Mobile Home Park Inspection Requirements Have Changed Over Time
Figure 1 is a timeline that describes how requirements in state law for mobile home park inspections have changed over time. In 1967, the Mobilehome Parks Act was enacted. The Mobilehome Parks Act required HCD to inspect all parks annually. In 1970, the park inspection requirement was changed to once every other year. In 1973, the park inspection requirement was repealed. In 1990, the park inspection requirement was changed to at least once every five years. In 1994, the park inspection requirement was changed to once every seven years. In 1998, the park inspection requirement was changed to once every eight years. In 2006, the park inspection requirement was changed to a goal of conducting a park inspection annually at a minimum of 5 percent of mobile home parks.
HCD Has Two Offices and 47 Inspectors Who Conduct Park and Complaint Inspections
Figure 2 is a map of California that describes the jurisdictions of HCD’s two field offices and the number of inspectors that each office employs. HCD has two field offices with a total of 47 inspectors who conduct park inspections and complaint inspections. The southern field office is located in the city of Riverside and employs 23 inspectors. It is responsible for 1,720 parks in the following 14 counties: Fresno, Imperial, Inyo, Kern, Kings, Los Angeles, Orange, Riverside, San Bernardino, San Diego, San Luis Obispo, Santa Barbara, Tulare, and Ventura. The northern field office is located in the city of Sacramento and employs 24 inspectors. It is responsible for 1,920 parks in the following 44 counties: Alameda, Alpine, Amador, Butte, Calaveras, Colusa, Contra Costa, Del Norte, El Dorado, Glenn, Humboldt, Lake, Lassen, Madera, Marin, Mariposa, Mendocino, Merced, Modoc, Mono, Monterey, Napa, Nevada, Placer, Plumas, Sacramento, San Benito, San Francisco, San Joaquin, San Mateo, Santa Clara, Santa Cruz, Shasta, Sierra, Siskiyou, Solano, Sonoma, Stanislaus, Sutter, Tehama, Trinity, Tuolumne, Yolo, and Yuba.
Timing Requirements for Park and Complaint Inspections
Figure 3 is a process chart that describes timing requirements in state law and in HCD’s policies, procedures, and practices for park inspections and for complaint inspections that are not deemed to be an immediate threat to health and safety. Park inspections and complaint inspections generally share the same timing requirements, but they have different timing requirements for the initial inspection. For park inspections, HCD must provide written notice of the inspection and coordinate a preinspection orientation for park owners and residents at least 30 days before the initial inspection. For complaint inspections, HCD must inspect the complaint within 30 days of receiving the complaint. For both park and complaint inspections, HCD must provide a Notice of Violation for cited violations within 10 days of completing the initial inspection, and then must wait at least 60 days before conducting the first reinspection. It must provide a Final Notice of Violation for any unresolved violations within 10 days of completing this reinspection, and must wait at least 30 days before conducting a second reinspection. For any unresolved violations it identifies, HCD must provide a Notice of Intent to Suspend the Permit to Operate within 10 days of completing the reinspection. After the second reinspection, HCD must wait at least 30 days before conducting a third reinspection. HCD may suspend the mobile home park’s permit to operate after conducting the third reinspection. HCD determines timelines for correction of complaints alleging immediate threats to life, health, and safety based on the nature of the violation, the type of immediate threat and the park owner or resident’s capability to repair or correct the violation. For part of our audit period, HCD provided a notice called a Final Compliance Order after a second reinspection and then conducted a third reinspection before issuing a Notice of Intent to Suspend the Permit to Operate. The Final Compliance Order and additional reinspection were applicable to some of the inspection records we reviewed. In February 2019, HCD eliminated the Final Compliance Order and the additional reinspection from its park inspection process. HCD eliminated the Final Compliance Order and the additional reinspection from its complaint inspection process in early 2020.
