Tim Shea ha n--Tenant Representative, Springdale Estates 2907 South Santa Fe Avenue/Space 2 San Marcos.CA 92069 ph//xt:(760)521-2490 emai/:[email protected] March 17, 2026
(PERSONALLY DELIVERED)
City Clerk and members of the Rent Review Commission
San Marcos City Hall
1 Civic Center Drive
San Marcos, CA 92069
RE: Tenant Representative Certification
To whom this concerns,
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MAR 1 7 2026
San Marcos City Clerk's Office
Please take note that the previously certified Mobilehome Park Rent Review Petition signed by tenants of Springdale Estates MH park in San Marcos, contesting the noticed 4% 2026 rent increase by the Park certified me to serve as the designated representative for tenants who are subject to the pending rent review proceedings.
Tim Sheahan
Tenant Representative, Springdale Estates
TR 00001
Tim Shea ha n--Tenant Representative, Springdale Estates 2907 South Santa Fe Avenue/Space 2 San Marcos.CA 92069 ph/lxt:(760)521-2490 emai/:[email protected] March 17, 2026
(Personally Delivered)
City Clerk and Members of the Rent Review Commission
City of San Marcos
1 Civic Center Drive
San Marcos, CA 92069
Re: Tenants' Response to Owner Submission -Springdale Estates' Space Rent Increase Request Dear Commissioners,
Tenants respectfully submit this response on behalf of resident homeowners of Springdale Estates (Springdale) manufactured home (MH) community (park) regarding the rent increase request submitted by park ownership. Current space rents range from $496/month •· $1,281/month and the requested 4% rent increase would create a range in increases from $19.84/m •· $51.24/m and raise the new range of rents to $515.84/m • • $1,332.24/m. While the owner's submittal attempts to frame the proposed increase as reasonable, necessary and promoting rent "balance," the submission contains several assertions that require clarification and rebuttal.
General comments
Springdale's initial submittal has failed to comply with the deadline set by the San Marcos Mobilehome Rent Review Commission (Commission) in accordance with the San Marcos Municipal Code; Title 16, Chapter 16.16 and/or related resolutions (Ordinance) regarding required financial information. Submittal of some financial information was provided over a week after the deadline, which hasn't provided our tenant rent committee adequate time to fully review. Springdale has failed to meet its "burden of proof' for why the requested 4% rent increase is "reasonable and necessary."
If proper due diligence had been performed prior to purchasing Springdale, Kleege Enterprises (Kleege) representatives would have educated themselves on requirements of the Ordinance/deadlines and unique aspects of the MH park. Apparently, Kleege representatives made no contact with City Hall officials (City) to inquire about deficiencies/Title 25 issues at the park, or details of the rent ordinance prior to purchasing the park. Even Springdale's previous law firm posted a "due diligence" TR 00002
2 warning on its website (see attached EXHIBIT 1), mentioning the need to be particularly careful if purchasing MH parks subject to local rent ordinances. It is our understanding that Kleege Enterprises operates dozens of MH parks, many of which are in jurisdictions with rent ordinances, so they should have understood the need to do their homework regarding the Ordinance and challenging conditions at Springdale that led to repeated sales of the property. Mr. Gregory himself described his vast experience in the industry and it seems remarkable that he and others failed to dig deep and discover a giant "red flag" appear during the evaluation process that should have triggered a fundamental question of, "why had the park sold so many times, even by some of the largest MH park operators in the industry?" Perhaps even questioning why a big company like Blackstone would sell one of its properties should have led to heightened scrutiny of conditions at Springdale and the purchase price fully adjusted accordingly. Also, Kleege purchased Springdale knowing it was subject to governmental rent regulation, making its value below "market," compared to MH parks in non-regulated areas. In addition, during the purchase consideration process, Kleege should have inquired of Blackstone and/or the City, if residents had been notified of an intent to sell and offered a required right to purchase, in accordance with the Municipal Code. No disclosure or offer was made by Blackstone and Kleege apparently did not raise that question.
Point-by-point responses to Owner's submittal:
"Initial Written Submission"
Consumer Price Index (CPI): Nothing in the San Marcos Municipal Code guarantees owners of land lease manufactured home communities in San Marcos ANY factor of the change in CPI/inflation rate. It is quite remarkable that Mr. Gregory portrayed the "All Urban Consumers" CPI as reflecting the impact of changes in goods and services on park owners like Springdale the same way as the changes impact general consumers.
The Bureau of Labor Statics (BLS} has classified all expenditure items into more than 200 categories, arranged into eight major groups (food and beverages, housing, apparel, transportation, medical care, recreation, education and communication, and other goods and services). Most of these groups impact general consumers far more than park owners; increases in costs of groceries and gasoline are a few costs, in particular, that have most dramatically impacted MH park tenants to a much greater extent than MH park owners. And, captive homeowners provide their own housing, while only renting the patch of dirt below their homes. Considering these important CPI distinctions, the San Marcos MH Rent Review Commission (Commission) has a history of granting less than "full CPI" rent increases. 75% of the change in CPI is a common standard in cities with rent stabilization ordinances for MH parks and some use a lower factor of the inflation rate (EXHIBIT 2a,b,c,d).
Mr. Gregory declared that his company has no desire to create an environment of confusion, misunderstanding and most of all unaffordability. That claim rang hollow TR 00003
3 from the very first days after Kleege bought Springdale. A letter to residents claimed ownership but no rent statements were provided to residents in the first billing cycle and no meeting was held to introduce the new owners/management to residents. A "shock and awe" and zero tolerance strategy in enforcing park rules blindsided residents who had grown accustomed to far different standards through several changes in ownership of the all-age park. Had the inspections been framed as "courtesy" inspections in a spirit of courtesy, compassion and goodwill, much of the resulting confusion, misunderstanding, anxiety and resentment could have been avoided. Some residents will provide statements in writing and/or address the Commission directly, if needed, at the scheduled April 14 hearing to refute Mr. Gregory's claims.
It's quite remarkable that Mr. Gregory implies that rents at Springdale are "balanced" and that providing such a balance, in effect, is the park's continuing intent. The practice for years at Springdale, and potentially continuing if a percentage rent increase is approved by the Commission, would escalate the growing rent imbalance by widening the rent disparity further with each annual percentage rent increase, due largely to past long-term leases. Many leases had annual rent increases of 10% and 12% in consecutive years during a period of time ranging from around years 2000 to 2020 (EXHIBIT 3a), even if CPI/inflation was 0%! For instance, it's likely that some residents received their rent high rent increases in 2009 and 2010, when CPI was 0.0% and 1.3% (EXHIBIT 3a). Some on leases received a 23.2% space rent increase over that two year period due to paying BOTH a 10% AND 12% increase (EXHIBIT 3b), while those protected by the Ordinance received no more than a 1.3% increase. Since 1995, the change in CPI has only exceeded 5% three times and has not been higher than 7.3% in the San Diego metropolitan area in that time. There was no logical justification for raising rents by both 10% and 12% in a long-term lease and would likely never be seen in a commercial setting if leases were also subject to rent regulation. In the "real world," leases provide security for landlords and the longer the term, the better the benefits for the lessee; just the opposite is often the case with captive homeowners in MH parks. In addition, some purchasers at Springdlae, even when forced to assume unexpired leases when purchasing a home, had to absorb more than a doubling of rent upon gaining tenancy in the park, a secondary means of inflating rents far beyond the CPI.
