AGENDA REPORT
DATE:
TO:
FROM: Jennifer Crawford, Interim City Manager/Rent Administrator Don Lincoln, Special Legal Counsel
Item No. 1
June 9, 2025
Honorable Mayor and City Council
SUBJECT: Biennial Review of Mobilehome Rent Stabilization Ordinance and Resolution RECOMMENDATION:
That the City Council:
1. Conduct a Biennial Review of the Mobilehome Rent Stabilization Ordinance (Yucaipa Municipal Code Chapter 15.20) and the Administrative Rules, and direct staff as appropriate; and
2. Direct staff to prepare the appropriate documents and return to City Council for approval.
BACKGROUND/DISCUSSION:
The Mobilehome Rent Stabilization Ordinance ("Ordinance") requires that the City carry out a Biennial Review (BR) of the Ordinance during odd -numbered years (YMC § 15.20.140). The last BR was completed in 2022.
On December 4, 2024, staff notified various stakeholders of the upcoming BR and requested that they submit written comments regarding the Ordinance and/or Administrative Rules ("Rules"), by January 30, 2025, at 5:00 p.m. In addition, the notice was advertised in the News Mirror on December 5, 2024 and reminder emails were sent to the various stakeholders on December 2, 2024, January 6th and 28th, 2025. Staff received comments from the following stakeholders:
• Matthew Alex, CEO-Dunex, Inc. — Management Company for Knollwood Mobile Estates (Attachment A)
• Robert Evans, Inland Empire Representative for Manufactured Housing Educational Trust (MHET) (Attachment B)
• Julie Paule, Regional Representative for Western Manufactured Housing Communities Association (WMA) (Attachment C)
• Jordan Conway-Pursglove — representing &/or owner of Bel Aire Mobile Estates, LLC (Attachment D)
• David Devin, Recording Secretary for Yucaipa Mobilehome Residents Association (YMRA) (Attachment E)
• Ian Dyer - owner of Hideaway and Yucaipa Valley Mobilehome Parks (Attachment F) Since the completion of the 2022 BR, parks have implemented the annual adjustments each year, based on the lesser of either 4% of the current space rent or 100% of the increase in CPI during the proceeding twelve months (YMC § 15.20.080).
Year
100%
CAP
Authorized increase
2023
7.49%
4%
4%
2024
4.28%
4%
4%
2025
1.13%
4%
1.13%
A 2025 summary showing high, low, and average rents in each park is attached to this Staff Report as (Exhibit I).
The intent of the BR is to address issues that have arisen since the last BR that are based on legal considerations, clarification to provisions and procedures, political and policy issues, and other issues raised by staff and various stakeholders, and to identify potential amendments to the Ordinance or Rules based on those issues.
With Council direction staff will revise appropriate code sections and administrative rules and return to Council for adoption.
To assist the Council's review and consideration of the issues, this Staff Report contains a summary of the proposed revisions submitted by the stakeholders, as well as staff recommendations, along with recommendations for Ordinance and Rules amendments and requests for direction from the City Council, where appropriate. In addition, back-up materials, written comments submitted by the stakeholders are enclosed as Attachments and Exhibits.
1. SUBJECT: ANNUAL ADJUSTMENTS (Issue raised by stakeholders) The Ordinance authorizes park owners to raise their space rents each year, pursuant to the Annual Adjustment process set forth in YMC § 15.20.080 and Rules, Chapter 3. The Annual Adjustment is calculated based on 100% of the CPI or 4% of current space rent, whichever is less (YMC §15.20.080; Rules, §§3.0001 and 3.0001(B)). During this BR, some park owners have requested that the City amend the Ordinance to review the rent cap percentage and consider implementing a minimum cap if the maximum cap is retained.
Staff Comments: The Annual Adjustment process allows park owners to obtain a rent increase once each year based on 100% of the increase in the Consumer Price Index (CPI) as published by the Bureau of Labor Statistics for the preceding twelve months. This adjustment, which increased from 80% to 100% of the CPI under the 2022 BR, is capped at 4% of the current base space rent. The cap was previously reduced from 5% to 4% as part of the 2017 BR. The process ensures that the park owners receive an annual increase based on inflation to cover increased costs and provide a profit. The 4% cap serves to mitigate the impact of large annual increases occurring as a result of substantial increases in inflation. The purpose of the Annual Adjustment process is to provide a relatively simple, expedited process that enables park owners to obtain rent increases without having to go through a formal noticed public hearing by means of the Special Rent Adjustment process.
The following chart shows the CPI increases between 2023 and 2025 determined under the current Ordinance:
2023
2024
2025
CPI (100%)
7.49%
4.28%
1.13%
Amount authorized by City based on 4% Cap
4%
4%
1.13%
Some Stakeholders have proposed removal of the 4% CPI cap, arguing that it restricts the extent to which the park owner can benefit from the full increase in the CPI. Others have requested that if the maximum cap is retained then it is fair and reasonable to include a minimum floor of 2% or 3%.
Thus, from a park owner's standpoint, even if the Ordinance is amended to allow 100% CPI to determine the Annual Adjustments, a cap will still preclude the park owner from increasing rents consistent with the full rate of inflation.
