MHRC Looking Out for Homeowners’ Best Interests!
Over the past year the Mobile Home Resident Coalition (MHRC) volunteers have been working long hours to protect park residents statewide. Our efforts have not gone unnoticed. Several legislative staff and housing advocates have remarked about how incredible MHRC is – we have such dedicated volunteers with no legislative training, who have been extremely productive as we:
- study affordability issues
- research legislators and the numbers of MH voters in their districts
- educate legislators about MH resident needs
- write potential legislation
- offer resources such as lease assistance for a city-owned MHP, a food program for low-income residents, info on rental assistance,
- connect with state and national housing advocates to help us all reach our goals
Request for
Recycling
It may not be possible for all our members to attend rallies and city council meetings but there is something everyone can do to show your support and contribute to our efforts. Recycle. Create a recycling program at your park and contribute the donation revenue to our Coalition. Some parks, like Skandia, have been doing this for over a year, contributing hundreds of dollars in the process. It’s not difficult to do. All it takes is one volunteer and container, although several volunteers and three recycling containers at each site is more effective. Three large plastic bins — identified for Plastic, Glass and Aluminum Cans — are best for collection. And several collection centers located in resident locations around the park make recycling easy and more convenient for everyone. Pickups of the recycling by one volunteer can be scheduled at the end of the week, or as necessary depending upon the participation of your park residents. That volunteer would then take the recycling to an appropriate center and arrange to deliver the collected funds to a coalition leader or park representative or directly to our coalition treasurer, Pat Taylor at Rancho Huntington. MHRC has a lot more work to do, and we can expect our costs — for flyers, postcards and other media and promotional materials — to increase. We’re hoping all our parks will establish a recycling program and support our ongoing struggle. If anyone needs more information about how to set up your program, please contact Art Estrada 562-588-5360 or Anita Thornton [email protected].
Mobile Home BILLS in The 2024 CA Legislature
- Each year hundreds of bills are introduced in Sacramento but may change drastically as they move along. Visit the Legiscan website – for up-to-date info.
- ACA 10 (Haney) - Fundamental Human Right to Housing - This law recognizes that every person is entitled to adequate housing and it is the shared responsibility of state and local jurisdictions to fulfill this right. Read measure text and status here. DRAMATICALLY CHANGED & PASSED
- AB 661 (Patterson) - Utility services: electronic communication - This law authorizes management, upon consent of the homeowner or resident, to provide notices through electronic communication. Read bill text and status here. PASSED & CHAPTERED
- AB 977 (Rodriguez) - Emergency Departments: Assault and Battery (includes assault and battery against HCD Code Enforcement Officers) - would make assault and battery on a health care provider or HCD Code Enforcement Officer punishable by jail and/or a fine Read bill text and status here. WITH THE GOVERNOR
- AB 1985 (Patterson) - Home Solicitation Contracts - would establish methods for the rescission or a contract, but does not appear to apply to MHPs Read bill text and status here. WITH ASSEMBLY JUDICIARY COMMITTEE
- AB 2022 (Addis) Mobilehome parks: emergency preparedness - would require MHPs to have an emergency plan or a permit to operate will not be valid Read bill text and status here. WITH THE GOVERNOR
- AB 2243 (Wicks) - Affordable Housing Developments - would make changes in affordable housing but appears to not apply to MHPs Read bill text and status here. WITH THE GOVERNOR
- AB 2247 (Wallis) Mobilehomes - would require utility connections to conform to State requirements Read bill text and status here. WITH THE GOVERNOR
- AB 2278 (W. Carillo) - Rent increases: percentage change in the cost of living: Department of Housing and Community Development - would require HCD to publish the maximum allowable rent increase on its website for each metropolitan area Read bill text and status here. ON SENATE SUSPENSE FILE
- AB 2373 (Rendon) - Mobilehomes: Late or Non-Payments - would change the tax clearance certificate requirements and would extend the compliance date for registration Read bill text and status here. WITH THE GOVERNOR
