HomeMy WebLinkAboutMemo - Mail Packet - 3/30/2021 - Memorandum From Jc Ward, Ryan Mounce, Emily Olivo Re: Mobile Home Park/Manufactured Housing Community Zoning And Enforcement Update
Planning, Development & Transportation
Community Development & Neighborhood Services
281 N. College Ave.
PO Box 580
Fort Collins, CO 80522
970.416.2350
970.224.6134 FAX
www.fcgov.com
MEMORANDUM
DATE:March 25, 2021
TO: Mayor Troxell and Councilmembers
THRU: Darin Atteberry, City Manager
Kyle Stannert, Deputy City Manager
Caryn Champine, PDT Director
FROM: JC Ward, Senior City Planner, CDNS
Ryan Mounce, City Planner, CDNS
Emily Olivo, Neighborhood Liaison, CDNS
RE: Mobile Home Park/Manufactured Housing Community Zoning and Enforcement
Update
This memo is in response to a request from the March 16, 2021 City Council meeting as well as
the March 22nd LPT meeting for updates on the status of Mobile Home Park/Manufactured
Housing Community rezoning and local enforcement plans.
Background
Rezoning: The City has completed the rezoning of six of the nine manufactured housing
communities in Fort Collins to the manufactured housing zone district. Three remaining
communities feature mixed or commercial zoning and additional consideration and amendments
to City policy plans before potential rezoning to the manufactured housing zone district could
occur.
Enforcement: Due to state legislation that established the state dispute resolution center, and
the enforcement that was anticipated as a result, local enforcement of City and state law
regarding MHP’s was paused in 2020. However, at least two complaints filed with the state
dispute resolution center in August 2020 have not received any response, so efforts to improve
local enforcement have resumed.
Manufactured Housing Community Zoning
A map of the three remaining manufactured housing communities which have not been rezoned
to the manufactured housing zone district can be found in Attachment 1. The three communities
are all located in the North College corridor and include:
North College (mix of residential and commercial zoning)
Montclair (commercial zoning; site also includes a motel)
Stonecrest (commercial zoning)
Staff determined the western half of the North College community within the Low Density Mixed
Use Neighborhood zone district is a candidate for rezoning. Staff recommends initiating this
rezoning as soon as conditions for in-person engagement allow as this community features a
senior population and a large number of residents without internet access.
Staff is not recommending rezoning the remaining two and a half properties based on their
commercial zoning designation and the policy/land use guidance provided by the North College
Corridor Plan and City Plan. Both documents indicate greater land use flexibility and intensity
along the North College Avenue frontage which conflict with standards of the manufactured
housing zone district. As rezonings must comply with the comprehensive plan and subarea
plans, an amendment to these policy documents will first require amending both plans and
reverting longstanding land use and policy guidance for these properties and their immediate
context related to redevelopment and infrastructure improvements.
Additional considerations for amending City Plan and the North College Corridor Plan are
outlined in Attachment 2, a November 2020 staff memo outlining options and additional process
required for the potential rezone of commercial properties.
Staff is also monitoring recently introduced state legislation (House Bill 21-1117) which would lift
restrictions on local jurisdictions’ ability to require affordable housing in rental (re)development.
If lifted, the City would have more tools available to consider requirements for affordable
housing preservation beyond a traditional rezoning.
Mobile Home Park Code Enforcement
The Mobile Home Park Residents’ Rights Team is currently developing the timeline and staffing
assessment for livability Code enforcement in mobile home parks and reviewing options for
local enforcement of the state’s Mobile Home Park Oversight Act and Amendments. The
purpose of Mobile Home Park (“MHP”) Residents’ Rights programs is to improve the city’s
relationship with MHP managers, increase manager and owner accountability, and provide
consistency in livability in all neighborhoods across the city.
The divided ownership model and related power dynamic unique to mobile home parks where
residents own the home but rent the lot from the MHP makes standard processes for Code
enforcement of Municipal Code less effective and has greater potential to create financial
hardship for residents. In other neighborhood types, property owners are ultimately responsible
for Code violations on the property including the cost of compliance and fines. In a mobile home
park, that enforcement structure would need modification to avoid MHP owners becoming
financially responsible for all violations within the park and passing the costs of compliance and
fines along to residents. Since proactive Code Compliance has not been occurring in mobile
home parks in the city for years, residents, property managers, and MHP owners will also need
some time and assistance to get their spaces prepared in advance of regular enforcement.
An education program with community clean-up days leading up to regular proactive Code
Compliance patrols will be implemented over the next three years, with a concentrated
engagement effort in 2021 and 2022 that will enable city staff to learn the full scope of the work,
build relationships with residents and management, and support MHP’s compliancy prior to any
official inspection. In 2021, we have already begun this engagement effort with senior (55+)
MHP’s and have 2-day grant funded, volunteer-based clean up and resource fair events
planned in each senior MHP this Fall. Other engagement techniques planned include mock
inspections and neighborhood walks with code enforcement staff to answer questions and
prepare managers.
The final Code Compliance enforcement program will include not only regular proactive patrols
and investigation of complaints, but also an annual inspection and requirements for
documentation for each MHP with a priority focus on water quality, infrastructure maintenance
or plans, tree maintenance, and utility billing transparency. Priority enforcement focus areas will
be periodically reviewed and updated to ensure emerging and important issues are addressed.
Additional requirements and opportunities for management are being explored, such as
providing a copy of MHP rules and lot rent amounts, incentives for enhanced livability initiatives,
and continuing education classes with certification for MHP property managers.
In order to meet the demands of this program, Neighborhood Services is submitting a 2022
enhancement Budgeting for Outcomes (“BFO”) offer to conduct staffing needs assessments,
track minimum and maximum intervals for proactive Code Compliance patrols, and pay for
community clean-up supplies such as roll-off dumpsters or landscaping supplies, Staff also
anticipates a 2023/24 BFO enhancement offer for the additional MHP Code Compliance staffing
needed and a mini-grant program to assist residents and property owners with mitigation of
Code violations through 2024.
The MHP Residents’ Rights Team seeks to balance the need for enforcement and improvement
of livability issues with the potential for the cost burden of enforcement fines to be passed onto
residents. Therefore, our approach puts engagement and education at the forefront and may
include an adaptation of the current Code violation citation fees as they apply to MHP’s.
Mobile Home Park Oversight Act and Amendments Local Enforcement
Enforcement of violations of the Colorado Mobile Home Park Oversight Act and Amendments
have been handled by the Colorado Department of Local Affairs through a complaint-based
system since May 2020. However, Staff is aware of accountability concerns based on
community input and complaint tracking of the state process. Complaints alleging violations of
state law from residents of multiple MHP’s in Fort Collins have not been investigated or closed
in seven months and other complaints are closed without notification of findings to the residents
who filed them. The MHP Residents’ Rights Team is beginning work with partners in the City
Attorney’s Office to develop mechanisms for local enforcement of state law to protect mobile
home park residents and improve accountability for property managers and MHP owners and
would like to bring options for Council to consider in a Work Session in 2021.
CC: Paul Sizemore, Interim CDNS Director
Marcy Yoder, Neighborhood Services Manager
Planning, Development & Transportation
Community Development & Neighborhood Services
281 N. College Ave.
PO Box 580
Fort Collins, CO 80522
970.416.2350
970.224.6134 FAX
www.fcgov.com
MEMORANDUM
DATE: November 12, 2020
TO: Mayor Troxell and City Councilmembers
THRU: Darin Atteberry, City Manager
Kelly DiMartino, Deputy City Manager
Caryn Champine, PDT Director
Paul Sizemore, Interim CDNS Director
Cameron Gloss, Long Range Planning Manager
FROM: Ryan Mounce, City Planner
RE: Manufactured Housing Rezonings Update
The purpose of this memo is to provide a status and schedule update on the rezoning of
properties containing manufactured housing communities.
Background
Within City limits there are nine properties containing manufactured housing communities. Six of
the properties are zoned residentially in the Low Density Mixed-Use Neighborhood (LMN) zone
district, two are zoned commercially in the Service Commercial (CS) zone district, and one
property has split LMN and CS zoning. Attachment 1 illustrates the location and rezoning status
for all nine properties in City limits.
LMN Properties
Staff initiated the rezoning process for the six LMN properties earlier this fall. Following two
neighborhood meetings, required Land Use Code notification procedures and a
recommendation from the Planning and Zoning Board, the proposal to rezone these six
properties to the Manufactured Housing (MH) zone district will be presented to Council on
December 1, 2020.
Staff is recommending small portions of two properties (Northstar and Skyline) remain under
their current LMN designation because they contain non-manufactured housing land uses.
Keeping these areas under LMN zoning allows property owners greater flexibility for land use
changes and would not result in the loss of any manufactured housing units.
Commercial Properties
At the July 28, 2020 work session, Council provided input that the rezoning of commercial
properties containing manufactured housing communities could be considered for each site
based on individual merits. Staff continues to analyze and collect input on the rezoning for the
three properties with commercial or split zoning, all of which are located in the North College
corridor.
Two smaller properties are currently designated fully with Service Commercial zoning and staff
does not recommend rezoning these properties to the MH zone district. Existing policy direction
provided by City Plan and the North College Corridor Plan encourage more flexible commercial
zoning for these properties and rezoning may present challenges to the US287 Access Control
Plan and future street/infrastructure plans. These properties also contain other types of land
uses, such as a motel, that could be impacted by a change to the MH zone district.
If Council directs staff to proceed with further analysis of MHC zoning for these properties, we
must first initiate a planning process to amend City Plan and the North College Corridor Plan.
This will serve to re-evaluate the long term land use policy for these sites in consideration of the
new MHC zone district. This will require a separate process with a recommendation from the
Planning and Zoning Board and approval by City Council and will take several months to
complete. If the conclusion of that process is support for the MHC zone district, then rezoning
action could be initiated.
Staff is also evaluating a third property, the North College senior manufactured housing
community, which contains LMN zoning on the western half and CS zoning on the eastern half.
Staff analysis indicates the western half could be rezoned to the MH zone district to support
manufactured housing preservation. Staff is likely to consider initiating the rezoning process for
the western half of this property in early 2021 while exploring alternative ideas for preservation
for the eastern commercial half of the property as well as the other two North College
commercial properties.