Thankfully, when Springdale (aka Villa Vista Estates) went to rent hearings previously, the Rent Review Commission (Commission) granted uniform rent increases among all affected residents so that the disparity wasn't widened further. At the most recent hearing for Springdale, in 2009/2010, the disparity in rent was around $275/m; it is now $785/m, The disparity alone is more than several residents pay in rent! Many residents were duped or required to sign egregious long-term leases/contracts of adhesion; the unfair business practices created "artificial inflation" of rents far beyond what the Ordinance allowed. But, since they were long-term leases, they were exempt from the local Ordinance until state adoption of AB 2782 in 2020. For several years, only two home sites out of 85 at Springdale were protected by the Ordinance. Those two spaces are the only legitimate spaces to base Maintenance of Net Operating Income (MNOI) or TR 00004
4 the change in CPI upon because those rents were not artificially impacted by leases or lawsuits. At the time the leases were first introduced in the early 1990s virtually all rents were within $10/m and if steps are not taken to stop the expansion of the rent disparity, it will reach $1162/m in ten years and $1721/m in 20 years at projected annual rent increases of 4% and highest rent reaches $2,824 (EXHIBIT 4a,b)I The continued widening of the disparity is simply not sustainable! Not only will the rent increases be hard to pay, the disparity will have a dramatic impact on home values amounting to tens of thousands of dollars of lost potential home value. An associated inequity due to the leases and the Ordinance is that some new residents could move into Springdale and pay less that half the rent of other residents who have lived in the park for over 30 years and paid over $200,000 in rent during their tenancy.
A legitimate alternative to an MNOl/inflation analysis would be to conduct a comparable rent study, as allowed by the Ordinance and previously performed by MAI appraiser, James Brabant, for the two most recent Springdale (aka Villa Vista) hearings (see attached excerpts--EXHIBIT 5a,b,c,d) in which a uniform rent increase of $8.47/m was ruled appropriate for 2008 and a uniform $0.0/m rent increase was ruled appropriate by the Commission for 2010. Both decisions were upheld in the courts following lawsuits filed by the park owner. Artificial inflation raised the SpringdaleNilla Vista average rent to a level that far surpassed comparable MH parks in San Marcos, which justified the nominal rent increases.
Mr. Gregory, declared that "balanced" rent increases are important to serve the residents and the property to "ensure affordability and habitability." To use one of his own terms, any representation that current rents are "balanced" is ABSURD! 2026 and 2027 "Proposed Maintenance" items deal with costs of repair/replacement for deferred maintenance or age of items that should have been disclosed and/or discovered during the purchase process and fully factored into the purchase price accordingly. The depreciation schedules submitted relate to condition of the park that was failing at the time of purchase and as potential isolated expenses, should not be claimed in order to justify higher permanent/compounded rent increases. Also, we noticed no reference to a transfer of park maintenance "reserve funds" upon change of ownership or income tax deduction estimates associated with the depreciated expenses.
"Other Points of Issue to Clarify"
The clutter in the Springdale RV lot was an area of focus because of the double standard in rules enforcement. It contains far more clutter than merely "junk vehicles" and contrary to Mr. Gregory's claims, the park uses the RV lot for storage for such things as trash dumpsters, retired BBQ grills/washing machines and greenwaste, as photos we will provide in a subsequent submittal clearly demonstrate. The CA TR 00005
Mobilehome Residency Law (MRL), section 798.23 (a) states that "management shall be subject to, and comply with, all park rules and regulations to the same extent as residents and their guests." That has not been the case with Kleege. Additionally, the items stored outside homes that were deemed acceptable by previous park owners/management and Title 25 inspections by San Marcos code enforcement, were cited as violations by Kleege, which forced some residents to seek outside storage facilities at a cost of roughly $150/m. That added an unreasonable expense and essentially constituted a extra $150/m rent increase for those homeowners.
The MRL also references in section 798.36 that park rules must be reasonable.
Applying rules adopted for a 55+ MH community in Desert Hot Springs was NOT a reasonable application for all-age Springdale Estates. It was unreasonable for the park rules to require residents to maintain and replace mailboxes, when previously that had been the responsibility of the park as an amenity provided to residents. The responsibility of maintaining and replacing mailboxes has been unfairly shifted to homeowners due to a park rule change that was not approved by residents in 2019.
Just as driveways installed by the MH park are the responsibility of the park (CA MRL, section 798.37.5 (c)), mailboxes installed by the park should remain the responsibility of the park.
A park rule citing that the swimming pool would only be heated four months out of the year is also unreasonable and another practical loss of an amenity previously provided year-round. Just because a rule exists doesn't mean it's legal or enforceable; otherwise, a park owner could add rules enabling such actions as arbitrary or retaliatory shuttering of the clubhouse and common areas with no recourse by homeowners.
Grandfathering of existing conditions recognizes what had been as reasonable and acceptable, in many cases, through several changes in park ownership and those standards should continue at Springdale, with resident input and support.
Springdale has provided no evidence that a majority of residents voted to accept modifications to the park rules in 2019, as required by the San Marcos Municipal Code, section 16.04.070 of chapter 16.04. Tenants intend to provide a statement in a subsequent submittal, if necessary, by the resident manager in 2019, confirming a vote was not taken and many rules were never enforced.
It was very disappointing to see Mr. Gregory take the arrogant position that rules "will never be rescinded or removed." That attitude alone demonstrates a lack of goodwill or spirit of partnership by Springdale.
5 TR 00006
"Taking Away Amenities"
A common definition of an amenity is "something that helps to provide comfort, convenience, or enjoyment."
While it might make sense to phase-out some amenities/benefits such as newspapers, cost savings should then be used for new benefits, such as complementary or discounted Wi-Fi access in the park.
6 We have mentioned the swimming pool no longer being heated year-round and apparently prior to discovering a park rule that dealt with the issue, at a 12/20/2025 meeting with residents, Mr. Gregory declared that Kleege "doesn't heat our swimming pools in the winter months." That is definitely the case at Eldorado MH park in San Marcos, which made our discovery that the pool at Town & Country MH park in Escondido was heated to over 80° in the winter quite surprising. Perhaps that exception is because Mr. Gregory is a resident of that same MH park! Tenants have contacted two previous Springdale resident managers to verify amenities/services provided over the course of decades and several changes of ownership; the swimming pool was heated year-round, even after introduction of the 2019 proposed rules. We anticipate the former managers will confirm a listing of those amenties/services/benefits previously provided at Springdale, which will be included in our subsequent submittal. Some additional examples of losses include, but are not limited to:
1) Reduction in park office hours to less than half of previous hours 2) Loss of online rent payment portal, which forces some residents to secure cashier's checks or money orders to make payments. Apparently, Kleege's Eldorado MH park offers "Rent Cafe," which we hope will be activated soon at Springdale Estates
3) Loss of access to guest parking spots, which forces many residents to seek overnight street parking outside the park
4) Loss of access/use of the RV lot and car wash area
5) Loss of holiday dinners/parties
6) Loss of extra large dumpsters for Fall/Spring cleanup 7) Loss of donut days that promoted social interaction among residents Tenants also feel "Goodwill" should be considered as an amenity at Springdale.