- AB 2387 (Pellerin) - Mobilehome Parks: Additional Lots: Exemptions from Fees - would allow a MHP to be enlarged by 10% if the permit to operate has not been suspended; would not allow existing facilities to be reduced in size; would prohibit additional fees Read bill text and status here. WITH THE GOVERNOR
- AB 2539 (Connolly) - MHP Sale - Notice: Right of First Refusal - would require notice to all MHP residents & HCD; would give a resident organization a right of first refusal to buy the MHP and to negotiate in good faith Read bill text and status here. DEAD
- AB 2584 (Lee) Single-family Residential Real Property: Corporate Entity: Ownership—This bill would prohibit a business entity that has an interest in more than 1,000 single-family residential properties from purchasing, acquiring, or otherwise obtaining an interest in another single-family residential property and subsequently leasing the property. Read bill text and status here. HEARING CANCELED BY AUTHOR
- AB 2778 (Muratsuchi) - Mobilehome Parks: Rent caps - would limit rent increases for mobilehome spaces; the bill is currently a “spot” bill meaning all its language is not included Read bill text and status here. DEAD
- AB 2997 (Patterson) Subdivisions: Manufactured Homes This bill aims to promote affordable housing by exempting the review and approval, conditional approval, or denial of a subdivision for a manufactured home development project from CEQA. Read bill text and status here IN ASSEMBLY COM ON H & CD
- AB 3200 (Hoover) - Master-Metered Mobilehome Parks and Manufactured Housing Communities: Transfer of Water Systems - would establish a pilot program for certain water corporations to take over the ownership and operation of water systems in a MHP; would prescribe procedures, costs and mediation Read bill text and status here. HEARING CANCELLED BY AUTHOR
- SB 37 (Caballero) Older Adults & Adults with Disabilities Housing Stability Act - This bill establishes the Older Adults and Adults with Disabilities Housing Stability Pilot Program (Program), administered by the Department of Housing and Community Development (HCD), to provide housing subsidies to older adults and adults with disabilities who either are experiencing or at risk of experiencing homelessness, in up to five geographic regions or counties. Read bill text and status here. WITH THE GOVERNOR
- SB 1052 (Seyarto) Mobilehomes - would make changes in the Mobilehome Residency Law Protection Program to allow free legal help to MH residents for less egregious issues and would suspend yearly payments by park owners to cover legal fees. If a MHP owner has passed this charge on to residents and the bill passes, residents should note the $10/year fee disappears from your bill, if this bill passes Read bill text and status here. DEAD
- SB 1095 (Becker) - Cozy Homes Cleanup Act: Building Standards: Gas- and Fuel-Burning Appliances - would not prohibit the installation of plumbing, heating, or air-conditioning systems for manufactured homes, mobilehomes, or multifamily manufactured homes from being located outside the home Read bill text and status here. WITH SENATE COM ON APPROPRIATIONS
- SB 1108 (Ochoa Bogh) - Mobilehome Parks: Notice of Violations - would require HCD (or the city if it enforces the Mobilehome Parks Act) to give notice of violations to the park owner; would give the tenant and park operator 90 days to fix the violations before taking further actions; would prohibit revocation of a permit to operate solely based on uncorrected violations Read bill text and status here. WITH GOVERNOR
- SB 1190 (Laird) - Mobilehomes: Solar Energy Systems - would allow MHP residents to install solar energy systems Read bill text and status here. PASSED
- SB 1201 (Durazo) Limited Liability Corporation (LLC) Owner Transparency Act - This bill passed in the Senate but was withdrawn by the author when the Assembly wanted significant changes. The author may re-introduce next year. This bill would have required Limited Liability Corporations (LLCs) to notify the Secretary of State as to its owners so that agencies could more easily communicate, especially in terms of health & safety violations. MHRC offered amendments to include MHCs. Read bill text and status here. DEAD
- SB 1212 (Skinner) Investment entities: purchasing, acquiring, or leasing interests in housing - The bill would increase opportunities for homeownership by barring hedge funds and other corporate investment entities from buying single-family homes or other dwelling that consists of one or 2 residential units in California on and after January 1, 2025. The bill would define “investment entity” as a real estate investment trust or an entity that manages funds pooled from investors and owes a fiduciary duty to those investors. The bill would exempt nonprofit organizations and other entities primarily engaged in the construction or rehabilitation of housing from the definition of “investment entity.” Read bill text and status here. DEAD
