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Home My WebLink About2021-08-26; Mobile Home Park Local Enforcement Agency Evaluation Results (Districts - All); Barberio, GaryTo the members of the: ... P~COUNCIL Date ~CA .::f::.._CC 'f-' CM :/=:.. ACM x.., DCM {3) .f:::._ Aug.26,2021 Council Memorandum To: Honorable Mayor Hall and Members of the City Council From: Gary Barberio, Deputy City Manager, Community Services Jeff Murphy, Community Development Dir~ctor {city of Carlsbad Memo ID #2021163 Via: Geoff Patnoe, Assistant City Manager (§s!,_ Re: Mobile Home Park Local Enforcement Agency Evaluation Results (Districts -All) This memorandum provides the results of a recent evaluation conducted by the California Department of Housing and Community Development (HCD) concerning the city's enforcement as the Local Enforcement Agency of the Mobile Home Parks Act and Special Occupancy Parks Act. Background The Mobile Home Parks Act (Section 18200, et. seq.) and the Special Occupancy Parks Act (Section 18860, et. seq.) of the California Health and Safety Code establish the processes and procedures for mobile home park administrative activities such as construction permitting, fees and inspections. Pursuant to state law, the HCD is responsible for ensuring that the Local Enforcement Agency (LEA) is complying with these state standards. The City of Carlsbad is the LEA that governs four city mobile home parks, and one special occupancy park, that are subject to these two state acts. Refer to Attachment A for a list and location of these parks. Two of the mobile home parks are not subject to LEA enforcement. As the LEA, the Building and Code Enforcement Division of the Community Development Department handles the plan review and permitting of alterations made to permanent buildings within these parks as well as additions or alterations completed on the mobile home property (e.g., decks, patio covers, additions). Enforcement of alterations made to the mobile home structure itself (exterior or interior) continues to fall within the jurisdiction of the HCD. Discussion On June 21, 2021, city staff met with representatives from the HCD to formally evaluate the city's enforcement efforts ofthe Mobile Home Parks Act and Special Occupancy Parks Act. Attachment B provides a summation of the HCD findings regarding the city's enforcement processes and procedures. Generally, the HCD found that the city's program was satisfactory, but there were a few areas that required improvement, which are reflected below along with staff's plan of action: Community Services Branch Community Development Department 1635 Faraday Ave I Carlsbad, CA 92008 I 760-602-2710 Council Memo -Mobile Home Park Local Enforcement Agency Evaluation Results (Districts -All) Aug.26,2021 Page 2 • Penalty Fees: The HCD found that the city did not consistently charge double fees for work that was completed without the benefit of a building permit. Staff contended that many park residents are on fixed incomes. As such, so long as the resident made meaningful progress in securing required permits, the city would only charge the regular permit fee rate. However, the HCD reminded staff that this is a state law that all LEAs must follow and is necessary to ensure consistency in statewide fee application. Effective immediately, staff have been advised that double permit fees shall be charged and collected prior to any building permit being issued. • Complaint Investigations: While the city scored well in responsiveness and how the citations accurately described a violation and construction deficiency, the HCD found that the citations did not consistently include the applicable municipal code or building code sections as a reference. To remedy, inspectors will be trained to cite relevant code sections and provided with a copy of the relevant municipal and building code sections that they will maintain in their city vehicle, for reference. • Annual Inspections: The city's Mobile Home Maintenance Inspection Program was cited for not performing the annual Mobile Home Park Maintenance Inspection (MPM). Staff acknowledged this deficiency and agreed to develop a website with content describing the entire Mobile Home and Special Occupancy Park Program. Appropriate forms, such as the Mobile Home Park Maintenance Program (MPMP) letter to residents, Notice of Planned Inspection and an inspection form very similar to the HCD MP 564 will be created for use by city staff during future maintenance inspections. The target date for implementation of these deficiencies is Dec. 1, 2021. • Preparedness Plans: The city was also cited for not