Unfortunately, there has been a shortage of good-faith and goodwill from the early days of Kleege ownership. In our next submittal, if necessary, tenants will provide more evidence of such concerns, including written communications with management.
Tenants do note that some loss of amenities/services started prior to Kleege's purchase of Springdale but with no corresponding reduction in rent, we feel it's Kleege's responsibility to restore them. We also note that two BBQ grills have recently been TR 00007
7 replaced, although no notice has widely been given to residents. Three chaise lounges and a different outside table have also been noticed by the swimming pool. Long awaited water pressure related repairs have also recently been made. We appreciate those recent steps to address some lost amenities and needed repairs/replacement and hope similar positive steps are made in the near future. "Residency Concerns"
Tenants agree with Mr. Gregory that a purpose of rent stabilization is to protect the less fortunate, but with a growing number of predatory capitalists purchasing MH parks, the purpose and value of rent ordinances to protect ALL captive homeowners without viable options to move their homes has become vitally important. There is virtually no place to relocate if conditions become too oppressive and it is very expensive to move a MH and can significantly damage the home. A Florida court declared a situation of "economic servitude" exists for those in the precarious position of owning homes on someone else's land without adequate protections. Just as the market manipulation by ENRON in the utility industry created widespread abuse in unregulated environments, all MH park homeowners need and deserve adequate consumer protections to help ensure "home/land security" of tenancy. Rent ordinances can also be vital in helping to ensure rent parity among spaces within MH parks and among MH parks in the jurisdiction to help ensure that homeowners receive a fair and appropriate "bang for their rental buck," based upon amenities, condition and operation of their MH park. Rent ordinances are an essential safety net of protection against policies of a growing number of opportunistic park owners.
On a personal note, I take some offense to Mr. Gregory's proposal to "back-bill" some residents. I have personally been paying extra space rent for my deceased mother's home at space four since year 2000 in the hope ii will be bought/used by one or more of my siblings at some point, which was our mother's wish. Her home is two spaces away from mine and for over a dozen years, park management allowed us to share a set of trash bins, which more than met our combined needs. After purchasing the park, Kleege started billing for trash at my mother's space, even though no trash pickup occurred at that space (or at my space two) for the entire summer. The trash charge of $37.37/m, in effect, was a 6.18% rent increase and "utility" charge instituted without notice. Previous management demonstrated compassion and courtesy considering my mother was a "snowbird" by not charging her a trash fee and using her bins somewhere else in the park. As a snowbird myself, I have seen no gestures of courtesy by Mr.
Gregory; in fact, he told me I must sell my mother's home, which was not only unfair, it was particularly hypocritical considering Kleege owns perhaps a dozen or more MHs at nearby Eldorado MH park! And, despite knowing I was gone for the summer and had TR 00008
8 requested that notices be sent or emailed to me, Springdale instead posted notices at my home. Many park owners recognize that snowbirds are, in effect, paying "double the rent" since they are only onsite for half the year and; consequently, offer space rent discounts to homeowners for periods if absence. In other cases, park owners have rewarded those who regularly pay their rent on time with a financial benefit, such as waiving one month's rent periodically. Neither has been the case with Springdale. I will be including past communications with Mr. Gregory in a subsequent tenant submission to demonstrate Springdale's management style and approach.
We urge the Commission to reject the proposed money grab by Springdale to add more artificial space rent increases based upon those who might have a second home or not live in the home. Many of the current situations have existed for years, have a family connection and been accepted through implied or written contracts with previous park owners. Also, rules signed by many homeowners prohibited subletting of homes, which under CA MRL section 798.21 (f)(1) allowed such homeowners to maintain rent ordinance protections. I personally have not rented rooms at either of the homes under my control at Springdale. Finally, there is no "means testing" of income to qualify for the Ordinance and we urge the Commission to support grandfathering of existing situations and special circumstances at Springdale by ruling that "back-billing" is unwarranted. "The Claim of Rent Disparity"
Despite me explaining the rent disparity situation to Mr. Gregory previously, he has either mistakenly or intentionally mischaracterized the situation at Springdale to the Commission, which is remarkable and disingenuous. Not only is there a huge rent disparity, as Mr. Gregory has acknowledged, some NEW residents of Springdale can be paying LESS THAN HALF the rent as long-time residents of the park, perhaps even for over 30 years and after paying over $200,000 in rent through their years of tenancy! Mr.
Gregory's mistaken example of a 25-year resident having been able to "receive the proper allowance and protection the ordinance gives" is contrary to the actual situations because for most longtime residents, long-term leases governed their annual rent increases for the majority of their tenancy, not the rent ordinance. And, the leases enabled the park owner a "whichever was greater" choice between CPI and the increase amount listed in the lease (EXHIBIT 3b) for annual rent increases. Those residents had to "ride out" their abusive leases before they could finally seek protection under the Ordinance.
There should be rent "PARITY," not unfair rent "DISparity'' causing rent "DESPAIRity"! TR 00009
9 "Home Sale Values"
Previous Commission retained expert Kenneth Baar has referred to a generally accepted estimate that for every $100/m increase in rent, home value drops by $10,000 (EXHIBIT 6), which demonstrates how devastating a rent disparity can be, especially if you have a nearby MH for sale where that buyer would pay less than half the rent as your buyer!
Mr. Gregory claims the "argument is always the same: No increase and the expectation of maintaining the park." Contrary to Mr. Gregory's generalized assertions, Springdale tenants have already made a tentative rent increase proposal during this cycle and even suggested trying to reach a long-term agreement. We have received no response to those suggestions. Residents have avoided the need for rent review hearings by negotiating/accepting rent increases EVERY year of positive inflation since the last rent review in 2010, during which park owner Cal-AM had attempted to increase some rents by over 70%, claiming it deserved to raise all rents to the highest in the park. Its claim of "Market Rent" was rejected by the Commission (and the courts subsequently), who recognized the absence of "market factors" such as competition in a monopolistic/oligopolistic situation. The only time a true free and open market existed was when MH parks were first constructed and developers were competing to attract customers to place homes in the new MH parks. Once the park was full of trapped homeowners, escalating rents triggered the need for local rent protections. MH values rise and fall due to market factors but space rents virtually never fall voluntarily. Also of note is that many apartment rents in the region have fallen in the past year, unlike MH space rents.
"Required Documents We Do Not Have"
Due Diligence should have provided production and examination of financials and the recent request for access to historic financial statements should have been made prior to February 22, which was 26 days after the initial deadline for submittal of January 27.
Conclusion
1) Springdale has not met its burden of proof to demonstrate a true need for the requested 4% rent increase and; therefore, should not be approved by the Commission.
