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Attachment No. 2 - Rent Stabilization Relocation Study

City Council / Housing Authority
January 26, 2026

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Attachment No. 2 - Rent Stabilization Relocation Study
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January 26, 2026
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City
of Pomona
Relocation Assistance Study
September 2025
Attachment No. 2

TABLE OF CONTENTS
Introduction ................................................................................................................... 1 Legal Context ............................................................................................................. 1 Local Policy Framework ............................................................................................ 1 Demographic and Housing Overview .......................................................................... 2 Analysis ......................................................................................................................... 2 Local Moving Costs ................................................................................................... 3 Moving Supplies and Labor ................................................................................................................... 3 Application Fees .................................................................................................................................... 4 Security Deposit .................................................................................................................................... 4 Utility Connection Fees ......................................................................................................................... 5 Temporary Storage ............................................................................................................................... 5 Temporary Lodging ............................................................................................................................... 5 Total Estimated Relocation Costs ......................................................................................................... 6 Comparison to Current Relocation Payment Structure .......................................... 6 Comparison to Peer Jurisdiction Policies ............................................................... 7 Conclusion and Next Steps .......................................................................................... 9 Appendix A: Peer Jurisdiction Relocation Structure ............................................... 11 Appendix B: Data Sources for Relocation Cost Estimates ..................................... 12

1 INTRODUCTION
Relocation assistance is intended to reduce the financial and logistical hardship for tenants who are required to move at no fault of their own. When a tenancy ends for reasons such as a substantial remodel, an owner or relative move-in, or the permanent removal of a unit from the rental market, tenants can face sudden and significant expenses. Relocation assistance helps bridge this gap by providing financial assistance to support tenants in securing new housing and making a smoother transition during what can otherwise be a highly disruptive process.

The City of Pomona (“City”) engaged RSG, Inc. (“RSG”) to conduct a Relocation Assistance Study (“Study”) identifying relocation assistance options tailored to Pomona’s needs. The Study evaluates the estimated costs of relocation in Pomona, compares these costs to current relocation assistance amounts and best practices in peer jurisdictions, and assesses special payment considerations for vulnerable tenant groups, including seniors, persons with disabilities, low-income households, and long-term tenants. Its purpose is to provide data-driven considerations to ensure Pomona’s tenant protection policies are both equitable and reflective of local needs.

Legal Context
Relocation assistance in Pomona exists within a broader legal context that includes both state and federal protections for tenants. While this Study focuses on Pomona’s local Ordinance, it is important to recognize that landlords may also have obligations under other laws, depending on the circumstances of displacement.

At the state level, the California Relocation Assistance Act provides benefits to tenants who are displaced as a result of public projects or government actions, such as infrastructure improvements or redevelopment activities. At the federal level, the Uniform Relocation Assistance and Real Property Acquisition Policies Act (Uniform Relocation Act) establish similar protections when tenants are displaced due to federally funded projects.

These laws may require payments, establish specific notice periods, or set other tenant protections that may differ from or exceed what is required for Pomona renters. For the purposes of this Study, the analysis focuses on Pomona-specific relocation provisions under the Rent Stabilization and Eviction Control Ordinance and does not attempt to replace, reinterpret, or provide guidance on state or federal obligations, which remain in full effect where applicable.

Local Policy Framework
The City adopted Urgency Ordinance 4320 on August 1, 2022, and subsequently Amended Ordinance 4329 on April 17, 2023, which implemented the City’s rent stabilization measures for residential rental properties. To establish a long-term policy framework, the City Council adopted Ordinance No. 43591, which will take effect on January 1, 2026.

The Ordinance requires landlords to provide relocation assistance when a tenancy ends for certain ‘no-fault’ reasons. In these situations, tenants have not violated their lease or engaged in misconduct but are required to move because the landlord plans to:

1. Demolish the rental unit;

2. Permanently remove the rental unit from the rental housing market;

1 For consistency, this Study uses the terms “Ordinance No. 4359,” “Rent Stabilization and Eviction Control Ordinance,” and “Ordinance” interchangeably to refer to the City’s permanent rent stabilization ordinance.