having historical copies of mobile home park Emergency Preparedness Plans (EPPs). EPPs are required to be submitted by the park owner to a jurisdiction upon renewal of the annual permit to operate. Staff acknowledged this deficiency and agreed to work with mobile home park owners to prepare and collect EPPs. • Statement of Citizenship Forms: As required by federal law, mobile home park operators must file documentation with an LEA to demonstrate eligibility to receive public benefits. This form is required prior to operating a mobile home or special occupancy park. Staff acknowledged this deficiency and agreed to work with mobile home park owners to collect the documentation. Next Steps A written plan was drafted and was submitted to the HCD describing how and when the city will implement improvements to its LEA responsibilities (Attachment C). Overall, the audit was a positive experience that shed light on areas of opportunity that will help the City of Carlsbad complete its responsibilities as a LEA for the Mobile Home Parks and Special Occupancy Parks Acts. Council Memo -Mobile Home Park Local Enforcement Agency Evaluation Results (Districts -All) Aug.26,2021 Page 3 Attachments: A. Mobile home park data B. Local Enforcement Agency Evaluation C. City response letter to the HCD cc: Scott Chadwick, City Manager Celia Brewer, City Attorney Ron Kemp, Assistant City Attorney Mike Strong, Assistant Director of Community Development Jason Pasiut, Building and Code Enforcement Manager/Building Official Mobilehome Park Data District No. Mobilehome or Special Occupancy Park Number of Units 2 Rancho Carlsbad 504 4 Lakeshore Gardens 383 3 Lanikai Lane 146 2 Camino Hills 112 1 Carlsbad Trailer Plaza 27 RV spaces 3 Solamar 108 2 El Camino Estates 20 1300 total Number of Units Five parks falling under LEA authority 1,168 Two parks not subject to LEA authority 132 Attachment A Page 1 of 1 LEA Responsibility Yes Yes Yes No Yes Yes No %of total 90% 10% Attachment B Page 1 of 12 ~JF OF CAI IFORNIA-BUSINESS CONSUMER SERVICES A""'N""D""'H,,,.o,..,11s""'1N..,.G""A""'G..,,E""N""'========~=----- OEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT DIVISION OF CODES AND STANDARDS MOBILEHOME AND SPECIAL OCCUPANCY PARKS PROGRAM 9342 Tech Center Drive, Suite 500, Sacramento, CA 95826 P.O. Box 278180, Sacramento, CA 95827-8180 1-800-952-8356 / FAX {916) 854-2551 From TDD Phones 1-800-735-2929 www.hcd.ca.qov -June 27, 2021 Mr. Jason Pasiut, Building & Code Enforcement Manager City of Carlsbad: Building and Code Enforcement 1635 Faraday Avenue Carlsbad, ·cA 92008-7314 -Dear Mr. Gil Estrada: RE: Local Enforcement Agency (LEA) Evaluation This letter is a summation of findings for the monitoring performed on June 21, 2021, by Mike Killian, Department of Housing and Community Development (HCD) Codes and Standards Administrator I. HCD is responsible for ensuring your agency's enforcement processes and procedures under the Mobilehome Parks and Special Occupancy Parks Acts (Acts) for inspection and administrative related activities. The LEAs are to meet the requir~ments defined in Health and Safety Code (HSC) · Division 13, Part 2.1, commencing with Section 18300; Which applies to Mobilehome Parks (MP) and H$C Division 13, Part 2.3, commencing with section 18865; Which applies to Special Occupancy Parks (SOP). In addition to requirements defined in Title 25 (T25), California Code of Regulations (CCR), Division 1, Chapter 2 and 2.2, commencing with Sections 1004 and 2004. Enclosed is the 2021 LEA Evaluation for the City of Carlsbad: Building and Code Enforcement. This report provides an overall evaluation of your MP/SOP Program as of the 2021 year, including, but not limited to, submission of applications and permits to operate (PTOs) to HCD, PTO issuance practices, complaint handling, and.the inspectors' activities and abilities. HCD's evaluation of the City of Carlsbad: Building and Code Enforcement's performance as an LEA under the Acts in the year 2021 revealed deficiencies in the assumption of enforcement. Final 2021 Rating as LEA under the Mobilehome Parks/ Special Occupancy Parks Act: Attachment B Page 2 of 12 Mr. Jason Pasiut, Building & Code Enforcement Manager Page2 As a result of HCD's monitoring conducted on June 21, 2021, the City of Carlsbad: Building and Code Enforcement has received a program evaluation of Improvement Needed. The following below include, but are not limited, to the reasons your LEA evaluation was scored this rating: • Mobilehome park operation and administration procedures, such as the Permit to Operate process was done in error. \ • Lack of fil)Jer ency re