 66427.4 also makes it clear that Sonoma’s Ordinance must cover subdivision conversions under it by clearly stating that conversions under it shall be subject to Government Code 65863.7 relating to the mitigation benefits it requires to be given to displaced residents to enable them to find adequate housing in another mobilehome park:
“At the time of filing a tentative or parcel map for a subdivision to be created from the conversion of a mobilehome park or floating home marina to another use, the subdivider shall adhere to the requirements of Section 65863.7 relating to the impact of the conversion upon the displaced residents of the mobilehome park or floating home marina to be converted.” (See subsection (a) of Government Code Section 66427.4) Accordingly, this problem can be easily fixed with the following or similar language:

9.82.020 A Applicability.

A. This Chapter shall apply to applications for the closure, conversion or cessation of use a mobilehome park under Government Code Section 65863.7 and to conversions of a mobilehome park to another use requiring subdivision map approval under Government Code Section 66427.4. This Chapter shall not apply to conversions of a rental mobilehome park to a resident owned mobilehome park requiring subdivision map approval under Government Code Section 66427.5, which shall, instead, be subject to the provisions of Chapter 9.84 of the Sonoma Municipal Code.

B. Subsection B of Section 9.82.020 (Conversion, Closure or Cessation of Use Applications to be Considered Concurrently with the Required Development Approval) Section 9.82.020 B properly requires an application for closure, conversion or cessation of use of a mobilehome park to be considered at the same time of any required planning permit or approval for the new intended use:

Agenda Item #9.1:

Honorable Mayor and City Council Members
Interim City Manager and
Community Development Director
City of Sonoma
April 7, 2026

Section 9.82.020 B. An application for the closure, conversion, or cessation of use of a mobilehome park, shall be considered concurrently with, and as a necessary prerequisite to, any required planning permit(s) or approval(s) for the new intended use, if any, of the mobilehome park, with review being the responsibility of the higher decision-making body. (See subsection (B) of Section 8.82.020 of the Proposed Amended Ordinance) As explained in our submission of December 2, 2025, this provision is required in order for the Ordinance to obtain the information needed to comply with the new requirements of Government Code Section 65863.7(e)(1)((B) (on making a required finding on whether or not a proposed mobilehome park conversion will result in a loss of affordable housing) and, if so, to then also obtain the information needed to comply with the requirements Government Code Section 66300(b)(1)(A), a provision of the Housing Crisis Act of 2019, (requiring a developer to present a plan under which they will provide equally affordable replacement residential dwelling units to the mobile homes and their spaces lost in the conversion of the mobilehome park, either within the development replacing it or within the City of Sonoma).(See subsections (b)(1)(A) and (b)(2) of Government Code Section 66300.6)
However, although amended Section 9.82.020 B states this requirement accurately, it does not contain the needed mechanism for preventing a park owner from circumventing it by simply claiming that they do not have a current intent to convert their park to any particular new intended use, but simply want to close it and decide on a new use later. On this basis, they can then file a standalone closure application. In other local jurisdictions, some park owners have done this and a newsletter of a law firm specializing in representing mobilehome park owners has advised their clients to do so.

Accordingly, to prevent a park owner from so easily circumventing this requirement, a mechanism must be provided that requires a park owner to demonstrate that they have a legitimate reason for closing their park early before they have made up their mind on what they want to do with their mobilehome park’s land once it is closed and empty.

As explained in our December 2, 2025 - submission to the City, a Court of Appeal addressed this circumstance and ruled that it is unlawful to allow a mobilehome park to be closed in reliance on such a claim, explaining that Civil Code Section 798.56(g) requires a park conversion or closure application to “disclose and describe in detail the nature of the change of use” and that:
“a statement that the use of the property would be changed to accommodate some other form of development to be determined at a future date does not comply with the statutory requirements for a specific plan.” (See Keh v Walters (1997) 55 Cal.App.4th. 1522, at 1533-1534)
To prevent this from occurring, we recommend the following, or a similarly worded requirement, be added to Section 9.82.060 of the Ordinance (the Ordinance’s Findings Section):

Agenda Item #9.1:

Honorable Mayor and City Council Members
Interim City Manager and
Community Development Director
City of Sonoma
April 7, 2026

(I) Finding Required for the Closure or Cessation of Use of a Mobile Home Park When an Applicant States that They Have No Intended New Use for the Property at the Time Their Conversion Application is Filed.

When an applicant for the conversion of a mobilehome park states that they have no current intent to file an application for a new use of the park, an additional finding must be made that the park owner has demonstrated, through filing a certificate signed under penalty of perjury, that the applicant is not seeking an early closure of the park in order to avoid the requirements of this Chapter or of controlling State or Federal law that regulate the conversion of mobilehome parks to other uses.

The certificate must state specifically articulable facts, which are supported by appropriate documentary or other evidence, that must meet the applicant’s burden of demonstrating that the circumstances described in it do in fact exist and require the closure of their mobilehome park prior to the submission of any required planning permit(s) or approval(s) for an intended new use of the mobilehome park.

An applicant may, but is not limited to, meet this burden by demonstrating, through clear and convincing evidence that, for reasons not caused by or contributed to by the park owner, the property cannot continue to be operated as a rental mobilehome park until the time that the park owner is ready to either file an application for a permit or other required approval for the new use of the park or ready to sell the mobilehome park, while also making a fair return on their investment in the mobilehome park during that time period, or by providing other clear and convincing evidence of other circumstances that require the current closure of their park before the park owner is able to apply for the required permit or approval for an intended new use of the mobilehome park’s land.

C. Subsection J of Section 9.82.020 (Relocation Assistance to comply with Housing Crisis Act of 2019)
Subsection J of Section 9.82.020 states that the applicant “shall comply with the requirements of the Housing Crisis Act of 2019” as one of Section 9.82.020’s categories of the permitted “relocation assistance” in its list of the categories of relocation assistance requirements that the City “may” impose as conditions of approval of a conversion application. However, Section

9.82.020 then nullifies this option by limiting the relocation assistance that the City may require to mitigation benefits that “shall not exceed the reasonable cost of relocation:”

9.82.065 Relocation assistance.

Agenda Item #9.1:

Honorable Mayor and City Council Members
Interim City Manager and
Community Development Director
City of Sonoma
April 7, 2026

In approving an application for a conversion permit, the city council may attach reasonable conditions to the permit in order to mitigate the impacts associated with the conversion. The specific conditions of approval of a particular application shall be determined on an application-by-application basis with regard to the facts and circumstances of the application and the relocation impact report, but shall not exceed the reasonable cost of relocation, as documented in the relocation impact report. The city council shall require the applicant to enter into a written agreement with the city to ensure compliance with and fulfillment of the conditions of approval, as described in SMC 9.82.075. The conditions of approval may include but are not limited to the following matters:
///.

J.That the applicant, mobilehome park owner (if the applicant is not the mobilehome park owner), and the mobilehome park owner’s successors in interest shall comply with the requirements of the Housing Crisis Act of 2019 (Government Code Sections 66300 to 66300.6.5), as amended from time to time.

There are several problems with the wording and placement of this requirement that must be fixed.

First, the Housing Crisis Act of 2019 makes all of its requirements mandatory, not permissive, once it is determined that they apply. However, the use of the term “may” in Section 9.82.065, when applied to the mandatory requirements of the Housing Crisis Act of 2019, converts those requirements into permissive ones that the City may choose to require or not. This causes the Ordinance to conflict with the Housing Crisis Act of 2019’s requirements and to, therefore, be preempted by it and unlawful.