2 3. Perform substantial work on the building that meets cost thresholds and requires the unit to be uninhabitable for 30 days or more;

4. Recover possession for occupancy by a resident manager;

5. Recover possession for use as the primary residence of the owner or certain immediate family members;

6. Recover possession for a tenancy requiring an occupancy agreement and intake, case management, or counseling as part of the tenancy; and

7. Recover possession to comply with:
• A government agency’s order to vacate, or another order requiring the building, housing, or rental unit to be vacated due to a violation of the Municipal Code or other law; or
• A contractual agreement relating to the qualifications of tenancy with a governmental entity, when the tenant no longer meets those qualifications.

In addition, the Ordinance restricts a landlord’s ability to recover possession for these no- fault reasons when the household includes a long -term tenant who is elderly (age 62 or older), disabled, or terminally ill, providing added protections for particularly vulnerable tenants.

The relocation assistance amounts in the urgency ordinances were modeled after comparable jurisdictions. However, the City Council directed staff to conduct a Pomona-specific analysis to determine whether adjustments are warranted based on local housing market conditions and tenant needs. The current provisions will remain in effect under Ordinance 4359 until modified by a future City Council resolution, which is expected to follow the findings and considerations outlined in Study.

DEMOGRAPHIC AND HOUSING OVERVIEW
The City of Pomona, located in Los Angeles County, spans approximately 23 square miles, and has a population of approximately 148,000 residents. Like many communities in the region, Pomona has a significant renter population—approximately 45% of households rent their homes, compared to 54% countywide. Renter households in Pomona have a median income of $57,195, which is lower than the $103,040 median for owner-occupied households, reflecting the differing economic profiles of these groups2.

Housing affordability is a pressing concern for many renters. About 54% of renter households are considered housing cost burdened, meaning they spend more than 30% of their income on housing. This is notably higher than the 28% of homeowners who face the same challenge3.

Seniors age 65+ make up 14.6% of renter households, while 27.5% of renters include one or more tenants with a disability. These factors highlight the financial vulnerability of many Pomona renters and underscore the importance of tailoring relocation assistance to reflect local housing costs and tenant needs.

ANALYSIS
RSG used local moving cost data and analyzed peer city policies to evaluate suitable relocation assistance amounts for Pomona tenants affected by no-fault evictions. Local expenses for typical relocation activities were collected from service providers and then averaged and categorized by unit size to determine a baseline cost range. RSG examined relocation

2 Source: U.S. Census Bureau, 2019-2023 American Community Survey 5-Year Estimates. 3 Source: U.S. Department of Housing and Urban Development. Comprehensive Housing Affordability Strategy (CHAS) Data, based on 2017–2021 American Community Survey 5-Year Estimates.

3 assistance programs in comparable jurisdictions to identify prevalent payment structures and special payment considerations for vulnerable tenants. This approach grounds the analysis in local market conditions while aligning considerations with best practices and the City’s tenant protection objectives.

Local Moving Costs
RSG identified the typical categories of expenses tenants are likely to incur when displaced due to a no-fault eviction to assess the financial impact of tenant relocation, including:

• Moving supplies and labor
• Application fees
• Security deposit
• Utility connection or transfer fees
• Temporary storage
• Temporary lodging

Local cost data came from outreach to multiple service providers and vendors operating in or near Pomona. Where possible, RSG averaged estimates across sources to establish a reasonable cost range, refining figures by unit size. The analysis assumed a standard relocation distance of 20 miles, reflecting both the City’s geographic size and the likelihood that tenants would seek housing nearby. These localized inputs provide a basis for identifying equitable assistance levels that mirror the actual costs faced by Pomona renters.

Moving Supplies and Labor

Relocating often requires tenants to cover the cost of both moving supplies and labor. For the purposes of this Study, RSG assumed the use of professional moving services. This conservative approach reflects a broad range of tenant circumstances and ensures relocation assistance levels account for households that may be unable to complete a self-move due to age, disability, or other limitations.

RSG obtained labor estimates from four Pomona-based moving companies and supply costs from Home Depot’s bundled kits, which include boxes, tape, and other standard packing materials tailored to unit size. Professional mover rates were averaged across companies and reflect the cost of two movers and a truck for a standard move, with additional labor hours included based on unit size. The combined estimates provide representative moving costs for one-, two-, and three-bedroom households, as summarized in Figure 1 below.

