Ordinance Number 1049 ORDINANCE NO. 1049
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF
SAN JUAN CAPISTRANO, CALIFORNIA, MAKING FINDINGS AND
MUNICIPAL CODE AMENDMENTS, ADOPTING LAND USE CODE
AMENDMENT (CA) 17-004, AND AMENDING SECTIONS 9-
3.101(a), 9-3.301(a), 9-3.301(b) AND 9-3.301 (c) OF TITLE 9
(LAND USE CODE) OF THE SAN JUAN CAPISTRANO
MUNICIPAL CODE, ESTABLISHING A SENIOR MOBILEHOME
PARK OVERLAY DISTRICT
WHEREAS, the City of San Juan Capistrano ("City") General Plan includes
policies and goals for senior housing oriented development, and it establishes the
City's objective to provide sufficient housing for senior residents; and
WHEREAS, the City is committed through the General Plan Housing
Element policies to preserving the City's existing affordable housing stock and to
maintaining housing for special needs groups, such as senior citizens; and
WHEREAS, one of the goals of the San Juan Capistrano General Plan is
that the City will promote the maintenance and viability of existing mobilehome
parks through the establishment of appropriate zoning and development
standards; and
WHEREAS, one of the goals of the San Juan Capistrano General Plan is
that the City will assist in the provision of a variety of housing to meet the needs
of the community; and
WHEREAS, approximately 16% of the City's population is made up of
persons age 55 years of age or older, which percentage is significantly larger
than that of Orange County (12%) as a whole; and
WHEREAS, approximately 12.4% of the City's housing stock consists of
mobilehome units; and
WHEREAS, the four (4) mobilehome parks in the City that have long
operated as senior mobilehome parks provide an important source of affordable
senior housing; and
WHEREAS, the four (4) seniors only mobilehome parks represent
approximately 583 spaces out of 1,223 spaces, or 47.6% of all mobilehome
spaces in the City; and
WHEREAS, in accordance with the provisions of Government Code section
65858, the City Council adopted Ordinance 1044, as an interim urgency ordinance
placing a moratorium on the conversion of any mobilehome park currently existing
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in the City from a park occupied primarily or exclusively by residents over the age
of 55 years (senior residents) to a mobilehome park allowing residents of all ages
(the "Moratorium") to assure the continued availability of affordable housing to
residents of existing parks and to individuals over the age of 55 years; and
WHEREAS, the Moratorium will expire on October 7, 2017. Should this
Ordinance be enacted sooner than the MoratoriUrn's expiration date, the
Moratorium will terminate on the day that this Ordinance goes in to effect; and
WHEREAS, the City Council has determined that new regulations are
necessary to protect the public health, safety and welfare of the citizens of the
City, particularly those tenants or residents who are over 55 years of age in
mobilehome parks within the special needs group; and
WHEREAS, certain senior restricted mobilehome parks are faced with the
threat of converting those facilities to all-age mobilehome parks, which would
allow residents of any age to reside in that community, and such conversions to
non-age restricted housing would result in the loss of existing predominantly
senior only housing and is detrimental to the senior citizens of the community.