- SB 1408 (Roth / Durazo) Mobilehome Parks: Vehicle Removal - This bill would prohibit management from removing a vehicle used or required by the homeowner for work or employment, or which advertises any trade or services on the vehicle, from a homeowner’s or resident’s driveway or designated parking space, or a space provided by management for parking vehicles, unless any part of that vehicle extends into the park roadway or otherwise poses a significant danger. Read bill text and status here. PASSED
- PRICE Program Funding (S.3264 / H.R.6321) – The Preservation and Reinvestment Initiative for Community Enhancement (PRICE) program was established in 2023 with $225 million for grants to bring manufactured home park community infrastructure up to code. A request for continued funding is authored by Senator Cortez Masto (NV), who has four co-sponsors, and Representative Bonamici (OR), who has two co-sponsors. DEAD
- Manufactured Housing Tenant’s Bill of Rights Act (S.2204 / H.R.4557) - The bill codifies basic tenant lot rental protections already required by the Federal Housing Finance Agency for manufactured home park communities purchased with federally-backed loans, including: one-year renewable leases, except for good cause; 60-days’ notice of rent increases, park sales and closures; a 5-day rent payment grace period; and a right to sell a home after eviction. The proposal is authored by Senator Jeanne Shaheen (D-NH), with two co-sponsors, and Representative Brittany Petersen (CO), with seven co-sponsors. IN COMS: U.S. HOUSE COM ON FINANCIAL SERVICES & U.S. SENATE BANKING HOUSING & URBAN AFFAIRS
- Fair Manufactured Housing Lending Act of 2023 (H.R.2481) - The bill adds manufactured housing retailers to the Truth in Lending Act as mortgage originators, in order to provide the same home buyer protections against predatory lending enjoyed by site-built home buyers. The proposal is authored by Representative Suzanne Bonamici (OR) with 17 co-sponsors. U.S. HOUSE COM ON FINANCIAL SERVICES
- Manufactured Housing Community Sustainability Act of 2022 (S.4475) - This bill provides a capital gains tax credit of 75% if a community owner sells a manufactured home park community to a resident-owned cooperative or qualified nonprofit organization. U.S. SENATE COM ON FINANCE
- The Housing Acquisitions Review and Transparency (HART) Act (S.4620) - This bill by Sens. Amy Klobuchar (D-MN) and Sherrod Brown (D-OH), requires corporations and private equity firms that snap up large amounts of housing to report those transactions to antitrust enforcers so enforcers can stop anti-competitive transactions that could increase rents, decrease services, and push homebuyers out of the market. U.S. SENATE JUDICIARY COM
- Stop Predatory Investing Act (S.2224) - Sponsored by Sen Sherrod Brown and his committee to lower housing costs, this national bill would deny taxpayers owning 50 or more single family properties any tax deduction for interest paid or accrued in connection with any single-family residential rental property. It also disallows depreciation of residential rental property owned by such taxpayers. The bill also offers incentives to investors to sell single family rentals back to homeowners or community non-profits. MHRC has requested a meeting to include manufactured housing. U.S. SENATE COM ON BANKING HOUSING & URBAN AFFAIRS
April 24, 2023 - Huntington Beach Mobile Home Advisory Board meeting
The meeting was called to order at 6:05 p.m. with all Board members, City Staff, Grace Yoon-Taylor, and Council liaisons present. There were about 20 members of the public present from various MHPs including Skandia, Del Mar Estates, Huntington by the Sea and Rancho Huntington. Kathy Carrick was sworn as the newest member at large.
The public comments ranged in topic from the need for Zoom to return as an alternative to attending in person, so our members can participate in the meeting, the need for the Market Rate Study, a question about a Board member not residing in HB as required for all other Boards and a request for an apology for a Board member’s remarks at the last meeting.
After a bit of wrangling, a new Ad-Hoc Committee was formed (Miller, Chase, Talley) to search for and implement ways to help MH resident owners other than rent. It will be very exciting to see what ideas come that are fresh and new.
Megan Kerkorian, CaliROC, presented on Resident Owned Communities in California and nationwide. The Investor versus Resident owned brings autonomy and control to a MH community. The Cooperative’s members decide on the rules, rent, services, maintenance and upgrades. There is the security of land ownership. The ROC team helps with documents, assistance with funding, ongoing education, and guidance in both property management and cooperative governance.