Second, some of the requirements of the Housing Crisis Act of 2019 and similar new requirements that AB 2782 added to Government Code Section 65863.7, are not “relocation requirements” but serve other purposes. For example, Government Code Section 65863.7 contains the mandatory requirement that if it is determined that a mobilehome cannot be relocated into another mobilehome park, then the displaced mobilehome owners must be paid the in-place fair market value of their mobilehomes which constitutes a compensatory payment rather than a cost of relocation:
“If a displaced resident cannot obtain adequate housing in another mobilehome park, the person or entity proposing the change of use shall pay to the displaced resident the inplace market value of the displaced resident’s mobilehome. (See Government Code Section 65863.7 (a) (2) (A)”
Agenda Item #9.1:

Honorable Mayor and City Council Members
Interim City Manager and
Community Development Director
City of Sonoma
April 7, 2026

However, the above introductory paragraph of Section 9.82.065 excludes these statutory requirements by limiting the mitigation measures that can be imposed under Section 9.82.065 to those that “shall not exceed the reasonable cost of relocation.” It appears the Ordinance’s “shall not exceed the reasonable cost of relocation” limitation may have been taken from the pre-AB 2782 text of Government Code Section 6583.7, which contained it. However, In 2022, AB 2782 eliminated this “reasonable cost of relocation” limitation and then added Section 65863.7 (a) (2) (A)’s new compensatory requirement of the payment of the in-place market value of a displaced mobilehome owner’s mobilehome, when it cannot be relocated, and, thereby, expanded its conversion impact requirements to not just requiring a relocation plan but instead to require a “replacement and relocation plan, which would include its new required in place value payments. ”(See the last sentence of Government Code Section 65863.7 (a) (2) (A))
Going even further, the Housing Crisis Act of 2019 contains not only relocation assistance requirements for displaced households, it also contains a strict low-income affordable housing preservation requirement that all of the existing housing in a mobilehome park that is occupied (or had been occupied in the past five years) by low-income households (which it refers to as “protected units”, which will be lost when a park is converted must be replaced by the developer with equally affordable housing units. (See subsections (b)(1) through (b)(2.) of Government Code Section 66000.6).

To fix this deficiency, the introductory paragraph of Section 9.82.065 should be modified to make it consistent with the mandatory requirements of the above two state statutes, which can be easily done with the below or similar language:

In approving an application for a conversion permit, the city council may attach reasonable conditions to the permit in order to mitigate the impacts associated with the conversion. The specific conditions of approval of a particular application shall be determined on an application-by-application basis with regard to the facts and circumstances of the application and the relocation impact report, but shall not exceed the reasonable cost of relocation, as documented in the relocation impact report. The city council shall require the applicant to enter into a written agreement with the city to ensure compliance with and fulfillment of the conditions of approval, as described in SMC 9.82.075. The conditions of approval shall include any applicable mandatory conditions required by the Housing Crisis Act of 2019 (Government Code Sections 66300 to 66300.6) and Government Code Section 65863.7 as amended from time to time. When a replacement and relocation requirement of these Government Sections requires mitigation measures that are greater than those required in this section, those State-mandated requirements will supersede the related requirements in this section.

Agenda Item #9.1:

Honorable Mayor and City Council Members
Interim City Manager and
Community Development Director
City of Sonoma
April 7, 2026

The additional replacement and relocation requirements under this section may include but are not limited to the following matters:”
////
EVEN MORE IMPORTANT, Subsection J of Section 9.82.020 should then also be moved to become a required finding of approval under Section 9.83.060 “Finding,” using the following or similar language:

That the replacement and relocation plan is in compliance with and contains all applicable requirements of the Housing Crisis Act of 2019 (Government Code Sections 66300 to 66300.6.5) and Government Code Section 65863.7as amended from time to time
This is required because, since both of the above statutes are mandatory, a conversion application cannot be approved unless a finding is made that the requirements of both statutes have been complied with. This can be easily done by slightly rewording Subsection J of Section 9.82.020, moving into and making it a required finding in “Section 9.83.060 Findings,” as suggested above.

Similarly, the title of Section 9.82.020 should be changed to “Replacement And Relocation Assistance” and, wherever the term” relocation assistance” is used in the Ordinance, it should be changed to “Replacement And Relocation Assistance.”
And
The title of Section 9.82.035 should likewise be changed to “Replacement And Relocation Impact Report” and wherever the term” “relocation impact report ” is used in the Ordinance it should be changed to “Replacement And Relocation Impact Report”.

D. The Proposed Ordinance’s Definitions Section’s (Section 9.82.015) Definitions of the following Terms Must Also Be Modified to Conform to the Mandatory Requirements of Government Code 65863.7, and the California Housing Crisis Act of 2019. (1.) The Definition of Relocation Impact Report. “Relocation impact report” is the term the Ordinance uses for the conversion impact report required by Government Code Sections 65863.7 and 66427.4.

However, as explained above, Government Code Section 65863.7 no longer restricts its mitigation requirements to only those related to the relocation of the mobilehome owners who will be displaced by the conversion or closure of a mobilehome park. Instead, it now requires a broader Replacement and Relocation Plan that not only provides relocation assistance to displaced mobilehome owners to enable them to relocate but also requires a compensatory payment for the in-place value of the mobilehomes to the displaced mobilehome owners when their mobilehomes cannot be relocated. Likewise, Government Code Section 66427.4 adopts the Agenda Item #9.1:

Honorable Mayor and City Council Members
Interim City Manager and
Community Development Director
City of Sonoma
April 7, 2026

same requirement by reference. Accordingly, this term should be changed in Section 9.82.015 of the Ordinance and everywhere else that it is stated in the proposed Ordinance as a “Replacement and Relocation:
“Replacement and Relocation Impact Report means a report required by Government Code Sections 65863.7 and 66427.4, as applicable and containing the information set forth in SMC 9.82.03(C). The required Replacement and Relocation Impact Report under this Section does not include the impact report required by Government Code Section 66427.5(b) for conversion to resident ownership. (2.) The Definition of Closure The amended Ordinance maintains its original definition of “closure of a mobilehome park” that limits the “closures’ that it covers to only two special circumstances, which are unique forms of a closure that should also be covered. However, by doing so, likely inadvertently, it excludes from the amended ordinance’s covered “closures” the normal broader definition of “closures” intended to be covered by Government Code Section 65863.7. It is, therefore, preempted by that Statute, since a local ordinance cannot contain a definition that is less protective than the definition for the same term in a controlling state statute.
2 2 In Sherwin-Williams Company v City of Los Angeles, 4 Cal.4th 893 (1993) California Supreme Court set out the standard for determining if a local ordinance preempted by a state statue for being in conflict with it (See SherwinWilliams Company v City of Los Angeles, 4 Cal.4th 893 (1993)) It first stated that provisions in local ordinances cannot be in conflict with state statutes:
“Under article XI, section 7 of the California Constitution, "[a] county or city may make and enforce within its limits all local, police, sanitary, and other ordinances and regulations not in conflict with general laws."[1]
"If otherwise valid local legislation conflicts with state law, it is preempted by such law and is void." (Candid Enterprises, Inc. v. Grossmont Union High School Dist. (1985) 39 Cal.3d 878, 885 [218 Cal. Rptr. 303, 705 P.2d 876]; accord, e.g., IT Corp. v. Solano County Bd. of Supervisors (1991) 1 Cal.4th 81, 90 [2 Cal. Rptr.2d 513, 820 P.2d 1023]; People ex rel. Deukmejian v. County of Mendocino (1984) 36 Cal.3d 476, 484 [204 Cal. Rptr. 897, 683 P.2d 1150]; Lancaster v. Municipal Court (1972) 6 Cal.3d 805, 807 [100 Cal.

Rptr. 609, 494 P.2d 681].)” (Id. at 898):

Sherwin-Williams Company then explained that a local ordinances standard is less stringent than that contained in the state statute, it conflicts with the state statute and is preempted and unlawful “Similarly, local legislation is "contradictory" to general law when it is inimical thereto. (See Ex parte Daniels (1920) 183 Cal. 636, 641-648 [192 P. 442, 21 A.L.R. 1172] [finding "contradiction" where local legislation purported to fix a lower maximum speed limit for motor vehicles than that which general law fixed].” (Id. at 898)
Agenda Item #9.1:

Honorable Mayor and City Council Members
Interim City Manager and
Community Development Director
City of Sonoma
April 7, 2026

This oversight can be easily corrected by substituting the new subsection A to the ordinance’s definition of “closure” and simply moving its two expanded definitions to become subsections B and C. New subsection A should state as follows or something similar:
“A. A Closure includes all closures referred to by the term 'closure' contained in Government Code Section 65863.7, as intended by that section and so interpreted by the courts.”
(3.) The Definitions of Comparable housing and Comparable mobilehome park. The amended Ordinance maintains its original definitions of “comparable housing” and “comparable mobilehome park” However these definitions do not take into account that the Housing Crisis Act of 2019 requires that replacement housing must comply with the definition of “comparable replacement dwelling” contained in California’s Uniform Relocation Act. This requires the criteria for both of the above terms to include that the comparable housing and park must, at minimum, be “decent, safe and sanitary” and located “in an area not subject to unreasonable adverse environmental conditions.” (See subsections (i)(1) and (2) of Government Code Section 7260.