The following are options that the Council may wish to consider:
Option #1: Amend YMC § 15.20.080(A) and Rules §3.0001(B)(3), to provide that the park owner may increase the rent in each regulated space once annually, by 100% of the increase in CPI, or by 6% cap of the current space rent, whichever is less and include a minimum percentage increase of 2% or 3% (Options proposed by some stakeholders).
Option #2:
Amend YMC § 15.20.080(A) and Rules §3.0001(B)(3), to provide that the park owner may increase the rent in each regulated space once annually, by 100% of the increase in CPI and eliminate the 4% cap (Option proposed by some stakeholders).
Option #3: Amend YMC § 15.20.080(A) and Rules §3.0001(B)(3), to provide that the park owner may increase the rent in each regulated space once annually, by 100% of the increase in CPI, or by 5% cap of the current space rent, whichever is less and include a minimum percentage increase of 2%. (Option recommended by staff).
Option #4: Retain the existing language of the Ordinance and Rules without change — maintain 100% CPI and 4% cap.
Option #5: Other possibilities, as may be suggested by City Council
STAKEHOLDER STAKEHOLDER COMMENTS
MHET (Att. B)
WMA (Att. C)
Requests that the Ordinance and Rules be amended to include a minimum 2% floor and maximum 6% cap to eliminate the
unanticipated volatile peaks and valleys and may lead to less MNOI adjustments in the future.
Requests that the Ordinance and Rules be amended to include a minimum 2% floor and maximum 6% cap that would allow park owners the ability to maintain and improve their communities and provide residents and owners predictable increases that allows both stakeholders to keep up with inflation.
Conway (Att. D)
Dyer (Att. F)
Requests that the Ordinance and Rules be amended to allow for a 3% minimum to address low inflation rates and allow park owners the ability to recapture the difference when the CPI is capped at 4%.
Requests that the Ordinance and Rules be amended to eliminate the 4% cap so parks can be maintained.
Staff Recommendation to the City Council
That the City Council approve option #3 - Amend YMC §15.20.080(A) and Rules §3.0001(B)(3), to provide that the park owner may increase the rent in each regulated space once annually, by 100% of the increase in CPI, or by 5% cap of the current space rent, whichever is less and include a minimum percentage increase of 2%.
2. SUBJECT: RENT ADJUSTMENTS UPON VACANCY (Issue raised by stakeholders) The purpose of the City's vacancy control provisions is to protect the investment by mobilehome owners in their homes, given the unequal bargaining position of residents, immobility of mobilehomes, and imposition of excessive rents.
As part of the 2020 BR, City Council approved for the first time in Yucaipa's rent control history the amendment to the Ordinance and Rules to redefine "vacancy" by establishing new vacancy categories, and to allow specified types of rent increases resulting from certain types of vacancies.
Currently, the Ordinance allows a rent increase upon any vacancy resulting when:
• The space becomes vacant because the resident voluntarily removed the mobilehome and moved out of the park; or
• The space becomes vacant because the mobilehome is destroyed by fire or other natural catastrophe and the resident moved out of the park; or
• The mobilehome is abandoned in -place by the resident and the park owner obtains title through the courts; or
• The vacant pad or lot has been empty for more than five consecutive years.
For these vacancy categories, when a new resident moves his/her own mobilehome onto the vacant space or purchases an abandoned in -place mobilehome from the park owner, the park owner may increase the last rent in effect on the space prior to vacancy based on the combined average of rent - controlled spaces in the park plus ten (10) percent.
The Ordinance continues to prohibit rent increases when vacancies result from a change in occupancy of a mobilehome on a space; when an existing mobilehome is replaced with another mobilehome on the same space and occupied by the same resident; and upon an in -place transfer where a mobilehome and/or existing resident remains in the park. An "in -place transfer" is defined to mean a vacancy that results: (i) when the home is replaced by the same tenant or resident for any
reason (such as age, fire, substantial destruction, or replacement with a new mobile home); (ii) from transfers of ownership of the mobile home by inheritance or other transfers to relatives, heirs, personal representatives of the estate, and successors in interest; (iii) any other voluntary or involuntary transfer of ownership of the mobilehome by the resident to a creditor; or (iv) any other voluntary or involuntary transfer of a mobilehome by the resident to the park owner as the result of an eviction or other termination of tenancy; but excluding an "abandoned -in -place" mobilehome.
For these types of vacancies, the last rent in effect prior to the vacancy is the base rent for that month - to -month resident. This means that no rent increase may be imposed for any such vacancy.
During this 2025 BR process, some stakeholders proposed that the City revise the Ordinance regulating vacancies, to allow rents to increase to market rent -- or full vacancy decontrol — upon the occurrence of an "in -place transfer," or the park has a vacant pad or lot, or the park sells a park owned coach to a new resident.
Staff Comments: As described above, in 2020 the Ordinance was amended to allow limited rent adjustments upon certain types of "vacancy." However, as in prior biennial reviews, and in this current review, some stakeholders have again proposed that the City amend the Ordinance to allow rents to increase to market rent levels if a new resident moves into the park, or the park has a vacant pad or lot, or the park sells a park owned coach to a new resident. In making this proposal, the stakeholders have not identified any method that they would use to determine market rent, and their proposal does not include any cap on such vacancy increase, allowing unlimited rent increases upon vacancies. YMRA and the park residents have consistently been opposed to vacancy decontrol. The purpose of the City's vacancy control provision, especially as it pertains to "in -place transfer" (defined above) is to protect the investment by Mobilehome owners in their homes, given the unequal bargaining position of residents, imposition of exorbitant rents, and the immobility of mobilehomes.