2) The current space rent situation at Springdale is anything but "balanced" and Springdale's requested rent increase of 4% would extend an unfair annual widening of rent disparity caused by a practice of annual percentage-based rent TR 00010
10 increases. Such a practice is simply not sustainable! Mr. Gregory mentioned the term "balance" as the "answer," which considering the current situation at Springdale should be viewed as an invitation to the Commission to intervene by truly promoting rent balance, equity and parity at Springdale Estates. 3) "Artificial Inflation" has created an abusive rent structure due to unconscionable leases/contracts of adhesion that made easy prey of na'fve, trusting or fearful residents who now pray for support of the Rent Review Commission.
Suggested options for Commission consideration and action:
1) Deem the application incomplete, insufficient and untimely and reject the requested rent increase, as has been done by a previous Commission. 2) Grant no increase, or an appropriate rent reduction, until there is a return to reasonable park rule policies, restoration of lost amenities and necessary repairs completed in accordance with City requirements to fix longstanding water-table issues or other Title 25 code violations.
3) Conduct a Comparable Rent Analysis to evaluate rental "bang for the rental buck" and promote greater rent parity for Springdale residents compared to MH parks of similar quality, facilities and services and approve an appropriate rent increase accordingly, as has been done by previous Commissions. Exempt consideration of outlier MH parks that have imposed artificial inflation due to long-term leases.
Grant any increase conditionally, requiring return to reasonable park rule policies, restoration of lost amenities and necessary repairs completed in accordance with City requirements to fix longstanding water-table issues or other Title 25 code violations prior to adoption of the rent increase.
4) Approve a conditional reasonable uniform rent increase among all spaces in the park with no increase being more than 4% applied to any space. "Uniform" rent increases have been a longstanding practice at nearby Vista Meadows MH park so any rent disparity at that MH park would not be widened. Grant the increase conditionally, requiring return to reasonable park rule policies, restoration of lost amenities and necessary repairs completed in accordance with City requirements to fix longstanding water-table issues or other Title 25 code violations prior to adoption of the rent increase.
5) Approve 75% of change in CPI rent increases with rents above a certain amount frozen for a defined number of years. Grant any increase conditionally, requiring return to reasonable park rule policies, restoration of lost amenities and necessary repairs completed in accordance with City requirements to fix longstanding water-table issues or other Title 25 code violations prior to adoption of the rent increase.
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11 6) If a rent increase is approved, do not make it retroactive to January 1, considering residents have suffered loss of amenities from January 1 continuing to the present or recent date.
Special requests of the Commission:
1) We ask that hearings for all-age MH parks start no earlier than 4 PM to help enable more affected tenants to attend and participate in the proceedings.
Otherwise, hardship is created by lost wages for working families hoping to attend.
2) Just as petition circulators are required to sign certification under penalty of perjury regarding signatures collected, we ask the Commission require MH parks to certify under penalty of perjury that a list of ALL tenants qualified to sign rent petitions provided to the City Clerk is complete and accurate and that the list be provided to petition circulators. That would encourage compliance with the Ordinance and help avoid confusion in the future. A full list used to be provided to all affected residents at Springdale.
3) We also encourage the Commission to adopt a policy requiring disclosure of existing large rent disparities to prospective purchasers of homes in MH parks that have notable disparities, considering the potential adverse impact on home values.
We appreciate the Commission's commitment to maintaining fairness, transparency, and housing stability for the residents of Springdale Estates.
Respectfully submitted,
Timothy Patrick Sheahan
Tenant Representative, Springdale Estates--on behalf of the resident rent committee San Marcos, California
Cc: Springdale Estates
TR 00012
Springdale Estates Tenants' Response 03/17/2026
(EXHIBIT1)
(Due Diligence warning on the Website of Treehouse's former law firm) (Excerpt from Hart King website)
Due Diligence for Mobile Home Park Purchase (Part 2)
Aug 3, 2015 I Sean O'Hair I Blog
The mobile home park WIii almost certafnly have stnJctutes of its own, including infrastructure; in addition to the mobile homes themselves. Having copies oltne plans for the panamd any C11Pilul Improvements could he e85fln(fal when conslntction need!i w be i/onq in tlTe /Qtu,e lo updalec utililie!i or add any nflW capital Improvements. The buyer !ihould also reque!lt any and allengl11eerinl/ reports regarding tlTe <.;qnslruction of Um pamor its 111a/11te11ance. Having 1/Jtµ;e documents on hand w/Urnake tlTe con!flnt(;tion or l'flPl1ffPf'(JCe$$ eniar In tlTe future, whether on a near-term or long'lerm time scale.
La$!, but not least, you will want to look forinfomrallon rogardingkJcal politics vis-a,vis mobile /,"11((JPJidr$. This. may reqqire some research of local publlcatloris for articles regarding tnobile hqme parks generally or.the mobile home park to be purchased specifically. Such politics can affect how much rent may .be charged, the types of red tape ihat may be encounter¢<! when seeking any government approvals, and even whether or not the use of the land the mobile home park is sited on can be used for a differentpurpose, Does the local city or county government vlew the park as attractive in i(s current state? Does the park have a "bull's. eye' on it by a particular government agency or city council? Are the local courts excessively tenant friehdly? These are all q1Jestions a bwer wiU want to ask, Rent confroloniln11nces may limit the amount nmf.s can be raised In e plven tlnie period, end may llmH the types or expenses, !luch D!I capita/ expenditures tor utt7/ty improvements, that c11n be p1t!iseda/ong lo tenants. Also assess the local court and talk with local counsel who represents mobile home parks, Cer/tlln locales am teJ1ant blued when tll!iPUhJ!i do arise, which 11 buyer !ihould be awilro or In evaluating the oven,// picture or tho value ol a 111()/}i/e home park.
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Springdale Estates Tenants' Response 03/17/2026
(EXHIBIT 2-a)
Justification for Limiting Mobilehome Park Rent
Increases to 75% of CPI
Purpose
This document explains the policy rationale for limiting annual mobilehome park rent increases to 75% of the Consumer Price Index (CPI). This standard is widely used to balance park owner cost recovery with resident housing stability.
1. Mobilehome Residents Are Uniquely Vulnerable
Mobilehome residents differ from traditional renters because they:
• Own their homes but rent the underlying land
• Face extremely high and often prohibitive relocation costs • Cannot easily move in response to rent increases
These conditions create a captive tenancy, justifying stronger rent protections than those applied to apartments.
2. CPI Overstates Actual Park Cost Increases
The CPI measures average household consumer inflation, not mobilehome park operating costs. CPI includes categories such as:
• Apparel and recreation
• Medical care and education
• Personal services
These categories do not directly affect park operations. Applying 100% of CPI therefore risks granting rent increases that exceed actual cost growth. A 75% CPI factor more accurately reflects real park expenses. 1 TR 00014
Springdale Estates Tenants' Response 03/17/2026
(EXHIBIT 2-b)
3. Core Park Expenses Typically Rise Below CPI
Major park costs-such as property taxes, long-term financing, infrastructure maintenance, and management generally increase more slowly than CPI or are regulated by law. A 75% CPI cap recognizes these realities while still allowing reasonable annnal adjustments.