Additionally, conversions to non-senior housing results in a loss of existing senior
only housing available within the City, and this loss of affordable senior housing in
the City creates a threat to the health, safety and welfare of the seniors in the
City; and
WHEREAS, the 2000 Census demonstrates that a senior citizen occupied
housing unit will likely have fewer residents in the unit than if the unit housed only
non-seniors; and
WHEREAS, Table 26 of the California Travel Trends and Demographics
Study Final Report that was issued to the Department of Transportation, Division
of Transportation Planning, Office of State Planning, in December 2002,
demonstrates that senior citizens are likely to make substantially fewer trips than
non-seniors; and
WHEREAS, that study found that individuals aged 55-59, 65-69, and 75-79
make 87.5%, 78.6%, and 64.5% less daily trips than those aged 40 to 44; and
WHEREAS, in contrast to other senior housing in the City, mobilehome
parks afford seniors the ability to live in their own homes rather than in
apartments and provide a senior living community in a low-rise setting that
typically provides a clubhouse for community events and socializing as well as
recreational facilities inside the park so that the residents can easily walk to these
facilities and events; and
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WHEREAS, many of the seniors living in these senior mobilehome parks
enjoy having their grandchildren visit them in the parks and love children, but
they, like the seniors without grandchildren, purchase mobilehomes in a senior
park in order to live in a quieter community with others in their own age group and
purchased their homes in these parks because they were senior parks that only
accepted prospective purchasers of homes in the park if at least one occupant of
the mobilehome being purchased was 55 years of age or older; and
WHEREAS, the California Mobilehome Park Residency Law, the California
Fair Employment and Housing Act, and the Federal Fair Housing Act each
recognize the need for and value of senior housing by expressly exempting
facilities in which 80 percent of the units are occupied by at least one person who
is 55 years of age or older from the requirement to rent to families with children;
and
WHEREAS, while senior housing complexes in the City, other than senior
mobilehome parks, are generally restricted to senior occupancy by conditions,
covenants and restrictions, this is not always the case in senior mobilehome
parks. The residents of those mobilehome parks have relied upon the
representations of the park management and park owners that only seniors could
purchase homes in those parks and obtain tenancies in those parks. These
representations are often set forth in the leases or rental agreements they were
required to sign upon purchasing a mobilehome in the parks and moving into the
parks and in the rules of those parks, which the residents were also required to
sign and acknowledge. Now some owners of senior mobilehome parks have
indicated that they can, and may be already attempting to, change their parks
from senior parks to family parks, over the objections of their senior residents,
simply by changing park rules using the procedure in Civil Code Section 798.25;
and
WHEREAS, while the seniors now living in senior mobilehome parks
could remain in a park that changed to a family park, those seniors would no
longer enjoy the quiet and companionship of a senior community and the limited
supply of senior parks that now exist in the City could be greatly diminished or
even eliminated. Since mobilehomes are not mobile in any practical sense due
to the high cost of moving a home, the risk of damage to the home in moving,
the loss of improvements such as porches, patios, carports and landscaping,
which cannot be moved, and the lack of available rental spaces in senior parks,
or in any mobilehome park in the City or surrounding areas that will accept re-
located homes, senior residents of a park that becomes a family park would
have to sell the homes in which they have lived for many years and in which
they have invested both financial and personal resources in order to move to
another senior facility. After selling their mobilehomes, these seniors may no
longer have sufficient funds to purchase a mobilehome in another senior park or
other senior facility. Further, as the number of senior mobilehome parks
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diminishes, it will become harder and harder to find a mobilehome to purchase
in a senior park in the City or surrounding areas; and
WHEREAS, for the reasons set forth in the preceding recitals, the City
Council finds it necessary to protect, enhance and encourage the preservation
and enhancement of senior-only mobilehome parks through the adoption of this
Ordinance; and
WHEREAS, the Housing for Older Persons Act amendments to the
federal Fair Housing Act, 47 U.S.C. §3607(b), and the provisions of the
implementing regulations set forth in the Code of Federal Regulations (24 CFR
§100.304(b)(4)) and the Appendix thereto (64 Fed.Reg. 16331) provide that a
senior housing facility or community includes a municipally zoned area and that
an area zoned by a unit of local government as "senior housing" satisfies the
intent requirement of the senior housing exemption from the provisions of the
Fair Housing Act prohibiting discrimination based on familial status; and,
WHEREAS, the City intends that this Ordinance be consistent with, comply
with and implement the federal Fair Housing Act as amended by the Housing for
Older Persons Act and the California statues providing senior housing
exemptions from statutes prohibiting discrimination in housing based on age and
familial status; and
WHEREAS, the subject Ordinance is not subject to the California
Environmental Quality Act (CEQA) because it will not result in a direct or
reasonably foreseeable indirect physical change in the environment as it is simply
maintaining the status quo of the existing use of a property; the activity is not a
project as defined in Section 15378; and the activity is covered by the general
rule that CEQA applies only to projects, which have the potential for causing a
significant effect on the environment. Where it can be seen with certainty that
there is no possibility that the activity may have a significant effect on the
environment, the activity is not subject to CEQA; and
WHEREAS, the Development Services Director has reviewed the
proposed project and has determined that the proposed Code Amendment is not
a project and is not subject to the California Environmental Quality Act (CEQA)
(Pub. Resources Code § 21000 et seq.), the State CEQA Guidelines (Cal. Code
of Regs., tit. 14, § 15000 et seq.), and the Environmental Review Procedures of
the City of San Juan Capistrano and will file a Notice of Exemption; and
WHEREAS, the City Council does hereby find that the Notice of Exemption
has been prepared in accordance with requirements of the California
Environmental Quality Act (CEQA) (Pub. Resources Code § 21000 et seq.), the
State CEQA Guidelines (Cal. Code of Regs., tit. 14, §15000 et seq.), and the
Environmental Review Procedures of the City of San Juan Capistrano, and
hereby directs staff to file said Notice of Exemption; and
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WHEREAS, on July 25, 2017, the City's Planning Commission held a duly
noticed public hearing to consider the provisions of this Ordinance, and following
the receipt of public comments and any written materials, the Planning
Commission closed the hearing, reviewed and considered all the evidence
presented and recommended the Ordinance to the City Council; and
WHEREAS, on August 15, 2017, the City Council held a duly noticed
public hearing to consider the provisions of this Ordinance and following receipt of
all written and oral public comments, the City Council closed the public hearing,
considered the evidence presented, and deliberated.