To incorporate the expanded mandatory requirements, the following, or similar, language could be added to the end of the ordinance’s definitions of comparable housing:
“Comparable housing” means housing which is comparable in size, number of bedrooms, bathrooms, amenities, and other rooms to the mobilehome to which comparison is being made, which housing meets the minimum standards of the Uniform Housing Code, is decent, safe and sanitary” and is located in an area not subject to unreasonable adverse environmental conditions. “Comparable mobilehome park” means any other mobilehome park within Sonoma County, substantially equal in terms of park amenities, rent and proximity to services, is decent, safe and sanitary” and is located in an area not subject to unreasonable adverse environmental conditions
E Additional Short But Essential Modifications to Miscellaneous Provisions of the Proposed Amendments to Conform Them with the New Low-Income Housing New Reporting and Replacement Housing Requirements of Government Code Section 65863.7 And The California Housing Crisis Act Of 2019.

For the reasons more fully explained above, short but essential modifications of the language in several other provisions of the Ordinance should be made to comply with the new low-income affordable housing loss reporting and replacement requirements of Government Code section 65863.7 and the Housing Crisis Act of 2019.
(1.) Subsection C of “Section 9.82.010 Purpose and Intent.” Agenda Item #9.1:

Honorable Mayor and City Council Members
Interim City Manager and
Community Development Director
City of Sonoma
April 7, 2026

This should be modified to add additional language to ensure that the intent section of the Ordinance includes its intent to comply with the new requirements on reporting and replacing the low-income housing that will be lost in the conversion with the following or similar language:

C. It is the intent and purpose of the city council in adopting this chapter to ensure that the social and fiscal impacts of a proposed conversion, closure, or cessation of use of a mobilehome park are adequately defined prior to consideration of a proposed change of use; to establish reasonable rules and regulations in accordance with the authority granted by state law to mitigate the adverse effects of displacement upon mobilehome park residents who are confronted with a proposed conversion, closure, or cessation of use of their mobilehome park or portions of the park; and so that the residents and owners of mobilehome parks understand their rights and responsibilities in such situations and to comply with the lost low-come affordable housing reporting and replacement requirements of Government Code Section 65863.7 and the Housing Crisis Act of 2019 (Government Code Sections 66300 to 66300.6.5) and as amended from time to time.
(2.) Subsection B of “Section 9.82.025 Application for Conversion Permit.” Subsection B of “ProposalSection 9.82.025 should be modified to ensure that an application for a conversion permit complies with the new requirements on reporting and replacing the lowincome housing that will be lost in the conversion required by Government Code Section 65863.7 and the Housing Crisis Act of 2019 (Government Code Sections 66300 to 66300.6.5), with the addition of the following or similar language:

B. A final application shall include, at a minimum, the following:

1. The replacement and relocation impact report and plan required under SMC

9.82.035 and Government Code Section 65863.7 must contain information demonstrating that the conversion is in compliance with the lost low-come affordable housing reporting and replacement requirements of Government Code Section 65863.7 and the Housing Crisis Act of 2019 (Government Code Sections 66300 to 66300.6.5) as amended from time to time

2. The resident questionnaires required under SMC 9.82.040. (3.) The Title of “Section 9.82.035 Relocation impact report required.” This should be modified to reflect that the impact report must also address the lost low-income housing reporting and replacement requirements of Section 65863.7 and of the Housing Crisis Act of 2019, with the following or similar language:

9.82.035 Replacement and Relocation impact report required (4.) The Title of “Section 9.82.055 Hearing on relocation impact report.” Agenda Item #9.1:

Honorable Mayor and City Council Members
Interim City Manager and
Community Development Director
City of Sonoma
April 7, 2026

This should be modified to reflect that the impact report must also address the lost low-income housing reporting and replacement requirements of Section 65863.7 and of the Housing Crisis Act of 2019, with the following or similar language:

9.82.055 Hearing on Replacement and Relocation Impact Report.

Sincerely,
Will Constantine
______________________
William J Constantine, Attorney for
Sonoma Mobilehome Owners
cc: clients
Attachment: November 18, 2024, California Housing and Community Development Department (HCD) Mobile Home Parks - Protection from Conversion - Letter of Technical Assistance Agenda Item #9.1:

STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
651 Bannon Street, Suite 400, Sacramento, CA 95811
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
November 18, 2024
Albert Lopez, Planning Director
County of Alameda
224 W. Winton Avenue, Rm 111
Hayward, CA 94544
Dear Albert Lopez:

RE: Mobilehome Parks – Protection from Conversion – Letter of Technical Assistance
The California Department of Housing and Community Development (HCD) commends efforts by the County of Alameda (County) to protect mobilehome parks from conversion to other uses. The purpose of this letter is to ensure the County and other stakeholders, including current mobilehome park owners and prospective mobilehome park buyers, are aware of key requirements under state law relevant to conversion of mobilehome parks to other uses.

Background
HCD understands that the County is in the process of developing a Mobilehome Park Overlay and Conversion Ordinance “to preserve land for the construction, use and occupancy of mobilehome parks.”1 Such an ordinance is proposed in Program 6.N of the County’s August 2024 draft housing element.
2 HCD applauds the County’s efforts to
protect this important and unique type of affordable housing.

HCD further understands that the Paradise Trailer Court, located at 16115 East 14th Street, San Leandro, has been listed for sale and described by the seller as a “Huge Infill Redevelopment Opportunity.”3 Any entity that purchases this, or any other, 1 Staff Report to Castro Valley Municipal Advisory Council, September 23, 2024, available at
https://www.acgov.org/board/bos_calendar/documents/CDAMeetings_09_23_24/1%20 MobileHomePark.pdf. 2 County of Alameda Third Draft Housing Element, available at https://www.acgov.org/cda/planning/housing-element/documents/AlamedaCounty_FINAL-Main-Body.pdf. 3 Sales listing, available at https://www.loopnet.com/Listing/16115-E-14th-St-SanLeandro-CA/30287619/.

Agenda Item #9.1:

Albert Lopez, Planning Director

mobilehome park with the intent of converting the park to another use must comply with all relevant state law. State law also includes responsibilities for the local jurisdiction regarding mobilehome park conversions.

Two key state laws that impact mobilehome park conversions are the Mobilehome Residency Law4 (MRL) and the Housing Crisis Act5 (HCA).

Mobilehome Residency Law
MRL includes noticing requirements that must be met by park management prior to termination of a tenancy, including for change of use of the park or any portion thereof.6 MRL also requires that local agencies inform any developers applying to convert a mobilehome park to another use of these notice requirements, and not take any action until they have “satisfactorily verified” the developer has actually served proper notice on residents and mobilehome owners.
7 Further, MRL requires that, prior to a mobilehome park being closed, converted, or no longer used as a mobilehome park, the applicant must file a report on the impact of the conversion, closure, or cessation of use. The report “shall include a replacement and relocation plan that adequately mitigates the impact upon the ability of the displaced residents of the mobilehome park to be converted or closed to find adequate housing in a mobilehome park.”8
Notably, MRL requires that “[i]f a displaced resident cannot obtain adequate housing in another mobilehome park, the person or entity proposing the change of use shall pay to the displaced resident the in-place market value of the displaced resident’s mobilehome.”9
Finally, MRL imposes responsibilities on and grants powers to the relevant legislative body to protect persons potentially displaced by a mobilehome park conversion. Before approving any change in use, the legislative body must review the report and “make a finding as to whether or not approval of the park closure and the park’s conversion into its intended new use, taking into consideration both the impact report as a whole and the overall housing availability within the local jurisdiction, will result in or materially contribute to a shortage of housing opportunities and choices for low- and moderateincome households within the local jurisdiction.”10 In addition, the legislative body “may 4 Civil Code, § 798 et seq. and Gov. Code §§ 65863.7, 65863.8. 5 Gov. Code, § 66300 et seq.
6 Civil Code, § 798.56, subds. (g), (h). 7 Gov. Code, § 65863.8. 8 Gov. Code, § 65863.7, subd. (a)(1).
9 Gov. Code, § 65863.7, subd. (a)(2)(A).
10 Gov. Code, § 65863.7, subd. (e)(1)(B).