HCD Conducted Park Inspections at Fewer Than Half of Mobile Home Parks Within Its Jurisdiction From 2010 Through 2019
Figure 4 is a color-coded stacked bar chart that describes the percentages of 3,640 parks within HCD jurisdiction that HCD visited for various types of inspections from 2010 through 2019. The first category, containing 45 percent, or 1,620 of the 3,640 mobile home parks, represents parks at which HCD has conducted a full park inspection. HCD has inspected all 88,100 mobile home lots associated with these mobile home parks. The second category, containing 37 percent, or 1,360 mobile home parks, represents parks at which HCD conducted a complaint inspection. Although complaint inspections may require the review of multiple mobile home lots, complaints are generally associated with only one mobile home lot. Therefore, some portion of the 164,500 mobile home lots from these 1,360 parks were inspected. The third category, containing 9 percent, or 330 mobile home parks, represents parks at which HCD conducted some other inspection work. Similar to complaint inspections, the other inspection work is generally associated with only one mobile home lot. The final category, containing 9 percent, or 330 mobile home parks, represent parks with no documented HCD activity. HCD records to not show that it performed any work between 2010 and 2019 at the 5,700 mobile home lots associated with these 330 parks. As we describe in the text, errors in CASAS may affect the precision of our count of the number of parks at which HCD has conducted other inspection work and the number of parks at which HCD has no documented activity for 2010 through 2019.
HCD Is Not Complying With Preinspection Notification Requirements for Residents
Figure 5 is a chart that describes how often HCD complied with the requirement to notify residents before conducting park inspections. State law requires HCD to provide written notice to residents at least 30 days before the inspection. The chart features 30 envelope icons that represent 30 park inspection files from 2017 through 2019 that we reviewed. Three of these envelopes represent notifications for three inspections in which HCD provided notices on time. Another 11 envelopes represent notifications for 11 inspections we reviewed in which HCD provided notices late. Five of these 11 represent inspections in which HCD provided the notices late, but before the day of the inspection. HCD sent one of these notices was four days late, and sent the other four between 13 and 27 days late. The remaining six envelopes represent six notices HCD sent after it conducted the inspection. HCD mailed four of these six notices between 31 and 40 days late, and mailed the remaining two notices 48 and 326 days late. The remaining 16 envelopes represent the 16 inspections in which HCD did not provide inspection notices, or it is unknown whether HCD did so.
HCD Did Not Provide Notices Within Required Time Frames or Did Not Document When It Sent Notices
Figure 6 consists of four pie charts that describe how often HCD complied with a requirement in state law to notify park owners and residents of violations within ten days after a park inspection. The four pie charts each represent one of four types of notices we tested when reviewing 30 park inspection files for 2017 through 2019. These notices are the notice of violation, the final notice of violation, the final compliance order, and the notice of intent to suspend permit to operate. The number of mobile home parks that receive these different types of notices decreases as outstanding violations are resolved or if HCD failed to provide a notice during a step in the inspection process. In the first pie chart, we identify that HCD was required to issue a notice of violation at 28 of the parks we reviewed. We identify that it did not provide notices to any of the parks within the required 10-day timeframe. HCD provided notices of violation late to 12 of the 28 parks, and could not demonstrate when it provided the notices to the remaining 16 parks. In the second pie chart, we identify that HCD was required to issue a final notice of violation at 23 of the parks we reviewed. We identify that it provided final notices of violation within the 10-day timeframe to one of the 23 parks we reviewed. HCD provided final notices of violation late to nine of the 23 parks, and could not demonstrate when it provided the notices to the remaining 13 parks. For part of our audit period, HCD provided a notice called a Final Compliance Order. In February 2019, HCD removed the final compliance order and an additional reinspection from its park inspection process. In the third pie chart, we identify that HCD was required to issue this final compliance order at 13 of the parks we reviewed. We identify that it provided final compliance orders within the 10-day timeframe to two of the 13 parks we reviewed. HCD provided final compliance orders late to seven of the 13 parks, and could not demonstrate when it provided the notices to the remaining four parks. In the fourth and final pie chart, we identify that HCD was required to issue a notice of intent to suspend permit to operate to seven of the parks we reviewed. We identify that it provided the notice of intent to suspend permit to operate within the 10-day timeframe to three of the seven parks we reviewed. HCD provided these notices late to one park, and could not demonstrate when it provided the notice to the remaining park.