The No Place To Go Project (“Project”) supports the proposed alternative housing ordinance (“Ordinance”). We have some suggestions to improve it, but we see no dealbreakers. We urge passage of the Ordinance.
It’s been our concern all along that the regulations would be so restrictive and expensive that it’s just housing on paper, not on the ground. The two-year requirement people will either discourage people from taking advantage of the Ordinance, or they will resort to the unregulated housing black market.
Consequently, the major effect of the Ordinance may be to give Code Compliance the guidelines to require the landlord and/or tenant to bring an existing and occupied alternative dwelling unit into compliance instead of forcing the relocation of the tenant.
Code Compliance must remain complaint-driven. Code Compliance must be directed to prioritize bringing violators into compliance. Forced relocation must only be used as a last resort. Meritless and malicious complaints must be dismissed.
Probably the biggest disincentive to requesting a permit for a legal RV placement is the requirement in Section C.1. of the Ordinance. That section requires a fee and inspection every two years to renew the permit. Very few people are going to want to agree to that. An initial inspection and permit should be sufficient.
Amendment #2 – Reduce permissible acreage
The purpose of the Ordinance is to provide more housing. Restricting RV tenancy to three acres (Section C.6.) or more limits the availability of housing. We recommend one acre with proper screening and setbacks.
Amendment #3 – increase rental term
The purpose of the Ordinance also is to provide housing for low-income locals, not tourists. We recommend changing Section C.5.a. from 30 days to 90 days to discourage short-term rentals.
Amendment #4 – permit removal of the wheels
Section C.10. prohibits removing the wheels from an RV. Because we are targeting low-income people who may need rental assistance, we recommend eliminating this provision. By converting an RV to an ADU (accessory dwelling unit), tenants could then qualify for federal rental assistance under the rules of the Department of Housing and Urban Development (HUD), which issues Housing Choice vouchers (aka Section 8).
Amendment #5 – prohibit movement during evacuations
Wildfire is a risk to all of us. In the event of a wildfire, we want to prohibit the movement of tiny homes on wheels and residential RVs during an evacuation because of the potential to slow down or jam up traffic. In exchange for the privilege of an alternative dwelling permit, tenants must sign an agreement not to jeopardize everyone’s safety by attempting to move their homes during a wildfire warning or evacuation. Penalties could be imposed for violation.
Amendment #6 – landlord-liaison program
To protect property owners who are concerned about renting to an unhoused person seeking to transition out of homelessness, Nevada County offers a landlord-liaison service that guarantees rent, offers financial incentives to landlords, and covers repair/replacement costs. Landlords may take advantage of this service by calling 530-878-5088 or writing HCT@amihousing.org.
Timely passage
We don’t want any amendments to stop the process if they’re going to require significantly more time to modify the regulations. For example, it might require additional staff time to stipulate what kind of support (e.g., blocks, foundation) will be required for Amendment #4.
Passage of the Ordinance should not be delayed because of an approved amendment. The Ordinance should be passed with language stating regulations for the amendment will be generated and implemented within six months after passage of the Ordinance.