Agenda Item #9.1:

Albert Lopez, Planning Director

require, as a condition of the change, the person or entity proposing the change in use to take steps to mitigate any adverse impact of the conversion, closure, or cessation of use on the ability of displaced mobilehome park residents to find adequate housing in a mobilehome park.”11
Housing Crisis Act
The replacement and relocation provisions of the HCA12 state that an affected county13 shall not approve certain development projects that involve demolition of housing units unless certain requirements are satisfied. A change in use that would result in demolition of a mobilehome park would trigger those requirements. The requirements vary based on the type of proposed development and the status of the demolished units; those different circumstances are italicized in the text below. Specific provisions include:
• A housing development project that requires the demolition of one or more residential dwelling units must create at least as many residential dwelling units as will be demolished.
14 • A development project (whether or not it is a housing development project) that will require the demolition of occupied or vacant protected units, or that is located on a site where protected units were demolished in the previous five years, must:
o Replace all such protected units.
15 Protected units include residential
dwelling units that are or were rented by lower- or very low-income households within the past five years.16
o Allow any existing occupants to occupy their units until six months before the start of construction and provide notice at least six months in advance of the date occupants must vacate.
17 o Provide existing occupants of protected units that are lower-income households:
 Relocation benefits that are equivalent to the relocation benefits required to be paid by public entities pursuant to Relocation Assistance Law (Gov. Code, § 7260 et seq.).
18 11 Gov. Code, § 65863.7, subd. (e)(2).
12 Gov. Code, §§ 66300.5, 66300.6.
13 HCD maintains a list of affected counties subject to these provisions. The list, which includes Alameda County, is available at https://www.hcd.ca.gov/planning-andcommunity-development/statutory-determinations. 14 Gov. Code, § 66300.6, subd. (a). 15 Gov. Code, § 66300.6, subd. (b)(1)(A).
16 Gov. Code, § 66300.5, subd. (h)(3).
17 Gov. Code, § 66300.6, subd. (b)(3)(A).
18 Gov. Code, § 66300.6, subd. (b)(4)(A).

Agenda Item #9.1:

Albert Lopez, Planning Director

 A right of first refusal for a comparable unit available in the new housing development, or in any required replacement units associated with a new development that is not a housing development, affordable to the household at an affordable rent or an affordable housing cost.19
• Notably, replacement units must comply with additional requirements:
o They must provide at least the same number of units of equivalent size (at least the same total number of bedrooms) at affordable rent or affordable housing cost to, and occupied by, households of the same or lower income category as those currently or formerly in occupancy. o If the replacement units will be rental dwelling units, these units shall be subject to a recorded affordability restriction for at least 55 years. If the proposed development is for-sale units, the units replaced shall be subject to an equity sharing agreement.20
Occupied mobile homes and mobile home rental pads that have been occupied by a mobile home within the last five years are subject to the replacement provisions of the HCA.

Conclusion
HCD appreciates the opportunity to provide technical assistance to the County. If you have any questions regarding the content of this letter or would like additional technical assistance, please contact Stephanie Reyes at [email protected].

Sincerely,
Shannan West
Housing Accountability Unit Chief
19 Gov. Code, § 66300.6, subd. (b)(4)(B).
20 Gov. Code, § 65915, subd. (c)(3)(b).

Agenda Item #9.1:

500 Capitol Mall, Ste. 1750
Sacramento, CA 95814
Direct: 408.299.1314

81488256.1
Andrew J. Ditlevsen
Partner
[email protected]
Lathrop GPM LLP
lathropgpm.com
April 9, 2026
Via Email
City of Sonoma
c/o Jennifer Gates, Community Development Director
[email protected]
Re: Proposed Changes and Revisions to Chapter 9.82 of the Sonoma Municipal Code – Mobilehome Closure Ordinance Addressing Legislative Updates Embodied by AB 2782 and SB 610
Dear Ms. Gates:

As you know, I am legal counsel representing the interests of ownership for each of the three permitted mobilehome parks within the City of Sonoma – Moon Valley, Pueblo Serena, and Sonoma Oaks (“Park Owners”). This letter follows my prior correspondence, dated November 24, 2025, a copy of which is attached hereto as Exhibit 1, incorporated herein by reference.

Thank you for providing Park Owners with the opportunity to comment on and participate in the further study session concerning the legal and procedural requirements for mobilehome park closures and conversions under the City of Sonoma (“City”), including how to best address the updates in state law embodied within Assembly Bill 2782 (“AB 2782”) and, more recently, Senate Bill 610 (“SB 610”). Please ensure this correspondence is included in the materials provided to City Council for its upcoming meeting on April 15, 2026.

Chapter 9.82 Requires Minimal Updating to Address the Changes Embodied in AB 2782 and SB 610
Enclosed with my original letter last November is a proposed redline of the changes to existing City law – specifically Chapter 9.82 of the City’s Municipal Code (“Closure Ordinance”) – which address completely each point raised in the Agenda Item Summary prepared by City Staff for City Council’s November 5, 2025 session. This redline continues to completely address the Agenda Item Summary. As you will see from the enclosed redline of the City’s Closure Ordinance, the required changes to the Closure Ordinance are relatively minimal. Reconciliation of the existing Closure Ordinance with updates to state law enacted through AB 2782 and SB 610 is a straightforward task, which should present no meaningful controversy for any constituency within the City. This should be a simple exercise.

Yet, a different iteration of Chapter 9.82 has been circulated recently to Park Owners for comment.

The proposed revisions to the Ordinance reflect a more refined version but it effectively accomplishes the same thing as the original version: it is riddled with unnecessary, overreaching provisions that effectively eliminate a landowner’s right to go out of business. More importantly Agenda Item #9.1:

Jennifer Gates, Community Development Director
April 9, 2026

81488256.1
to City Council, it hamstrings your future discretion and authority to address housing needs, land use goals, and the needs of future constituents. Effectively, in adopting policy of this sort, you elevate the theoretical concerns of the present few over the needs and interests of the many (now and in the future).

No other changes, other than what is reflected in Park Owner’s original redline, are required to bring existing City law into full compliance with changes in state law spanning 2020-2025. Park Owner’s reiterate they have no intent to close their respective mobilehome communities.

Examples of Overreaching In Proposed Draft Ordinance
At a high level, as drafted, this Ordinance effectively ensures that it financially infeasible for a park owner to go out of business. It also ensures that in the event of a natural disaster, a park owner would be incapable, as a matter of basic economics, from rebuilding a mobilehome park in the City of Sonoma. If adopted, the City is communicating unambiguously that it intends to assault the interests of Park Owners, and it wishes to discontinue its partnership with an important partner in providing needed housing.

Park Owners note six specific issues, as examples, of issues that infect this draft Ordinance – there are a significantly greater number of issues to which Park Owners object:

1. The City does not provide for an exemption from payment of relocation expenses in the event a community is destroyed by natural disaster – this exemption language is contained in the redline version submitted with my November 2025 letter. Requiring a park owner to pay tenants relocation expenses after the total loss of a significant asset is both unfair and short sighted. Tenants should have their homes insured, along with the contents of their homes. It appears that personal responsibility for one’s self and one’s belongings is being outsourced to the Park Owners. It is not Park Owners obligation to function as a de facto insurance policy for each resident (while not collecting premiums for such insurance function and charging less than fair market rent for the mobilehome lot in the first instance).

Moreover, this ignores the harsh reality that Park Owner(s) will have lost a sizeable asset, have no income from that asset, ongoing debt service and tax obligations, and its own insurance policy/company that is often not a willing payor. I have seen this first-hand in my representation of a large community destroyed by a recent wildfire.

2. The updated proposed ordinance includes non-tenant/homeowner persons within the categories of persons that receive full relocation benefits. This would include persons with whom Park Owner has no contractual relationship (no lease or rental agreement). For example, long-term guests, additional occupants and caregivers. These persons have no obligation to pay rent to Park Owner and Park Owner has no relocation obligation to them.

These individuals are simply permitted to occupy the dwelling under applicable law.

Including these categories of persons and providing them with a year of rent subsidy, as well as a amount equal to first and last month’s rent, is outrageous and does not find support in existing law.

3. The updated proposed ordinance provides for a broad definition of “disabled persons.” To these persons, they are provided with three years of rent subsidy and other relocation Agenda Item #9.1:

Jennifer Gates, Community Development Director
April 9, 2026

81488256.1
benefits. As drafted, a disabled person may be a non-tenant living in a mobilehome, and park owner would have to pay (i) fair value of its tenant’s home, (ii) 1-3 years (depending on status) of relocation benefits to its tenant, (iii) moving costs, and (iv) 3 years of relocation costs to the disabled additional occupant (who may move to a separate living facility), first/last month’s rent, moving costs, and the costs of any ADA improvements made to the home (even though this “improvement” would have been captured and paid as part of the in-place value of the mobilehome). Effectively, this proposed ordinance shifts the public burden of caring for a disabled person, with whom the Park Owner has no contractual relationship, from the public to the Park Owner as a condition for the right to go out of business.

4. Park Owner always maintains control of drafting and preparing the Relocation Impact Report. This is not an outsourced function. The current draft ordinance reflects a lack of understanding as to the mechanics of the closure process.