NOW, THEREFORE, BE IT RESOLVED THE CITY COUNCIL OF THE
CITY OF SAN JUAN CAPISTRANO DOES ORDAIN AS FOLLOWS:
SECTION 1. The City Council of the City of San Juan Capistrano
hereby finds and determines that all of the above Recitals are true and
correct and incorporates such Recitals into this Ordinance as if fully set forth
herein.
SECTION 2. CEQA.
This Ordinance is not a project within the meaning of Section 15378 of the
State of California Environmental Quality Act ("CEQA") Guidelines, because it has
no potential for resulting in a physical change in the environment, directly or
indirectly. The City Council further finds, under Title 14 of the California Code of
Regulations, Section 15061(b)(3), that this Ordinance is nonetheless exempt from
the requirements of CEQA in that the activity is covered by the general rule that
CEQA applies only to projects which have the potential for causing a significant
effect on the environment. Where it can be seen with certainty that there is no
possibility that the activity in question may have a significant effect on the
environment, the activity is not subject to CEQA. The City Council, therefore,
directs that a Notice of Exemption be filed with the County Clerk of the County of
Orange in accordance with CEQA Guidelines.
SECTION 3. Findings.
a) The proposed Land Use Code amendment contained within this
ordinance conforms with the goals and policies of the City's General
Plan because it provides for the fulfillment of the General Plan's goals
and policies, including Land Use Goal 7, which provides, "Enhance and
maintain the character of neighborhoods," and Land Use Policy 7.2,
which provides, "Ensure that new development is compatible with the
physical characteristics of its site, surrounding land uses, and available
public infrastructure." The proposed Land Use Code amendment will
ensure that the seniors-only neighborhoods are maintained, and that
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the parks which were developed for seniors-only use, including limited
parking and open space areas, remain compatible.
b) The proposed Land Use Code amendment contained within this
ordinance is necessary to implement the General Plan and to provide
for the public safety, convenience, and general welfare of the City's
residents. This Land Use Code amendment is necessary to mitigate the
unregulated effects of the conversion of senior housing to non-senior
housing, the potential shrinking of inventory of existing quality housing
which is affordable for seniors, the increased environmental effects of
non-senior housing and to prevent inconsistency with the General Plan
and Development Code. No feasible alternative is available to
satisfactorily mitigate or avoid these specific adverse impacts as well as
or better with a less burdensome effect than the adoption of the
proposed ordinance.
c) The proposed Land Use Code amendment establishing a seniors-only
overlay district for existing seniors-only mobilehome parks does not
modify or impact the development code or standards of the Land Use
Code, but solely restricts the conversion of an existing seniors-only
mobilehome park to an all-age mobilehome park.
d) The conversion of senior mobilehome parks to non-senior mobilehome
parks will result in harmful environmental effects and the loss of
existing affordable senior housing within the City. These effects present
a threat to, and a specific adverse impact upon, public health, safety
and welfare and the City's ability to provide safe and decent housing
opportunities to senior citizens. This threat to and specific adverse
impact upon public health, safety and general welfare that would result
from allowing the conversion of senior housing to non-senior housing
justifies the adoption of this ordinance
e) The proposed Land Use Code amendment contained within this
ordinance conforms with the intent of the City's Development Code and
is consistent with other applicable related provisions thereof.
f) This ordinance is necessary to mitigate the unregulated effects of
conversion of senior housing to non-senior housing, the potential
shrinking inventory of existing quality affordable housing for seniors, the
increased environmental effects of non-senior housing and to prevent
inconsistency with the General Plan and Development Code. No
feasible alternative is available to satisfactorily mitigate or avoid these
specific adverse impacts as well or better with a less burdensome
effect than the adoption of the proposed ordinance.