Figure 1 – Estimated Moving Supplies and Labor in Pomona Category 1 Bedroom 2 Bedroom 3 Bedroom
Moving
Supplies
$104 $300 $424
Professional
Movers (5 avg.)
$570 $1,066 $1,083
Total Cost $674 $1,366 $1,507

4 Application Fees

Tenants relocating due to a no-fault eviction are often required to pay application fees when seeking new rental housing. These fees are typically assessed per adult applicant to cover the cost of background checks, credit reports, and application processing.

RSG analyzed 5-Year ACS data to estimate the average number of adults in Pomona households. Based on typical household patterns—two adults in married households, one in single-householder families, and 1.5 adults in nonfamily households—the analysis suggests Pomona households include an average of 1.6 adults. While actual household composition may vary, this assumption provides a consistent and equitable basis for estimating costs in line with standard occupancy expectations.

RSG reviewed active rental listings on Zillow for five one-bedroom, five two-bedroom, and five three-bedroom units. The average application fee was consistent across all unit sizes, averaging approximately $40 per adult applicant.

Applying this fee to the average number of
adults per household results in an estimated $64 in application fees per household, consistent across one-, two-, and three-bedroom units, since fees are assessed per adult rather than by unit size.

Effective January 1, 2025, Assembly Bill (AB) 2493 established new requirements for how landlords process tenant applications and screening fees. The law mandates a first-come, first- served application process and requires landlords to refund screening fees for applicants who are not selected. This change may reduce the cumulative application costs for tenants who apply to multiple units before securing new housing.

Security Deposit

Security deposits are required by landlords when tenants relocate. Although generally refundable, tenants must pay the full amount at lease signing, adding to the overall financial burden of moving.

Under Assembly Bill 12 (effective July 1, 2024), landlords in California may collect no more than one month’s rent as a security deposit, with an exception that allows certain small property owners to collect up to two months’ rent. RSG assumed security deposits equal to two months’ rent as a conservative approach that accounts for this legal exception.

RSG estimated deposit amounts using Pomona-specific Fair Market Rents (FMRs) published by the U.S. Department of Housing and Urban Development (HUD). FMRs represent the 40th percentile of typical rents for standard-quality units, and are considered a consistent benchmark for housing costs. RSG averaged FMRs across Pomona zip codes, then applied a multiplier of two to reflect the estimated security deposit requirement by bedroom size.

Figure 2 – Estimated Security Deposits for Pomona Rental Units

Category 1 Bedroom 2 Bedroom 3 Bedroom
Average Monthly
Rent (FMR)
$2,187 $2,760 $3,517
Total Cost
(2x Rent)
$4,374 $5,520 $7,034

5 Utility Connection Fees

When relocating to a new rental unit, tenants are typically required to establish or transfer utility accounts, which often involves one-time connection or transfer fees. These charges vary by provider and utility type but are most commonly associated with water, electricity, gas, trash, and internet services. RSG reviewed publicly available information from local providers, including the Pomona Water Department (water), Southern California Edison (electricity), SoCalGas (natural gas), and Athens Services (trash). Internet connection fees were also included, based on the average of three major providers serving Pomona.

Figure 3 – Utility Connection Fees for Pomona Providers Utility Service Connection Fee
Water/Sewer (City of
Pomona)
$61.75
Electricity (S outhern
California Edison)
$0
Gas (SoCalGas) $25
Trash (Athens) $0
Internet $39
Total Cost $126

Temporary Storage

Tenants may need temporary storage for their belongings during relocation, particularly when there is a gap between move-out and move-in dates. RSG averaged prices from four local storage companies in Pomona for standard unit sizes commonly used by one-, two-, and three- bedroom households. An average administrative fee of $29 was found to be typical and is included in the totals. For the purposes of this Study, one month of storage plus the administrative fee is assumed to represent a reasonable estimate of temporary storage needs.

Figure 4 – Estimated Temporary Storage Costs in Pomona

Category 1 Bedroom 2 Bedroom 3 Bedroom
Storage Unit Size 10x10 10x15 10x20
Average Monthly
Rate
$159 $250 $420
Administrative Fee $29 $29 $29
Total Cost $188 $279 $449

Temporary Lodging

Similar to storage, tenants may need to secure temporary lodging during the relocation process if there is a gap between their move-out date and when their new rental unit becomes available.