aredness Qlam;, (EPP} for parks, pursuant to T25, CCR§ 1013. • Lack of delinquent PTO fees being assessed nor is administrative action taken against the park for delinquency, pursuant to T25, CCR§ 1009 and HSC §§ 18550 and 18700. • The State_Cllfillt of Citizenshi forms are not being distributed or collected, pursuant to T25 CCR § 1007 • Mobilehome park permits and procedures, such as the Permit to construct or alterations process was done in error. • Lack of municipal codes or building codes used to cite violations, pursuant to Health and Safety Code (HSC} § 18300. • The City of Carlsbad: Building and Code Enforcement has not performed or scheduled the annual MPM. Pursuant to HSC §§ 18400-18424. HCD provides assistance regarding the Acts requirements for county and city staff upon request. Due to the rating received, the City of Carlsbad: Building and Code Enforcement shall submit to HCD a written plan, describing how and when improvements will be made regarding the LEA's assumption, pursuant to HSC section 18300(d}(1) and 18865(d}(1}. If you have any q'uestions or wish to discuss general MP issues, please contact the Parks program at LEA@hcd.ca.gov. Sincerely, Brandon Holloway . Staff Services Manager I Enclosures STATE OF CALIFORNIA BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT DIVISION OF CODES AND STANDARDS MOBILEHOME PARKS PROGRAM LOCAL ENFORCEMENT AGENCY EVALUATION Attachment B Page3._of12 _· '5 Agency: City of Carlsbad County: San Diego County ID#: _3_7 ______ _ Agency Director: Jason Pasiut ------------------------- Agency Contact Person: _J_as_o_n_P_a_s_iu_t ____ _ Title: Bldg & Code Enforce Mgr Date Issued: June 21, 2021 HCD Evaluator: Mike Killian -CSA I Evaluation Dates: June 21 , 2021 Total Pages: _1_1 _____ _ ------------ The California Health and Safety Code (HSC) section 18306 requires the California Department of Housing and Community Development (HCD) to conduct an evaluation of Local Enforcement Agencies .(LEAs) that have assumed enforcement responsibility of the Mobilehome Parks Act (HSC sections 18200-18700) and Special Occupancy Parks Act (HSC sections 18860-18874), the California Code of Regulations, Title 24 (24CCR) and -Title 25 (25CCR), and other administrative standards adopted pursuant to those Acts. □ 0 0 □ Program Evalu,tion Summary Excellent-No deficiencies noted. Satisfactory -Only minor deficiencies observed. Refer to findings within the Checklist. Improvement needed -Substantial deficiencies observed. Program marginally effective. Changes required to properly enforce the Acts are explained within the checklist. Unsatisfactory -Program ineffective. Necessary changes to the properly enforcement activities are noted within the checklist. Failure to make necessary changes may result in action to revoke your assumption. HCD MP 504 (Rev. 01/21) Fillable Page 1 of 11 Attachment B Page 4 of 12 Program Administration Persons Interviewed: Name Title Telephone Jeff Murphy CD Director 760-602-2783 Jason Pasiut Bldg and Code Enforcement Mgr 760-602-2788 Julie Lopez Accounting Supervisor 760-602-2430 Tony Alvarado Building Inspector II 760-602-2771 The records should collect information and track inspection activities in order to ensure appropriate inspection, reinspection, and enforcement. Part A -Mobilehome Park Permits to Operate (PTO) Issuance Permit to Operate Yes 1. Are parks being invoiced for their PTO annually? (25CCR section 1008) [l] 2. Are the PTO fees consistent with 25CCR section(s) 1008 and/or 2008? l✓l 3. Are copies of the PTO sent to HCD when issued? (25CCR section 1012) Ill 4. Are the state fees being forwarded to HCD within 30 days of receipt? Ill (25CCR section 1012) 5. Are parks properly listed as a mobilehome park (MP) or special occupancy park Ill (SOP) with the number of each type of lot? (25CCR section 1014) 6. Has the LEA collected an Emergency Preparedness Plan from each park? □ (25CCR section 1013) (# collected # not collected ) 7 .. Are there any parks with delinquent PTO fees? If so, how many ? I I 8. Has the LEA notified each park of delinquent PTO fees? (25CCR section 1009) □ 9. Are parks being assessed with penalties for late submittal of the PTO fees? [ZJ (25CCR section 1009) 10. Is Administrative Action taken against park owners who fail to submit the PTO [ZJ fees and the Emergency Preparedness Plan on time? (HSC sections 18550 and 18700) 11. Does the LEA have Statement of Citizenship forms on file for new park □ owners? (25CCR section 1007) 12. Are parks that were converted from rental parks to resident-owned parks [ZJ subjected to the same PTO and inspection processes? (HSC section 18214) Additional Comments/Clarifications: 6. LEA is now aware that they are mandated to collect EPP's, and will correct. No I I f l n □ □ [Z] Ill Ill □ □ [ZJ □ 11. LEA is now aware that they are mandated to get Statement of Ci!izenship forms on file for new park owners, and ~ill correct. HCD MP 504 (Rev. 01/21) Fillable -Page 2 of 11 · Part B -Permits to Construct -Permits to Construct 1. Has the LEA filed all permits to construct for MP, MHI, AS, and EBS? 2. Are fees for permits to construct consistent with 25CCR sections 1020.1 , 1020.4, and 1020.7? 