City of Camarillo
Comments received by 3:00 p.m. for City
Written comments received after the stated
time will be distributed after the meeting.
PUBLIC COMMENTS Tuesday, April 21, 2026 12:15 PM
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, April 22, 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 V. Mobilehome Park Rent Control
Position Oppose
Comments
Upload Additional Information
Casa del Norte - Letter to Camarillo Ci...pdf
PDF
IDENTIFICATION
Name Michael Cirillo
Address 660 West First Street
Tustin, CA, 92780
Telephone (714) 918-8360
Email [email protected]
Public Records Acknowledgement
D THE STAR COMPANIES
Value in Housing - Integrity in Service
660 West First Street, Tustin, CA 92780 Tel: (714) 480-6828 Fax: (714) 480-6830 April 20, 2026
Honorable Mayor David Tennessen
Vice-Mayor Martita Martinez-Bravo
Councilmembers Tony Trembly, Susan Santangelo, and Kevin Kildee City of Camarillo
c/o City Clerk
601 Carmen Drive
Camarillo, California 93010
Re: City Council Hearing, April 22, 2026 - Item: Mobilehome Park Rent Stabilization Ordinance (Proposed Chapter 10.55 of the Camarillo Municipal Code) Position: Oppose as drafted - Request Targeted Amendments Dear Honorable Mayor Tennessen, Vice-Mayor Martinez-Bravo, and Councilmembers:
Star Management serves as the managing agent for Casa del Norte Mobile Home Park, the 135- space community that is one of the three mobilehome parks affected by the proposed Chapter
10.55. We share the Council's stated goal of preserving affordable housing and protecting residents from genuine displacement risk, and we acknowledge the considerable work the subcommittee and staff have invested in this ordinance.
We respectfully oppose the ordinance as currently drafted. Casa del Norte has no history of excessive or sudden rent increases, and the transaction record at our park (discussed below) shows a stable, appreciating market with no evidence of the distress the ordinance presumes. If the Council nevertheless proceeds at the April 22 hearing, we urge the adoption of three narrowly tailored amendments. Each is essential to preserving our ability to operate the park responsibly, and each also reduces the administrative burden the ordinance will otherwise place on City staff and the arbitration process.
Casa del Norte - Letter to Camarillo City Council 2026-04-22.docx Camarillo City Council
April 20, 2026
1. Raise the Annual CPI Cap to at Least Eight Percent (8%) Proposed Section 10.55.070(C) sets a floor of 2% and a cap of 6% on the ministerial annual CPI increase. The 6% cap provides only a 1.8-point margin above the 4.2% threshold the Council itself authorized in Urgency Ordinance No. 2033 in October 2025. That margin is too narrow to absorb the categories of cost growth that most often affect a mobilehome park - property tax reassessments, insurance renewals, and utility rate schedules set by outside agencies — none of which are reliably correlated with the Los Angeles-Long Beach-Anaheim CPI the ordinance references.
A cap of at least 8% — whether structured as a flat cap or as "CPI + 2% with a 2% floor and an 8% cap" — provides appropriate headroom in years of unusual cost pressure. In ordinary years, the cap is not reached. It matters only in the years when the alternative is a contested NOI arbitration that is expensive and slow for the City, the residents, and the park alike. A slightly higher cap will reduce the number of fair-return petitions the City is asked to administer without any meaningful change to what sitting residents actually experience in a typical year.
2. Provide Full Vacancy Decontrol
Proposed Section 10.55.050(A) caps the permissible rent adjustment at 8% when an existing mobile home is sold in place to a new tenant. We respectfully request that this cap be removed and that full vacancy decontrol apply to every lawful vacancy defined in that section.
The ordinance already recognizes that full vacancy decontrol is appropriate in closely related circumstances. Section 10.55.050(B) permits a new base rent at any amount when a space is re- rented to a new tenant who replaces the existing mobilehome or brings a new mobilehome to an empty space, and also when an existing tenant of less than one year replaces the coach. The policy logic of that subsection — that a new, arm's-length renter who knowingly chooses to occupy a mobilehome space at a given rent should be free to do so at the then-current market rate — applies with equal force to an in-place resale.
