City of Camarillo
Comments received by 3:00 p.m. for City
Council; 4:00 p.m. for Planning Commissior
on the meeting date, will be distributed to all
Council/Board Members prior to the meeting.
Written comments received after the stated
time will be distributed after the meeting.
PUBLIC COMMENTS Monday, March 23, 2026 11:46 AM
NOTICE
This is a public document and will be posted as part of the public record. Any attachments, pictures, and information submitted will be subject to disclosure in accordance with applicable law, including the Public Records Act.
City Council / Camarillo Sanitary Wednesday, March 25, 2026 District / Camarillo Library Board
Meeting Date
Planning Commission Meeting Date
Agency City Council / Camarillo Sanitary District / Camarillo Library Board
Item Type Agenda Item
Item Number or Subject P - Mobilehome Land Rent Stabilization Ordinance Position Oppose
Comments Please see uploaded letter requesting an opposition to the Proposed Ordinance. Hard copy of letter will follow.
Upload Additional Information
2026-03-23 Comments to City Council....pdf
IDENTIFICATION
Name Ariel Bedell
Address 2121 Palomar Airport Road, Suite 200
Carlsbad, CA, 92011
Telephone (760) 444-4034
1 Email [email protected]
Public Records Acknowledgement
/ Attorneys at Law
Via Overnight Delivery
Via Upload Through City Website
March 23, 2026
City of Camarillo
Honorable Mayor David Tennessen, Vice-Mayor Martita Martinez-Bravo, and Councilmembers Tony Trembly, Susan Santangelo and Kevin Kildee
c/o City Clerk
601 Carmen Drive
Camarillo, California 93010
RE: City Council Hearing March 25, 2026
Agenda Item P: Mobilehome Land Rent Stabilization Ordinance
OPPOSITION TO ORDINANCE
Request: Deny The Recommendation To Establish A Mobilehome Park Land Rent Stabilization Ordinance
Dear Honorable Mayor, Vice-Mayor and Councilmembers,
On behalf of the owners and operators of Camarillo Estates and Lamplighter Camarillo, we request that the City Council reject the adoption of the proposed ordinance to enact the Mobile Home Park Rent Stabilization Ordinance on the basis that are summarized below.
The proposed ordinance will regulate only three mobilehome parks in the City, all of which tend to follow a simple CPI increase annually. The ordinance seeks to regulate for a nonexistent problem, only to create more difficulties and ongoing compliance issues for the park owners and the City.
Process Issues: As the Agenda Report notes, the Park owners meet with the subcommittee to discuss the proposed ordinance, the actual increases incurring in the three parks, the sales of mobilehomes in the three parks and how the current mediation program functions within the City.
The park owners provided a redline of proposed changes to the ordinance and discussed an alternative of a "Memorandum of Understanding" to avoid heavy regulation of an ordinance. The Park owners expected at least a response from the subcommittee and potentially additional meetings, but instead the subcommittee did not respond to any of the comments. 2121 Palomar Airport Road, Suite 200 • Carlsbad • California • 92011 T: 760.444.4034 • F: 760.842.0432 • www.bedellapc.com • [email protected]
BEDELL LAW PC
March 23 2026
Substantive Issues with Ordinance: The proposed redline to the Ordinance would assist in providing clarity for all parties involved and ensure that the Park owners actually receive a fair rate of return on their investment. These proposed changes were provided in good faith with the belief that a complete and accurate ordinance was the goal of the City. Below are some examples of issues raised and corrected that were either misinterpreted by the subcommittee or merely rejected.
1. Vacancy Control/Decontrol - the proposed ordinance allows an increase upon the sale of a mobilehome by only 6%. Mobilehomes in each of these parks have been selling without issue with increases upon turn over to bring the space to "market rent". The information presented to the Council that mobilehomes are selling at substantially low values is inaccurate. Camarillo Estates has homes currently listed between $99,000 and $315,000, not $39,500 as originally presented to the City. For Lamplighter Camarillo, there are three homes listed for sale between $92,500 and $224,900. The value of the mobilehomes varies greatly based on the size, age and condition of the particular mobilehome with the lower valued homes typically being small, single wide homes that were built in the early 1970s.
By eliminating the parks ability to increase rents upon turn over, the City will be unreasonably limiting the park's ability to maintain its net operating income thereby forcing future rent increase applications.
For example, the parks are dealing with increase in payroll over the last three years by 35- 40%, increase in utilities of 8-11%, and increase in property insurance of 35-42% - these increase in actual costs are in addition to the increases in costs relating to general park maintenance.