Our next speakers, Ken Lynch (HOA President Huntington Harbor Village (HHV)) and Charley Payne (resident HHV) spoke from a local resident owned community viewpoint, HHV in HB. They introduced us to the history and how much work it was to become a resident owned community. These two gentlemen shared their responsibilities from 2011 to the present. Their monthly HOA fee of $258 (maintenance, landscaping, etc) has remained the same for almost 5 years. The last MH sold for $968K and this year co one could sell for a million. HHV (now called a Condo Association) has a lot of pride in being Resident owned.
The rest of the meeting was about future topics for July 24,2023. It was agreed that the board would invite HCD (Housing and Community Development) which governs safety regulations in MHPs to present. It has been about 10 years since the last HB MHP’s inspection in the city and hopefully, this presentation can help us all get prepared for the next one.
After brief Board member remarks the meeting adjourned at approximately 7:30 p.m. The next meeting is July 24, 2023, 5pm, City Hall Room B-8. See you then!
The meeting was called to order at 6:05 p.m. with all Board members, City Staff, Grace Yoon-Taylor, and Council liaisons present. There were about 20 members of the public present from various MHPs including Skandia, Del Mar Estates, Huntington by the Sea and Rancho Huntington. Kathy Carrick was sworn as the newest member at large.
The public comments ranged in topic from the need for Zoom to return as an alternative to attending in person, so our members can participate in the meeting, the need for the Market Rate Study, a question about a Board member not residing in HB as required for all other Boards and a request for an apology for a Board member’s remarks at the last meeting.
After a bit of wrangling, a new Ad-Hoc Committee was formed (Miller, Chase, Talley) to search for and implement ways to help MH resident owners other than rent. It will be very exciting to see what ideas come that are fresh and new.
Megan Kerkorian, CaliROC, presented on Resident Owned Communities in California and nationwide. The Investor versus Resident owned brings autonomy and control to a MH community. The Cooperative’s members decide on the rules, rent, services, maintenance and upgrades. There is the security of land ownership. The ROC team helps with documents, assistance with funding, ongoing education, and guidance in both property management and cooperative governance.
Our next speakers, Ken Lynch (HOA President Huntington Harbor Village (HHV)) and Charley Payne (resident HHV) spoke from a local resident owned community viewpoint, HHV in HB. They introduced us to the history and how much work it was to become a resident owned community. These two gentlemen shared their responsibilities from 2011 to the present. Their monthly HOA fee of $258 (maintenance, landscaping, etc) has remained the same for almost 5 years. The last MH sold for $968K and this year co one could sell for a million. HHV (now called a Condo Association) has a lot of pride in being Resident owned.
The rest of the meeting was about future topics for July 24,2023. It was agreed that the board would invite HCD (Housing and Community Development) which governs safety regulations in MHPs to present. It has been about 10 years since the last HB MHP’s inspection in the city and hopefully, this presentation can help us all get prepared for the next one.
After brief Board member remarks the meeting adjourned at approximately 7:30 p.m. The next meeting is July 24, 2023, 5pm, City Hall Room B-8. See you then!
HB City Council
The City of Huntington Beach is the only Charter City that bans any form of rent control (in Section 803 of the City Charter). This was initiated years ago by a group of park owners and developers and passed by a small number of voters. Since 2020 the MHAB has worked to convince the City Council to remove Section 803, to no avail. We also convinced the MHAB to recommend the City Council fund a modestly-priced study of MHP resident owners. Again no dice. We were told finding out who we are and what we’re up against would lead to rent control.
Now the City Council may be considering disbanding the MHAB which is our only representation in city government. City Council members continue to take large donations from park owners and their lobbyists and then do their bidding.
When will our elected officials consider us – hard-working MHC homeowners including young families, disabled, low-income, and seniors on a fixed incomes? When will they approve a Housing Plan that attempts to help city workers to actually live in Huntington Beach?
City Council Links
The City Council meets the first and third Tuesday of each month. Unless otherwise announced, the meetings are held in the City Council Chambers at 2000 Main Street and typically begin at 4 P.M. with a study session or closed session meeting. The open session portion of the City Council meeting starts at approximately 6 P.M. and can be viewed on cable television on channel 3.
Council meetings are webcast live and also archived on the City's website. See below for links to see MHRC in action.
The Public Comments portion of the meeting is at the beginning of the meeting. During Public Comments anyone may address the City Council on any issue for a maximum of three minutes.