4. Predictability and Fairness
A 75% CPI standard:
• Provides a clear, objective, and predictable method for rent adjustments • Prevents sudden rent shocks during inflation spikes
• Allows residents, many of whom are on fixed incomes, to plan responsibly At the same time, it ensures park owners receive consistent annual increases without the need for constant cost litigation.
5. Prevents Windfall Increases During High Inflation
During periods of elevated inflation, full CPI increases may far exceed actual operating cost increases. A 75% CPI cap serves as a moderating safeguard, preventing excessive rent hikes unrelated to park expenses.
6. Consistent With Established Rent Stabilization Policies Many jurisdictions adopt rent increase limits below I 00% CPI-commonly 70-75%-specifically for mobilehome parks. These policies reflect legislative findings that mobilehome residents require enhanced protections due to their inability to relocate.
2 TR 00015
Springdale Estates Tenants' Response 03/17/2026
(EXHIBIT 2-c)
7. Preserves the Right to a Fair Return
Rent stabilization frameworks typically allow park owners to petition for additional increases when justified by extraordinary or unforeseen costs. The 75% CPI standard serves as a presumptive baseline, not an absolute ceiling.
Conclusion
Limiting mobilehome park rent increases to 75% of CPI is a fair and reasonable policy that aligns rent growth with actual operating costs, protects residents from displacement, and preserves long-term housing stability while ensuring park owners retain the ability to earn a fair return.
Prepared for: Resident Committees, Rent Review Boards, and Park Management Discussions 3 TR 00016
I
I
Springdale Estates Tenants' Response 03/17/2026
(EXHIBIT 2-d)
In California, several cities and counties have adopted the 75% of CPI formula as a standard for "permissive" or "automatic" annual rent increases in mobile home parks.1 This is often paired with a "floor" (minimum increase) and a "ceiling" (maximum cap) to provide stability for both residents and owners.2
Below are the primary jurisdictions that currently use or have recently used this specific formula for their mobile home rent control ordinances:
Jurisdictions Using 75% of CPI
City/ County
San Jose
Oceanside
Palm Springs
I
Rent Increase
_ Formula
II 75% of CPI
II
75% of CPI
II
75% of CPI
I Limits / Specifics
II Minimum of 3%; Maximum of 7%.
I
Maximum cap of 8%. (Administered by a
Commission).
I
One increase per year; owner can petition for
"hardship" more.
I Carson II 75% of CPI II Maximum cap of 8%.
Cathedral City
I
75% of CPI
I
Specifically for tenants on month-to-month rental
agreements.
I Morgan Hill II 75% of CPI II Maximum cap of 8%.
I
I
Sunnyvale
II
75% of CPI
I
Minimum of 3% (set via a Memorandum of
Understanding).
Santa Monica
II
75% of CPI
I Uses the Los Angeles area CPI specifically.
Los Angeles
I
75% of CPI
I
For unincorporated areas: Minimum 3%, Maximum
County 8%.
Contra Costa
I
75% of CPI
I
Minimum 2%, Maximum 6% for unincorporated
County areas.
The 75% Argument: Proponents argue that since a park owner's mortgage is usually fixed and property taxes are restricted (by Prop 13 in CA), their actual "out-of-pocket" inflation is lower than the general economy's, justifying a smaller percentage. 4 TR 00017
14 Springdale Estates Tenants' Response 03/17/2026
(EXHIBIT 3a)
Springdale Estates "Artlflc:lal. lnfladon"
1995·2~25 full CPI &75% CPI vs; possible 10%& 12%.space rentlncreasl\Slmposed under 1.•~-t•nn leases '")•nysp~~s Incurred vacancy re11tJ~creases ran,Jng from 33_%tooverl!JO% durlnt the.30:ye.rperlod 12 ·············•-·-·············• .................. •·· 8 0 .. '.·:•
,· j:i, J,f$.~ ?">li'-1 ,f',f ,l,f,f ,l-,~,1',p-$>#'~*,p-$',p~-,4',,~,p~~,I'",,~" San Diego CPI/inflation rate applied to Springdale Estates under San Marcos Ordinance 1995 1.5% 2006 3.4% 2016 2.0%
1996 2.6 2007 2.3 2017 3.0
1997 1.7 2008 3.9 2018 3.4
1998 2.0 2009 0.0 2019 1.4
1999 3.5 2010 1.3 2020 2.1
2000 5.8 2011 3.0 2021 6.0
2001 4.6 2012 1.6 2022 7.3
2002 3.5 2013 1.3 2023 4.3
2003 3.7 2014 1.9 2024 3.5
2004 3.7 2015 1.6 2025 4.0
2005 3.7
TR 00018
2.2 Springdale Estates Tenants' Response 03/17/2026
(EXHH31T 3b)
CQST OF UvtNQ OB INCBfASE AQ.JU$TMFNT
2.2(a) !'or lhe period beginning with (C) above. HOMFOWNER(S) Shall pay VILLA VISTA MOBILE: ESTATES the sum sel forth at (F) above per month i!S RENT. commencing On the dale set forth at (G) above. and each year 111ereaNer on an annual basis (that is. ohce eve1y twelllh monlh). VILLA VISTA MOBILE ESTATl!S
2.2(b)
shalf increase the monthly rent HOMEOWNER(S) are th paying, for the following twelve (12) months. by the percentage listed ~lo e Inc e In the ·consumer f'rice fnde~· for the prior twelve (12) m s. Whlchllver Is great~.
year 2
year 3
year 4
year5
year G
year7
year a
year 9
yea110
()%•
2%
2%
3%
4%
4%
~f§>> (combined 23.2o/o rent increase)
• 'Indicates no cost ofliving adjustment.
The "Consumer Price Index• used lo delermine this amOllnt shall.~ the •cost of Uving Index for Urban consumer of the .san Diego Metropolitan Area' (all hems) based on year 1982 • 100 as published by Ihe United States Department ot Labor Bureau or Statistics, as of the nearest publication date llefore lhe date set forth at (G) abOva. In the event tl)e •consumer Price lndex· ceases to lncorpQrale a significant numbe1 of items, or If a substal'l!lal Change Is made In the method ol establishing such ·consumer Price Index: then the •con,;umer Price. Index• shall be adjusted to the figure that would have resulted. had no ch;lnge occurted In the manner of computlnQ lhat ·consumer P1lce Index.• In the event that such 'Cons'!l'l'ler Price Index• (or Us successor or substitute index) is not avanable. a reliable Q()vernm~ntaJ or other non~partlsan publication,· evaluating the lnto11T1at1on thereIotore used In deWmlnlog the •consumer Price Index• Shall be used In lieu of such •consumer ·Ptlce Index:
2.3 AQ,JUSIMEN'J: e:aa INGBfA$1;$ IN IAXFS ASSE$SMENI$
~QYEBNMENTAl LY MANDATED PBO,!ECIS NlP INSUBANQE
In addition lo a.II other rent due under the term$ of this agreement, the mont~ly rents shall be increased arid assessed . on the date set forth at (G) above and on each anniversary ol that date in the manner describe(.! balow. (However. rent shall not be increased due to any cost. fine. forleilure. penally. or fee auribotable to any loss or. fee incurred on account of a viOlaliOn by the PARK of any Chapter of the MObllehome Residency Law.) The Increase In monthly rent shall be equal 10 the ne.t Increase ol one 1v1elflh (1/12) of the lncrme in the following factors Incurred by the PARK over the previous twelve month pet!Od, divid~ by lh& number of occupied spaces In lhe PARK:
V/LU. VISTA MOB!lii /iSTATES
120-1,/onlh L•~·•• P/r 10028
910528 P•g• 3 •
//we have read and agrfe to all prov/$/ons on this paga.