5. The City may not mandate the Park Owner plan its intended use of its property as a condition for going out of business. Again, this is unlawful and reflects a lack of understanding as to how closures function. Frankly, it is not in the City’s best interest to process both a closure and redevelopment concurrently.

6. The proposed draft Ordinance imposes a confidentiality requirement on the Resident Questionnaire, which as drafted is the basis for evaluating whether the relocation assistance offered is adequate, but then purports to make them confidential from Park Owners. You cannot conceal Resident Questionnaires and then make them the basis of the monies Park Owners must pay to go out of business.

Request for Action
The existing Closure Ordinance, with the added provision as reflected in the redline document enclosed with my November 2025 letter, accomplishes this goal. Existing language in the Closure Ordinance provides City Council with ample flexibility to impose additional requirements to ensure the goal is fully achieved. City Council is being led, by both special interests and those within the City that align themselves with those interests, into error. The result is a net negative for the City at-large. Park Owners reiterate that (i) there is no threat of any closure facing the City, and (ii) should a closure be proposed at some unknown point in the future, the Closure Ordinance provides a sufficient floor from which City Council may evaluate the proposed closure and craft other additional protective measures as may be required under the specific circumstances presented by the future closure application. City Council’s decisions should be grounded in fairness to all its constituents, and they should respond to facts, real circumstances.

The Closure Ordinance has existed for over 20 years, and a radicalization of local law is dangerously unnecessary. Park Owners look forward to continuing their partnership with the City and working closely to craft surgical amendments to the Closure Ordinance. Conversely, passage of the current ordinance will be understood by Park Owners that the City desires an end to the current partnership, and Park Owners will evaluate how best to move forward exercising their reasoned business judgment.

Agenda Item #9.1:

Jennifer Gates, Community Development Director
April 9, 2026

81488256.1
Thank you for your prompt attention to these matters.

Sincerely,

LATHROP GPM LLP
Andrew J. Ditlevsen
Partner
AJD/emt
[Encl. November 24, 2025 Letter to Sonoma City Council, including redline of Chapter 9.82 of Sonoma Municipal Code – Mobilehome Park Conversions]
Agenda Item #9.1:

EXHIBIT 1
Agenda Item #9.1:

Lathrop
GPMaAr
500 Capitol Mall, Ste. 1750
Sacramento, CA 95814
Direct: 408.299.1314
November 24, 2025
Lathrop GPM LLP
lathropgpm.com
Andrew J. Ditlevsen
Partner
[email protected]
Via Email
City of Sonoma
c/o David Guhin, City Manager
[email protected]
Re: Proposed Changes and Revisions to Chapter 9.82 ofthe Sonoma Municipal Code - Mobilehome Closure Ordinance Addressing Legislative Updates Embodied by AB 2782 and SB 610
Dear Mr. Guhin:

I am legal counsel representing the interests of ownership for each of the three permitted mobilehome parks within the City of Sonoma - Moon Valley, Pueblo Serena, and Sonoma Oaks ("Park Owners"). Thank you for providing Park Owners with the opportunity to comment on and participate in the study session concerning the legal and procedural requirements for mobilehome park closures and conversions under the City of Sonoma ("City"), including how to best address the updates in state law embodied within Assembly Bill 2782 ("AB 2782") and, more recently, Senate Bill 610 ("SB 610"). Please ensure this correspondence with the enclosed redline of the existing City law - Chapter 9.82 of the City's Municipal Code - is included in the materials provided to City Council for its upcoming meeting on December 3, 2025.

Chapter 9.82 Requires Minimal Updating to Address the Changes Embodied in AB 2782 and SB 610
At the outset, enclosed herewith is a proposed redline of the changes to existing City lawspecifically Chapter 9.82 of the City's Municipal Code ("Closure Ordinance") - which address completely each point raised in the Agenda Item Summary prepared by City Staff for City Council's November 5, 2025 session. As you will see from the enclosed redline of the City's Closure Ordinance, the required changes to the Closure Ordinance are relatively minimal.

Reconciliation of the existing Closure Ordinance with updates to state law enacted through AB 2782 and SB 610 is a straightforward task, which should present no meaningful controversy for any constituency within the City. This should be a simple exercise.

The Park Owners have no intent to close any mobilehome park within the City - nor have they threatened to do so.

However, in connection with this study session, I strongly encourage City Staff and members of City Council to study the closure of Winchester Mobilehome Park in the City of San Jose. The San Jose City Council approved the closure and conversion unanimously and without objection by the park's resident association. The net result of that project was a win for all involved:
81488256.1
Agenda Item #9.1:

David Guhin, City Manager
November 24, 2025

residents who wanted to stay were able to do so, resulting in no displacement, and the residents that wanted to go were compensated more than fairly. Additionally, the City experienced a net increase in the number of affordable housing units, a net increase in the number of total housing units, all of which lessened the housing burden which continues to afflict the City of San Jose, and many others through California.

I urge City Staff and City Council to exercise caution when evaluating overreaching proposals, driven not by sound housing policy, but by ideology and grounded in a foundation of misleading statistics and conclusory assertions. Proponents of a new ordinance, which is discussed below, cite several jurisdictions that have passed similar ordinances drafted by the same legal counsel.

The City of Sonoma is not the City of Watsonville, Palo Alto or Lancaster. The proponents of the new ordinance submit that City Council should adopt their ordinance because others have done so. Park Owners believe that this City Council is comprised of leaders and not followers.

Turning back to the enclosed redline of the Closure Ordinance, I summarize the changes for ease of reference as follows:
• Changes Addressing AB 2782: the substantive changes addressing the updates embodied in AB 2782 may be found in Sections 9.82.030.C.15, 9.82.025, 9.82.035,

9.82.045, 9.82.050.1, and 9.82.055.F.
• Changes Addressing SB 610: the substantive change addressing SB 610, recently passed in October 2025, is set forth in newly created exemption Section 9.82.065. • All other redlines are stylistic and primarily result from using defined term "RIR" in lieu of repeatedly referring to "Relocation Assistance Report." No other changes are required to bring existing City law into full compliance with changes in state law spanning 2020-2025. I also note that the changes in state law would operate, as a matter of law, to modify the Closure Ordinance without any action from City Council. Certainly, bringing clarity through the simple proposed update is aspirational, but not legally required.

Sonoma Tri Park Coalition's Proposed New Closure Ordinance My clients would also like to document their objection to and genuine concern about the proposal submitted on behalf of the AB 2782 Revision Committee and the Sonoma Tri Park Coalition, which was submitted in August 2025 (the "New Closure Ordinance").

The tone and tenure of the New Closure Ordinance, and related memorandum from legal counsel, raises serious concern. Since 2004, when the existing Closure Ordinance was adopted, there have been zero mobilehome park closures in the City. Indeed, there has been no discussion or threat of closure. Despite these facts, the proponents of the New Closure Ordinance conclude:
"there is a growing threat of park conversions and closures, require a robust and effective mobilehome park and closure ordinance ...." This conclusion is without foundation and is fairly characterized as "fear mongering." There has been no such threat for more than twenty years and no owner is threatening to close any park within the City now. 81488256.J
Agenda Item #9.1:

David Guhin, City Manager
November 24, 2025

Moreover, to characterize state law as "encouraging" closures is also without foundation. State law may broadly be seeking to address California's housing crisis, but to leverage these policy efforts (designed to provide more housing and to address what may only be characterized as an unhealthy housing market state-wide) is both dangerous and unfair. Simply put, proposals like the New Closure Ordinance are not a part of the solution, but drive and exacerbate the problem.

All Californians - individual residents and business alike - have a stake in the current housing crisis and all have a role to play in its solution. Certainly, the Park Owners did not cause nor contribute to the current crisis, but that is the narrative string that runs through the proposed New Closure Ordinance.

The New Closure Ordinance encourages City Council to make many unsubstantiated - and in my opinion demonstrably false -findings in support of many overreaching provisions. For example, the proponents conclude: "most of the time, the parks that park owners choose to convert or close are parks with older and smaller mobilehomes in them. This results in their in-place values being insufficient for purchasing the actually available mobilehomes in their communities." This is not my experience - and I may be the only active attorney licensed in the State of California that has successfully closed a mobilehome park in the last five years. Most recently, I closed a smaller park in East Palo Alto - which closure commenced because a third-party investor in distressed mobilehomes purposely purchased homes within the park to gain standing, and then claimed occupancy rates were below a threshold in the ordinance, thus requiring its closure. It was not owner-initiated. Moreover, each resident received the in-place value for their homes, many of which were long-term RVs. In one example, we had a receipt for the mobilehome purchased in the early 1990s for $3,500.00. The in-place value paid for this home over 30 years later exceeded $160,000.00. Mobilehomes and RVs are, by legal definition personal property, and as such a depreciating asset class. Yet, because of the existing protections and laws, residents, such as those in the East Palo Alto closure, realized appreciation of nearly 15%, compounded annually.

