Is converting a mobilehome park from tenant occupancy to resident ownership considered development for the purpose of requiring a coastal development permit?

Facts: The sole owner of a coastland mobilehome park applied to the city to convert their mobilehome park from tenant leasehold occupancy to fee ownership occupancy of each existing space in the park. The city rejected the application, stating the owner needed to first obtain a coastal development permit before subdividing the property.

Claim:  The owner claimed they did not need a coastal development permit since subdividing the mobilehome park to change only the nature of the occupancy from that of a tenant to resident ownership for each space was not considered development.

Counterclaim:  The city claimed the conversion of the park required a coastal development permit since a subdivision changed the intensity of land usage.

Holding: The California Supreme Court held the owner must first obtain a coastal development permit before converting the mobilehome park leasehold interests to resident ownership of park spaces since any subdivision changes the intensity of use of the land and thus qualifies as a development. [Pacific Palisades Bowl Mobile Estates v. City of Los Angeles (2013) 243 CA4th 574]