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CITY OF PLEASANTON <br />LAW OFFICES <br />GILCHRIST 8a RiJTTER <br />PROFESSIONAL CORPORATION <br />WILSHIRE PALISADES BUILDING <br />1298 OCEAN AVENUE, SUITE BOO <br />SANTA MONICA, CALIFORNIA 80401-t 000 <br />March 31, 2009 <br />VIA FEDERAL EXPRESS <br />Mayor Jennifer Hosterman <br />Vice Mayor Cheryl Cook-Kallio <br />Councilmember Cindy McGovem <br />Councilmember Matt Sullivan <br />Councilmember Jerry Thome <br />City Council of Pleasanton <br />City of Pleasanton, City Hall <br />200 Old Bernal Avenue <br />Pleasanton, Califomia 94566 <br />APR 0 1 2009 <br />CITY ATTORNEY <br />TELEPHONE (310) 383-4000 <br />FACSIMILE (3'10)394-4"l00 <br />E-MAIL: rcloae®gllcM1nsiruttar.cam <br />Re: PMCC-2 /Mobile Home Park Conversion to Resident Ownership for 3263 <br />Vineyazd Avenue: <br />Deaz Mayor Hosterman, Vice Mayor Cook-Kallio, and Councilmembers McGovem, Sullivan, <br />and Thorne: <br />On April 7, 2009 you will be considering the approval of the conversion subdivision of <br />Vineyard Mobile Villas to convert the Pazk from a rental park to a resident-owned pazk pursuant <br />to the Subdivision Map Act, Government Code section 66427.5 (the "Conversion"). <br />Although not given as a ground for denial, some Commissioners were concerned that no <br />one is able to determine at this time at what prices the lots will be offered for sale, in part <br />because the Pazk Owners have guazanteed that the Conversion will not occur for at least ten <br />years. Because the Pazk Owners have agreed not to sell lots for ten yeazs after City approval of <br />the subdivision, such an appraisal today would be useless conjecture. <br />Furthermore, the City has no legal role in evaluating the price of the units. As the Court <br />of Appeal stated in El Dorado, "section 66427.5 does not require disclosure of the tentative <br />price, or the proposed rental prices, at the time of the filing of the tentative map application." <br />Accordingly, the unknowable nature of the price that lots will be offered at also cannot be <br />adequate grounds for denial of the Conversion. <br />That being said, it is important that you consider the fact that the State of Califomia <br />supports such conversions of pazks to resident ownership. One way that they encourage the <br />success of these conversions is through astate-funded financing program called the Mobilehome <br />Pazk Resident Ownership Program (MPROP). This program exists solely to provide low- <br />income residents the opportunity to own their land and to secure and maintain affordable housing <br />through the conversion of existing rental mobilehome pazks to resident owned pazks. <br />ill; J <br />'.~_ y <br />