Homeowners initials and d~te:.......------
X
TR 00019
Springdale Estates Tenants' Response 03/17/2026
(EXHIBIT 4a)
Projected Monthly Rent Increase Comparison
Highest vs. Lowest Current Space
Rent
(example: 4% increase)
I> .... ......... .,. .....
.. ~----------~----~-----~----~-----
"ld-11!> :2G1S i&'c:W llt1$ !~$ l.lM~ ~
-6-Lowt-st re,nt --½-Higheestrent
Rent projection using highest current rent al Sprlng(fale Rent pro}ectlon using lowest current .ont at Springdale Year Spae&Rent YvarfyTotal Year Space Rent Yearly Total 2025 $1,261 $15.372 2-025 $496 $5,952
2026 $1,333 $15,996 2026 $516 S6,1!n
2027 51,387 $16,644 2027 $537 $6,444
2028 $1,443 $17,316 2-028 $559 $6,708
2029 $1,501 $18,012 2029 S582 5 .... ,
2030 $1,562 $18,744 203-0 $606 $7,272
2031 $1,625 $19,500 2031 $631 $7,572
2032 $1,690 $20,280 2032 $657 $7,884
2033 $1,758 $21,096 21)33 $684 $8,208
2034 $1,829 $21,948 2034 $712 $8,544
2035 $1,903 $22,836 2035 $741 $8,892
2036 $1,980 $23.760 2036 $771 $9,252
2037 $2,060 $24,720 2037 $8-02 $9,624
2038 $2,143 $25,716 2035 $635 $10,020
203" $2,229 $26,748 2039 $869 $10,428
2040 $2,319 $27,828 2040 $904 $10,848
2041 $2.412 $28,944 21141 $941 $11,292
2042 $2,51)9 $30,108 2042 $979 $11,748
2043 $2,610 $31,320 21143 $1,019 $12,228
2044 $2,715 $32,580 2044 $1,060 $12,720
2045 $2,824 $33,888 2045 $1,103 $13,236
2045 (4%" $112,96-/m !ncre.se) 2045 {4%,. $44.12/m lncre.i1e) D!fferenee In monthly rent and yearly payments
(2025) $ I ,281 ·$496=$785 (monttiy) / $15,372--$5,952=$9,420 {yearly) (2-035) S 1,903·$ 741=$1162 (moolhfy) I $22,836-$8,892=$ 13,944 (yearly) (2045) $2,824-$1, !03=$1,721 {monthty) I $33,888-$13.236=$20,652 (yearly) TR 00020
Springdale Estates Tenants' Response 03/17/2026
(EXHIBIT 4b)
Highest vs. Lowest Rent Trend & Disparity Increase Over Time' *Example assume, a 4¾ monthly Increase
2025 Ul26 2027 202' ).,)29 2010 20n :wn 20:n 21)1-4 ZOJS 2016 2:0)7 zon 20l9 M40 ZM1 2:042 20H 2044 2!W5 -+-Lowest Rent ..,._Highest Rent ....,Disparity
Rent Disparity Projection (2025-2045)
::,-:,;.,;;,.;;.ijf:" :,,t\/'.l Hl&h'•i·fii~rif-' ilti'W.-1t'1Htil'i:'::;: ·:::F:::DhiPa'ritY:::
•• --i=::-;,:;;/2Cfa:i::::· ·; ?it$t;i&i: ;:;iL.$1411\i'~? iii$7'$Jf;:), :'/iO~i(i:tf' 1:::gfn\s1;3-;·:r • r:::;:$fi1i:i: ·'''.'./;:?:• ,,::::usan:- •. ,· .. w~,., $1,an.'., ·,$a~, : : • ·$aoo· :::,:1.(iu> · .:,$1,*43 • • $t!lll· " : .'·$88* •
:1.<12~ , . • •· .£1;,oi· .. _., --:$a•2. . . ·_4911i . 20,0· ,--u;•~• : ,· $Obo : . ,--. :, ·$956 :
. -_20a1.·' ·,;$M2s . ·.:,e,1:· ,·.$iia~•
·~on· • ·-,,$1,Mo :--$•~-".. , $il1•~
.. --. ~oao:. . .. :. ::_$i,~•• -.. ,~s4.. -$lio74
• ::.,:\i!,?i:Q)~-;::;,;; /$t$;i~ :HI$7'ii:f::'. .. /_$ifai1:
-''.~6!15'\L:: \$il~~,, .. .,. /(;:(ji;..ii{ -,:s$i;iii .20•1<·,,: • .,J:oso .. ,. --. $77< .. •si:20,i:
i~ijff:< J$;iiii~::;;::,: ::;:::;:$ijc),f', :;;;~iii~i
;:,,::;z:c;Jiij:'::: :;::;;:i,:i ·'$jJMJifi:: ·i:jBijf;i fJ/?: \h$l!IOJ,-.,::;:,,i" '"'m>rn;'iQ~O'?; :'.$2~2::zi; ;;•'$1~f0:::•: ii/$ij8~:::i'." • "\):20.:0: i.$~jii_f, ::;,:::-$1i(J',f'.'". ;·:::.:•:::$f◄'.i5:;,c;·,::;';'::
'2041 $2 ◄12' , $941 '• :•· _ :$:i'.,1i : :
' • ioiui • ~•:sci9· • $iii, : • ' $r;sao. -
• .. 20d / . s,;.,o • $t.'019 • ., . ,: fi,;5tii :. •
:::·;:;)2044:0:: •
:·,·::12045\;i·;"
'.($2/715•
:$J1Si4i:;
-$t.'oeo • > • "i:$1;ns5 ,'.:::·:
-.:··u,;H
TR 00021
O'ctober I, 2007
Springdale Estates Tenants' Response 03/17/2026
(EXHIBIT Sa)
ru:,.L "~11:-n ;tP~,\tt_t;!t"'"'Nn o:)1-'l~l,,IP-""t~
·i,S.i w: t1iNl'H ./,;vE:f,i\JE
r:ScoN~I_OO; _C/',\.!'f'()FfNfA}i201~'.~;~f~
-1~-~-E~~~N~ •itl_Oi?4 f,,~ 1,4!}
.f'/l{J'..(601 '7,4-ldQ~~ •
MobllO'llonW ilcnt !l~\•leW CorruniS$ion
CityofS~ iv!i(roos •
l clylp'P~!jj¥r•~rlv¢.·
~an1v!arciis, California.92069
l'>iJar.tomrni;$ipri lvkni\it:rs: .
