The proposal would convert the park, located near Los Robles Avenue in the Barron Park neighborhood, into a 187-unit housing complex. While local law requires the city to try to identify "comparable" housing for the displaced residents and pay reasonable relocation costs, the letter from the law firm argues that this could be next to impossible without residents having to move to a distant location.
"Being forced to move from the Park will create a considerable hardship for the residents," the letter states. "Most residents will not be able to afford to live anywhere else in Palo Alto, one of the most expensive places in the country to live, without significant housing subsidies or other assistance."
The letter argues that because the city is "significantly involved" in the closure of Buena Vista, it can be considered a "displacing agency" under the California Relocation Assistance Act. The city, the letter notes, has been facilitating community meetings on the project and helping Prometheus find a relocation specialist and appraiser. The city's involvement, the letter states, makes residents eligible for benefits under the CRAA, which applies to projects "undertaken by a public entity." This includes "significant relocation benefits, including the purchase of a comparable home."
The law firms also argue that closing the park would "wreak havoc in the lives of its residents in less tangible ways" by severing the ties that have formed between neighbors and eliminating what has become a "distinct community" in Palo Alto.
The conversion would also exacerbate Palo Alto's already severe shortage of affordable housing, the law firms argue, and would run contrary to the city's housing element, its official vision document for housing. It urges the city to deny efforts to convert the mobile park or, failing that, to only approve the project if it's consistent with the CRAA and the city's ordinance.
"The closure of Buena Vista Mobile Home Park would be nothing short of catastrophe for many of its residents, and it would cause the loss of an important source of affordable housing in one of the country's most expensive cities," the letter co-signed by attorneys from the two firms states.
The proposal to convert Buena Vista to an apartment complex has created a swell of anxiety and opposition among the park's residents, about 30 of whom attended a City Council meeting in October to urge the council to oppose the project. Several said the displacement would have a particularly harsh impact on their children, who would no longer be able to attend Palo Alto schools. Residents from the surrounding Barron Park neighborhood, school volunteers and affordable-housing advocates have been critical of the Prometheus proposal and have formed working groups in recent months to consider ways to help the roughly 400 Buena Vista residents.
While the council has yet to discuss the project, the city's Human Relations Commissions passed a resolution on Feb. 28 calling for the city to make "every effort" to help displaced residents relocate somewhere in Palo Alto. The commission also urged the school district to allow children of Buena Vista residents to continue to attend local schools and ensure that no residents become homeless because of this project.
The proposed conversion comes at a time when the city is struggling to meet regional mandates for affordable housing. While the city has about 600 rent-controlled units, they are all occupied and have long waiting lists. Buena Vista residents pay between $800 and $1,300 in monthly rent.
While the mobile park lies on private property, the city has some leverage when it comes to the Prometheus proposal. The conversion of the mobile park to an apartment complex would require a zone change by the City Council to allow greater density at the site. Such a zone change would run counter to at least one provision in the city's Comprehensive Plan, the official land-use bible.
The Comprehensive Plan states that "to the extent feasible, the city will seek appropriate local, state and federal funding to assist in preservation and maintenance of the existing units in the Buena Vista Mobile Home Park."
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