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Project Title: |
Continued Family Occupancy of an Existing Mobile Home |
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County File Number: |
#CDLP26-02010 |
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Appellant: |
Janelle Craig |
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Applicant/Owner: |
Janelle Craig (Applicant) / Eleanor and Kenneth Nolen (Owners) |
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Zoning/General Plan: |
A-40 Exclusive Agricultural District / AC Agricultural Core |
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Site Address/Location: |
16 Hoffman Lane, Brentwood (Assessor’s Parcel Number: 011-050-012) |
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California Environmental Quality Act (CEQA) Status: |
Exempt, CEQA Guidelines Section 15061(b)(4) |
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Project Planner: |
Allison Seoane, Project Planner (925) 655-2871 |
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Allison.Seoane@dcd.cccounty.us |
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Staff Recommendation: |
Deny (See section II for full recommendation) |
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I. PROJECT SUMMARY
This is an appeal of the County Zoning Administrator’s decision to deny a Land Use Permit application for continued use of a temporary mobile home for family occupancy to care for family members with hardships due to health and age that was established in 2001. No modifications to the mobile home are proposed.
II. RECOMMENDATION
Department of Conservation and Development, Community Development Division (CDD) staff recommends that the County Planning Commission:
A. OPEN the public hearing, RECEIVE testimony, and CLOSE the public hearing.
B. FIND that the project is exempt from CEQA under Section 15061(b)(4) of the CEQA Guidelines.
C. DENY the appeal by Janelle Craig.
D. UPHOLD the Zoning Administrator’s denial of County File #CDLP26-02010, based on the attached findings.
E. DIRECT staff to file a Notice of Exemption with the County Clerk.
III. GENERAL INFORMATION
A. General Plan: AC Agricultural Core.
B. Zoning: A-40 Exclusive Agricultural District.
C. California Environmental Quality Act (CEQA) Compliance: CEQA Guidelines, Section 15061(b)(4), Review for Exemption, exemption for projects that will be rejected or disapproved by a public agency.
D. Previous Applications:
1. RZ93-3005: A rezoning application to rezone approximately 11,644 acres of land with a range of former designations to the Exclusive Agricultural District (A-40) to conform with the General Plan designation of Agricultural Core (AC).
2. LP75-2029: A Land Use Permit application to establish a temporary mobile home to be occupied by a caretaker or watchman was approved on April 9, 1975, for a period of 2 years.
3. LP77-2036: A Land Use Permit application to renew LP75-2029 for the continued use of a temporary mobile home to be occupied by a caretaker or watchman was approved in April of 1977.
4. LP01-2119: A Land Use Permit application to establish a temporary mobile home for occupancy to care for a family member with hardships due to health was approved by the Zoning Administrator on December 10, 2001, for a period of 5 years. This is the initial approval of the subject mobile home.
5. BI322649: A Building Permit application to install the subject mobile home on a temporary foundation passed its final inspection on May 20, 2002.
6. LP09-2032: A Land Use Permit application to renew expired LP01-2119 for the continued use of a temporary mobile home for occupancy to care for a family member with hardships due to health and age was approved by the Zoning Administrator on October 19, 2009, for a period of 5 years with an opportunity to apply for a 3-year administrative extension.
7. LP17-2024: A Land Use Permit application to renew expired LP09-2032 for the continued use of a temporary mobile home for occupancy to care for a family member with hardships due to health and age was approved by the Zoning Administrator on January 8, 2018, for a period of 5 years with an opportunity to apply for a 3-year administrative extension.
8. CV23-0005: A Compliance Verification to extend LP17-2024 to allow the temporary use of a mobile home to continue for 3 more years was approved administratively on January 19, 2023.
IV. BACKGROUND
The proposed project was heard at the County Zoning Administrator hearing held on Monday, August 3, 2026, with staff’s recommendation for approval. The hearing was open to the public and testimony was accepted by the applicant, Janelle Craig. No other members of public spoke on this item.
The Zoning Administrator found the project no longer qualifies as temporary pursuant to County Code Section 84-68.2002 because the caregiver has needed to live on the property for 24 years to continue providing care and, therefore, denied the Land Use Permit to allow further extension. The Zoning Administrator recommended the applicant explore the option of converting the mobile home into a detached Accessory Dwelling Unit (ADU) to legally establish it as a permanent living unit.
An appeal of the Zoning Administrator’s decision was filed on August 11, 2026, within the 10-day appeal period, by Janelle Craig, the project applicant, to again request approval of the continued use of the mobile home in its current state. Her reasons for appeal are summarized under section VII. A, and the letter of appeal is attached to this staff report.
V. SITE AREA/DESCRIPTION
The subject property is a 22-acre parcel on the southwest corner of Marsh Creek Road and Hoffman Lane located outside the Urban Limit Line. The property is developed with a single-family residence, a temporary family-member-occupied mobile home, and a barn located off of Hoffman Lane, but is primarily used for producing crops. The majority of surrounding properties are used for agricultural production and contain single-family residences for owner occupation. Some properties in the vicinity are zoned Light Industrial and maintain uses for manufacturing.
VI. PROJECT DESCRIPTION
The applicant requests approval of a Land Use Permit to continue the use of an existing mobile home for family occupancy for the applicant (daughter) to care for family members (parents) with hardships due to health and age. The mobile home has been occupied by the caregiver since its initial approval in 2001. Land Use Permits approved in 2009 and 2018 to continue the caregiver occupancy have expired. No modifications to the mobile home are proposed.
VII. APPEAL
An appeal letter from Janelle Craig, the applicant and on-site family caretaker, was received on August 11, 2026. The appeal letter is included as Attachment B. It is summarized below and followed by a staff response.
A. Appeal Summary: In accordance with section 84-68.2002 of the County Code, there are hardships involving age and health, and not mere financial need or convenience, that require the use of a temporary mobile home for the applicant to occupy as familial caregiver. Both of the applicant’s parents, who are also the property owners of 16 Hoffman Lane, are elderly (aged 86 and 87) and have multiple medical conditions. As such, they require their daughter’s on-site assistance for daily care and regular transportation to their numerous doctors’ appointments related to their confidential medical conditions. One parent is already unable to drive, and the other parent will soon be ineligible to renew their license to be able to drive, furthering the need for the applicant to live nearby to provide transportation. The applicant states that the mobile home is a temporary use, as she has expressed the intent to remove the mobile home once it is no longer necessary for her to care for her parents.
Staff Response: While there is evidence to support the need for the applicant to live on-site to provide assistance to her parents, the Zoning Administrator determined that the mobile home can no longer be considered “temporary” as it is 24 years old and an extension for additional years of use has been requested.
Per County Code Section 84-68.2002, financial need and convenience cannot be considered as factors for approving a family occupancy mobile home. Further, there is a zoning-compliant alternative that allows the applicant to continue living on-site without needing a temporary mobile home. The applicant may apply for a ministerial ADU permit to construct an entirely separate detached ADU up to 1,200 square-feet in floor area with an attached garage as large as 800 square-feet. This option did not exist when the mobile home was originally approved. Because the family occupancy mobile home has proven to not be temporary, and a viable option to replace it exists, the Zoning Administrator could not support continued use of the mobile home.
Staff’s recommendation is to uphold the Zoning Administrator’s decision to deny CDLP26-02010 based on the attached findings. However, if the County Planning Commission determines that continued use of the family occupancy mobile home is compliant with the County Ordinance Code, then an approval may be based on the findings and conditions of approval included in Attachment G Staff Report for the August 3, 2026, Zoning Administrator hearing.
VIII. STAFF ANALYSIS
A. General Plan Consistency: The subject property has a General Plan designation of Agricultural Core. Specifically, this prime agricultural area is designated for cultivating intensive row crops, while estate-style residential development is inconsistent with this designation. The allowed density is one unit per 40 acres. Neither a temporary mobile home nor ADU count toward density. All existing development is limited to a small, consolidated portion of the property, and the majority of the property is used for cultivating row crops. As such, the existing single-family residence and family-occupied mobile home do not qualify as estate-style residential development and are consistent with the Agricultural Core designation.
As the Agricultural Core designation is an allowed designation for properties located outside of the Urban Limit Line, and this project is consistent with the Agricultural Core designation, this project is also permitted outside of the Urban Limit Line.
B. Zoning Compliance: The subject property is located in the A-40 Exclusive Agricultural District. The project complies with all objective development standards (setbacks, height limit, etc.) of the zoning district. Pursuant to County Code Section 84-68.2002, in any land use district, family members may occupy a temporary mobile home for the purpose of caring for their relatives who live in the principal residence and have hardships due to age and health, but not for mere financial need or convenience, with the approval of a Land Use Permit. While there are hardships due to age and health, the mobile home has been in place for 24 years, which the Zoning Administrator determined exceeds the temporary nature of the intent of the Code Section. Therefore, continued use of the mobile home is not compliant with the County Code.
C. Sacramento-San Joaquin Delta: The subject property is located within the Secondary Zone of the Delta, and therefore, not subject to the Delta Protection Commission’s Land Use and Resource Management Plan for the Primary Zone of the Delta.
IX. CONCLUSION
The Zoning Administrator determined that continued use of a 24-year-old mobile home for caregiver occupancy to care for family members with hardships due to health and age is not consistent with County Code Section 84-68.0002. The mobile home no longer qualifies as a temporary use, and an alternative is available that allows the applicant to live on-site without continued use of the mobile home. Staff recommends that the County Planning Commission uphold the Zoning Administrator’s denial of County File CDLP26-02010 based on the attached findings.
ATTACHMENTS
A. Findings for Denial
B. Letter of Appeal received on August 11, 2026
C. Maps
D. Project Plans
E. Site Photos
F. Agency Comments
G. Staff Report for the August 3, 2026 Zoning Administrator Meeting
H. Power Point Presentation