3. Are Standard Plan Approvals being used and accepted without additional plan check fees being assessed? (25CCR section 1020.9) 4. Are permits to construct applications for structures accompanied by a plot plan? (25CCR sections 1020 and 1020.3) 5. Are double fees being assessed for construction work commencing without first obtaining a permit to construct? (25CCR section 1050) 6. Are inspection reports being written for each inspection and specific code sections cited for each violation found as required by 25CCR section 1611? 7. Do inspection reports specify the applicable reinspection fees due when violations are noted or subsequent under construction inspections are needed? (25CCR sections 1020.1, 1020.4, 1020.7, and 1048) 8. Do inspection reports provide an accurate description of cited violations? (25CCR section 1611) 9. Are reinspections performed to clear cited violations? 10. Are municipal codes or building codes used to cite violations? (HSC section 18300) 11. Does the LEA issue alteration permits for manufactured homes? (MHO/UCI) (HSC section 18025) 12. Does the LEA conduct plan checks and inspections on fire sprinkler systems being installed within a manufactured home? (HSC section 18025) 13. Is there an issuance fee for issuing a permit? · 14. Does the LEA charge fees other than those stated in the regulations? Additional Comments/Clarifications: Yes l✓I [l] [l] [l] □ [l] [l] Ill l ✓I □ □ □ I I n Attachment B Page 5 of 12 No □ □ □ [l] □ □ □ [l] [l] [l] ✓ ✓ 5. LEA is now aware that they are mandated to collect double fees for construction work commencing without first obtaining a permit to construct. Re-inspection fees are not collected. The City will start to collect re-inspection fees as required. HCD MP 504 (Rev. 01/21) Fillable Page 3 of 11 Part C -Complaint Handling Complaint ln_vestigatioris 1. Do the individual park file records include complaints received along with the investigative report and actions taken when necessary? 2. Are complainants given advance notice of the pending investigation? (25CCR section 1004.5) 3. Are the complainants being kept apprised ~s to the investigation process? (25CCR section 1004.5) ' 4. Are complaint investigative reports written and violations cited with specific code references? (25CCR section 1611) 5. Do the Notices of Violations provide a notice regarding cqmplaint reinspection fees due when a second reinspection is required due to an ongoing violation? (25CCR section 1004.5) 6. Are complaint investigations with violations followed up in a timely manner? 7. Is appropriate enforcement action taken when violations are not corrected within a reasonable amount of time? (25CCR sections 1610 and 1617) 8. Are complaints concerning immediate threat to health and safety being investigated within 5 days? (25CCR section 1611) 9. Are complaints concerning an unreasonable risk to health and safety being investigated within 30 days? (25CCR section 1004.5) 10. When complaints are referred to the LEA by HCD's Mobilehome Assistance Center (Office of the Mobilehome Ombudsman), does the enforcement agency provide HCD with the results of the investigation within 35 days of receipt of the complaint? (25CCR section 1004.5) 11. Are complaint investigations conducted in compliance with the provisions contained in 25CCR section 1004.5? Additional Comments/Clarifications: None HCD MP 504 (Rev. 01/21) Fillable Page 4 of 11 Yes [l] [Z] [l] [l] [l] ·[l] [l] [l] [l] [l] [l] Attachment B Page 6 of 12 No □ □ □ □ □ I l □ □ □ □ □ Attachment B Page 7 of 12 Part D -Mobilehome· Park Maintenance (MPM) Inspection Program Pre-lnspectio11 Conference This section is based on the MPM process stated in HSC sections 18400 through Yes No 18424. 1. Does the LEA conduct meetings with park operators to explain the MPM □ process? IZl 2. Does the LEA verify the park is operating with a valid PTO? n l ✓l 3. Does the LEA provide or post a Notice of Planned Inspection at least 30 days □ [Z] prior to the park inspection? 4. Does the LEA provide operator and residents with park inspection information □ [Z] booklets prior to the inspection? 