The following are options that the Council may wish to consider based on stakeholder comments with respect to vacancy adjustments:
Option #1: Amend YMC §15.20.050(A) and Rules §3.0001 to allow the park owner to increase rents to market rent upon a vacancy resulting from an in -place transfer (as defined), on a vacant pad or lot, or the sale of a park owned coach; but retain all other existing Ordinance language including the requirement that upon re -occupancy, the space is placed immediately back under rent control and only subject to the permissible annual adjustments or approved special rent adjustments.
Option #2:
Amend YMC §15.20.050(A) and Rules §3.0001 to allow the park owner to increase rent to market rent upon a vacancy resulting from an in -place transfer (as defined), on a vacant pad or lot, or the sale of a park owned coach; include specified limitations on the increase amount and number of times the same space may increase due to vacancy; but retain all other existing Ordinance language including the requirement that upon re -occupancy, the space is placed immediately back under rent control and only subject to the permissible annual adjustments or approved special rent adjustments.
Option #3: Amend YMC §15.20.050(B) to allow the park owner to increase rents for vacancy categories as defined in §15.20.020, subsection (1), (2), (3), or (8), based on the combined average of rent -controlled space in the park plus twenty (20) percent. This option currently exists in the Ordinance; however, it adjusts the current percentage increase from 10% to 20%. This option continues to impact only new residents moving into the park — existing residents are not impacted by this option. (Option recommended by staff)
Option #4: Retain all existing language of YMC §15.20.050(A) and the Rules without change.
STAKEHOLDER STAKEHOLDER COMMENTS
Alex (Att. A)
MHET (Att. B)
Dyer (Att. F)
Requests that the Ordinance and Rules be amended to consider some measure of vacancy decontrol to address elevated expenses and ongoing challenges of maintaining park infrastructure.
Requests that the Ordinance and Rules be amended to allow for full vacancy decontrol as a means of both encouraging park rehabilitation and long-term rent stability for all residents.
Requests that the Ordinance and Rules be amended to allow full vacancy decontrol for vacant spaces and park -owned coaches giving the park owner incentive to invest in improvements to the park and installing newer homes, which improves home values for all residents and makes the park nicer.
Staff Recommendation to the City Council
That the City Council approve option #3 - Amend YMC §15.20.050(B) to allow the park owner to increase rents for vacancy categories as defined in §15.20.020, subception (1), (2), (3), or (8), based on the combined average of rent -controlled space in the park plus twenty (20) percent.
3. SUBJECT: PRE -APPROVAL / AUTOMATIC PASS THROUGH OF CAPITAL IMPROVEMENT COSTS (Issue raised by stakeholders)
The Ordinance contains comprehensive provisions addressing when park owners may obtain approval of a rent adjustment based on a capital improvement. Pursuant to YMC § 15.20.085 and the Administrative Rules, Chapter 5, a park owner may obtain approval of a Capital Improvement Rent Adjustment if the project meets the definition of a "capital improvement," including that prior to completion of the Capital Improvement, at least 51 % of the regulated spaces consented to the Capital Improvement Rent Adjustment pursuant to a confidential ballot conducted after holding a resident meeting; or alternatively, if no resident election is held or the park owner does not obtain at least 51% consent, the park owner demonstrates that the Capital Improvement is necessary for the health and safety of the park, its residents, or its neighbors. In order to obtain approval of a Capital
Improvement Rent Adjustment, the park owner must submit an application to the Rent Administrator for approval and demonstrate that the work qualifies as a capital improvement and that the necessary 51% resident consent was obtained before carrying out the capital improvement, or the capital improvement was necessary for health and safety. The Rent Administrator's decision may be appealed to the Hearing Officer by the park owner or park residents.
The Ordinance also allows a park owner to apply for approval of an emergency capital improvement, under YMC § 15.20.085. If the park suffers damage due to an unforeseen event (fire, earthquake, water main break, flooding, etc.) and there is no time to conduct the resident meeting and vote because the capital improvement must be carried out immediately to prevent or correct an imminent threat to the health and safety of the park, the residents, or its neighbors, a park owner may also apply for approval of a Capital Improvement Rent Adjustment without conducting the resident meeting or obtaining 51 % consent of the residents. In this situation, the Ordinance imposes certain time and procedural requirements on a park owner who contends the Capital Improvement qualifies as an emergency capital improvement.
Any Capital Improvement Rent Adjustment granted by the City may not be included as part of the monthly space rent but must be itemized as a separate charge on the residents' monthly rent statement and may only be charged for the useful life of the capital improvement, as determined by the City. In order to prevent the costs of a capital improvement from being incorporated into permanent rent increases, under YMC § 15.20.085(D), costs incurred for capital improvements or emergency capital improvements cannot be included as operating expenses in an application for an MNOI rent adjustment or a rent adjustment based on a readjusted 1987 NOI. If a park owner includes expenses for capital improvements or emergency capital improvements in any such special rent adjustment application, the Ordinance requires that those expenses will be processed and heard by the City as a separate capital improvement rent adjustment application.
