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HomeMy WebLinkAboutEmail from Kimberly Carr – Expert Public Comment on Emergency Housing Ord RE 12.11.18 BOS Item 4.10 Schuman, Amy From: Menchaca, Clarissa Sent: Monday, February 11, 2019 9:17 AM To: Schuman,Amy Subject: FW: Expert Public Comment on Emergency Housing Ordinance Attachments: Dec 11 Public Comment BOS Butte.pdf Correspondence. CICWW,a,M e nchacc Associate Clerk of the Board Butte County Administration 25 County Center Drive, Suite 200, Oroville, CA 95965 T: 530.552.33081 F: 530.538.7120 Twitter 1 Facebook 1 YouTube 1 Pinterest From:Snyder,Ashley Sent: Monday, December 10, 2018 4:22 PM To: BOS<BOS@buttecounty.net> Cc: Menchaca,Clarissa<cmenchaca@buttecounty.net>; 'info@turtleshells.org' <info@turtleshells.org> Subject: FWD: Expert Public Comment on Emergency Housing Ordinance All— Please see the attachment and below correspondence with regard to Item 4.10 on tomorrow's agenda. Take care, Aslil.e1j N. .swder Assistant Clerk of the Board Butte County Administration 25 County Center Drive, Suite 200, Oroville, CA 95965 T: 530.552.3300 1 F: 530.538.7120 Twitter 1 Facebook 1 YouTube 1 Pinterest From: Kimberly<infoPturtleshells.org> Sent: Monday, December 10, 2018 4:19 PM To:Snyder,Ashley<ansnyder@buttecounty.net> Subject: Re:Test 1 Hello Ashley, Thank you for passing along the attached public comments for the emergency housing policy. Here's internet the link to it, if desired. http://www.turtleshells.ore/buttebos121118/ You will find that I will have information on this website that will support general community needs with RVs. I have no economic stake in any outcome for the recovery, I'm doing this because it's the right thing to do. I will publish your final policies as determined by your board and staff. For questions, I can be reached at (805) 215-4429 Wishing you well in your recovery, Kimberly Carr 2 ''.'y "'ei:: rte-� �x ' .'». ` F:.r•'.. ..�s.;:-M wr,..,.., , �5,� v'af:r,,,:}'sa v4 ' " "i=•/"" "Ssei 'ti}2'G ';t, ta. " ' N, �«lsA � rry,.�t,'<;. .. s,;.. 3"'.h �d;�°'is.s lc';.v_;..-'�, �.Y,o.,�x1c� :rs.S,s.. r,g, `,c:vz%: �3 .,`vu��s,. ,,.r;:,�"' ,:r.v�E'�•.;��..a,l, -..,r.. :a���,.g>�s ,��l- ,cf!�. y,k'��- rs�72�;;,K�;,%, r•E�r, ;,�, `�,, a �',�:. rx<.n..r C. A ,e X)�y,Q�:�;�`r ,.s'` -,tj�,. �,.. ,.„.cc,;;r. � c ,y...w,S,r;�";;,."°,e .',^,'yyl�� Z f ;a`�•v.,_rF.,;si..°n 7 /c,��w?�r "yc,`'iv_nsr =r:. Yr ) r.,�.-��y'^�1.:�. ;;Ic,.,r.,.,a: .:'ham;; K>' •w� n l,`<�,;:E�ia •<.�a ';,;'<L;?"-,,.��H�.^,rz n"` • ' Si �u 3 = `5' C,S �) rP w� 7. , Cz'" �„' 7 s.:;;isy y i' • ta' "' ',,',,�.,��. .M .,ti;.R13,., S� ' 3 w .• a fzy,*,v,�t. ,s 3 y y. 'z„ vr�xr- `�dC� e��:' �- ?.i�`y' • Wm�r1�S� �w?;• ^, �, �7„,,.y,f,:^,;�.,�'"s3w:'� '-�"u`�-ri'�:' �.�.'S;�, G r� ";�� 'Y's"`'v a ��"� ,� �� �'r�-w✓' F��_y- � ���:\�`'�4 '`°�� i vas",1✓/F`�'`�;r�m�3l��s,�� °� • ; ra' �-?...�..Sf r�,,,�..,-'•z:Ta.:1,c^-2. �nom.. � "' �. *ti.�S`. �n .�. rX,h.. :� -Y�'�;���c�r.��s.;r,�' �dR.':ti'� ���s°��.;�s:�.>" The following public comment is in response to the Emergency Housing Ordinance proposed by The County of Butte which will be discussed at the Board of Supervisors meeting on December 11,2018. I don't have a stake in the outcome of your recovery,but I care whether your neighbors are able to stay&rebuild. Their inability to rebuild has economic consequences that ripple FAR BEYOND the boundaries of the burn scar&can affect people throughout the entire state of California. Sometimes choices made in emergency situations aren't well-considered.Everyone is time starved,which makes it difficult to collaborate&consider choices carefully.In government it isn't unusual to follow what other jurisdictions have done without understanding the context,and i caution you against that. I've observed the recovery process in over a dozen communities over the past 4 years &have 15 years,of,RV experience. Each disaster affected community has unique characteristics&fundamental similarities. It is also important to know what aspects were a failure.The choices you make today could be seen as a model for future&just as you look to Santa Rosa as a model,this will destine you&others in the future to repeat the same mistakes. Santa Rosa has the most restrictive post disaster policy in the state,which may have been in part to being severely under-staffed. They made the news headlines several times because they severely limited the geographic area&demographic that the emergency housing policy served.