5. Does the LEA provide the park operator and/or residents with a link to the MPM □ [Z] inspection video and/or HCD web address to view video? 6. Does the LEA obtain a list of resident names and addresses? □ l✓l 7. Does the LEA obtain a list of registered mobilehome owners when the □ [Z] registered owners are not the occupants? 8. Does the LEA identify all park-owned units by space numbers and check for □ [Z] current registration? 9. Does the LEA provide individual written notices to each resident of the pending □ [Z] inspection? 10. Does the LEA provide the park operator with a summary report of the □ Ill Pre-Inspection Conference? Additional Comments/Clarifications: The City states that they were unaware of the MPM program. DR II/Senior Building Inspector, Carlos Arce, and DR I/Building Inspector, Michael Sanders, has offered to train the City officials in the MPM program. The City expressed gratitude for the offer of help. HCD MP 504 (Rev. 01/21) Fillable Page 5 of 11 Attachment B Page 8 of 12 Part D -Mobilehome Park Maintenance (MPM) Inspection Program (continued) -- -. _ Initial Park Inspection Yes No 1. Are maintenance inspections conducted within 30-60 days following the □ [l] Pre-Inspection. Conference? 2. Does the inspection include all lots and common areas of the park? □ [71 3. Is the enforcement agency citing local ordinances or regulations during the □ [l] inspection? 4. Are current laws and regulations being imposed on pre-existing conditions? I I [l] 5. Are violations determined by the MPM Task Force the only violations being cited during the MPM inspection? (immediate or unreasonable risks to life, □ [l] health, and/or safety) 6. Is the park operator and one representative of the park residents afforded the □ [l] opportunity to accompany the inspector during the MPM inspection? 7. Are detailed reports being written describing the inspection findings? [ l [l] 8. Does each cited violation reference the specific code section being violated? n [71 9. Are parks and the park residents given 60 days to correct violations cited □ [l] during the MPM inspection? 10. When an immediate hazard is observed, is a Notice of Violations issued □ [l] immediately to the responsible party? 11. Are the residents and park owners issued individual Notices of Violations? I I l ✓I 12. Does the park operator have access to the initial resident notices? n [71 13. Are the Notices of Violations issued within 10 days of the inspection? r l [l] 14. Do the Notices of Violations inform the park operator and/or residents of their □ [l] right to request an Informal Conference? Additional Comments/Clarifications: The City states that they were unaware of the MPM program. DR II/Senior Building Inspector, Carlos Arce, and DR I/Building Inspector, Michael Sanders, has offered to train the City officials in the MPM program. The City expressed gratitude for the offer of help. HCD MP 504 (Rev. 01/21) Fillable Page 6 of 11 Attachment B Page 9 of 12 Part D -Mobilehome Park Maintenance Inspection Program (MPM) (continued) Reinspections Yes No 1. Are reinspections for unreasonable risks being conducted in a timely manner □ [l] (end of 60 days for initial inspections and 30 days for reinspections)? 2. Are immediate threats to health and safety violations being followed up within □ [l] 5 days or less? 3. Is the enforcement agency listing the remaining uncorrected resident violations □ [l] and providing the park operator with copies? 4. Is the enforcement agency issuing Final Compliance Orders to the park and residents for uncorrected violations and giving them an additional 30 days to □ [l] comply? 5. Is the enforcement agency following up on the Final Compliance Orders in a □ [l] timely manner (end of 30 days)? 6. Is the enforcement agency issuing letters notifying the park operator of the intent to suspend the Permit to Operate when a park fails to comply with the □ [l] · Final Compliance Orders? 7. Does the enforcement agency take appropriate administrative action against □ [l] the park/residents for failing to comply? (HSC section 18700) 8. Does the enforcement agency grant time extensions for compliance pursuant □ [l] to HSC section 18420(c)(4)? 9. Does the enforcement agency post a list of uncorrected violations against the □ [l] park in a central conspicuous location in the park available to residents? 10. Does the Final Compliance Order issued to a park inform the park operator of □ [l] their right to an Informal Conference and/or Hearing? 11. Do the Final Compliance Orders contain the statement mandated by □ [l] HSC section 18401? 