The capital improvement adjustment procedures outlined in the Ordinance and Rules ensures that residents of regulated spaces are informed about the proposed project, costs associated with the improvements and have input on whether they agree and are willing to pay for the improvements before the improvement is carried out in the park. If the residents are not in favor and the improvement does not qualify for health and safety, the park owner can decide to proceed or not with the improvement at their own expense. The emergency capital improvement procedures also reflect that the City recognizes in cases involving emergencies, the requirement for prior resident input or approval should not be required in order to allow a park owner to prevent imminent harm due to park damage resulting from fire and other unanticipated natural events.
Approval of the pre -approval or automatic pass -through modifications suggested by some Stakeholders would negate the procedures in place that involve resident input and consideration. It also appears that some of the Stakeholders have misinterpreted the Ordinance and Rules and as it relates to capital improvements based on health and safety. Some of the Stakeholders are under the impression that the Rent Administrator can only approve a health and safety capital improvement only after the improvement is made. This interpretation is not correct; however, YMC §15.20.085(A)(1) should be amended to clarify the process.
STAKEHOLDER STAKEHOLDER COMMENTS
MHET (Att. B)
WMA (Att. C)
Requests that the Ordinance and Rules be amended to allow the pre - approval of capital improvement expenses, to streamline process and reduce administrative burdens.
Requests that the Ordinance and Rules be amended to allow a park owner to petition the rent administrator to approve a bid for a capital replacement at the "end of its useful life" before the park owner lays out the costs of the project.
Staff Recommendation to the City Council
That the City Council Amend YMC §15.20.085(A)(1) as follows:
An application for a rent increase based on the cost of a completed capital improvement may be filed with the rent administrator. It shall be approved if it satisfies the definition of capital improvement set forth in Section 15.20.020 and the criteria set forth in the capital improvement guidelines and as set forth in the administrative rules adopted by resolution of the city council; the park owner has provided documentation to demonstrated that prior to the completion of the proposed capital improvement, the park owner met with the park residents and considered input from the park residents regarding any proposed capital improvement; the park owner held a capital improvement ballot election.....
4. SUBJECT: SELECTION OF RESIDENT REPRESENTATIVE (Issue raised by stakeholder) Section 15.20.060 of the Ordinance requires the residents of each mobilehome park in the city to elect by majority vote, with one vote per regulated space, a resident representative to receive all notices required by the Ordinance. The elected representative shall continue to serve as park resident representative until his or her resignation or the subsequent election of another resident by the park residents. The residents shall advise the rent administrator of the name, address and phone number of the elected resident representative in writing no later than January 31 st of each year and shall promptly notify the rent administrator of any change of representative. If a resident representative or point of contact is not established, all notices required by this chapter shall be posted in the clubhouse, park office and one other location accessible to the residents.
Of the 41 mobilehome parks regulated by the Ordinance, only 5 parks have a resident representative.
The following are options that the Council may wish to consider based on stakeholder comments with respect to resident representative:
Option #1: Amend the Ordinance to change the majority vote requirement to 10 or 10% of the regulated spaces, whichever is less. (Option proposed by stakeholder)
Option #2:
Amend the Ordinance to adjust the majority vote requirement to 10 or 10% of the regulated spaces, whichever is less. If multiple residents express interest in serving as the resident representative, a ballot election shall be held, with one vote per regulated space, and the winner determined by a by majority vote. (Option recommended by staff)
Option #3: Retain the existing language of the Ordinance pertaining to the selection of the resident representative.
STAKEHOLDER STAKEHOLDER COMMENTS
YMRA (Att. E)
Requests that the Ordinance be amended to change the number of votes needed per park to 10 or 10% of the spaces under rent control, whichever is less. Concerns have been raised regarding the lack of interest to serve and the majority requirement is time-consuming and difficult for those who have mobility issues.
Staff Recommendation to the City Council
That the City Council approve option #2 - Amend YMC §15.20.060 to adjust the majority vote requirement to 10 or 10% of the regulated spaces, whichever is less. If multiple residents express interest in serving as the resident representative, a ballot election shall be held, with one vote per regulated space, and the winner determined by a majority vote.
5. SUBJECT: PROPERTY TAX PASS THRU UPON SALE OF PARK (Issue raised by stakeholders)
In determining whether a park is entitled to an MNOI/Readjusted Base Year NOI under YMC §15.20.100(A) or (B), the park owner's net operating income (NOI) must be determined for the base year (1987) or since its last special adjustment and the current year. The procedure to make this determination is set out in Rules §4.0003. Under the Rules, a park's NOI is determined by subtracting the park's operating expenses from the park's gross income for the relevant year. The park's operating expenses include real property taxes and assessments. (Rules, §4.0003(D)(3)(a).) Staff Comments: Under the Ordinance and Rules, any property taxes paid by the park owner in the base year will be deducted from the park's base year gross income to determine base year NOI; and any property taxes paid in the current year will be deducted from the park's current year gross income to determine current year NOI. Depending on the park, a substantial increase in property taxes since the base year may affect whether the park owner is able to demonstrate justification to receive approval of an MNOI/Readjusted Base Year NOI rent adjustment. The current Ordinance and Rules allow consideration of any increase in property taxes between those two time periods.