RSG collected nightly rates from four local hotels considered to be reasonable accommodations in or near the City. Pricing reflects standard rooms for a 7-day stay for 1-4 guests.

6 Figure 5 – Hotel Rates in Pomona for Temporary Lodging

Category Cost Estimate
Average Nightly Rate
(including fees)
$156
Total Cost (7 Nights) $1,089

Total Estimated Relocation Costs

RSG aggregated cost estimates across all relevant relocation categories to provide a comprehensive picture of the financial impact of relocation. Estimates reflect expected costs for households relocating within the City and are presented by unit size, as detailed in Figure 6 below.

Figure 6 – Total Estimated Relocation Costs by Unit Size

These estimates provide a baseline for the likely costs tenants face when relocating in Pomona.

The following sections examine how these costs compare to Pomona’s current relocation assistance framework and to best practices in peer jurisdictions.

Comparison to Current Relocation Payment Structure
Pomona’s current relocation assistance amounts are based on the tenant’s household status, length of tenancy, and household income and include the following categories:

• Qualified Tenant – A tenant who, at the time the notice of termination is served, is:
o 62 years of age or older;
o Disabled, as defined under applicable state or federal law; or o Responsible for one or more minor dependent children, as defined for federal income tax purposes.
• Eligible Tenant – Any tenant who does not meet the definition of a Qualified Tenant.

Payment amounts for Eligible Tenants vary based on the length of tenancy and household income.

Category 1 Bedroom 2 Bedroom 3 Bedroom
Moving Supplies $104 $300 $424
Professional Movers (+ fees) $570 $1,066 $1,083
Application Fees $64 $64 $64
Security Deposit $4,374 $5,520 $7,034
Utility Connection Fees $126 $126 $126
Storage $188 $279 $449
Temporary Lodging (7 nights) $1,089 $1,089 $1,089
Total Costs $6,515 $8,444 $10,269

7 • Income Eligible Tenant – A tenant whose household income is at or below 80% of the Area Median Income (AMI), adjusted for household size, as determined by the U.S.

Department of Housing and Urban Development. Tenants claiming this status must submit a Tenant Household Income Verification Form to the City. • Reduced Relocation Eligible Landlord – In certain no-fault termination cases, landlords who meet specific criteria outlined in the Ordinance may pay a reduced relocation amount.

Current relocation payment amounts for each category are provided in Figure 7 below:

Figure 7 – Current Pomona Relocation Amounts

Tenant
Household
Tenants
Residing Less
Than 3 Years
Tenants
Residing More
Than 3 Years
Income Eligible
Tenants
Reduced Relocation
(Eligible Landlords)
Eligible Tenant
Household
$6,164 $8,074 $8,074 $5,926
Qualified Tenant
Household
$12,998 $15,377 $15,377 $11,960

When compared to the relocation costs estimated in this Study ($6,515 for a one-bedroom household to $10,269 for a three-bedroom household), the baseline amounts for Eligible Tenant households ($6,164 to $8,074) fall slightly below actual relocation expenses. This comparison is not exact, as the City’s current payment structure does not vary by bedroom size, but it provides a useful benchmark for understanding the relationship between estimated costs identified in this Study and existing assistance levels.

Relocation assistance for Qualified Tenant households is set at nearly twice the baseline level, underscoring Pomona’s policy priority of protecting vulnerable groups such as seniors, persons with disabilities, and households with children. These higher payments, however, may exceed the actual costs of relocation. This approach creates an opportunity for the City to evaluate whether the current multipliers strike the right balance between tenant protections, landlord obligations, and alignment with regional best practices, which is explored further in the next section.

It should be noted that City staff have observed the current relocation categories and corresponding payment amounts can be difficult for both landlords and tenants to interpret due to the number of eligibility distinctions and varying payment levels. As a result, tenants and landlords frequently seek clarification from legal counsel regarding their rights and responsibilities. Providing clearer policy guidance could help improve understanding and compliance among all parties.

Comparison to Peer Jurisdiction Policies
As part of the City’s Long-Term Implementation Study, RSG reviewed relocation assistance requirements across 11 peer jurisdictions to identify common approaches and assess how Pomona’s current framework compares. While all jurisdictions require relocation payments for no-fault evictions, the methods used to calculate payments vary. The review identified two common approaches, which are summarized below and detailed further in Appendix A:

8 Approach #1 - Multiples of Rent

Four jurisdictions, including Culver City, Hayward, Inglewood, and Mountain View calculate relocation payments as a multiple of monthly rent, most commonly equal to three times the tenant’s rent. This approach ties assistance directly to current housing costs, is relatively simple to administer, and provides predictability for both landlords and tenants.