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g) The proposed Land Use Code amendment contained within this
ordinance is reasonable and beneficial at this time.
h) This threat to, and specific adverse impact upon, public health, safety
and welfare that would result from allowing the conversion of senior
housing to non-senior housing justifies the adoption of an ordinance.
i) California's Unruh Civil Rights Act (Civil Code § 51.1 et seq.) expressly
allows private parties to establish housing for senior citizens and the
Federal Fair Housing Act (42 U.S.C. § 3601 et seq.) expressly allows
for "housing for older persons."
j) On average, senior citizens make less impact on the environment than
do non-seniors, as occupancy rates for seniors are significantly less
than non-senior occupancy rates. Seniors also make substantially
fewer trips than non-seniors, as seniors drive fewer vehicles, and
therefore, they require fewer parking spaces per housing unit than do
non-seniors.
k) Based on the foregoing, all-age family mobilehome parks have a
greater impact on the environment than do existing senior facilities.
SECTION 4. Adoption of Senior Mobilehome Park Overlay District.
A public hearing has been held before the City Council of the City of San
Juan Capistrano, duly noticed and conducted pursuant to the Planning and
Zoning Laws of the State of California. The applicable provisions of the Land Use
Code and the Official Zoning Map, City of San Juan Capistrano, is hereby
amended as provided for in Sections 5 through 11 below.
SECTION 5. Amendment of Official Zoning Map
The proposed MPH-SO Overlay District designation contained on the
"Senior Mobile Home Park Overlay District Map" on file with the City, and bearing
the file number as follows:
Code Amendment 17-004
is hereby approved, and hereby adopted by the City Council and incorporated as
part of the Official Zoning Map, City of an Juan Capistrano, provided in this
Ordinance as Exhibit A.
SECTION 6. Section 9-3.101, subdivision (a) of Article 1 of Chapter 3 of
Title 9 (Land Use Code) of the San Juan Capistrano Municipal Code is hereby
amended to add the following: "(33) Senior Mobilehome Park Overlay (MHP-
SO)".
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SECTION 7. Section 9-3.301, subdivision (a) of Article 3 of Chapter 3 of
Title 9 (Land Use Code) of the San Juan Capistrano Municipal Code is hereby
amended to add as follows:
"(15) Senior Mobilehome Park Overlay District.
The purpose and intent of the Senior Mobilehome Park
Overlay District is intended to preserve a variety and balance of
housing types within the City, and it provides assurances that
existing senior mobilehome parks within the Mobilehome Park
District will remain exclusively available to seniors. The Senior
Mobilehome Park Overlay District shall be designated by the
symbol (MHP-SO) on the City of San Juan Capistrano Official
Zoning Map. The (MHP-SO) designation applies to all of the four
(4) senior mobilehome parks that exist as age-restricted in the
City of San Juan Capistrano as of the effective date of this
section."
SECTION 8. Section 9-3.301, subdivision (b) of Article 3 of Chapter 3 of
Title 9 (Land Use Code) of the San Juan Capistrano Municipal Code is hereby
amended to add as follows:
"(5) No Senior Mobilehome Park located within the MHP Senior
District shall convert to a non-senior mobilehome park. At least
80% of the spaces in mobilehome parks in the Senior
Mobilehome Park Overlay District shall be occupied by at least
one person 55 years of age or older. If an existing mobilehome
park met this qualification on January 1, 2017, and fell below the
80% percent requirement between that date and the effective
date of this section, the Senior Mobilehome Park Overlay District
shall be applied to that mobilehome park and that park shall be
required to operate as a Senior Mobilehome Park by renting
spaces and mobilehomes only when at least one occupant of the
mobilehome is 55 years of age or older. The signage, advertising,
park rules, regulations, rental agreements and leases for spaces
in a Senior Mobilehome Park shall state that the park is a senior
park.