The City Council meetings are rebroadcast on the city’s cable television station (HBTV) on Tuesday at 10am and Wednesday at 6pm.
In Person
City of HB
2000 Main St. City Council Chambers (lower level)
For more information visit: https://www.huntingtonbeachca.gov/government/elected_officials/city_council
Now the City Council may be considering disbanding the MHAB which is our only representation in city government. City Council members continue to take large donations from park owners and their lobbyists and then do their bidding.
When will our elected officials consider us – hard-working MHC homeowners including young families, disabled, low-income, and seniors on a fixed incomes? When will they approve a Housing Plan that attempts to help city workers to actually live in Huntington Beach?
City Council Links
The City Council meets the first and third Tuesday of each month. Unless otherwise announced, the meetings are held in the City Council Chambers at 2000 Main Street and typically begin at 4 P.M. with a study session or closed session meeting. The open session portion of the City Council meeting starts at approximately 6 P.M. and can be viewed on cable television on channel 3.
Council meetings are webcast live and also archived on the City's website. See below for links to see MHRC in action.
The Public Comments portion of the meeting is at the beginning of the meeting. During Public Comments anyone may address the City Council on any issue for a maximum of three minutes.
The City Council meetings are rebroadcast on the city’s cable television station (HBTV) on Tuesday at 10am and Wednesday at 6pm.
In Person
City of HB
2000 Main St. City Council Chambers (lower level)
For more information visit: https://www.huntingtonbeachca.gov/government/elected_officials/city_council
August, 2023
RUMOR HAS IT!
Members of the public in Huntington Beach (HB) have heard a rumor that the city’s Mobile Home Advisory Board (MHAB) may not be long for this world. The MHAB was formed years ago by the City Council to (a) ensure the quality of life in mobile home (MH) parks
and to review matters concerning mobile home parks in the City of Huntington Beach through healthy communication with park owners, manufactured home owners and the City Council; and (b) to act in an advisory capacity to the City Council on matters concerning the mobile home community.
What has the MHAB done for residents? Mobile homeowners in HB represent nearly 3000 residents, primarily seniors, veterans, persons with disabilities, and low-and moderate-income families of all ages. Over the years the MHAB has presented information to the public on new legislation affecting MHs, homeowners’ insurance, permits and inspections, surviving a disaster, buying one’s own MH park, the Mobilehome Residency Law, and many other topics.
How has the MHAB helped residents? The MHAB has also been the agency MH residents approach to voice their concerns about unscrupulous park owners, unfair city ordinances, and their needs for more assistance. MHAB has helped get a lease extended for the city-owned MH park, provided funds for some low-income families to get rental assistance, and helped residents bring their homes up to code. It is the only place where MH residents and park owners can voice their concerns and be on the public record.
How has the City Council failed us? In the past year the MHAB members recommended to the City Council that it approve (1) removal of MHs from the city’s ban on rent control under Section 803 of the City Charter and (2) develop a city-wide MH market study to better understand this constituency. Both recommendations, approved and recommended by the MHAB were turned down by the City Council. Public records show Thousands of Dollars in contributions by MH park owners and their lobbyists to the four new City Council members!
HB City Council has now appointed a group of three members to determine which Committees, Boards, and Commissions will be erased from our local city structure.
Please sign our electronic letter to alert the HB City Council and the MHAB and to express your dissatisfaction with any potential disbanding of the MHAB.
Link To Our Electronic Letter
and to review matters concerning mobile home parks in the City of Huntington Beach through healthy communication with park owners, manufactured home owners and the City Council; and (b) to act in an advisory capacity to the City Council on matters concerning the mobile home community.
What has the MHAB done for residents? Mobile homeowners in HB represent nearly 3000 residents, primarily seniors, veterans, persons with disabilities, and low-and moderate-income families of all ages. Over the years the MHAB has presented information to the public on new legislation affecting MHs, homeowners’ insurance, permits and inspections, surviving a disaster, buying one’s own MH park, the Mobilehome Residency Law, and many other topics.
How has the MHAB helped residents? The MHAB has also been the agency MH residents approach to voice their concerns about unscrupulous park owners, unfair city ordinances, and their needs for more assistance. MHAB has helped get a lease extended for the city-owned MH park, provided funds for some low-income families to get rental assistance, and helped residents bring their homes up to code. It is the only place where MH residents and park owners can voice their concerns and be on the public record.
How has the City Council failed us? In the past year the MHAB members recommended to the City Council that it approve (1) removal of MHs from the city’s ban on rent control under Section 803 of the City Charter and (2) develop a city-wide MH market study to better understand this constituency. Both recommendations, approved and recommended by the MHAB were turned down by the City Council. Public records show Thousands of Dollars in contributions by MH park owners and their lobbyists to the four new City Council members!
HB City Council has now appointed a group of three members to determine which Committees, Boards, and Commissions will be erased from our local city structure.
Please sign our electronic letter to alert the HB City Council and the MHAB and to express your dissatisfaction with any potential disbanding of the MHAB.
Link To Our Electronic Letter
May 2023
“Higher Rents — More Tents”
This was the rallying cry of members of the Mobile Home Resident Coalition (MHRC) who gathered outside of Huntington Beach City Hall on May 2. The mobile homeowners had placed their hope and efforts into AB1035, the Mobile Home Affordability Act, a statewide bill that places a rent cap on what park owners can charge mobile homeowners for space rent, But the legislation hit a roadblock in April when Buffy Wicks, Chair of the Assembly Housing Committee shelved the bill for a year in light of a lawsuit that could potentially threaten the bill’s implementation. With Wicks’ decision, and without any rent stabilization ordinance in the city, coalition members gathered to call attention to the city council’s proposed opposition to AB1035 and their unwillingness to do anything to assist the 7000 constituents – mainly seniors, veterans and lower income families — many of whom now face continued skyrocketing rents and a very real risk of homelessness.
April 2023
Delayed, Not Defeated!
Mobile home owners have three bills we’ve been supporting:
All three bills have suffered at the hands of legislators.
Click here for more details.
WE CANNOT GIVE UP!
- AB 318 (Addis), the Mobilehome Residency Law Protection Act, would extend the program by three years. This program helped resolve complaints from homeowners when park owners violated the MRL.
- AB 1035 (Muratsuchi), the Mobilehome Affordability Act, would have protected lower-income and seniors on fixed incomes from losing their mobile homes as rents across the state skyrocketed. The legislation would have capped mobile home space rents from increasing more than 3% plus the percentage of change in cost of living, or 5% annually, whichever is lower. Additionally, it would not have preempted any local ordinance that offered even stronger protections for renters.
- SB 567 (Durazo), the Homelessness Prevention Act, would reduce the state rent caps from 10% to 5% for all renters. It also contained provisions to prevent landlords from evicting for “substantial repairs” but then immediately renting to new people at higher rents. It also included enforcement provisions.
All three bills have suffered at the hands of legislators.
Click here for more details.
WE CANNOT GIVE UP!
Huntington Beach Mobile Home Park History
Huntington Beach has 17 Mobile Home (MH) Parks (9 are senior parks) with 2,865
spaces = approx. 7,000 people, most of whom are registered voters. All of the
parks are potentially at risk due to conglomerate buyouts and predatory
practices.
In the last 10 years, 8 out of 17 mobile home parks in Huntington Beach have
been purchased by investment firms who immediately raised rents, causing many
residents to either sell or abandon their homes, some becoming homeless.
In the last few years, the purchase of MH Parks by investment firms have become
a national emergency, per U.S. Senate Banking, Housing and Urban Affairs
Committee testimony of March 31, 2022.
Huntington Beach MH residents have asked City Council to adopt the
recommendation of its Mobile Home Advisory Board to place a measure on the
ballot to amend the City Charter Section 803 to allow a Rent Stabilization
Ordinance for MH Parks.
spaces = approx. 7,000 people, most of whom are registered voters. All of the
parks are potentially at risk due to conglomerate buyouts and predatory
practices.
In the last 10 years, 8 out of 17 mobile home parks in Huntington Beach have
been purchased by investment firms who immediately raised rents, causing many
residents to either sell or abandon their homes, some becoming homeless.
In the last few years, the purchase of MH Parks by investment firms have become
a national emergency, per U.S. Senate Banking, Housing and Urban Affairs
Committee testimony of March 31, 2022.
Huntington Beach MH residents have asked City Council to adopt the
recommendation of its Mobile Home Advisory Board to place a measure on the
ballot to amend the City Charter Section 803 to allow a Rent Stabilization
Ordinance for MH Parks.