The transaction record at Casa del Norte itself is the most direct evidence that the market logic of decontrol is sound. Over the 24-month period ending April 20, 2026, eight homes at Casa del Norte sold at prices ranging from $65,500 to $209,100, averaging $144,000, with seven of the eight sales - 87.5% — clearing at or above $110,000. As of today, four additional homes at the park are actively listed at asking prices of $180,000, $206,500, $279,000, and $310,000, averaging $243,875 — a 69% premium over the recent closed-sale average. Mobilehome values Casa del Norte - Letter to Camarillo City Council 2026-04-22.docx Camarillo City Council
April 20, 2026
at Casa del Norte are rising, not distressed. New buyers are entering the community with full information and paying market prices that reflect the current space-rent environment.
3. Add a Line-Item Pass-Through for Unavoidable Cost Increases Under the ordinance as drafted, the only path for a park owner to recover any cost increase above the 2%-6% ministerial CPI is a full "fair return" NOI petition under Section 10.55.110(C) - with a 90-day notice, Administrator review, audited financials, pre-hearing briefs, an arbitration hearing, a written decision, and potential judicial review under Code of Civil Procedure Section 1094.5. That process is appropriate for genuinely disputed fair-return questions. It is disproportionate for routine, documented, non-discretionary cost increases that every mobilehome park faces every year.
We respectfully request that the Council add a streamlined alternate process — a line-item pass-through process — that permits a park owner, upon documented proof, to pass through to affected homeowners, on a per-space basis and separately itemized on the rent bill, the year-over-year increase (above the CPI-based ministerial increase already received) in the following categories:
• Real property taxes, special assessments, and any reassessment-driven tax increase; Property, liability, earthquake, and related insurance premiums; Water, sewer, refuse, gas, and electric utility costs that are not separately metered and billed directly to residents;
• | Governmental fees, permits, inspections, and mandated exactions imposed by federal, state, county, or City authorities; and
Documented Capital Improvements and Capital Replacements that already satisfy the criteria of Sections 10.55.110(D) and 10.55.140(A)(10).
The mechanics can track the existing 90-day notice and per-space allocation standards of Section 10.55.080. An affected homeowner retains the full petition right under Section
10.55.090 in the event of disputed documentation or allocation. What is eliminated is the requirement that a park owner initiate a full NOI arbitration simply to recover routine property- tax, insurance, and utility-rate increases that are not within the owner's discretion and that are easily verified on the face of a tax bill, a premium renewal, or a utility rate schedule. The California Supreme Court has already confirmed that pass-through provisions of this kind are consistent with state law. In Cacho v. Boudreau, 40 Cal. 4th 341 (2007), the Court held that Casa del Norte - Letter to Camarillo City Council 2026-04-22.docx Camarillo City Council
April 20, 2026
Section 798.31 of the Mobilehome Residency Law does not preempt a local rent-stabilization ordinance permitting a park owner to separately charge residents for property taxes assessed on the park — the precise question most directly at issue here. Comparable California mobilehome rent programs, including those of the Cities of Goleta, Santa Barbara, and Chula Vista, incorporate analogous line-item treatment of non-discretionary operating costs.
Alternative: Memorandum of Understanding
As several park owners have already noted on the record, a voluntary Memorandum of Understanding among the three parks, their residents, and the City would accomplish the Council's policy objectives with far less regulatory and administrative burden. Star Management reiterates its willingness to participate in that framework in good faith. If the Council is determined to proceed with the ordinance, however, the three amendments identified above are, in our respectful view, essential to preserving the economic viability of Casa del Norte under the new regime.
Thank you for your attention to these issues and for the opportunity to submit these comments in advance of the April 22, 2026 hearing. I intend to appear and offer brief testimony at the hearing, and would welcome the opportunity to discuss any of the points above with Council members or staff at your convenience.
Respectfully submitted,
Michaal A. Cirillo
Michael Cirillo
President
Star Management
Managing Agent, Casa del Norte Mobile Home Park
Casa del Norte - Letter to Camarillo City Council 2026-04-22.docx