Permit to operate

I own an 18 space mobile park. 12 mobile homes 6 Rvs. Northern California, and I’ve owned it for 17 years. A month ago the state inspector informed me I didn’t have a permit to operate the 6 rvs in addition to the 12 mobile homes. I have old photos from the previous owner (40years old), utility bill showing 18 units, etc, etc. Just no permit for the 6 RV spaces. He’s requiring I go through this overwhelming process to amend the number of spaces.
Is it possible those 6 spaces fall under some sort of grandfathering due to their lengthy existence?
Love the site and community, thank you.

A permit is sometimes required for registration purposes, but it should not be an overwhelming process for a grandfathered property.

Check the ordinance the inspector is trying to enforce to see how it applies to you, if at all. Speak with the city: bring along the papers the inspector gave you (if any), your photos, and anything else to demonstrate it has been operating this way for a long time, and understand 1) why they believe your park is not non-confirming; and 2) what are they trying to achieve with this process.

If you are not happy with the answer then you should speak with a muni attorney with non-conforming use experience to help straighten it out.

It’s a hassle, but can be done.
Start by asking your county or city for any documents they might have on the property. It’s possible they will have the original building permit stuff for the park. Maybe a map, or something showing 18 spaces?

Also contact the permit to operate dept. in Sacramento. Ask them to look back in their file for the park. I’ve seen parks change number of spaces because of a clerical error. Also seen the park owner change the number of spaces in an effort to save on the permit fees.

Look at past tax records to see if those lots are included in your taxed value and if they have been collecting taxes on the lots. If so… bring those receipts to attention of the city as well.

Thank you all for your replies.
Originally I was told by the state inspector that a letter from the county acknowledging the RV spaces would be enough for the spaces to be added to my permit to operate, which I got. HCD (the inspectors supervisor) has since decided that I must go through the process of adding the spaces as if I were expanding the park today, ie drawings, load calculations, environmental impact, signatures from health, public works, cal fire, building, etc.
Seems onerous, but of course I’m biased.
I’m afraid I’ll be held to standards that didn’t exist when they were put in years ago. The attorney I spoke with suggested I go through the permitting process.
I’m curious all your thoughts.
Thanks again!

Why did the attorney suggest that as a better alternative? What kind of attorney was this?

I actually sought the advice of two attorneys.
The first suggested the same, go through the arduous process and get the permits. HCD is so bureaucratic, not worth the fight.
I was unhappy with his analysis of my situation, so found another attorney who suggested the same. Both attorneys practiced real estate law

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I would try talking to a municipal attorney.

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I will try that. Thank you