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April 21, 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 April 22, 2026
Agenda Item V: 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. Comments sent to the City on March 23, 2026 are reiterated herein in part with additional comments, but is also incorporated into this letter.
The proposed Ordinance will regulate only three mobilehome parks in the City, all of which tend to follow a simple CPI increase annually for existing residents. The proposed Ordinance seeks to regulate for a nonexistent problem, only to create more difficulties and ongoing compliance issues for the park owners and the City.
On behalf of Investment Property Group, we do appreciate modifications made to the proposed Ordinance based on comments provided, but continue to believe that the Ordinance is not needed and will create unnecessary regulations. Should the City Council feel that the Ordinance is needed, we ask that the City hold adoption of the Ordinance at this time and instruct City staff to return to the stake holders to further evaluate other issues within the Ordinance, partially summaries below.
BEDELL LAW PC
April 21, 2026
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Continued Issues with Process: 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.
After the March 25, 2026 City Council Hearing, staff reached out to request additional information on the singular issue relating to the anniversary date impact on Park owners. Other than this limited input, all comments provided by the Park Owners has been ignored without response or opportunity to further meet and discuss with City Staff.
Continued Substantive Issues with Ordinance:
1. Vacancy Control/Decontrol – the updated proposed Ordinance allows an increase upon the sale of a mobilehome by 8%. The change from a 6% to an 8% increase is recognized; however, the cap upon the increase in rent upon turn over is an arbitrary number selected without reason. If the City is inclined to move forward with the proposed ordinance, we request that the City proceed forward with an ordinance that follows many jurisdictions within the state and to provide for full vacancy de -control – i.e. no regula ted cap on the increase upon sale of the mobilehome.
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 arbitrarily capping the parks’ ability to increase rents upon turn over, the City will be unreasonably limiting the parks ’ ability to maintain its net operating income thereby forcing future rent increase applications.
2. Anniversary Date – The updated proposed ordinance incorporated suggested language to avoid a substantial financial impact on the Parks. We appreciate the incorporation of the recommended language. This is a good example of corrections and clarifications that exist in the Ordinance that highlight the fact that an ordinance is not needed.
3. Annual Increases – the current proposal allows for an annual increase of CPI with a minimum of 2% and a maximum of 6%. We reiterate the request that should the City elect to proceed with an ordinance, that the annual increase should be CPI plus 2%, but with a
BEDELL LAW PC
April 21, 2026
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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.
The Park’s existing long term leases provide for a systemic process for passing through various expenses of the Park. The ordinance would eliminate that process thereby capping the income from the Park. A rent control ordinance has a fundamental purpose an d obligation of protecting residents while also ensuring that the park owners receive a fair rate of return. This small additional flexibility in annual increases ensures that the Parks will be able to recover additional annual operating costs that will no longer be passed through under the long-term leases.
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. As no changes to these provisions have been proposed, we continue to request that the City reject the proposed ordinance or at least allow additional time for discussions and input from the Park owners who have had ample experience in dealing with various rent control jurisdictions across the state to provide substantive input on the faults within the Ordinance.
The above is a summary of some of the key elements that we encourage the City Councilmembers to not move this ordinance forward.
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
April 21, 2026
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Bedell Law PC
Ariel R. Bedell, Esq.
Shareholder