The following are options that the Council may wish to consider based on stakeholder comments with respect to property tax pass thru upon sale of park:
Option #1:
Option #2:
Option #3:
Amend the Ordinance and Rules to allow the park owner to phase in property tax increases over two years. (Option proposed by stakeholder).
Amend the Ordinance and Rules to allow park owners the ability to pass through the tax increase without the need for a full Special Rent Adjustment MNOI increase application. (Option proposed by stakeholder).
Retain the existing language of the Ordinance and Rules relating to treatment of property taxes as operating expenses under YMC § § 15.20.100(A) or (B) or the Rules, §§4.0003 or 4.0004. (Option recommended by staff).
STAKEHOLDER STAKEHOLDER COMMENTS
MHET (Att. B)
Requests that the Ordinance and Rules be amended to address property tax increases in a way that is fair and reasonable to park residents.
Staff Recommendation to the City Council
That the City Council approve option #3 - Retain existing language of the Ordinance or Rules relating to treatment of property taxes as operating expenses under YMC § § 15.20.100(A) or (B) or the Rules, §§4.0003 or 4.0004.
6. SUBJECT: INSURANCE INCREASE PASS THRU (Issue raised by stakeholders) Stakeholders have highlighted that securing insurance in California has recently become increasingly challenging, with costs rising sharply. They suggested an easy pass thru process allowing park owners to request a separate special rent increase to address the surge in property insurance costs which could help avoid the need for an MNOI application and the expenses associated with such applications and hearing procedures.
In determining whether a park is entitled to an MNOUReadjusted Base Year NOI under YMC § 15.20.100(A) or (B), the park owner's net operating income (NOI) must be determined for the base year (1987) or since the last special adjustment and the current year. The procedure to make this determination is set out in Rules §4.0003. Under the Rules, a park's NOI is determined by subtracting the park's operating expenses from the park's gross income for the relevant year. The park's operating expenses include insurance premiums. (Rules, §4.0003(D)(3)(j).) Staff Comments: Under the Ordinance and Rules, any insurance premiums paid by the park owner in the base year will be deducted from the park's base year gross income to determine base year NOI; and any insurance premiums paid in the current year will be deducted from the park's current year gross income to determine current year NOI. Depending on the park, a substantial increase in insurance premiums since the base year may affect whether the park owner is able to demonstrate
justification to receive approval of an MNOI/Readjusted Base Year NOI rent adjustment. The current Ordinance and Rules allow consideration of any increase in insurance premiums between those two time periods.
The following are options that the Council may wish to consider based on stakeholder comments with respect to insurance premiums pass thru:
Option #1:
Amend the Ordinance and Rules to allow park owners the ability to pass through the insurance premium increase without the need for a full Special Rent Adjustment MNOI increase application. (Option proposed by stakeholder).
Option #2: Retain the existing language of the Ordinance and Rules relating to treatment of insurance premiums as operating expenses under YMC § § 15.20.100(A) or (B) or the Rules, §§4.0003 or 4.0004. (Option recommended by staff).
STAKEHOLDER STAKEHOLDER COMMENTS
MHET (Att. B)
Conway (Att. D)
Requests that the Ordinance and Rules be amended to provide for a separate special rent increase to address the surge in property insurance costs.
Requests that the Ordinance and Rules be amended to provide an easy process to allow a separate line -item expense on space rent invoices for the park's insurance premiums.
Staff Recommendation to the City Council
That the City Council approve option #2 - Retain existing language of the Ordinance or Rules relating to treatment of insurance premiums as operating expenses under YMC § § 15.20.100(A) or (B) or the Rules, §§4.0003 or 4.0004.
7. SUBJECT: ANNUAL REGISTRATION FEE (Issue raised by stakeholder) Pursuant to YMC Chapter §15.20.073(E) and Rules 2.0007 the intent of the annual registration fee is to cover the costs of administering the Mobilehome Park Rent Stabilization Program (Program).
Since 2004 the costs associated with this Program have increased due to special rent adjustment applications and appeals, on -going litigation based on the findings of these applications and changes in personnel costs.
Based on these factors, and to ensure that the Program remains financially self-sufficient, City Council approved an overall funding model that addresses the funding for any accumulated deficit/surplus and the ongoing costs associated with the administration of the Program. This fee is reviewed by the City Council each fall, implemented every January, with residents in the Program
covering 50% of the fee and the park owners covering the remaining 50%.
The following are options that the Council may wish to consider based on stakeholder comments with respect to the Annual Registration Fee:
Option #1: Amend the Ordinance and Rules to allow park owners the ability to pass through 100% of the Annual Registration Fee to residents under the rent control program. (Option proposed by stakeholder).
Option #2: Retain the existing language of the Ordinance and Rules relating to the Annual Registration Fee under YMC §15.20.073(E) and Rules 2.0007. (Option recommended by staff.
STAKEHOLDER STAKEHOLDER COMMENTS
Conway (Att. D)
Requests that the Ordinance and Rules be amended to have the residents under rent control cover 100% of the Program fee since the Ordinance is written to benefit the residents and the city.
Staff Recommendation to the City Council
That the City Council approve option #2 - Retain the existing language of the Ordinance and Rules pertaining to the Annual Registration Fee.