A far greater return on the modest investment than was realized by the landowner.

The veracity of the findings proposed in the New Closure Ordinance is apparently unimportant to the proponents, which is reflected by the following admission: "These findings are also risk-free to the City, because a park owner cannot challenge them (they can only challenge the lack of sufficient findings but not that they disagree with them) if they file a lawsuit challenging the ordinance, ..." First, the contention that a park owner harmed by a finding cannot challenge its foundation or its veracity is unsupported, and untrue. Second, Park Owners - as long-time partners with the City in providing important housing -find it repugnant that a group of individuals would suggest the City would adopt findings of fact it knows to be untrue or which are without foundation. To do so strongly suggests the City would be targeting Park Owners for disparate and unfair treatment. Park Owners do not believe the City would engage its housing partners in such an unnecessarily unfair manner.

There are so many substantive issues with the proposed New Closure Ordinance that it belies an easy summary. Generally, many of the provisions are designed to make closure and conversion functionally impossible. Understandably, residents do not want the parks to close, at least not while they have a stake in those communities. However, to pass the proposed New Closure Ordinance would unnecessarily constrain future City Council's from addressing problems known and unknown - and it is not necessary to provide ample resident protections, which the current Closure Ordinance accomplishes. For example, proposed Section 9.82.030(a)(2) imposes 81488256.1
Agenda Item #9.1:

David Guhin, City Manager
November 24, 2025

requirements in the Relocation Impact Report that are functionally impossible to accomplish: I know because I have drafted, completed and presented these reports. As proposed, an application would have to obtain the income and other residency requirements for comparable parks, the income of current residents and report as to whether these residents would qualify under the standards at comparable parks. This is not possible. It would require each resident to submit a compliant application at each of these comparable parks and to have those applicants evaluated and approved by the comparable parks, with the outcome of each to be reported in the Relocation Impact Report. This condition, among many others, is functionally impossible to satisfy.

Other examples include: (i) demonstrating compliance with the Uniform Relocation Act - which is only applicable to government takings, not private businesses seeking to go out of business; (ii) adopting the standards in Nash v. City of Santa Monica which the legislature explicitly rejected through passage of the Ellis Act; (iii) satisfying the impossibly narrow definition of a "comparable park" including satisfaction of a "CalEnviroScreen" analysis tantamount to an environmental impact report; and (iv) additional subsidies that guarantees the ability to purchase a new mobilehome housing in a comparable park which is more valuable than a resident's current home.

In the event City Council and Staff elect to continue studying the proposed New Closure Ordinance, Park Owners reserve the right to make additional, specific comments on that document, as well as reserve all rights to challenge its adoption in court.

Request for Action
Respectfully, the goal of state and local law with respect to closures and conversion of mobilehome parks - or any existing housing assets - is to ensure those currently residing in any such community or complex are treated fairly and receive sufficient assistance to reasonably and adequately mitigate the consequences of the closure/conversion. The existing Closure Ordinance, with the added provision as reflected in the enclosed document, accomplishes this goal. Moreover, there is existing language in the Closure Ordinance that provides City Council with flexibility to impose additional requirements to ensure the goal is fully achieved. Park Owners submit that (i) there is no threat of any closure facing the City, and (ii) should a closure be proposed at some unknown point in the future, the Closure Ordinance provides a sufficient floor from which City Council may evaluate the proposed closure and craft other additional protective measures as may be required under the specific circumstances presented by the future closure application. City Council's decisions should be grounded in fairness to all its constituents, and they should respond to facts, real circumstances, and not developed in response to fictional melodramas and driven by fear mongering and ideological warriors.

Accordingly, Park Owners respectfully request the City Council carefully study the matters before it and take only that action which is necessary to reconcile existing law with modest recent amendments to relevant state law. The Closure Ordinance has existed for over 20 years, and a radicalization of local law is dangerously unnecessary. 81488256.1
Agenda Item #9.1:

David Guhin, City Manager
November 24, 2025

Park Owners look forward to continuing their partnership with the City and working closely to craft surgical amendments to the Closure Ordinance. Thank you for your prompt attention to these matters.

Sincerely,

LATHROP GPM LLP
Pa
t
rtner
AJD/emt
Enclosure [Redline of Chapter 9.82 of Sonoma Municipal Code - Mobilehome Park Conversions]
81488256.1
Agenda Item #9.1:

Chapter 9.82

MOBILEHOME PARK CONVERSIONS
Sections

9.82.010 Purpose and intent.

9.82.015 Definitions.

9.82.020 Applicability.

9.82.025 Disclosure of notification requirements.

9.82.030 Relocation impact report required.

9.82.035 Notice and distribution of relocation impact report.

9.82.040 Notice to new residents.

9.82.045 Hearing on relocation impact report.

9.82.050 Findings.

9.82.055 Relocation assistance

9.82.060 Bankruptcy exemption.

9.82.065 Administration fee

9.82.010 Purpose and intent.

A. Where a person proposes to convert an existing mobilehome park to another use or to close a mobilehome park or to cease using land as a mobilehome park, current provisions of state law, as set forth in Government Code Section 65863. 7 and Civil Code Section 798.56, authorize the city to require the person proposing the change of use to file and distribute a report on the impact of such change and further authorize the city to require measures to be undertaken to mitigate the adverse effects of the change of use upon the tenants of the mobilehome park who would be displaced by such change.

B. The city council finds and determines that unless mitigation measures are undertaken, the conversion, closure or cessation of use of mobilehome parks could have a substantial adverse effect upon park residents in terms of cost of relocation, scarcity of similar comparable housing within a reasonable proximity to the city, and the significantly higher costs of other types of housing in the immediate area if park residents cannot relocate to other mobilehome parks.

C. It is the intent and purpose of the city council in adopting this chapter to establish reasonable rules and regulations in accordance with the authority granted by state law to mitigate the adverse effects of relocation upon mobilehome park residents who are confronted with a proposed change of use for their mobilehome park or portions of the park and so that the owners and occupants of mobilehomes and the owners of mobilehome parks understand their rights and responsibilities in such situations. (Ord. 05-2004 § 1, 2004).

Agenda Item #9.1:

9.82.015 Definitions.
"Applicant" means the person(s), firm(s), entity{ies) or corporation(s) applying for any application for the purpose of converting, changing to another use, closing, or ceasing to use land as a mobilehome park. If the owner of the controlling interest in a mobilehome park is not the applicant, then the applicant must provide evidence of the controlling owner's consent to the filing of the application.
"Cessation of use of land as a mobilehome park" means a decision by the owner(s) of a mobilehome park to discontinue the use of property as a mobilehome park which is not an adjudication of bankruptcy.
"Closure of a mobilehome park" means one of the following:

A. A closure of a mobilehome park occurs when less than 75 percent of the occupiable spaces are leased by qualified homeowners as defined in the Mobile-Home Residency Law (Civil Code Section 798 et seq.). However, upon application of a mobilehome park owner, the city council may, in its absolute discretion and upon a finding of good cause, determine that a closure of a mobilehome park is not occurring, notwithstanding that less than 75 percent of the occupiable spaces are leased. Any such application by the mobilehome park owner shall be accompanied by an estimate of a qualified appraiser as to the fair market value of the mobilehome(s) and all associated fixed property for which the foregoing exemption is requested. The appraiser's estimate shall conform to the requirements of SMC 9.82.030(C)(12).

B. Notwithstanding the provisions set forth in subsection A of this definition, a closure of a mobilehome park occurs when the city council, in its absolute discretion and upon a finding of good cause, determines that the mobilehome park owner has acted and/or has failed to act in a manner which would cause a reasonable person to conclude that the mobilehome park owner intends to eliminate or reduce mobilehome spaces available for rent to the general public. Such acts or omissions include, but are not limited to, the withholding of available mobilehome spaces under the control of the mobilehome park owner, and statements by authorized agents and representatives of the mobilehome park owner to prospective buyers of the mobilehome park that the mobilehome park is being closed by the mobilehome park owner. "Comparable housing" means housing which is comparable in floor area and number of bedrooms, bathrooms, and other rooms to the mobilehome to which comparison is being made, which housing meets the minimum standards of the Uniform Housing Code. "Comparable mobilehome park" means any other mobilehome park within Sonoma County, substantially equal in terms of park amenities, rent and proximity to services. "Conversion of a mobilehome park" means changing the use of a mobilehome park for a purpose other than the rental, or the holding out for rent, of two or more mobilehome sites to accommodate mobilehomes used for human habitation. A conversion shall include, but not be limited to, a change of any existing mobilehome park or any portion thereof to condominium, stock cooperative, planned unit development, or any form of ownership wherein spaces within the mobilehome park are to be sold, or the cessation of use of all or a portion of the park as a mobilehome park, whether immediately or on a gradual basis, or the closure of a park. "Conversion of a mobilehome park" shall not include a conversion of a mobilehome park to resident ownership.