Spaces and mobilehomes in a mobilehome park in the Senior
Mobilehome Park Overlay District shall be rented only to an
occupant that meets the age requirements set forth in this
Section, provided, however, that if any occupant of a space or
mobilehome who does not meet this requirement rented the
space or mobilehome before the effective date of this section, that
occupant shall be allowed to remain, and provided further that
when such occupant ceases to occupy a space or mobilehome,
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the mobilehome and space cannot thereafter be rented except to
an occupant that is at least 55 years of age or older."
SECTION 9. Section 9-3.301, subdivision (b) of Article 3 of Chapter 3 of
Title 9 (Land Use Code) of the San Juan Capistrano Municipal Code is hereby
amended to add "and MHP-SO" to the MHP column within Table 3-1.
SECTION 10. Section 9-3.301, subdivision (c) of Article 3 of Chapter 3 of
Title 9 (Land Use Code) of the San Juan Capistrano Municipal Code is hereby
amended to add "and MHP-SO" to the MHP column within Table 3-2.
SECTION 11. Section 9-3.301, subdivision (b) of Article 3 of Chapter 3 of
Title 9 (Land Use Code) of the San Juan Capistrano Municipal Code is hereby
amended to add as follows:
"(6) Land Use Regulations and Limitations on Rentals.
a) At least 80% of the spaces in mobilehome parks in the designated
Senior Mobilehome Park Overlay District shall be occupied by at least
one individual aged 55 years of age or older. If an existing mobilehome
park met this qualification on January 1, 2017 and fell below the
requisite 80% threshold between that date and the effective date of this
section, the Senior Mobilehome Park Overlay District shall be applied
to that mobilehome park and the park shall be required to operate as a
seniors only residential park by renting spaces and mobilehomes only
to individuals where at least one occupant of the mobilehome or space
is 55 years of age or older.
b) Except as otherwise provided in state law, spaces and mobilehomes in
seniors only residential parks shall be rented only to an occupant who
meets the age requirement set forth in Section 9-3.301, subdivision (b)
of Article 3 of Chapter 3 of Title 9 (Land Use Code) of the San Juan
Capistrano Municipal Code; provided, however, that if any occupant of
a space or mobilehome does not meet the above specified age
requirement for living in a park within the Senior Mobilehome Park
Overlay District before January 1, 2017, such occupant shall be
allowed to remain. When such occupant ceases to occupy any space
or mobilehome, the rmobilehome and space cannot thereafter be rented
except to an occupant who does meet the age requirement set forth in
Section 9-3.301, subdivision (b) of Article 3 of Chapter 3 of Title 9
(Land Use Code) of the San Juan Capistrano Municipal Code and is 55
years of age or older.
c) All signage, advertising, park rules, regulations, rental agreements and
leases for spaces in a seniors only residential park in the Senior
Mobilehome Park Overlay District must state that the park is a seniors
9 01049
only residential mobilehome park and must specify that such
mobilehomes and/or spaces are only available for rent or lease by
individuals such that at least one occupant of the mobilehome or space
is aged 55 years of age or older.
d) Each and every mobilehome park within the Senior Mobilehome Park
Overlay District and designated as seniors only residential park must
have procedures, as may be established and revised by the Director of
Community Development from time to time, for verifying that it qualifies
as a senior facility under applicable federal and/or state law, including
documentation establishing that at least 80% of the mobilehomes or
spaces within the mobilehome park are occupied by at least one
occupant who is 55 years of age or older. These procedures shall
provide for regular updates, through surveys or other means of initial
information supplied to the City by occupants of the park. Such updates
must take place at least once every two years commencing within 180
days following the effective date of this ordinance. Further, a summary
of this occupancy verification documentation required to be maintained
by the owner of a seniors only residential mobilehome park shall be
available for inspection by the City upon written notice and request by
the City."
SECTION 12. Severability.
If any section, subsection, subdivision, paragraph, sentence, clause or
phrase of this Ordinance or any part hereof is for any reason held to be invalid,
such invalidity shall not affect the validity of the remaining portions of this
Ordinance or any part hereof. The City Council of the City of San Juan
Capistrano hereby declares that it would have passed each section, subsection,
subdivision, paragraph, sentence, clause or phrase hereof, irrespective of the
fact that any one or more sections, subsections, subdivisions, paragraphs,
sentences, clauses or phrases be declared invalid.
