City of Corona
Staff Report
400 S. Vicentia Ave.
Corona, CA 92882
File #: 22-0513
REQUEST FOR CITY COUNCIL ACTION
DATE: 06/15/2022
TO: Honorable Mayor and City Council Members
FROM: Community Services Department
SUBJECT:
Direction from City Council on whether to pursue research and analysis on mobile home park rent stabilization.
EXECUTIVE SUMMARY:
Residents of the City of Corona have petitioned the City Council and met with City staff to request the creation of a rent stabilization ordinance for mobile home parks. Creating this type of ordinance is a complex process which will require specialized assistance as well as staff time and research.
According to California Law, a public entity must make legal findings that a legitimate government interest exists for the municipality to create a mobile home rent stabilization ordinance. The City Council should consider if they wish to allocate the budget necessary to explore the legal findings to determine if the City of Corona has a legitimate government interest to create a local mobile home rent stabilization ordinance.
RECOMMENDED ACTION:
That the City Council provide staff with direction on whether to pursue a study of legal findings required to enact a mobile home rent stabilization ordinance.
PROPOSED OPTIONS:
Option 1: Direct staff to conduct a mobile home market data, affordability, and feasibility study to determine if the City of Corona has a legitimate government interest to create a mobile home rent stabilization ordinance. The cost for contract services, staff and legal time is estimated at $150,000 Option 2: Take no action on this item.
BACKGROUND:
Several years ago, a few local mobile home parks were sold to new owners who implemented space rent increases shortly after the purchase. For many of Corona’s mobile home residents, the rent City of Corona Page 1 of 3 Printed on 6/9/2022
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File #: 22-0513
increase created financial hardships. At the request of a group of mobile home residents, the City Council tasked staff with researching the feasibility of mobile home rent control to mitigate the financial hardship of the mobile home residents. On April 26, 2017, a City Council Study Session was held to discuss options for potential mobile home rent control regulations. The City Council, at the time, opted against moving forward with local rent control regulations.
ANALYSIS:
Mobile home parks are regulated by the Mobile home Residency Law (MRL). As such, local regulations are valid only if they are not in conflict with the MRL. California courts have upheld a local agency’s authority to regulate mobile home rents. However, to enact mobile home rent stabilization regulations, a public entity must demonstrate a legitimate government interest exist.
To determine and document whether the City of Corona has a legitimate government interest, an analysis should be conducted to obtain specific market data. Staff will work with the City Attorney to develop a scope of work and issue a Request for Proposal (RFP) for a consultant to conduct this analysis. A strong outreach component will be included in the scope of work, which will consist of meetings with the Mobile Home Park Owners Association and the petitioning residents. Other components of the analysis will include, but are not limited to, the following list of activities:
1. Analyze mobile home resident demographics (i.e., income, household size, age, etc.).
2. Assess rates of mobile home ownership, including how many residents own their structure and how many residents rent their structure, and whether the space rent is included with the structure.
3. Examine past and current space rent rates and what components are included with the space rent (i.e., utilities, property tax, etc.).
4. Conduct a space rent to income comparison to determine if rent burdens exist.
5. Evaluate the feasibility of relocating mobile homes, including cost, space availability, depreciation, etc.
6. Review local housing element to determine if mobile homes constitute an important source of affordable housing.
7. Research whether mobile home depreciation practices have occurred.
If the findings conclude a legitimate government interest exist, the following activities would be researched and presented to City Council for further discussion:
1. Other cities in California that have mobile home rent stabilization regulations in place.
2. Options for mobile home park rent stabilization uniquely suited to the City of Corona.
3. Cost comparison models for all options to achieve rental stabilization.
The RFP process to select a consultant to conduct the analysis is estimated to take four months to complete, and it is anticipated that the study may take an additional six to 12 months to complete.
The actual project timeline and cost will be known at the conclusion of the RFP process and will be reported to the Council when staff returns to award the project.
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File #: 22-0513
FINANCIAL IMPACT:
The preliminary cost estimate for the study of legal findings is $150,000. The actual cost will be subject to the costs outlined in the consultants’ proposals, which will come back to the City Council for final approval with the award of the contract. Staff recommends paying the allocation necessary for this project from the General Fund Measure X Reserves. If staff receives direction to move forward with this item, the appropriation amount will be requested at a future City Council meeting with the contract award, based on proposals received.
ENVIRONMENTAL ANALYSIS:
This action is exempt pursuant to Section 15061(b)(3) of the Guidelines for the California Environmental Quality Act (CEQA), which states that a project is exempt from CEQA if the activity is covered by the common sense exemption that CEQA applies only to projects that have the potential for causing a significant effect on the environment. Where it can be seen with certainty that there is no possibility that the activity in question may have a significant effect on the environment, the action is not subject to CEQA. This action considers pursuing studies and analysis related to rent stabilization, and there is no possibility that approval of the report will have a significant effect on the environment. Therefore, no environmental analysis is required.
PREPARED BY: CYNTHIA LARA, COMMUNITY ASSISTANCE MANAGER REVIEWED BY: ANNE TURNER, COMMUNITY SERVICES DIRECTOR
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