2. Anniversary Date - The proposed ordinance requires that the Parks have a single month for annual increases throughout the park. These two parks have rolling increases so that there are some residents who receive increases each month, but each space is subject to only one increase in a 12 month period. In order to now switch to having all increase be in a single month, the park owners proposed language coming from the City of San Marcos that clarified that when establishing the first single annual increase date, that such first notice will not be deemed to be a violation of the prohibition of more than one increase in a 12 month period.
The proposed language is: "In establishing an initial annual anniversary date for a Mobile Home Park, the one-time rental adjustment of the Mobile Home Spaces within the Mobile Home Park to establish the first annual increase in Rent pursuant to this Chapter shall be exempt from any provision prohibiting an increase more than once in a 12-month period." Without the language, the parks will have to delay increases to ensure that ALL spaces do not receive more than one increase in a 12 month period and that will result in a substantial delay in the initial increase after adoption of the ordinance thereby further impacting the maintenance of net operating income. For example, as the parks have to provide a 90 day M:IPG-Lamplighter Camarillo\450 City|2026-03-23 Comments To City Council V2.Docx
BEDELL LAW PC
March 23 2026
notice of rent increase, the notices for July 1" rent increases have already gone out. If this ordinance is adopted as is, then (i) likely those notice will have to be amended causing confusion and issues for the residents, but as to this point, (il) the parks will now have to wait until July 2027 before it can increase rents again - this means residents that would have had an increase in August 2026 through June 2027 will be on hold creating a greater disparity of income and likely lead to the need for a net operating income application.
3. Annual Increases - the current proposal allows for an annual increase of CPI with a minimum of 2% and a maximum of 6%. The park owners propose that the annual increase should be CPT plus 2%, but with a minimum of 2% and a maximum of 6.5%. By allowing parks to have the option of going a little above CPI provides the continued opportunity to actually maintain net operating income while preserving overall the minimum and maximum rent increases. A fair balance with the imposition of a rent control ordinance.
4. Calculation of Fair NOI - As discussed above, the actual increase in operating expenses far exceeds a mere CPI increase. The proposed ordinance will result in a continued decrease in NOI and arbitrarily concludes that so long as the park gets the base year NOI plus CPI each year, then it is receiving an actual fair rate of return. This is inaccurate as the actual expenses increase far in excess of CPI each year leading to an increase differential in NOI due to the arbitrarily capped rent increases. As a middle ground, we proposed that the fair NOI calculation be based on a change in CPI since the base year, plus 2% to be considered a fair rate of return.
5. Process for Hearings, Petitions and Appeals - Park owners provided comments, recommendations and changes to the Ordinance's provisions relating to the process for hearings, petitions and appeals and recommended further discussion on these items.
Unfortunately, no further discussion occurred and all substantive recommended changes were rejected. This leads to processes that may not actually be fair and reasonable, may overly encourage petition hearings, increase the costs of compliance and enforcement and restrict a party's constitutional rights to fair hearings and to receive the investment backed expectations.
The above is a summary of some of the key elements that we encourage the City Councilmembers to not move this ordinance forward
As an alternative to the ordinance, the park owners presented a concept of a Memorandum of Understanding - essentially a contractual agreement to provide clear expectations for the park owners, residents and the City but ultimately removes the City from the substantial oversigh process and reduces risks to the City's costs. Park owners included some deal points and provided several examples of successful and fair MOUs. No response or further discussions were provided.
Existing Long-Term Leases: Camarillo Estates has 71% of its residents on a long-term lease and Lamplighter Camarillo has 91% of its residents on long-term leases. These long-term leases provide stability and clarity as to the expectations for increases, pass-through expenses, and rents M:IPG-Lamplighter Camarillo\450 City|2026-03-23 Comments To City Council V2.Docx
BEDELL LAW PC
March 23 2026
upon the sale of the mobilehome. By enacting the rent control ordinance, the City will be eliminating the protections provided under these leases and interfering with the contractual relationship between the parks and the residents.
We respectfully request that the City not move this ordinance forward at all; but certainly not yet. Either take more time to review and discuss the input from the three park owners or to evaluate a Memorandum of Understanding, or simply reject this unnecessary ordinance.
Sincerely,
Bedell Law PC
Aral Seder
Ariel R./Bedell, Esq.
Shareholder
M: UPG-Lamplighter Camarillo1450 City\2026-03-23 Comments To City Council V2.Doex