Attachment 2
************************************************************************Dear Anky and Wayne:CC City Council:Thank you for your presentation to the Mountain View Mobile HomeAlliance on Saturday, 10/26/24, regarding modificationsto the MHRSO.As some of the longest residing renters in Mountain View'smobile home parks (some of us over 17 years) we'd like to reinforce the messagesyou heard on Saturday.Namely ...1) The current AGA structure is not working.Renters have experienceda cumulative increase of 12.9% over the last 25 months (5% + 5% + 2.4%).This is on top of rents that are already the highest in the country.Some renters are paying $4000 a month. They are potentially facing rentsapproaching$11,000 a month in 20 years if inflation is reignited and the 5% capis not altered.In short, the current model is simply not sustainable and itis already failing at it's goal of keeping people housed.2) We need a new AGA.We are proposing a new AGA of:* 60 % of CPI* a 3% CAP* with no floor3) Landlords will balk at changing the AGA.Landlords may claim that rent control is hurting them and that they won'tsurvive with a lower AGA.But here's the truth.Look at how the current legal regime sustainsan ongoing windfall for landlords.Under current federal, state, and local law, landlords receive:
the benefits of Prop 13, which caps the increase in the assessed value of theirproperties at 2% annually,they receive tax deductions on their tax returns which are not available torenters,they receive preferential treatment on mortgages which are not available tofolks who don't own land,they are guaranteed a current 2% AGA floor, which they can pass on to renters,even in a deflationary environmentor in a market with high vacancy rates, andthey can take advantage of a builtinmechanism in the current rent control lawwhich allows landlords to request rent increases beyond the AGA if they feel they are making insufficientprofit ...Think about that for a minute ...There is not a single industry or market segment anywhere in the country thatreceives such a comprehensive set of guarantees ... Mountain View landlords receivethiswindfall which is not available to any other industry.And what if the economy tanks ?? It doesn't matter. Landlords still receive thiswindfall.And why should landlords have one of their major expenses, property taxes,capped at 2% while renters have their major expense, which is rent, cappedat 5% ? How is that at all fair ?4) Renters lost the benefit of concessions with the MHRSO.Upon enactment of the MHRSO, renters lost the one benefit they hadpreviously received from landlords. Namely, as a result of the MHRSO,landlords have eliminated all concessions and longterm leases for renters which historically resulted in lower rents for residents.As landlords will happily tell you and as they have told us in nouncertain terms ... "this is what you get forfighting for rent control".5) Help is needed before the next AGA cycle.Ensure that the new AGA (60% of CPI, 3% CAP, no floor) is in place forthe next AGA adjustment cycle which is scheduled for 09/01/25.6) We are not alone in this request.Antioch and Richmond, recognizing this problem of outofcontroltoo high rents, recently passed a rent control ordinancewith an annual CAP of 3% or 60% of CPI, whichever is less, with no floor.
And there are numerous rental communities throughout the State (Santa Ana,Inglewood, Beverly Hills)with similar AGA's. So Mountain View would not be blazing a new trail here.Concord is also looking at a 3% or 60% of CPI regime.And here's the kicker.Mountain View has higher rents than any of these communities, compoundingthe ill effects of our current high AGA cap, meaning the urgency to lowerthe AGA is even greater here.7) We started with a base rent that was and is too high.Mobile home residents are starting with "controlled" rents that are already toohighbecause our base rent was set 6 years after the base rent allowed by the CSFRA. Howis that fair ? The only way to remedy this is to adoptthe new AGA model we are recommending.Usually, rent control helps lomgterm residents. That's not the casein Mountain View. People that have been in their homes over 17 years arestill paying "market rates". In some cases, residents are paying higherthan "market rates" even with rent control due to landlord's insistenceon passing along the maximum allowable increases, irrespective of marketconditions. And landlords are able to do this because they knowthey have a captive audience ... as moving and relocating becauseof high rents for seniors, thedisabled, and families is difficult if not impossible.Effectively, the high AGA allowed by the MHRSO is a legal "freebie"to landlords giving them permission to raise rents without regardto market conditions or the length of time the resident has been in their home.Landlords have explicitly told us their intent is to raise the rents every yearto the maximum allowed by law, irrespective of market conditions. This is notsustainable longterm. And they haveeven stopped doing market studies and don't offer rent increase relief to longtermresidents. As a result, longterm renters pay as much as if not more than newrenters.8) We are Seniors, disabled folks, families with kids, folkson fixed income, blue collar workers, and more ... the kind of CommunityMountain View wants and needs.Did you know that two of Mountain View's 6 parks are senior parks? AndSahara Village used to be a senior park. We had two Senior families leave recentlydue toescalating unsustainable rent increases.You can help fix all this with a simple AGA modification.
In closing, let us say "thank you for your efforts and hardwork on this critical issue" and please ensure that your officeincorporates this info intoyour analysis and presentation and recommendation to City Council.Residents are counting on you to recommend modifying the AGAto 60% of CPI, a 3% CAP, and no floor. (we are calling this 3/60/0)It's critical that we get this AGA improvement implemented forthe next AGA cycle and we appreciate your efforts at making that happen!Sincerely, Anna Marie Morales (sahara mobile village) Susan Morales (sahara mobile village) Jim Schwartz (sahara mobile village) Christopher Saleh (sahara mobile village)and 100's of others we interact with dailyin our Community who want to stay in theirhomes and who maintain the currentAGA model is simply too high and not sustainable.************************************************************************
110 N. Wacker Drive, Suite 4500 Chicago, IL 60606: TEL: 312-604-7500 www.hometownamerica.com December 11, 2024City Clerks OfficeAttention: Rental Housing Committee and City Staff500 Castro StreetMountain View, CA 94041Subject: Opposition to Lowering the Allowable Rent Increase Under the MHRSODear Members of the Rental Housing Committee,Thank you for the opportunity to provide input on the potential amendments to the Mobile Home Rent and I respectfully urge you not to lower the allowable annual rent increase under the MHRSO.Current MHRSO Aligns with Comparable Jurisdictionswith a 100% CPI annual general adjustment (AGA), a 2% floor, and a 5% ceilingfall within the range of rent stabilization measures adopted by comparable jurisdictions, meeting the goal set out in the Citys Housing Element to studyamendments to the Mobile Home Rent Stabilization Ordinance (MHRSO) such that allowed rent increases are consistent with or less than comparable jurisdictionswith rent control for mobile home parks (emphasis added).While it is true that 70% of jurisdictions have a lower AGA, the data also protection.The current AGA structure has effectively balanced the needs of residents and park owners. Residents have benefited from stable, predictable rents, while park owners have maintained the ability to cover rising operational costs. Altering this balance by reducing the AGA to 75% of CPI would impose additional financial strain on park owners, jeopardizing their ability to maintain and invest in their communities.Residents Benefit from the Current StructureThe MHRSO has delivered tangible benefits to residents since its implementation. Mobile home residents in Mountain View have experienced stable and affordable rents, even during periods of high inflation. Importantly, the current system has helped preserve housing stability and affordability, as evidenced by:Reasonable annual rent increases averaging 3.5% since 2021, lower than Social Security cost-of-living adjustments (4.7%) and the San Francisco CPI-U (3.6%).Preservation of home equity while remaining a critical source of affordable housing. The resale value of mobile homes in Mountain View averaged $262,000 over the last 24 months compared to the median single family home sales price of $1.9 million1. Lowering rent increases further could 1
110 N. Wacker Drive, Suite 4500 Chicago, IL 60606: TEL: 312-604-7500 www.hometownamerica.com drive up home prices, making ownership less accessible to prospective buyers and increasing financing costs for current and prospective residents.Full occupancy across mobile home parks, with strong demand from prospective buyers.Lowering the AGA Could Undermine Housing StabilityA reduction in the allowable rent increase to 75% of CPI risks creating unintended consequences that could undermine the very stability the MHRSO aims to preserve. Revenue generated from rents is critical for covering operational costs and reinvesting in community improvements. If costs outpace revenues, park owners may face difficult choices, including:Delaying or reducing essential maintenance and upgrades.Filing hardship petitions, which could result in significant rent increases, as seen in other jurisdictions.2Exploring more drastic measures, such as park closure or sale, which would directly conflict with ConclusionThe MHRSO, as currently structured, achieves a careful balance that protects residents while ensuring park owners can sustain operations. Lowering the allowable rent increase would upset this balance and risk unintended negative consequences for both partiand in many respects, more tenant-protective thancomparable jurisdictions.I respectfully request that the Committee recommend maintaining the current MHRSO provisions without amendments. Instead, I encourage exploring collaborative approaches to address specific resident eness.Thank you for your time and consideration.Sincerely,Ken KravenasChief Operating OfficerHometown Americaonbehalfof New Frontier Mobile Home Park2
A reduction of the AGA would be an attack on the income of the park and only serves to inhibit the ability of the park to operate successfully in the goal of providing a quality housing opportunity within the city. Furthermore, reducing the AGA further accelerates the likelihood of the bumpy pathway that MNOI adjustments produce, and results in a greater a divide between residents and community owners. We should be looking at actions that support building, not tearing down this important relationship. The desire to create housing stability and reduce displacement is not achieved through further restriction of the financial viability of mobilehome communities. In fact, a reduction in the AGA, while sounding attractive as a short term “solution” to displacement, leads to increasing the probability of the loss of housing opportunities. On behalf of our family business, we ask the commission to forward a recommendation to the city council to not modify the MHRSO. The Mountain View MHRSO, when looked at in its totality, is already consistent with, or lower than comparable jurisdictions and does not need to be modified to be consistent with the City’s Housing Element. Any attempts to address displacement resulting from financial instability should focus directly on methods that would assist those residents in need, and not as a general and further restriction on rental charges across the board. Respectfully, Frank Kalcic Sunset Estates Mobilehome Community