S. SUBJECT: STAFF RECOMMENDED AMENDMENTS TO THE ORDINANCE AND
RULES TO PROVIDE CONFORMITY WITH STATE LAW AND CLARIFICATION A.
Document:
Ordinance Section 15.20.010 — Purpose & Findings
Issue:
Section needs to be updated to reflect Council approved amendments pertaining to the implementation of a Hearing Officer
Recommendation:
Add a new Section W to read as follows:
W. On April 10, 2023, at a noticed public meeting, the city council approved amendments to Chapter 15.20 of the YMC and the Administrative Rules pertaining to the implementation of a Hearing Officer in place of the Mobilehome Rent Review Commission and the elimination of the appeal process, and thereafter enacted Ordinance No. 422.
B.
Document:
Ordinance Section 15.20.020 - Definitions
Issue:
Currently there is no provision which identifies which CPI should be used for the purpose of calculating special rent adjustments for each of the years 1987 through 2017.
Recommendation:
Under the definition of "Consumer Price Index (CPI) add a new number 4 to read as follows:
4. For the purpose of calculating Special Rent Adjustments for each of the years 1987 through 2017 the "Consumer Price Index" or "CPI" means the CPI index for the Los Angeles -Long Beach -Anaheim Metropolitan Area, All Urban Consumers, published by the Bureau of Labor Statistics, U.S. Department of Labor.
In addition, renumber former number 4 as number 5
C.
Document:
Ordinance Section 15.20.030 - Exemptions
Issue:
Effective January 1, 2023, California Civil Code sections 798.7(a) and 798.45(a) were amended by Cal. Stats 2022, Ch. 666 (SB 940) to redefine what constituted "new construction," and to limit the time such spaces would be exempt from local rent regulation.
Recommendation:
Under Section A amend exemption 1 to read as follows:
1. Newly constructed mobilehome spaces first held out for rent on or after January 1, 1990 for a period of 15 years from the date upon which the space is initially held out for rent. A Mobilehome park space shall be considered "initially held out for rent" on the date of issuance of a permit or certificate of occupancy for that space by the enforcement agency in accordance with Section 18551 or 18613 of the California Health and Safety Code. Upon expiration or termination of such exemption under Civil Code Section 798.45(a), that space shall become subject to the rent regulation of this chapter.
D.
Document:
Ordinance Section 15.20.030 - Exemptions
Issue:
Effective January 1, 2023, California Civil Code sections 798.7(b) and 798.45(b) were amended by Cal. Stats 2022, Ch. 666 (SB 940) to redefine what constituted "new mobilehome park construction," and to limit the time such parks would be exempt from local rent regulation.
Recommendation:
Under Section A add a new exemption number 2 to read as follows:
2. New mobilehome park construction, as defined in subdivision (b) of California Civil Code Section 798.7 for a period of 15 years from the date upon which 50 percent of the spaces in the new Mobilehome park are initially held out for rent measured from the date of issuance of a permit or certificate of occupancy for that space by the enforcement agency in accordance with Section 18551 or 18613 of the Health and Safety Code. Upon expiration or termination of such exemption under Civil Code Section 798.45(b), that space shall become subject to the rent regulations of this chapter.
In addition, renumber former number 2 as number 3.
E.
Document:
Ordinance Section 15.20.030(B), 15.20.050, 15.20.050(D),
15.20.073(C) & (D)(1), 15.20.080(B) and Administrative Rules Section 2.0003(A) & (B), 2.0005(A)(6), 3.0001(A)(6), 3.0001(B)(6),
3.0001(D)(3), 3.0001(F), 4.0003(C), 4.0003(H)(6)
Issue:
Clarify additional statutory exemptions from local space regulation Recommendation:
Amend Section 15.20.030(B) to read as follows:
B. The rent regulation provisions of this chapter shall not apply to any that is to lease that
space while space exempt subject a which exempts
spat-c from rent regulation pursuant to the California Mobilehome Residency Law, Civil Code Section 798 et seq. Upon expiration or termination Civil Code Section 798.17, that
of such an exemption under
space shall become subject to the rent regulations of this chapter.
Amend the initial paragraph of Section 15.20.050 to read as follows:
A park owner shall not be permitted to charge a new space rent for a mobilehome space upon vacancy except as expressly provided in this section. It is the intent of the city that no rent increase shall be allowed as a result of a vacancy resulting in a change in occupancy of a mobilehome on a space, the replacement of a mobilehome with another mobilehome on the same space and occupied by the same resident, or any in -place transfer of a mobilehome (as defined in Section 15.20.020 of this code), and that such mobilehome spaces shall continue to be subject to the rent control provisions of this chapter unless such space is exempt from rent regulation pursuant to Section 15.20.030 of this code, subject to a long term lease exempt from rent control pursuant to California Civil Code Section 798.17 is
or a vacancy adjustment
authorized pursuant to subsections B, C, D or E of this section. No vacancy adjustment shall be imposed pursuant to subdivisions B, C, D or E of this section without the park owner's submittal of a complete
application and the prior approval of the RA in accordance with this subdivision and the rules and regulations.
