Capistrano Shores Mobile Home Park Space 54 San

Capistrano Shores Mobile Home Park Space 54, San Clemente Application No. 5 -20 -0432 Support for Staff Recommendation California Coastal Commission May 12, 2021 (Th 12 c) Sherman L. Stacey, Esq. – Gaines & Stacey LLP

• Location The Commission has Approved 10 Replacement Mobile Homes At Capistrano Shores since 2015 with the Same Special Conditions Slide 1 • • • Space #6 Space #12 Space #22 Space #36 Space #67 Space #68 Space #80 Space #81 Space #90 CDP No. Date CDP 5 -19 -1093 CDP 5 -14 -1582 CDP 5 -16 -0265 CDP 5 -19 -1179 CDP 5 -16 -0265 CDP 5 -18 -0326 CDP 5 -09 -179 -A 2 CDP 5 -09 -180 -A 1 CDP 5 -10 -180 -A 1 May 13, 2020 April 15, 2015 February 9, 2017 May 13, 2020 February 9, 2017 February 7, 2019 August 10, 2018 October 11, 2017

The seawall and revetment that protect Space 54 and the remainder of Capistrano Shores is pre-Coastal. According to the hazards engineering report it “is in good condition and not in need of maintenance at this time. ” Even with projected sea level rise in accordance with the Commission adopted Guidance, the seawall will protect the mobile home for its useful life. If ever imperiled, the mobile home can be readily moved. Slide 2

California has detailed regulations adopted by the Department of Housing and Community Development to assure that mobile homes are, and remain, transportable. The building code for mobile homes adopted by HCD is in Title 25 of the California Administrative Code. Subpart J of Section 4070 of Title 25 contains the Regulations on transportability. Slide 3 Subpart J of this Standard covers the general requirement for designating the structure of the mobile home to fully withstand the adverse effects of transportation shock and vibration without degradation of the integrated structure or of its component parts and the specific requirements pertaining to the transportation system and its relationship to the structure. Calif. Code of Regs. , Title 25, Section 4070, Subpart J, Section 280. 901.

Section 280. 903(a) requires mobile homes to fully withstand transportation forces. Section 280. 903(b) requires that structural components resist highway shock and vibration during the original and subsequent moves. Slide 4 The cumulative effect of highway transportation shock and vibration upon a mobile home structure may result in incremental degradation of its designed performance in terms of providing a safe healthy, and durable dwelling. Therefore, the mobile home shall be designed, in terms of its structural, plumbing mechanical and electrical systems, to fully withstand such transportation forces during its intended life. (See 280. 303(c) and 280. 305(a)) California Code of Regs. , Title 25, Section 4070, Subpart J, Section 280. 903(a). Particular attention shall be given to maintaining watertight integrity and conserving energy by assuring that structural components in the roof and walls (and their interferences with vents, windows, doors, etc. ) are capable of resisting highway shock and vibration forces during primary and subsequent secondary transportation moves. California Code of Regs. , Title 25, Section 4070, Subpart J, Section 280. 903(b).

Section 280. 904 contains the applicable standards. The entire system (frame, drawbar and coupling mechanism, running gear assembly, and lights) shall be designed and constructed as an integrated, balanced and durable unit which is safe and suitable for its specified use during the intended life of the mobile home. In operation, the transportation system (supporting the mobile home structure and its contents) shall effectively respond to the control of the towing vehicle in terms of tracking and braking, while traveling at applicable highway speeds and in normal highway traffic conditions. California Code of Regs. , Title 25, Section 4070, Subpart J, Section 280. 904(a) Section 280. 904(b) establishes specific requirements that cover all of the topics listed. (1) Drawbar. (2) Coupling mechanism. (3) Chassis. (4) Running gear assembly. (5) Spring assemblies. (6) Axles. (7) Hubs and bearings. (8) Tires, wheels, and rims. (9) Brake assemblies. (10) Lights and associated wiring. Slide 5