Agenda Item #9.1:

Ch. 9.82 Mobilehome Park Conversions I Sonoma Municipal Code "Conversion of a mobilehome park to resident ownership" means a sale, transfer or assignment of a mobilehome park either directly or indirectly in whole or in part to mobilehome park's homeowners and prospective homeowners for the benefit of the mobilehome park's homeowners and prospective homeowners. A conversion of a mobilehome park to resident ownership may include but not be limited to, conversion of the community to a subdivision, condominiums, planned development, community apartments, stock cooperative, other form of corporate ownership, or by a nonprofit organization qualified pursuant to Internal Revenue Code Section 501 ( c)(3) for the homeowners' or prospective homeowners' benefit. Notwithstanding any provision in this chapter to the contrary, in the event the conversion of a mobilehome park to resident ownership is by a nonprofit corporation qualified under Internal Revenue Code Section 501 (c)(3), homeowners may or may not have the right to participate through direct ownership of the mobilehome park and the nonprofit shall not be required to make an offer of participation to the homeowners.
"Homeowner" means the owner(s) of a mobilehome.
"Impact report" means a report required by California Government Code Sections 65863.7 and 66427.4, as applicable, and containing the information set forth in SMC 9.82.030(C). "Impact report" does not include the impact required by Government Code Section 66427.5(b) for conversion to resident ownership.
"Long-term lot" means any mobilehome lot that has been occupied by the same mobilehome for at least nine of the 12 months prior to the adoption of this chapter. "Mobilehome" means a vehicle designed or used for human habitation and shall include camping trailers, motorhomes, slide-in campers and trailers, when used as the occupant's principal place of residence, and mobilehomes as defined in Health and Safety Code Section 18211. "Mobilehome lot" means any area or tract of land, or portion thereof, occupied or held out for occupancy by one mobilehome that is not owned by the park owner. "Mobilehome park" means any area or tract of land where 10 or more mobilehome lots are rented or leased or held out for rent or lease to accommodate mobilehomes used for human habitation. "Resident" means a homeowner or tenant.
"Tenant" means a person who occupies a mobilehome within a mobilehome park pursuant to a bona fide lease or rental agreement and who, during his or her tenancy, is not the owner or member of the immediate household of the owner of the mobilehome. (Ord. 05-2004 § 1, 2004).

9.82.020 Applicability.

For applications involving the redevelopment, closure, or conversion of a mobilehome park that include a subdivision map, the provisions of Chapter 9.84 SMC shall apply. The provisions of this chapter shall not apply to such applications, except as specifically referenced in Chapter 9.84 SMC. (Ord. 05-2004 $1,2004).

Agenda Item #9.1:

9.82.025 Disclosure of notification requirements.

When an application has been made to the city for the redevelopment, closure or conversion of a mobilehome park, the city shall inform the applicant, in writing, of local regulations regarding notifications to residents and mobilehome owners within the affected park, as well as the notification requirements set forth in Section 798.56 of the Civil Code. This disclosure shall be made at least 3060 days prior to any hearing on the application or the relocation impact report.

No hearing on the application shall be held or any other action on the application taken until the applicant has satisfactorily verified that required notices have been provided. (Ord. 05-2004 § 1, 2004).

9.82.030 Relocation impact report required.

A. Any person who files an application with the city for a general plan amendment or for a rezoning of land use type or density, or for approval of a conditional use permit or any other application for the purpose of converting a mobilehome park to another use, close a mobilehome park or cease to use land as a mobilehome park, shall concurrently file with the city a mobilehome relocation impact report ("RIR") that complies with this section. No such applications shall be considered or deemed complete or processed for consideration or approved unless and until such relocation impact reportRIR is filed and approved in accordance with this chapter.

B. At any time at which the occupancy of a mobilehome park is such that it meets the definition of "closure" as set forth in this chapter, the owner shall immediately provide written notification to the city of the event and shall either file a request for the preparation of a relocation impact report RIR or shall petition the city council to make a finding that a closure is not occurring as set forth in SMC 9.82.015(A).

C. The city shall select a consultant to perform the relocationimpact reportRIR within 90 days of a written request from the applicant. The applicant shall be noticed in writing of the estimated cost of the relocation impact reportRIR and shall deposit that sum with the city prior to commencement of any work on the relocationimpact repontRIR. The city will then contract with a consultant for the preparation of the relocationmpact reportRIR, Once an application is filed, the residents of the mobilehome park shall be notified by the city that an application has been filed and that the preparation of a relocationimpact reportRIR will be required. The relocation impact reportRIR shall contain, but need not be limited to, the following information:

1. A legal description of the property.

2. A map and a detailed description ofthe condition of the mobilehome park, including the nature and location of structures, landscaping, easements, utilities and other on-site features and amenities.

3. The names and addresses of all mobilehome owners within the park (including absentee mobilehome owners), as shown on the rental agreement for the mobilehome park spaces, and the names and addresses of all mobilehome tenants within the park as of the date of the application.

4. The characteristics of each mobilehome within the park, listed by space number and address, including the date of manufacture, type, width, living area, and number of bedrooms.

Agenda Item #9.1:

5. The number of spaces within the park, length of occupancy by the current occupant of each space and the current lease rate for each space.

6. The total number of mobilehome residents, listed by space identifying owner or renter occupancy, principal or second home occupancy, and the number of residents who are physically disabled, including the chronically ill.

7. A description of the proposed new use and all discretionary approvals necessary therefor, if any.

8. The proposed timetable for conversion, closure or cessation of use of the land as a mobilehome park and for obtaining other discretionary approvals for the proposed use, if any.

9. The location of all comparable mobilehome parks within Sonoma County, including the park name, number of lots, number of vacancies, lease rates and terms, policies and restrictions on the type of mobilehomes and residents accepted, amenities offered and proximity to services (bus stops, grocery stores, hospitals, etc.).

10. A determination based on the information provided in subsections (C)(4), (5) and (9) of this section of the total number of mobilehome units that are eligible to be relocated to a comparable mobilehome park.

11. The estimated cost of relocating the mobilehomes identified in subsection (C)(10) of this section to available lots in mobilehome parks within the study area. The cost of relocating shall include the costs of dismantling, packing, moving, reassembling, rebuilding and unpacking, as necessary, the mobilehome, all personal property, skirting, tie-downs and all other associated structures and property. If the consultant determines that the mobilehome cannot be relocated to another mobilehome park, it must state the basis for this determination, which may include the opinion of one or more mobilehome movers solicited to bid on the cost for such contemplated relocation, and any other information germane to the consultant's determination.

12. Anestimate of the fairmarket value of eachmobilehomeandalassociated fixed propertythat cannotberelocated toacomparable mobilehome park. In determiningfair market value, theconsultant shall consider themobilehomes intheir currentlocations assuming thecontinuationof themobilehome park ina safe, sanitary and wellmaintained conditionwithcompetitiveleaserates. Theconsultantshallspecify the basisfora conclusion that anymobilehome cannotberelocated to a mobilehome parkandthebasis for determining the value of the mobilehome.

13. The availability and cost of rental housing of comparable size and quality in the city of Sonoma for each mobilehome park tenant.

14. A relocation plan that will include a timetable for physically relocating the mobilehomes, or payment of relocation assistance.

15. A description of applicant's Pproposed measures to mitigate the adverse impacts of the conversion upon each park resident based onas required and identified in SMC

9.82.055. Additionally, if the mitigation measures required under state law exceed that provided by this ordinance at the time applicant submits its application to close or convert Agenda Item #9.1:

the subject mobilehome park, then applicant shall also be required to identify and describe its proposal for satisfying those requirements.

16. A list of persons, firms and organizations with proven expertise in the fields of housing and relocation of persons displaced from housing. This list shall include the names, addresses, telephone numbers, and fee schedules of persons who are qualified as mobilehome movers and appraisers of mobilehomes. The information shall include an explanation of the services that the housing specialists can provide.