Amend the Section 15.20.050(D) to read as follows:
D. Spaces Previously Exempt. In the event a space which was previously exempt from rent regulation pursuant to Section 15.20.030 of this code no longer remains exempt, under a lease pursuant to California Civil Code Section 798.17, the base space rent, for purposes of calculating the annual adjustment, shall be the rent in effect as of the date of the expiration of the exemption lease, provided that space rents can be verified by information required on, and/or documentation submitted with the annual registration application.
Amend Section 15.20.073(C) to read as follows:
Complete Registration Required. The registration statement shall not be accepted as complete unless it includes all information required on the form by the rent administrator, including but not limited to the last names of homeowners/tenants, rents for all spaces in the park (including but not limited to, month -to -month spaces, spaces subject to leases exempted pursuant to Section 15.20.030 of from this chapter this code under Civil Code Section 798.17, non-exempt leased spaces, spaces occupied by park -owned mobilehomes, spaces occupied by the park manager or other park employees, and rent -to -own spaces), the term of any exempt and non-exempt leases, renewal and/or extension thereof, amount and date of most recent rent increase for each space, all information and documentation that establishes any other exemption from the rent provisions of this chapter, and such other information required by the rules or otherwise deemed necessary by the rent administrator for the implementation and administration of this chapter.
Amend Section 15.20.073(D)(1) to read as follows:
Annual registration fees based on the number of spaces in the mobilehome park to be used for the costs of administering this chapter.
Registration fees shall be paid by each park owner to the city for each space, which is not exempt pursuant to Section 15.20.030(A)(1) and (A)(2) Civil Code Section 798.17 or 15.20.030(A) of this code at the time the initial and annual statements are filed.
Amend Section 15.20.080(B) to read as follows:
If the mobilehome space was previously subject to an exemption pursuant to Section 15.20.030 and such exemption expired, long term lease which exempted the space from rent control under state law, the
rent for such space shall not be increased under this section until twelve months after the most recent rent increase under the previously exempt lease. Thereafter, the rent may be increased once every twelve months in accordance with Subsection (A) of this section.
Amend 2.0003(A) & (B) to read as follows:
2.0003 LEASED SPACES CURRENTLY EXEMPT AND PRIOR
EXEMPT SPACES
A. Exempted Spaces under Civil Code Section 798.17. In
the event a mobilehome park owner believes that his/her park contains any space which is subject to a lease, which exempt that space from rent regulation pursuant to the California Mobilehome Residency Law (Civil Code Section 798, et seq.) or YMC Section 15.20.030, the park owner shall submit information on the registration form setting forth the date the park or space was initially held out for rent, the duration of each lease, current space rents, effective date of most recent rent increase, lease execution dates, lease expiration dates, last names of the homeowners/tenants of each leased space, all other information required by Sections 2.0004 and 2.0005, and any other information determined to be necessary by the RA to demonstrate compliance with an exemption under Civil Code Sections 798 et seq or YMC Section
15.20.030.
In the event that a resident or park owner questions
whether the space is exempt the terms of a long term lease or whether the lease is exempt from the rent regulation provisions of YMC Chapter
15.20, he/she may request that the RA review the terms to determine whether it satisfies the requirements for an exemption from space rent regulation long term lease exemption from rent control.
B. Non Exempt Lcascd Space Prior Exempted Spaces
which are No Longer Exempt. For any space that was previously exempt from rent regulation under YMC Chapter 15.20 but such exemption has expired or terminated based on pursuant to the provisions of Civil Code Section 798 et seq., or YMC Section
15.20.030 as amended by Assembly Bill 2782 (Chapter 35, Statutes of 2020), the park owner shall submit information on the registration form setting forth the date the park or space was initially held out for rent, the duration of each lease, current space rents determined in accordance with YMC Chapter 15.20, effective date
Amend 2.0005(A)(6) to read as follows:
6. List of leased spaces claimed to be (exempt and/or non-exempt pursuant to Civil Code Section 798.17) et seq., or YMC Section 15.20.030 and all information required by Section 2.0003.
Amend 3.0001(A)(6) to read as follows:
6. Prior Exempt Leased spaces. In the event that the application for an Annual Adjustment includes a space that was previously exempt from space rent regulation control under long term lease pursuant to Civil Code Section 79847 et seq. or YMC Section 15.20.030 and such exemption has expired or terminated, the annual adjustment shall be determined based on the last rent in effect prior to the space becoming subject to rent control regulation, and the date said rent increase was imposed.
Amend 3.0001(B)(6) to read as follows:
6. For any space that was previously exempt from rent regulation to long term lease Civil Code Section 79847
control pursuant a under
et seq. or YMC Section 15.20.030 and such exemption has expired or been terminated, and for which the long term lease has expired or terminated the has terminated by
or rent control exemption as required
Civil Code Section 798.17, the determination the initial Annual of
Adjustment following termination of the rent control exemption shall be determined in accordance with this subsection (6). The last rent in the long tcrm lcasc be inserted
effect under exempt provision shall on
the Annual
Amend 3.0001(D)(3) to read as follows:
3. If the application includes a space that was previously exempt from long tcrm lcasc to Civil Code
rent regulation control under a pursuant
Section 79847 et seq or YMC 15.20.030 and such exemption has expired or been terminated, the space shall not have had a rent increase the long tcrm lcasc in the twelve to
under preceding (12) months prior
approval by the RA. Subsequent Annual Adjustments shall comply with subsection (D)(2).