12. Is the park cited for resident violations when the resident fails to correct t~em? f l l ✓I Additional Comments/Clarifications: The City states that they were unaware of the MPM program. DR II/Senior Building Inspector, Carlos Arce, and DR I/Building Inspector, Michael Sanders, has offered to train the City officials in the MPM program. The City expressed gratitude for the offer of help. HCD MP 504 (Rev. 01/21) Fillable Page 7 of 11 Attachment B Page10of12 THE FOLLOWING PARTS ARE TO BE COMPLETED IN THE FIELD DURING AN INSPECTION Part E -Mobilehome Park Maintenance (MPM) Inspection Ability to Inspect and Identify Violations Rating Legend: 1. Item inspected; no violation 2. Item inspected; violation appropriately cited 3. Item inspected; violation missed 4. Item inspected; cited as being a violation inappropriately 5. Item NOT inspected, violation present 6. Not applicable to mobilehome park Inspections Park Common Areas and Facilities Rating Comments 1. Does the fire protection equipment No MPM Inspection Perfonned During Audit comply with 25CCR, Chapter 2, Article 6 section 1300, et seq., or a more stringent local ordinance? 2. If applicable, snow removal program No MPM Inspection Perfonned During Audit approval with documentation 3. Accumulation of rubbish and combustible No MPM Inspection Perfonned During Audit debris-collection system 4. Park permanent buildings-lighting-No MPM Inspection Perfonned During Audit maintenance 5. Overhead electrical-poles-grounding-No MPM Inspection Perfonned During Audit height above buildings 6. Primary electrical systems No MPM Inspection Perfonned During Audit 7. Secondary electrical systems No MPM Inspection Perfonned During Audit 8. Swimming pools, spa, and equipment No MPM Inspection Performed During Audit 9. Earth embankments and retaining wall No MPM Inspection Perfonned During Audit maintenance 10. Roadways-widths-parking-signage No MPM Inspection Perfonned During Audit Additional Comments/Clarifications: No MPM Inspection Performed During Audit. The City states that they were unaware of the MPM program. DR II/Senior Building Inspector, Carlos Arce, and DR I/Building Inspector, Michael Sanders, has offered to train the City officials in the MPM program. The City expressed gratitude for the offer of help. HCD MP 504 (Rev. 01/21) Fillable Page 8 of 11 Attachment B Page 11 of 12 · Part E -Mobilehome Park Maintenance (MPM) Inspection (continued) l_nspections Lots and Accessory Structures Rating Comments 1. MH/RV accessory structures substandard conditions No MPM Inspection Performed During Audit 2. MH/RV accessory structures setbacks and No MPM Inspection Performed During Audit fire separations 3. All corner markers in place No MPM Inspection Performed During Audit 4. Lot coverage 75 percent maximum No MPM Inspection Performed During Audit 5. Stairs provided at each·MH exit door No MPM Inspection Performed During Audit 6. Construction without permits No MPM Inspection Performed During Audit 7. MH utility connections No MPM Inspection Performed During Audit 8. Utility island-electric, gas, water and No MPM Inspection Performed During Audit sewer 9. LPG vessels No MPM Inspection Performed During Audit 10. Accumulation of debris and combustible No MPM Inspection Performed During Audit materials Additional Comments/Clarifications: The City states that they were unaware of the MPM program. DR II/Senior Building lnspector,Carlos Arce, and QR I/Building Inspector, Michael Sanders, has offered to train the City officials in the MPM program. The City expressed gratitude for the offer of help. HCD MP 504 (Rev. 01/21) Fillable Page 9 of 11 Part F -Inspection Report Writing Inspection Reports This section is based on HSC section 18420 and 25CCR section 1611. 1. Is a written notice provided to the person responsible for correction and the responsible person from the park? 2. Do inspection reports include all citable violations observed? 3. Are inspection reports clearly written and describe in the violation(s) in easy to understand (nonexpert) language? 4. Does each report reflect the correct code reference for each violation? 5. Are the reports being issued at the time of the inspection? 6. Does each report give an allotted time for correction? Additional Comments/Clarifications: None Part G -Inspection Preparedness · Inspection Preparedness 1. Is the inspector equipped with or has access to the current HSC? 2. Is the inspector equipped with or has access to the current 25CCR, Chapter 2 and/or 2.2, as applicable? 3. Is the inspector equipped with or has access to the current 24CCR, the California Building Standards? 