. ·• As ~~uesi.eJ; •rhll\'e c;o1npfe\c~ ·#.ye11taJ1111\i1~is••?f VUJa.v1~1a E$1~;•flll. Ii$. ~Cl!. mobile .. h-001~ .J)!llk 1<.if;a¢<! 2907Si~nnta Fil A\iel1t1e,.;laµ!1,farc-0s, Cl).!lfont.l!J. Th¢ obj~tiVil ofJl.1\Nlllll.lys.l.s ~\•~~. lo to,n! 1111 ®lll!Ol\ of ll)e Clll)\\11) rental value. 9f spaces !n the park !!lat lilt subje,ct to rent ®ntror . mid toreview llie. appraisal.of Jolm N~t, Mt\l,Jbal w~s s11bll\llt!Xbvitb die appliea:tfon for uenf increase.•·.·· . ' • • • • • • • • • • • ... J,
It.iii II))' \IJW.•!Sll!~.~~ \harthe•i)P,Prnisl).!. ~porl will !Je .. utjlize<l ·i\). a• he.Rf ins. of \he Mobile· l;loine ~e11f ~vie~,Con1missi<1n Qf tb.eCity of $;111,Mareos, Discussions ofmy. Pnal)'sis ns well os.my Jlru\l «>t\~l\lsli>ns .are it)~lajed in I)~ atl!!Ched 1'.ejlOft. • ··1~•~ }Jiproi.$!lI'6Qnf<1m*to .. ,heQ ,.1!fot1t1 'SWn<~d$· i)f. ]>T(ljJ;~~i.o.nitl Apprttisjil fractice ((!SPA~) l!(loptaj !>~)he Ap~lsal • Stan(lard s Board,of tlw Appritis,,I Po.\lhd~tiori ... 111 · (tdt;1itio11, tb~ ·wnOcn report hllli ~M ptepMld ilS 8. $"1lllll/)/11')' f(:jl(lri JI) i.\C<)Otdnncc • with Sl«ndards Rule :2·?(b)r and iltl Aj)prqis11/ • Revleiv fa.• accor.d.aoc~ witli; $tailM.rd$ R1lle 3, • ~dop1ed. by JIM.\· Awnusal. Standards ~iJ;
.'fliil • QJ)J)Nisal . lf subje~t • tQ certain assun1ptions alld lii11itin; ~onditki.ns # set fo/(11 in .1119 a.ttMb(xl fejlOrt,
Rlispe~ttµllf ~#bt.iiitted,
ANDERSON & BRABANT,JNC.
TR 00022
Springdale Estates Tenants' Response 03/17/2026
(EXHIBIT Sb)
S\IMMAltV Ol' C'l)MPi\ftA,Q.l.E lllttitf Al.",
···-,.,,._ c,_.." '-lNilnd
-~·
y-
l~~!~:J l
M>Wlly A,i,. 1,1-Jtlf]
-
l.,s,: ...... ,,_. ... - ... ..
I
'
'
•
'
'
,._ ,. ... • •• :,-~, ... , ....... Wfitit$ ,_ ('tndiwl lu1nlilb\'i)tfltijllt ... ' ., ,,.
·-·
,. Jci,ul
···-· ··--" .. ·~ ""'"""fl't"-..._la,) .... l'JO?f.,;i,,!Ja,.•f,A,&t. 1.11 (l:u.n-illll/j (i,:)..J muntlth!Ahual,h.1:1.ty S.."'-"'•
-111(f.1lbn.Mnt.-lll llfJ~ }3.!14 140:il'A, ,._.,).9}1 Jt01 ,.,_.,.,., ,u, AIU.i,i .... :11Uh1N0,.fk>t,. ~ .... YH tlhnull<)ltl .\91 .... .... "llftkh!IN"'"ta,"'~' "'"' . T ••• -, •,••• , ..... Ill
''""
1.-.10
"'"""
$.~U-4i0 im
-
$411
~ .... 'l,~~ .... -.illffl,
.~W\al~.,,
"'" .,,., ka<t;J.~J~ll\d ......
S.Mm$:t,Ujlb.ru,tL'l!i!
"" ,_ n.:11 ... ,,,. $llli--:'f,ll
"" , ... "" ~ '"'
':t,Uuu,. pqA ipo,. i:uUUJ.,
u~nlffl1n1~ 'VJ.1 1,'UM11t) 0,, .. .1 (Od;~l~!~<P"-•lo:>•~ ..-v~lk ,n IWfhJ l.l.,ti JI)~ J't!S--01
'"' "°' ... ...:::. .... ~-~~~1f ...
tl!l,1~~
'" .... , L•.u1•t• -.,)~ itulf(l,f;1.Wd, wr.rui~ l:nW.-h.il,l" ...,._ IVll!fii~M Ul
'"''
I\PI l!l~°'4 fl:~~>ff! J10~ ..... ""'
Aa.,A,fll !,.~
l,;,.i...,_~P" .. fl_.-'W"-
L" !~ lb,• Dm,; ,., (1¥-b711W-)
"""
•~,~-~ll8Q.
MaduV~ )II
'"'"'
.,,., .. .,,. $,lll-~
"" .... ... Ail' "'·'
••lfu.~p<Jil,. l'>)..-.tq)I',
l.J;ti .... ~Doi,• .. , ........ "'"
leflQIDJpui,:-,lllml'1 ........
After a oouskleration of the oompamble reutnl data, it is my opinion that the average rental value of spaces at Villa Vista Estates is S440 per month, plus all utilities, as of October I, 2007, This couclusion of rental value is substantially below the current overall average space rent in the park of $546 per 10011th. It is also below the current avemge rent of S505 per month for the 32 spaces where an increase is being requested, lu other words, ott average the spa-ce rents at Villa Vista Estates are already above the average rents at the roost comparable parks itl 8an Mat'l,10$. Therefore, when you look 111 the requei,ted inc1-ease in light of the current 11verage rent in the park, and the rents at comparable patlcs in San Marcos, in my opinion a rent incl'ea.~e is 110t warrauted.
TR 00023
Springdale Estates Tenants' Response 03/17/2026
Deoember 17, 2009
ANDER.SON & llR.AfiANT, INC.
JUAl. E$To\TC AP'PP:AISJUtS ,mo 1!0fo'l{.<LTANU,
353 W. IHNTH AYENIJE
E9t::ONOl-OO, CA i202S~S0S2
THEPHGNE (760) 741 .. U4$
FAX (7EIO) Hi-10-49
Mobilehome Rent Review Com1niss.io11
City of San Marcos
l Civlo Center Drive
Sau M.-i"COs, Clllifornia 92069
Dear COmmiss.iou Members:
(EXHIBIT Sc)
AF, requested, I have completed a rental analysis of Villa Vista Estates, an 85 space mobile home park kx:ated 2907 S. Santa Fe Avenue, San Marcos, California. The objective of the analysis was o form &11 opinion of the current rental value of spaces in the park tlll!t are subject to rent control and to review Ute Declaratinn of Jobn Neet, MAI, that was submitted with the application for a rent increase.