---A strict policy will create what you don't want:.Price gouging&forcing people OUT as housing market prices become out of reach. You must do everything in your power to maximize owner occupancy rates for everyone.Your failure to keep that rate high as possible will result in severe long term economic damage&housing will remain available only to the highest bidder. In order to influence higher owner occupancy. 1. Create the broadest short term emergency policy for housing supply that is within your power,to discourage rising prices for your ENTIRE population,not lust for those displaced by the firestorm. Not only should the whole county consider no burn scar boundaries for the emergency housing policy,but there is always significant under-forecasting of the housing need with the focus on the"victims."The reality is the secondary displacement is HUGE&the influx of contractors for debris, rebuilding,insurance&can far outnumber the people displaced. 2. DO NOT release:.deed restrictions on accessory dwellings for the owner occupancy requirements on SFR 1-4 units.(See SB 1069.Investors,not developers who actually build stuff,want this option badly,so stay vigilant of this.) The economic consequence.of rising prices&restrictive housing policy means fewer people can afford to purchase,pay the annual tax bill or have incentive to return after a disaster. As many locals have said,the vultures are circling...Within 5 days of the fire a handful of investors bought most of the residential inventory&the problem will not stop there. I'm here to help you have a chance to find Paradise again,on your own terms because it is the right thing to do. Thank you for your consideration of this humble wisdom. Kimberly Carr Drafted by TurtleShells.org If referencing,please give credit. "'Page 1- December 11,2018 I've given thousands of hours of my time to this work without pay. Wishing you well on your journey home AGAIN I'm seeking angel support for this work it should be done without consideration to profit generated,which sometimes leads to bad decisions, `"�-�<x.�.��.<{.s-��<:F..,��, -. iñRi 'i.q.�3✓-Y ti.�.,-.y.y r Emig <j;:-_:4rh.,,`'r<t'S-�Sr-Ar a <Fr<s , <✓- vnyhi�r.l 1.:o✓a�`vT'r S3 Y�:-„!��.'�"� s.;...fR.a�>.,•::.<,.�.`a�.�;e, r�..0�r s;'rr�F� m!�4.^:) .r,.x. P•71 'T-.5...�:�,- s r.�fx�, x...�.4�, P ;.<�..r'.�,r.�,,•,�...<�v3 <:r�?:..n;,_.�x�i.,�-��'4. Please see specific comments, then a suggested model policy for your consideration Page 3,Line 24: "to meet the urgent need for housing of displaced persons" Page 3Line 26: Displaced person(s)A county resident whose dwelling was destroyed or damaged...may be required to provide verification..." Page 4,Line 1: "...return to properties within the boundaries of the Camp Fire." Suggested:Do NOT model the Santa Rosa policy! The impact that such a policy will have on housing prices is staggering & such a policy is not about the displaced,it is about the ENTIRE community. Take a look at Mendocino &Lake Counties which are more reflective of your housing density &acute shortage of units. --- Provide the broadest options possible to mitigate price escalation&plan for termination of the policy on a specific future date Page 4,Line 10:'Shall remain in effect until December 31,2020" 1 Suggested: Due to the anticipated extra-ordinary length of time for the,debris clean-up(Up to 1 year), I think the reality is that there will be many RVs living off-grid until they can return to Paradise &;leniency will be required. I believe the permit minimum should be 3 years, with a likely possibility of being extended to five years,expiring on