17. Any information which the city manager determines is necessary to address the specific issues raised by the application or the impact study and any information that may be necessary to implement provisions of this chapter. (Ord. 05-2004 $1,2004).

9.82.035 Notice and distribution of relocation impact report.

Not less than 1560 days prior to a scheduled hearing before the city council, the park owner shall transmit to the owner or occupant of each mobilehome occupying a site within the mobilehome park and to all other persons described in SMC 9.82.030(C)(3), a copy of the relocationimpact reportRIR, a copy of this chapter, and notices of the dates, times and places of the public hearings or any informational meetings. The copies provided shall be free of charge.

Proof of service of distribution of the impact reportRIR to each resident must be filed by the applicant with the city manager seven days prior to the hearing and shall be signed under penalty of perjury. (Ord. 05-2004 $1,2004).

9.82.040 Notice to new residents.

When an application for a change of use and/or closure of a mobilehome park has been filed with the city, the park owner shall advise each prospective new resident who proposes to occupy a mobilehome within such park after the filing of such application, in writing, prior to the execution of a rental agreement or commencement of such occupancy whichever occurs first, that such application has been filed. (Ord. 05-2004 $1,2004).

9.82.045 Hearing on relocation impact report.

A. When an application has been filed for a general plan amendment, rezoning, or conditional use permit for the proposed change of use and/or closure of a mobilehome park, the city manager shall schedule a public hearing on the relocation impact reportRIR before the city council within 30 days of receiving the relocation impact reportRIR, but not sooner than 60 days after applicant provides each impacted resident with the disclosures. notices and documents required under the Ordinance, including but not limited to Sections 9.82.025, 9.82.035 and 9.82.045. The city council, in considering the relocation impact reportRIR, shall make written findings based on evidence regarding the factors outlined in SMC 9.82.050.

B. At the public hearing, all interested parties will be allowed to present evidence to the city council on any aspect of the application. The evidence may include, but is not limited to, justification for the payment of relocation costs, including the fair market value of any mobilehome, evidence why a mobilehome cannot be relocated to a comparable mobilehome park, and similar information.

C. If the city council is unable to make findings consistent with SMC 9.82.050 and is unable to impose reasonable measures as provided in SMC 9.82.055 to mitigate the adverse impact(s) of relocation, the city council shall deny the application for the proposed conversion, closure or Agenda Item #9.1:

cessation of use. No other permit or approval shall be granted in furtherance of the proposed conversion, and no change of use, including cessation or closure, shall occur unless a relocation impact reportRIR has been approved. (Ord. 05-2004 § 1, 2004).

9.82.050 Findings.

The city council, in considering the relocationmpactreportRIR, shall accept and hear evidence, shall consider such evidence, and shall make written findings based on such evidence regarding each of the following factors and any other factors as it deems appropriate:

A. That the relocationimpact reportRIR provides the information required by state law and this chapter and that it provides the city council with adequate information on the impacts of the park conversion in terms of disruption to affected residents and the methods available for addressing relocation needs.

B. That there will exist, at the time of conversion, closure or cessation of use available mobilehome lots within Sonoma County to accommodate the mobilehomes to be displaced.

C. That adequate options are available for residents who would be disrupted by the conversion.

D. That the relocation plan provides for reasonable costs of relocation based on the findings of the relocation impact reportRIR,
E. If the proposed conversion is to another residential use, whether the residents of the mobilehome park will have an opportunity to purchase, if for sale, or rent the new units, and whether the construction schedule will result in unreasonably long-term displacements.

F. That the proposed conversion will not be detrimental to the public health, safety and general welfare.

G. That all reports and notices required by law have been properly prepared and properly served. (Ord. 05-2004 § 1, 2004).

H. The applicant has satisfied the provisions of Government Code section 65863.7,as may be amended from time to time.

I. Whether or not the approval of the park closure and the park's conversion into its intended new use, taking into consideration both the RIR as a whole and the overall housing availability within the City of Sonoma will result in or materially contribute to a shortage of housing opportunities and choices for law - and moderate - income households with the City of Sonoma.

9.82.055 Relocation assistance.

In approving a relocationmpact reportRIR the city council may attach reasonable conditions in order to mitigate the impacts associated with the conversion, closure or cessation of use. The specific conditions of approval of a particular application shall be determined on an applicationby-application basis with regard to the acts and circumstances of the application_, but shall not exceedthereasonablecostof relocation, asdocumentedintherelocationimpactreportThe city council shall require the applicant to enter into a written agreement with the city to ensure Agenda Item #9.1:

compliance with and fulfillment of the conditions of approval, which may include but are not limited to the following matters:

A. Payment of relocation assistance to each resident who resided in the mobilehome park as of and after the date the application is filed or the date a closure, conversion or cessation of use is deemed by the city council to have commenced.

B. Payment of the cost of physically moving the mobilehome to a new site, including teardown and setup of movable improvements such as patios, carports and porches; packing, moving and unpacking all personal property; and in-transit costs for meals, lodging and gas.

C. Payment of a lump sum to compensate for payment of the first and last month rent and any security deposit at the new mobilehome park.

D. Payment of a lump sum to compensate for any differential between rental rates at the closing mobilehome park and the new mobilehome park during the first year of the new tenancy.

E. For tenants the costs may include all reasonable expenses incurred in moving to a new location, up to a maximum distance of 50 miles.

F. Unless otherwise exempt under provisions of this Ordinance or state law,_ Ffor homeowners who are unable to reasonably relocate their mobilehome to another comparable mobilehome park, payment to the mobilehome owner equivalent to the "in-place market value" of the mobilehome. The "in-place market value" of the mobllehome shall be determined by a state-certified appraiser with experience establishing the value of mobilehomes. The appraisal shall be based upon the current in-place location of the mobilehome and shall assume the continuation of the mobilehome park. The applicant is responsible for payment of each appraisal required under this Chapter and shall include a copy of each appraisal as part of an addendum to the FIR paymentof fair marketvaluefortheirmobilehome, basedoninformation contained in the approved relocation impact report.

G. Setting aside a certain number of affordable units for the residents of the park, if the park is to be converted to another residential use; or providing a certain number of affordable units on-site or off-site, if the park is to be converted to a use other than residential.

H. In order to facilitate a proposed conversion, closure, or cessation of use of a mobilehome park the residents and applicant may agree to mutually satisfactory conditions. To be valid, such an agreement shall be in writing, shall include a provision stating that the resident is aware of the provisions of this chapter, shall include a copy of this chapter as an attachment, shall include a provision in at least ten-point type which clearly informs the resident of the right to seek advice of an attorney prior to signing the agreement with regard to the resident's rights under such agreement, and shall be drafted in the form and content otherwise required by applicable state law. (Ord. 05-2004 § 1, 2004).

9.82.060 Bankruptcy exemption.

The provisions of this chapter shall not apply if it is determined that the closure of a mobilehome park or cessation of use of the land as a mobilehome park results from an adjudication of bankruptcy. The applicant shall have the burden to produce substantial evidence that a court of competent jurisdiction has determined in connection with a proceeding in bankruptcy that the closure or cessation of use of the affected park as a mobilehome park is necessary. The Agenda Item #9.1:

documentation shall include the title, case number and court in which the bankruptcy proceedings were held and certified copies of all pertinent judgments, orders and decrees of the court. (Ord. 05-2004 § 1, 2004).

9.82.065 Exemption for closure, conversion, or change of use arising from damage or destruction by a disaster.

If it is determined that the closure, cessation or change of use is related to damage or destruction resulting from disaster the provisions of this Chapter shall not apply. Applicant shalt, however, be required to satisfy the standards imposed by Government Code section 65863.7. As used herein, "disaster" means a natural or manmade emergency resulting from an earthquake, flood, fire, riot, storm, drought, plant or animal infestation or disease, pandemic or epidemic disease outbreak, or other natural or manmade disaster.

9.82.07065 Administration fee.

The city council may establish by resolution reasonable fees to cover any costs incurred by the city in implementing this chapter. Such fees shall be paid by the park owner or applicant subject to the provisions of this chapter, in accordance with the limitations of Section 65863. 7(g) of the Government Code. (Ord. 05-2004 § 1, 2004).

The Sonoma Municipal Code is current through Ordinance 11-2025, passed August 6, 2025.

Disclaimer: The city clerk's office has the official version of the Sonoma Municipal Code. Users should contact the city clerk's office for ordinances passed subsequent to the ordinance cited above.

City Website: www.sonomacity.org
Hosted by General Code.

Agenda Item #9.1: