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Home My WebLink AboutMemo - Read Before Packet - 02/25/2025 - Memorandum from JC Ward re Council Work Session Item - Mobile Home Park Oversight and EnforcementSocial Sustainability Department Neighborhood Services 222 Laporte Ave. PO Box 580, Fort Collins, CO 80522 970.224.6047 jcward@fcgov.com CC: Marcy Yoder MEMORANDUM Date: February 25, 2025 To: Mayor Arndt and City Councilmembers Through: Kelly DiMartino, City Manager Jacob Castillo, Chief Sustainability Officer From: JC Ward, Community Engagement Manager, Neighborhood Services Subject: Read Before – Council Work Session Item – Mobile Home Park Oversight and Enforcement The purpose of this memo is to provide City Councilmembers an updated version of Attachment #4 for the Mobile Home Park Oversight and Enforcement item’s Agenda Item Summary. Some formatting changes were made but the content is consistent with the previous version and with the other AIS materials. Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here Community Engagement Manager – Neighborhood Services JC Ward Mobile Home Park Oversight and Enforcement 02-25-2025 Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 2 Direction Sought 1)Given the increase in complaint resolution at the State level, does Council want to consider local enforcement of issues that are governed by state regulations? 2)What priorities does Council have regarding the City’s mobile home park work? 3)Who else should we bring into the conversation to inform this work? Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 3 Agenda Background •Mobile Home Parks in Fort Collins •City Mobile Home Park Activity Highlights •Colorado Mobile Home Park Oversight Program Current Oversight & Enforcement Enforcement Gaps Next Steps Direction Sought Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 4 Background – MHPs as Affordable Housing •Residents may own their home, but the land it sits on is owned by the mobile home park. •Mobile home parks are private property, as are their streets, water infrastructure, and most fencing and safety lighting. •MHP neighborhoods in Fort Collins are home to some of the largest concentrations of historically underserved populations including non-English speakers, lower-income households, and senior citizens. Mobile home parks are private, unsubsidized,“naturally- occurring” affordable housing. Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 5 MHP Location Map City GMA Total Communities 10 14 24 Home Sites 1,400 2,137 3,537 City Limits Manufactured Home Community GMA Boundary Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 6 Background – MHP Residents’ Rights TeamDocusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 7 Current City MHP Activities – Promote Resident Awareness & Empowerment Activity City Departments Involved Education & Outreach Building Services Code Compliance Conflict Transformation Works Cultural Services Economic Health Office Environmental Services Department Equity Office FC Moves Healthy Homes Natural Areas Neighborhood Services Park Planning Parks Department Planning & Development Review Police Services Transfort Urban Renewal Authority Utilities - Energy Conservation Utilities – Income-Qualified Programs Utilities – Water Conservation Utilities - Water Field Operations Utilities – Water Quality Lab Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 8 Current City MHP Activities – Promote Resident Awareness & Empowerment Activity City Departments Involved MHP Mini-Grants Environmental Services Department Healthy Homes Neighborhood Services Utilities – Water Conservation Resident Association & Organizing Assistance Equity Office Neighborhood Services Local Complaint System (Access Fort Collins) Neighborhood Services Communications & Public Involvement Office (“CPIO”) MHP Webpage CPIO Neighborhood Services Targeted Community Mediation & Community Mediators/Promotoras Program Conflict Transformation Works External - Community Partners Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 9 Current City MHP Activities – Promote Resident Awareness & Empowerment/ Improve Livability, Habitability, & Safety Activity City Departments Involved Community Consultants Neighborhood Services Utilities – Energy Conservation MHP Handbook Neighborhood Services Neighborhood Liaisons Neighborhood Services Community Conversations Focus Group Equity Office Enforcement of Municipal Code (Section 18) Code Compliance Forestry** Neighborhood Services Section 18 Residents’ Rights Updates City Attorney’s Office Code Compliance Neighborhood Services Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 10 Current City MHP Activities – Improve Livability, Habitability, & Safety Activity City Departments Involved Complaint-Based Inspections & Enforcement Building Services Rental Housing Zoning Services Local & State Policy Analysis & Recommendations City Manager’s Office Neighborhood Services Social Sustainability Department Local Nuisance Code Proactive Enforcement Rollout Code Compliance Neighborhood Services Broadband Infrastructure & Income-Qualified Service Fort Collins Connexion Transportation Access Planning & Projects FC Moves Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 11 Current City MHP Activities – Improve Livability, Habitability, & Safety/ Preserve Housing Affordability Activity City Departments Involved Limitation of Required Upgrades Neighborhood Services Maintenance Responsibilities Code Changes City Attorney’s Office Neighborhood Services Larimer Home Improvement Program & Emergency Grants External - Loveland Housing Authority Healthy Homes Neighborhood Services Utilities – Energy Conservation Utility/Water Services Billing Transparency Code & Process Changes City Attorney’s Office Fort Collins Utilities Neighborhood Services MHP Home Improvement Grants Environmental Services Department Healthy Homes Neighborhood Services Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 12 Current City MHP Activities – Preserve Housing Affordability Activity City Departments Involved Partner/Contractor Projects - CARE; LCCC Utilities – Energy Conservation External - Larimer County External - Energy Outreach Colorado Eviction Legal Fund Trainings & MHP Resident/Landlord Support External - Community Partners Neighborhood Services Maintenance Responsibilities Code Changes City Attorney’s Office Neighborhood Services Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 13 Background – Colorado MHPOP The Colorado Mobile Home Park Oversight Program: •Began operating in May 2020, allowing mobile homeowners, property managers, and owners to file complaints. •Has subpoena power for records related to their investigations, ability to levy monetary penalties for violations of the Act, and power to issue cease and desist orders. •Requires mobile home park owners to register annually and maintains a statewide database of registered parks. Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 14 MHP Complaints •318 complaints from Fort Collins residents since 2020 •29 Notices of Non-Violation •7 Notices of Violation •11 cases still open 9 Key Data Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 15 MHPOP Complaints & Enforcement Outcomes Number of Fort Collins MHPOP Complaints and Enforcement Outcomes Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 16 Overlaps & Gaps in MHP Enforcement Sample of Current MHP Enforcement in Fort Collins Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 17 Overlaps & Gaps in MHP Enforcement Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 18 Enforcement Gaps •Infrastructure & Maintenance Issues: •No on-the-ground inspectors from MHPOP for complaints like tree assessment, snow removal, or lot grading •No oversight by technical experts for maintenance/repair of water lines or enforcement of repairs •Limited or no jurisdiction for oversight of road maintenance, streetlights, speeding, fences, or parking issues •Resident Barriers to Self-Advocacy: •Fear of retaliation from landlords and no local investigation of retaliation •Frequent changes in property management and lack of training •No enforcement of manager availability during office hours •No state-level mediation services •Lack of Coordination Between Agencies: •Confusion over which entity (City or MHPOP) handles specific complaints •Navigating issues within a complex network of enforcement agencies (like water access during shutoffs) Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 19 Next Steps - Staff Evaluation Potential Areas for Staff Evaluation: •Ways to coordinate with MHPOP on specific complaint types that align with City Staff expertise. Explore options for payment or service models to fill gaps in investigations. •Cost analysis to increase local capacity for mediation and community-based promotoras for earlier, efficient resolution of conflict between parties. •Partnerships and negotiated investment opportunities with property owners to provide or assist in making infrastructure assessments and recommendations. •Coordination of a template library for enforceable park rules and lease terms based on MHPOP’s determinations Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 20 Next Steps – Staff Evaluation (Low-Cost or Tradeoff) Potential Low-Cost Activities or Tradeoffs for Existing Resources Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 21 Possible Next Steps - Code ChangesDocusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73 Headline Copy Goes Here 22 Direction Sought 1)Given the increase in complaint resolution at the State level, does Council want to consider local enforcement of issues that are governed by state regulations? 2)What priorities does Council have regarding the City’s mobile home park work? 3)Who else should we bring into the conversation to inform this work? Docusign Envelope ID: 66E25162-468F-4443-BC51-8ACAEAF98F73