SECTION 13. Publication.
The City Clerk is hereby directed to cause the following summary of this
Ordinance to be published by two (2) insertions in the Capistrano Dispatch, a
newspaper of general circulation that is printed, published, and circulated in the
City of San Juan Capistrano.
SECTION 14. Effective Date.
This Ordinance shall take effect thirty (30) days after its adoption. The City
Clerk shall attest to the adoption of this Ordinance and shall cause this Ordinance
to be posted and published in the manner required by law.
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SECTION 15. Location and Custodian of Records.
The documents and materials that constitute the record of proceedings on
which this Ordinance is based are located at the City Clerk's office located at
32400 Paseo Adelanto, San Juan Capistrano, California 92775. The custodian of
these records is the City Clerk.
PASSED AND ADOPTED this 15th day of August, 2017.
*KR 4K AYOR
ATTEST:
(I LW V/� �_V-
M RIA MOR I I CLERK
STATE OF CALIFORNIA )
COUNTY OF ORANGE )SS
CITY OF SAN JUAN CAPISTRANO )
I, MARIA MORRIS, appointed City Clerk of the City of San Juan Capistrano, do
hereby certify that the foregoing is a true and correct copy of Ordinance No.
1049 which was regularly introduced and placed upon its first reading at the
Regular Meeting of the City Council on the 15th day of August 2017, and that
thereafter, said Ordinance was duly adopted and passed at the Regular Meeting
of the City Council on the 5th day of September 2017, by the following vote, to wit:
AYES: COUNCIL MEMBERS: Maryott, Patterson, Reeve, Farias and Mayor Ferguson
NOES COUN .IL EMBERS: None
ABSENT: IL EMBERS: None
(I[�, ('
mkRiA MOARIS'CIYY CLERK
11 01049
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss AFFIDAVIT OF POSTING
CITY OF SAN JUAN CAPISTRANO )
I, MARIA MORRIS, declare as follows:
That I am the duly appointed and qualified City Clerk of the City of San Juan
Capistrano; That in compliance with State laws, Government Code section
36933(1) of the State of California, on the 17th day of August 2017, at least 5 days
prior to the adoption of the ordinance, I caused to be posted a certified copy of
the proposed ordinance entitled:
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF
SAN JUAN CAPISTRANO, CALIFORNIA, MAKING FINDINGS AND
MUNICIPAL CODE AMENDMENTS, ADOPTING LAND USE CODE
AMENDMENT (CA) 17-004, AND AMENDING SECTIONS 9-
3.101(a), 9-3.301(a), 9-3.301(b) AND 9-3.301 (c) OF TITLE 9
(LAND USE CODE) OF THE SAN JUAN CAPISTRANO
MUNICIPAL CODE, ESTABLISHING A SENIOR MOBILEHOME
PARK OVERLAY DISTRICT
This document was posted in the Office of the City Clerk
i�
MIA MOR IS, -, ITY CLERK
Sari.fuan Capistrano, California
STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss AFFIDAVIT OF POSTING
CITY OF SAN JUAN CAPISTRANO )
I, MARIA MORRIS, declare as follows:
That I am the duly appointed and qualified City Clerk of the City of San Juan
Capistrano; that in compliance with State laws, Government Code section
36933(1) of the State of California.
On the 8th day of September 2017, 1 caused to be posted a certified copy of
Ordinance No. 1049, adopted by the City Council on September 5, 2017,
entitled:
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF
SAN JUAN CAPISTRANO, CALIFORNIA, MAKING FINDINGS AND
MUNICIPAL CODE AMENDMENTS, ADOPTING LAND USE CODE
AMENDMENT (CA) 17-004, AND AMENDING SECTIONS 9-
12 01049
3.101(a), 9-3.301(a), 9-3.301(b) AND 9-3.301 (c) OF TITLE 9
(LAND USE CODE) OF THE SAN JUAN CAPISTRANO
MUNICIPAL CODE, ESTABLISHING A SENIOR MOBILEHOME
PARK OVERLAY DISTRICT
This document was posted in the Office of the City Clerk
t
( --,(C -i L.,
MARIA MOR I l Y CLERK
San Juan Capistrano, California
13 01049
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