either November 9,2021 or November 9,2023,respectively. Page 6,Line 15: "occupancy of up to two recreational vehicle on any lot that permits a residential use outside of the area affected by the Camp Fire." Suggested:Evaluate suggested density based on the available power drop. This is for 1-4 temporary housing units per residential parcel. (Electric infrastructure availability is typically limited to 1 RV on a 100 amp service with a single family residence. Whereas a 200 amp service Dina vacant residential parcel can easily accept 4 RVs, if space permits.) Sewer & water are rarely the limiting factors,rathersuitable flat land &power are. Page 7,Line 16:"RVs shall be locatedoutside=required setbacks..." Suggested:Consider temporary leniency,as a fire department always deals with realities of situation. ie San Francisco has zero lot lines so'ivhy in�a disaster for a temporary situation would we eliminate using a property based on this criteria? If this is about privacy,have a minimum space between structures with off-sets on the windows. RV placement in driveways is permitted,if it does not encroach on the sidewalk. Drafted by TurtleShells.org "If referencing,please give credit. "'Page 2'" December II,2018 I've given thousands of hours of my time to this work without pay. Wishing you well on your journey home AGAiN I'm seeking angel support for this work. It should be done without consideration to profit generated,which sometimes leads to hod decisions. yC"^' e":rte" w.,'%:•yrt - :.-Y - :,4^':]: e`%eC.'"' .y,-n ..Y✓ v",'row":FC'Y:: ',V'=',-. ..,�.. "':J:'4:h:.. Wires.., ..t x;�:.-;��. =.•"s�,;�r- rw,� a:ss-;:ss^� 'r -�,�:^ s.. °+z>'-� ss— �^ .5a. ,���-�:... i�'�'°�:, �r` ;�. 'k -V�:;gW-,x'tr .�f. ,w- RzSs •_x"•�''cs✓,a.-,'.�o.-�rc:."s,"s.,:S:�.�,�.5i�5•.'-z,r,.,.�f.4.5aa�e:'-'>':.,.�.,L,"„t-ra;:;>�i✓"4--�;.*e��,>s.,....,°n,.?rs�.f�,..g:ra,,•'.'i. .�:���,t,,��,��on,..rt='�r•-„�Si.,',.,,a1tir.z„.i h.„�,��.��.r`F,�r,�.r.2;+.•�r:•vs:i.jri`,'.Wi:m_"r'.�Y'xvFa,,',w.'<F?.���'<,^s,U��r'.;„.-",�x;.,.,-:..�t<.z`s.>.a,.i4a.�,`r"sr9� = apS ^F L �rot ; j Y \`_,wi;v,aa,�.s�✓. r,. ,.. r, '��,�s �✓�, s rk F„£:4.:r✓�.�.:frc:”";,���•.a;.,..,. zs..�ArSv ��.,.F;ls,.. a..,.;s�•,9�,:,�.. Suggestions to Consider for Drafting of a Model Emergency Housing Policy Due to extra-ordinary losses of dwellings from the Camp Fire,certain state &local regulations are suspended temporarily. This will provide an economic benefit to the city &county. This is temporary in nature & unlikely to produce significant negatiie • environmental consequences. The use of temporary dwellings by the residents of Butte County will be allowed outside of the fire-damaged sites,without a permit for an Initial period of 180 days which expires June 9,2019. Beyond this initial period that the board/council determines,a temporary permit is required in which health &safety requirements are met. This ordinance expires on (Please read"Author's Note on Compliance &Timing of Debris Clean-up”regarding lenience &need for a street parking program.") A temporary dwelling permit is required beginning June 10,2019 until then there is no need to visit your building department for permission. If you are ready to meet the health &safety requirements outlined iii-the ordinance•`now,you are invited to file for a temporary dwelling permit. The permit will be issued for a recommended.3 year minimum with a likely possibility of being extended to five years,expiring on either November 9,2021 or November 9,2023,respectively. !Author's Note on Compliance, Timing of Debris Clean-up& Need for RV Street Parking Program Due to the anticipated extra-ordinary length of time:for the debris.clean-up(Up to 1 year),I think the reality is that there will be many RVs living off-grid until they can return to Paradise &leniency will be required. The probability you'll get them paired with a neighbor's infrastructure isn't as high as you'd like. Based on my experience,it's not lack of willingness of RV dwellers,but rather lack of willingness of homeowners to engage in the permit processor even know it exists. 1 recommend acknowledging this problem by.providing significant PR,education &positive enforcement,rather than just making the policy available &hoping homeowners step up. By making hosting homeowners heroes in this phase of recovery,it will help with policy adoption. Secondarily,1 recommend implementing a county wide street permit parking program which involves a placing a permit on the dashboard to identify:the'occupants &length of stay. This street parking program wil!'have a higher level of compliance &of course nothing iso perfect situation. The permit program can pay for itself,by accessing nominal fee with issuance, which is self-service &doesn't require a visit to the building department. For those thatdon't have printer access,local libraries can help with this. Of further note,loss of use allowance on mobile homes(built off-site)is typically one year &site-built dwellings is 2 years. There is goingobe a'liirgenumber of people finding their loss of use allowance inadequate for this particular disaster. The only way to cope with that4shyHieing their living expense budget by purchasing an RV until they can re-develop their land. I recommend working towards offering this parking permit program by January 18,2018 &amending your emergency ordinance accordingly. If desired I havecifc proven resources in mind to support this initiative &am prepared to provide an educational meeting about this policy option. I have no economic stake,either way- Drafted by Turtleshells.org"if referencing,please give credit. ""Page 3'" December 11,2018 I've given thousands of hours of my time to this work without pay. Wishing you well on your journey home AGAIN I'm seeking angel support for this work. it should be done without consideration to profit generated,which sometimes leads to bad decisions. �„:G"`w �` .�Y"2.„ \';'Y,":-n:?,. ;.a�-;-..\;an .��. �.. Amy., .,.r•rr-v:� aaw..vz::.� ..;.sem;ce,,' ..o.r„c:,'.w�cti.v;�';<.,�., ,�t';�w .+?'m,. ,:°,W,� ,.:`�.. .mS.�p,�v g,br,.. s✓�,./&;::� p „`'N",..,.[ r�`(�i'�`.'�lin' .;4:,. ..a`.\ i`� e-i:�'-:" "^�,�”,-''., r'��=' ,22i%'v� "'a ,R.. .��aa -�`� .,,c z•,�.�'=v.�.t-'Vi,;µ �sl Ci` Y' i.<. '":)vim N•1fF.7".z .C? •.:+�:, _ �'i.i.n $-v 2 .;.`Z� J ";A ,ice\'-` �`:,•- f'� t< �'��`i'���f:�4;€��.a.;�,c�r'�31Crf�!:'f\�fF d4`�y�✓,,,1'vls3.-r1G<:,,��,�_p,rr�•s.��_j,�vL'.�a,.-�N�yy"iv yi�,�t.`S,F1:.,a.'-�,6�-.'1;�:,,1�r�tz�cv�C,\�S'�'vS -�;i•'=w <\fnPrJcywFvf- �.e 'r•.k i'n�L �•'>,�=`:`,� �..F.c.C,3v;",vFFat�:.k,�i;y {How does one apply for a permit? There will be 2 types of temporary dwelling permits: 1. Ministerial("over the counter")Limited Term Permit-This is for 1-4 temporary housing units peri\esidential parcel. (Depending in electric infrastructure availability, which is typically limited to 1 RV on a 100 amp service,;witha single family • residence. Whereas a 200 amp service on a vacant residential parcel can easily accept 4 RVs,if spate permits.) NO NOTICE IS REQUIRED.(Typical.) 2. Administrative Limited Term Permit-This type requires an opportunity for public.comment from surrounding neighbors.Ali property owners &occupants within 300 feet will be notified The process to this`achieve this second type of permit varies by municipality with their public comment process &staff availability. Submittal Requirements to Request this Permit Provide 2 copies of each document below z7 Temporary Dwelling Permit Application f r Ehiergen0110irrg ❑ Pictures Required of Housing Unit(s)(All 4 sides`&VIN number) ❑ Parcel Plot Plan(aerial view of parcel,detail on power &sewer connections) O Property Owner Authorization Of applicable) O Emergency Housing Use Certification O Indemnification Agreerrient O Property Owner/ApplicantAcknowledgements &Authorizations Drafted by TurtleShells.org~rf referencing,please give credit —Page 4~ December 11,2018 I've given thousands of hours of my time to this work without pay. Wishing you well on your journey home AGAIN Pm seeking angel support for this work. It should be done without consideration to profit generated,which sometimes leads to bad decisions. a ,°.;,.%:::<;.._..c:,s r-`x-�-e,-.„ ,rr�^•,..,� af�s. .:,:r. ,.z:;-w '�� ;;,7.,-crc ,L• - ::"ka.. :.�;`zG.' •3";,. ' .�r., :::rte. ...xvr .at i`:°�G7�_ :{w r'�3:,:�:.^,r,•`�,ss. w-^ ;Sl"=5Tr.".� ice, �; -. a kid l u, ,w5 h ; , r ., f r �,H . ,5.t4' " : zu.�, � "."� m,,„ .a�,. •..r.„a, s",3s.. i:.jr': ..,E'.,.h 2 a y:5 - �S'C:r c �rcv.\FL ,�C.`�.,re'.rv,�,..:e.::.v { -� E ;.0�„7".r <.”, --- � t;�3 f: �''-_k e;�-�.C,'r `�.y �`?�.. t `cy A�r. 6.. r. •#�-: S' c Fes,- Cv ,_;v5 L�4v „,nr�<.�`,?�^,e;7 11— ' �, C�,�. �..s<r •>,,..z W4r`` �c �<� ✓"it-t�,'✓�sj;�J fir¢-�`,x^���',��s b �x��� '��C i, c 3 .s�: , �J s= 3 r: "''2 F ...a ,;Z��-�`•'e�^v�=�`*7.t��E-`” 3�-�'f'k pro. -K.-�:��e:,wr .,�'�a�^'�. . "t. .G�L ..y4_ '� Nr`r,E.{ • ..�<2��6. ;'.r.�>.ti �;,�; ��>�,�7� �,r...>,s'�t,,.w. .9 < ti '�'Aq�.I,<•':G>„ ...i.11>5&t �'+rrs;'N'2� .�o,. �: c•;ex �4, -v•r.�v,,.._, :�sxhr�:>s�..,:,<Tv:'^w fs` �",: '"�• �D,r•. ', s .<>^ ,�.. � @ w*�' � n.s., .z :� ,g`rs1 rt• „�`"..L•;����a! �,.w^.,.,�� � � ��s��;r•:?'.��:��J..:rn'�%"��M�.�.t5';"�:'8:o%a�.' ;'s'r"-���,',h:,h rWhat rules do I need to follow for health &safety? Who is eligible:Emergency temporary dwellings are required to house displaced people(both primarily &secant/drily) aswell as workers involved in the recovery &reconstruction. No distinction will be made regarding who is eligible to use'temporary housing due the scale of destruction. Zoning Requirements:My residential or commercial lot,except (zones).HOAs'are subject to additional rules & consent. Due to the foundation requirements imposed under FEMA regulations on non-mobile housing`uhits,Only vehicles on tires may be allowed on properties located in a F2(Floodplain)zoning district. No occupancy of R.Vs is allowed in the FI(Floodway)zoning district. Placement Requirements: RV occupancy of fire damaged sites before debris isnot advised until approved as safe for reconstruction by the city or county, unless the damaged site is 1 acre or more where habitation will not be in proximity to a burn site. RV placement in driveways is permitted, if it does not encroach on the sidewalk: Dwelling Type(Budding Code Used):The temporary dwelling permit allows for the occupancy of trailers &recreational vehicles (RVs)currently licensed by the DMV. Collectively known as RVs,the vehicle must be 1988 or newer. Otherwise it will be subject to review &approval by the community development director (Based on my 15 years experience,this age is quite reasonable for most situations.) All other emergency structures are subject to the go ted inspection process to meet construction code for on-site built dwellings (California Building Code aka CBC)or off-site built dwellings built to HUD code(aka modular/manufactured or mobile homes). These structure types are still subject to a similar,;review:,&approval process of a traditional home. As such this usually isn't considered emergency housing. These building types may havesome reduced fees&an expedited permit process,but unlike RVs,they will have a significant impact on building department'staff resources. Sewer:Can use septic,sewer or proof of a,pumping service • Dump service station Driving to service tanks is ONLY acceptable during the initial 180 day period. • Truck pump service Proof of a monthly contract will be required,if not connected to septic or sewer. • Septic system::The system must have capacity &is subject to review &approval.(immediate occupancy may require a monthly pump,contract until the septic system is approved for use.) • Public sewer;Connection might require a backflow device. • Draining an RV to septic or sewer connection:Sometimes a tool called"Sewer Solution"is needed to solve gravity problems fror:ilrnk drainage. It can pump waste up to 100 feet over level ground &up to 3 feet above the level of the holding tank & specifically designed for RVs with holding tanks. This tool uses water,not electricity, to move waste. Also black tanks should never be left open. Use of RV black holding tanks requires periodic release. Most county engineers &RU owners to not know this! Drafted by TurtleShells.org"if referencing,please give credit. "'Page 5"' December 11,2018 lyre given thousands of hours of my time to this work without pay. Wishing you well on your journey home AGAIN I'm seeking angel support-for this work. it should be done without consideration to profit generated,which sometimes leads to bad decisions. "xs r < � �f '�t`�n' ',,%'2v � � � :i r�cc a�,3: y ✓ f a- ?- � �"'r,�.�rr,,f'�,� v^m. 3 .�'�' p •� > o. • Y \ �F ;% >_r. v,+!• ..lZ! trti r t f„wwr r,.{' .+ �• �, >rr \ N'� •%,,�h`. ,... ...;F..... .✓ �..;,��.,s`�1.,;•�-cylr��.4�.�� ,.... .a4 ._.... �. .4 'E.,c.._,-,. ._.rCr�r ,✓,iu ;}..ss,'�u�^-T.<bn<s ,ti.d..;x,-awF.,.. .�P.� .�.,tiz�,v ,Y`�,rs.'�,.,ca..�,.��.� - ...a. Power:Connection to the power grid is required.For immediate TEMPORARY use,a 15 or 20 amp connection with a 10 gauge cord & dogbone is sufficient, unless electric heat or A/C is used. Less than 100 feet from a weather proof power connection is acceptable.A 30 amp connection should be required for extended. That may come either from a dryer outlet(220 amp)or a small permanent modification to the house electrical panel.(See handout for further explanation.)—A larger cord with proper connection might be able to go a longer distance.—Generators will be accepted within the initial 180 days &may not operate bet en'tll ;boars of 11 pm &7am. Exceptions might be granted under extenuating circumstance. Water:Operating well or community water, with a water pressure regulator connection is required. Contracted Water delivery service is not likely to be accepted &is at the discretion of the building department A water.:pressure regulator should be added to the service connection to avoid damage of RV plumbing. Housing Density:Density+1 for all single family residences or 30-50 Amps per RV. (This is the common bottleneck on most successful placements.) if a property has 200 amps dedicated to 4 RVs, that is an ideal connection,if it adequate space to accommodate this many RVs. Debris/Tree:No less than 30 feet from burn debris &no standing dead/darnaged trees that could fall on the living uni£.Not close to landslide risks that could trap or harm occupants. Occupants will notstay on property'if debris removal is active within 300 feet of their living unit. Life Safety Requirements:A functioning fire extinguisher &detectors for carbon monoxide &propane gas is required. The RV must also have a rear emergency exit. Under no circumstance is portable propane heaters permitted inside the RV. Cost:Free recommended for RVs. Cost structure for a gated inspeti on process is far more involved with CBC or HUD code built dwellings,as well as time required to implement.Such structures will incur plan check &inspection fees. Expiration of the permit 3 year minimum'with a`possibility of being extended to five years,expiring on either November 9,2021 or November 9,2023, respectively.. (NOT 31.5 years franc date of permit issuance!An apparent mistake in drafting by one municipality.) Termination Failure Penalties: rap. 'A bond was proposed by one municipality which is the first time l've seen this in the past 4 years in over a dozen jurisdictions having authority. I don't recommend such a cumbersome concept for a site hosting 14 RVs, There is already a process in place for abating property nuisance &attaching liens to property to cure the nuisance. Larger developments may be an understandable concern As part of the permitting process the owner would agree to be subjected to these penalties for failure to comply with termination instructions. Procedures &Penalties for Abandoned RVs: Coming soon. Drafted by Turtleshells.org”'If referencing.please give credit ~Page 6'" December 11,2018 i've given thousands of hours of my time to this work without pay. Wishing you well on your journey home AGAIN I'm seeking angel support for this work. it should be done without consideration to profit generated,which sometimes leads to bad decisions.