Under this model, relocation payments would equal three times the tenant’s current monthly rent, meaning actual payments would vary by household. For illustrative purposes, Figure 8 shows what relocation payments would look like if HUD Fair Market Rents (see Figure 2) were used as typical rents by bedroom size. This provides a reasonable sense of scale for the amounts Pomona households may receive. The City could also consider adding supplements for vulnerable households, consistent with practices in many peer jurisdictions.

Figure 8 – Relocation Payments Based on 3x Monthly Rent

These illustrative amounts align closely with the relocation cost estimates identified in this Study, which range from $6,515 for a one-bedroom household to $10,269 for a three-bedroom household.

Approach #2 - Unit-Size Schedule

The majority of peer jurisdictions (7 of 11) determine relocation assistance amounts according to the number of bedrooms in the rental unit. This approach recognizes that larger households face higher moving costs and provides a standardized schedule that is relatively straightforward to administer. Many jurisdictions also index these amounts annually to the Consumer Price Index (CPI) to keep pace with rising costs of living.

If Pomona adopted this model, relocation payments would be tied to unit size rather than tenant categories or rent levels. In applying this framework locally, the City could use the figures identified in this Study as reasonable baseline moving costs by bedroom size. This would align Pomona’s relocation payments more closely with local costs while preserving the administrative simplicity of a unit-size model. Figure 9 illustrates how relocation payments in Pomona could be structured under this approach. As with the rent-multiple approach, the City could also consider adding supplements for vulnerable households.

Figure 9 – Relocation Payments Based on Unit Size

1 Bedroom 2 Bedroom 3 Bedroom
Relocation Amounts 3 x tenant’s monthly
rent
3 x tenant’s monthly
rent
3 x tenant’s monthly
rent
Estimate using 3x HUD
FMRs*
$6,561 $8,280 $10,551
*Actual payments would be based on the tenant’s current rent. 1 Bedroom 2 Bedroom 3 Bedroom
Relocation Amounts $6,515 $8,444 $10,269

9 Special Payment Considerations

Nine of the eleven peer jurisdictions reviewed provide supplemental relocation payments for vulnerable households, typically defined as seniors, persons with disabilities, families with minor children, or low-income tenants. These supplements average about 30 percent of the base relocation amount and are intended to provide additional support to households that may face greater challenges when displaced. If Pomona were to adopt a similar approach, applying an upward adjustment of 30 percent would place payments for vulnerable tenants in line with the supplemental enhancements observed in peer jurisdictions, while still grounding the payments in documented local costs.

Pomona’s Ordinance also allows certain landlords to pay reduced relocation amounts in specific no-fault termination cases. Among the peer cities reviewed, only Culver City includes a comparable provision, permitting “small landlords” (three or fewer units) to pay 50 percent of the base relocation amount when the owner or an immediate family member moves into the unit.

While reductions can provide relief to smaller landlords, they also lower assistance levels for displaced tenants and create additional complexity in the payment process. As the City evaluates potential adjustments to its relocation framework, it may wish to consider whether maintaining this provision continues to serve its policy objectives.

Figure 10 below incorporates all options, including supplements for vulnerable households and reductions for certain landlords.

Figure 10 – Relocation Payment Options with Supplements and Reductions

CONCLUSION AND NEXT STEPS
This Study establishes a clear baseline of the typical costs Pomona tenants face when displaced through no-fault evictions, and it highlights the need for a relocation assistance 1 Bedroom 2 Bedroom 3 Bedroom
3x Monthly Rent (HUD FMRs)
Base Payment* $6,561 $8,280 $10,551
+ 30% Supplement (vulnerable
households)
$8,529 $10,764 $13,716
50% Reduction (small landlord) $3,281 $4,410 $5,276
Unit Size Schedule
Base Payment $6,515 $8,444 $10,269
+ 30% Supplement (vulnerable
households)
$8,470 $10,977 $13,350
50% Reduction (small landlord) $3,258 $4,222 $5,135
*Actual payments would be based on the tenant’s current rent.