4. Is the inspector equipped with or have access to the current General Order 95 for overhead wiring and General Order 128 for underground wiring? 5. Is the inspector equipped with the proper tools during the inspections? (i.e. · tape measure, ladder, continuity tester, polarity tester and other necessary tools) 6. Does the inspector demonstrate the ability to identify violations during the inspection exhibiting satisfactory knowledge of the HSC and 25CCR during the inspection? Additional Comments/Clarifications: All the applicable inspection tools and codes are provided to the Building Inspectors. The Department has provided the LEA with a disk of Title 25. HCD MP 504 (Rev. 01/21) Fillable Page 10 of 11 Yes [l] l✓I [l] l✓I [l] l✓I Yes l ✓I [l] [l] [l] [l] [l] Attachment B Page 12 of 12 No □ □ □ No I I □ □ □ □ □ August 11, 2021 Brandon Holloway Staff Services Manager I Department of Housing and Community Development 9342 Tech Center Dr., Suite 500 Sacramento, CA 95827-8180 Dear Mr. Holloway: Attachment C Page 1 of2 ( City of Carlsbad This letter is in response to your recent request for a written plan, describing how and when improvements will be made regarding the City of Carlsbad Local Enforcing Agency assumption. The City of Carlsbad recently completed an LEA evaluation where five deficiencies were discovered: • Lack of emergency preparedness plans (EPP) for parks, pursuant to T25, CCR 1013. • Lack of delinquent PTO fees being assessed nor is administrative action taken against the park for delinquency, pursuant to T25, CCR 1009 and HSC 18550 and 18700. • The Statement of Citizenship forms are not being distributed or collected, pursuant to T25, CCR 1007. • Lack of municipal codes or building codes used to cite violations, pursuant to Health and Safety Code (HSC) 18300. • Building and Code Enforcement has not performed or scheduled the annual MPM. Pursuantto HCS 18400-18424. The City of Carlsbad is committed to upholding our responsibility as the local Enforcing Agency. I propose to plan for and implement the following items listed below in order to more completely fulfill our obligation as the LEA for mobile home and special occupancy parks within our jurisdiction. Specifically, for each of the five deficiencies: • A letter will be drafted to communicate the recent evaluation results with all of the parks within our jurisdiction. We will describe the shortfalls and request that each park do its part to help the city achieve compliance with emergency preparedness plans and statements of citizenship. This letter will be mailed by December 1, 2021. Community Development Department Building and Code Enforcement Division 1635 Faraday Ave. I Carlsbad, CA 92056 I 760-602-2719 t Mr. Holloway August 11, 2021 Page 2 Attachment C Page 2 of 2 • Emergency preparedness plans (EPP}are required to be submitted to a jurisdiction upon renewal of the annual permit to operate. After a plan is approved it is not necessary for the parks to submit the EPP unless changes to the plan were made the previous year. The letter to be drafted to each park by December 1, 2021 describing the results of the recent evaluation will also ask each park to submit a copy of the EPP to the City of Carlsbad Building and Code Enforcement Division. • Further research with the Finance Department discovered that the city has not had to impose delinquency fees on our parks because they all pay the annual permit to renew fee within 30 days. Therefore, I request that this deficiency be removed. • Concerning the Statement of Citizenship forms, the letter to be drafted to each park by December 1, 2021 describing the results of the recent evaluation will also ask each park to submit a copy of the Statement of Citizenship forms to the City of Carlsbad Building and Code Enforcement Division. • A list of municipal and building codes will be distributed to Building and Code Enforcement Division staff for use on correction and violation notices. • Website content will be generated describing the entire City of Carlsbad mobile home parks program. • Relevant forms will be generated, such as the MPMP letter to residents, notice of planned inspection and an inspection form very similar to the HCD MP 564. • Code Enforcement staff will be trained to conduct the annual maintenance inspections. An outreach effort will be made to the parks in our jurisdiction describing our intent concerning the M PM inspection. I would like to express my gratitude for the professional conduct of HCD during this process and the effort being made to help the City of Carlsbad make much needed improvements to our MPA and SOPA program. Sincerely, Jason Pasiut Building and Code Enforcement Manager