Hi RHC:I'm here speaking tonight on behalf of myself and my neighbors.Like 44% of my mobile home neighbors,I'm a senior, and I've been renting my mobile home in MV for the last 18 years.When I tell people I live in a home with rent control they askme:1) Why is your rent so high if you have rent control ?2) Why are your rent increases so high every year if you have rent control ?3) Why are you paying market or above market rates for your homethat you've lived in for 18 years, if you have rent control?You think of places like New York City that have rentcontrol and folk's rent increases are modest, sustainable, and wellbelow market rates.Unfortunately, that's not the way it is in Mountain View.The simple fact is the current mobile home ordinance is not workingand Staff's recommendation on fixing it falls short.Rents remain too high, rent increases are not sustainable, andrents are at or even well above market rates in some cases.The whole point of the ordinance is to keep folks in their homes,yet in the last 2 months two senior families were forced to leavein my park because they could't afford their rent increases.So the residents are proposing an ordinance that allowsrent increases of 60% of CPI or 3%, whichever is lower,with no floor. We are calling this 3/60/0 instead of the current5/100/2 regime implemented in Mountain ViewAntiochRichmondConcordPittsburgDelanoSanta AnaInglewoodBeverly HillsConcordand other cities all have a 3/60/0 model.And arguably, Mountain View has higher rents than any of these communities, compoundingthe ill effects of our current high 5% AGA cap, meaning the urgency to lowerthe AGA is even greater here.Since I have limited time, let me refute some of staff's claims surroundingthe CAP, the AGA, and the Floor.THE CAP:Staff's entire analysis and basis for keeping the cap at 5%is based on "comparable jurisdictions".But there is no comparable jurisdiction to a City that has the highestrents in the country.An owner's current space rent of $2100 balloons to almost $5600 in 20 years at 5%.A renter's current home rent of $4000 balloons to almost $11000 in 20 years.I'm a senior as are many of my neighborsand my social security increase did not even covermy rent increase this year as an example.So we need a 3% cap. I mean how is it fair that park owners havetheir largest expense, property taxes, capped at 2% while residentshave their highest expense, rent, capped at 5%. Not tomention the tax benefits available to park owners that are not availableto renters.And remember ... we're talking about percentage caps ... not dollar caps ...percentage caps impose real burdens on residents as rents rise due to thecompoundingeffect.THE AGA:As for the AGA, Staff points out that 70% of jurisdictions have a lowerAGA than Mountain View and almost 1 of every 3 mobile homes in Staff's reporthave AGA's of 60% or less.In addition, we have the highest rents in the Country,which reinforces the need for a lower AGA.So let's adopt an AGA that mimics almost 1 in 3 mobile homesin California which is 60% or less.THE FLOOR:The discussion around the floor and justification for it is the most insidious.Simply put, we need to eliminate it. 85% of jurisdictions have NO floor.
It makes no sense to have a floor. I ask each member of the RHC to identifyan industry, any industry, that is guaranted a 2% increase in revenues, in spiteof market conditions. A great depression, a weak market, high vacancy rates,a silicon valley bust, world war 3,global pandemic, armageddon ?? Doesn't matter ... landlords can still raise rentsin Mountain View2%. And they have told us in no uncertain terms that they plan to do just that.In summary ... There is absolutely no justification for having a floor. None ...None whatsoever.So please ... Do not accept Staff's recommendation. It falls short. Change the AGAto 60% of CPI, a 3% CAP, and no floor.And you know what ... with a 3/60/0 regime, park owners will do just fine.Thank youChristopher From:Anna Marie Morales <[email protected]> Sent: Thursday, December 12, 2024 4:03 PM To: Kennedy, Andrea <[email protected]>; van Deursen, Anky <[email protected]>; [email protected] Subject: RHC mobile home comment Dear RHC, Thank you, Anna Marie Morales From: [email protected] <[email protected]> > Dear RHC, Thank you for taking the time to address this very issue of amending the to ensure that more residents don't face has been a long hard battle for the mobile home community to get any from our city, as the did not sufficient in the face of inflation and the greed of most owners. is with a heavy heart that the Mountain Mobile Home Alliance and myself ask for real are tired of our feedback for it to be overlooked and ignored. Please refer to the letter from the for more details. is not too late to the grossly insufficient recommendations of Housing staff, in favor of what our residents need to stay housed in our beautiful city. disabled living on a fixed income and scared. Your recommendation will not like me. us, choose over the of greedy landlords. Thank you, Morales