10 framework that is both equitable for tenants and administratively feasible for landlords and City staff.

In considering future policy direction, the City should evaluate whether to maintain the existing framework or adopt modifications that more closely align with the relocation cost estimates identified in this Study:

1. Adopt a rent-multiple model (3x tenant rent). This option offers ease of application for both tenants and landlords and produces estimated amounts that closely reflect the actual costs of relocating in Pomona identified in this Study. Under this model, the City could also include supplemental payments for vulnerable tenants, consistent with practices in many peer jurisdictions.

2. Implement a unit-size schedule. This option would base relocation assistance on the cost estimates identified in this Study by bedroom size, providing a clear and predictable standard across households. As with the rent-multiple approach, the City could consider adding supplemental payments for vulnerable tenants.

In addition, RSG recommends that the City reassess the reduced relocation provision for landlords to determine whether it continues to advance the City’s policy objectives.

Moving forward, staff should prepare and present a draft resolution for City Council consideration. The resolution should outline the preferred policy direction, incorporate the recommended updates to the relocation assistance framework, and formally adopt the selected approach. Adoption of such a resolution will provide clarity to landlords and tenants, establish enforceable standards, and ensure that Pomona’s relocation assistance provisions remain responsive to local conditions while reflecting best practices from peer jurisdictions.

11 APPENDIX A: PEER JURISDICTION RELOCATION STRUCTURE
Jurisdiction Relocation Amounts4
Alameda Amount ranges from $6,004 for studio apartments to $15,900 for qualified tenants living in 4+ bedroom units.

Berkeley
Flat rate of $18,011 for eligible households and an additional $6,003 for qualifying households.

Amounts increase annually in accordance with the CPI adjustment.

Culver City
Three times the current monthly rent in effect or the small area fair market rent as established by the U.S. Department of Housing and Urban Development (“HUD”) for a comparable unit in the same zip code, plus $1,000.

“Small landlords” (three or less units) pay 50% of this amount when owner or owner’s immediate family move in.

Hayward One month of rent, or waiver of the final month of rent.

Inglewood Three times the monthly rent plus up to $9,500 depending on tenure, senior or disability status, or if minor(s) reside in the unit.

Mountain View Three months median market rent for similar sized apartment, plus $8,000 for special circumstances tenants.

Oakland
Amount ranges from $7,861.52 to $11,943.47 depending on bedroom count, plus $2,500 if the household is low income, has elderly or disabled tenants, and/or children reside in the unit.

Amounts increase annually in accordance with the CPI adjustment.

Richmond Amount ranges from $4,177.01 to $20,147.05 depending on bedroom count, qualified status, and reason for termination of tenancy.

San José
Amount ranges from $6,925 to $17,380 depending on bedroom count, qualified status, and reason for termination of tenancy.

Santa Monica
Amounts range from $18,250 to $34,950 depending on bedroom count and qualified status.

Amounts increase annually in accordance with the CPI adjustment.

West Hollywood
Amounts range from $8,206 to $27,356 depending on bedroom count and qualified status.

Amounts increase annually in accordance with the CPI adjustment.

4 Source: Long Term Implementation Study, finalized August 2024. Please note that this reflects data available at the time of the study and may not capture more recent program changes.

12 APPENDIX B: DATA SOURCES FOR RELOCATION COST ESTIMATES The following sources were used to develop the cost estimates presented in this Study:
• Moving Costs (Supplies + Professional Movers): Home Depot (moving supply kits) and average rates from four Los Angeles-based moving companies (Master Movers, Qshark Moving, Amigos Moving, Rigos Moving and Storage), collected September 2025. • Application Fees: Zillow rental listings for Pomona, collected August 2025. • Security Deposits: U.S. Department of Housing and Urban Development (HUD), Fair Market Rents (FMRs), 2019–2023 American Community Survey 5-Year Estimates, averaged across Pomona zip codes.
• Temporary Storage: Average rates from four Pomona-based storage companies (Extra Space, Public Storage, US Storage Centers, and one independent operator), collected August 2025.
• Temporary Lodging: Average rates from four Pomona hotels (Comfort Pomona Inn, La Quinta Inn & Suites by Wyndham Pomona, Hilton Garden Inn, Double Tree by Hilton), collected October 2025.

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