It Is my understanding that the appraisal repoit will be utilized in a hearing of the Mobile Home Rent Review Cornnussio11 of the City of San Marcos. Dl$Cll$sions of my analysis as well as my final conohtsions are included in U1e alta\lhed report.
This appraisal conforms to the Uniform Standatds of Professional Appraisal Practi.;e (lJSPAP) adopted by the Appraisal Standards Board of the Appraisal Foundation. In addition, the written report has been prepared as 11.iimmary report in accordance with Standards Rule Z.2(b), and 1111 Appr(l./$a/ R(!Vfew in acoordallC<l with Standards Rule 3, adopted by the Appraisal Standards Board.
111e appraisal is subject 10 certain assumptions and limiting conditions as set forth in the nnaohed report,
Respectfully submitted,
ANDERSON & BRA.BANT, INC.
•.·.·•~ •• /~
~~bant, MAI
Certified General Re&I Estate Appraiser
OREA Appraiser No, AG002l00
TR 00024
0, ..
... .. ;
I
'
]
'
I
•
Springdale Estates Tenants' Response 03/17/2026
(EXHIBIT Sd)
J ..
~ A!li!,-Wndlt, ,..,_, ,.,~..:., V• r:;f.Aba-'I MNfft A~M.ltditt ....... Jt~A,j., .. .... - A,~j-. ... o.:...--=• ~""Rm ..::-,m ld,o.~I ,_ 1 (J)uJD>• Ao'l~mutufi filliliV"~ .....
" ''"
l!l.',1,t
·-
SU,1-'11} NIA ... ~ NIA -"'A;,, Ay ~~ u,;,e,,011...._ ~ ~~~•l),,,"'"l'°A~ n, "~'
l>)~·~~Jtli, .. 1,i,j..,
61!¢fo)~W.,._
'"
1'11111 2f.'1'4
·-
$49>,6.jl 1,.U! W.lil!oll!, ..,,.,>a; Uti Ai.A;,, Ay ~~.P-»"-~"PI'- llJJl~121I;~
"'' -,,.. ~~.<!) .. ..-.-. ... ,
-
Ill
"""'
IUl
·-
JJttUffi $411
"'"'
Hn
. .:.:.,
Ay Uh'HM/>\pt»I, ibltl:kad,
IJ)WqiDliiit~ m
""''
kolJJ.bl'l!M3ltNrWdl .. ..,,.
Wlh,hu).\<_.....I...,...
"'
lt~
""' "'""
$l1Mll) $4Jt , ... "" . .:.:.. •.; aamu1llJi£,,pri_>I,..,_~ 114$ Oilfifffll""" J.111 O:lfM·,.) ,.,., ~1'8)fW,iu,J,:,,l\ll\<, ••--w-<1 .. -· •u.t- ,_V-.1,: µ, .. , .. li,4t
·-
UW.4ll
"'' "'~ "" a..:!!ru ... ....>u1ot,,11<»l,.~lp .. ,
Ulll4~"'1~ m 0,..,,1 ,,.....,.""'IQiil~. : .... ,..
.............. 1<1 l'IH N~H
"""'
HD-dfi)
"" "'~ .... -
A'I/ ~~,... ....... ~'I"',
L~ l•t11-.hfto lill
"""
\a ....... tlr,i,ua4 fll~
w-• ..•
..... v ... ~·
1'11~ ..... , ..... U»-41' $HO ~ ... J:t!O .;.r.,, 0,.,11 ;t,lib!-.pw\~--.1-. .. .i,ii$ •••I" Y• l:w. .. , ""'
le1Q.wJ11,:-.:--. .... t}'
......
After a consideration of the comparable rental data, it is my opinion that the average rental value of spaces at Villa Vista Estates is $475 per month, plus all utilities, as of December 15, 2009. This conclusion of rental value is substantially below the current average space rent of $560 for the 44 spaces in the park that are the subject of this hearing. In other words, on average the space rents at Villa Vista Estates are already above the average rents at the most comparable parks in San Marcos. Therefore, when you look at the requested increase in light of the current average rent in the park, and the rents at comparable parks in San Marcos, in my opinion a rent increase is not warranted.
TR 00025
Springdale Estates Tenants' Response 03/17/2026
(excerpt from Dr. Kenneth Baar report for City of Montclair) X
Preliminary Report
Under the definition of ~windfall• set forth in a classic work on land use regulation, Wjpdfalls for Wipeouts: Land Value Capture & Comoensation. both park owners and mobilehome owners are receiving types of windfalls. In that work, •windfall" ~s defined as " ... any increase in the value of real estate-other than that caused by the-owner--or by general inflation."" In the cases . of both mobilehcme ownership in parks and mobilehome park ownership. increases in value are caused by soarcity propelled by land use restrictions.
2. The hnpacts of Vacancy Decontrol on Mobilehome Values It is a common rule of thumb that each $100 iIK:rease in mobilehome space rent reduces the value of the mobilehome by $10,000. Such an estimate is consistent with the concept rhat for _each $10,000 in purchase costs, the monthJy carrying costs are increased by roughly SIOO. In cases where exceptional rent iD::reasc3 have been iNtituted upon vacancies, rnobilehomes have ~ome nearly wonhless.
3. Trends In l\fobilehome and MobOohome l'lltk Valuf5 Compared fo fact, while average mobilehome values are about the same as their original costs plus installation costs, park values are several hundred percent above lhe original costs of the land and construction associated with creating the parks.
Reports and surveys indicate that average park costs were about $6,000 per pad in the decades when most parks were constructed, the 1970's or earlier. A 1974 repOrt by the We.stem Mobilehome Association projected that the total cost of onsite improveme:ntS averages $2,600 to $4,(X)() per lot, exclusive of land. •11lis includes instalfarion of all underground utilities, utility services, sewers and sewer connections, landscaping, paving of parking areas and streets, and con.struction of services, swimming pools. and recreation buildings."" The report projected land costs in the range of $5,000 IO $25,000 per acre, with pennitted densities of 8 l/2 sp,ces per acre. This translates into land costs of $600 to $3,000 per space. A 1984 stUdy by the City of Los Angeles found that park owncn paid about $6,000 per mobilehome pad and that they estimated that the current value of their parks was $18,000 per pad/• 2Z Hagnwi,Donafd & M&eynski, Wlpdfalls for Wipg,uts: Land Val)u; CWU1re and Compmution 15 (1978),
1J Western Mobilehomt Association, Mobilchome Parle DevelQQ'D\"nt p.4 (1971-74 p:!jtjon) U City of Los Angeles Rent Slabiliz.ation Division, Rental Homing Slydy Mqbjfebqmc Paa-ks Under Rent Stabiliz.arion, p.33 (1985).
(EXHIBIT 6)
TR 00026