Amend 3.0001(F) as follows:
pursuant to YMC Section 15.20.030, 15.20.050(D) and YMC Section 15.20.080(B) and subsections (A) through (D) of this Section."
Amend 4.0003(C) as follows:
C. Leased Spaces, Vacant Spaces Calculation the NOI
and of
Adjustment. Except as otherwise provided in Section 4.0003(H) of these Rules, when calculating the MNOI adjustment or MNOI rent adjustment based on readjusted Base Year NOI pursuant to YMC
15.20.100, the park's NOI shall be calculated for all spaces in the park, including month to month spaces, vacant spaces, and all spaces subject to to the long term leases defined in the
an exemption pursuant as
California Mobilehome Residency Law (Civil Code Sections 798 et seq.) or YMC Section 15.20.030. However, only those spaces, which are not exempt month to month spaces shall receive a rental increase, based upon a prorated allocation of the MNOI adjustment among all spaces in the park. Exempt leased spaces shall
Amend 4.0003(H)(6) as follows:
6. Except as otherwise provided in Subdivision (a) of this Subsection (6), the park's MNOI adjustment shall be allocated among all spaces in the including to leased
park, month month, vacant and spaces,
that, be to for
provided no adjustmcnt shall addcd any space rent a space currently and all spaces subject to an exemption from rent control pursuant to the California Mobilehome Residency Law (Civil Code Section 798, et seq.), or YMC Section 15.20.030 and no adjustment be to However, those
shall addcd any vacant space. only spaces which
are not exempt or vacant shall receive a rental increase, based upon a A prorated allocation amount of the paw MNOI adjustment among all spaces in the park shall be allocated to the individual regulated spaces_ A prorated amount of the park's MNOI adjustment shall be allocated to the individual regulated spaces. To allocate the MNOI adjustment to regulated spaces, the allocation should be made by multiplying the park's MNOI adjustment calculated pursuant to Section 4.0003(H)(5), above, by a fraction which is the number of regulated rental months divided by the total annual rental months for the park.
F.
Document:
Ordinance Section 15.20.073-Registration, posting and fees Issue:
Ordinance Section 15.20.073(A) is outdated language that is no longer required since the Annual Registration captures all park information.
Recommendation:
Delete 15.20.073(A) and renumber the sections accordingly.
G.
Document:
Ordinance Section 15.20.085(E) — Appeal of Rent Administrator's Decision on Capital Improvements
Issue:
Clarification is needed to emphasize that the rent administrator's capital improvement decisions are final unless appealed to the Hearing Officer.
Recommendation:
Amend Section 15.20.085(E) to read as follows:
Appeal of Rent Administrator's Decision on Capital Improvements.
The decision denying Any decision
rent administrator's granting or of
the the improvement
rent administrator on merits of a capital rent
adjustment or granting or denying an emergency capital improvement is a final decision, unless an application for appeal to the Hearing Officer is filed to this
rent adjustment application pursuant section
be to the hearing by filing for
may appealed officer an application
appeal within ten days of the date the rent administrator's written determination is mailed to the affected park owner and residents.
Except as otherwise provided in this subsection, any appeals shall be filed, processed, and determined in accordance with Sections
15.20.105 and 15.20.110 and the administrative rules adopted by resolution of the city council.
H.
Document:
Ordinance Section 15.20.100 - Rent increases by application to the hearing officer
Issue:
This section needs to include capital improvement rent increase adjustments pursuant to Section 15.20.085
Recommendation:
Amend the first sentence Section 15.20.100 to read as follows:
A park owner may seek a space rent increases in addition to those permitted by Section 15.20.080 and 15.20.085 pursuant to subsections A, B and E C of this section.
I.
Document:
Ordinance Section 15.20.116 - Recovery of application costs in connection with successful approval of a rent adjustment application to the hearing officer.
Issue:
Add additional language for clarification.
Recommendation:
Amend Section 15.20.116(A) to read as follows:
A park owner may seek a temporary rent adjustment to reimburse the park owner for the reasonable cost of professional services actually incurred by the park owner in preparing and presenting an application under Sections 15.20.085(E) and 15.20.100 to the hearing officer as set
forth in the administrative rules adopted by resolution of the city council. The park owner shall bear the burden of proof and shall provide the evidence to justify a temporary rent adjustment submitted under this section, and approval of the application will be conditioned upon the park owner's successfully obtaining approval of a rent adjustment pursuant to Sections 15.20.085(E) and 15.20.100 of this chapter. Any temporary rent adjustment shall be amortized over a five-year period with interest at the rate of seven percent per year, compounded monthly, and any increase granted shall remain in effect only during the five-year period. Any such increase shall not be included as part of the monthly space rent but shall be itemized as a separate charge on the residents' monthly rent statement. Nothing in this provision shall preclude a park resident from paying the full amount of the temporary rent adjustment as one lump sum without any payment of interest, following issuance of the cis hearing officer's final decision. Any such lump sum payment shall be made in accordance with the administrative rules adopted by resolution of the city council.
J.
Document:
Ordinance Section 15.20.140 — Biennial review
Issue:
Add additional language for clarification.
Recommendation:
Amend Section 15.20.140 to read as follows:
This chapter shall be reviewed by the city council in odd -numbered years to determine whether it is still appropriate and whether there should be any modifications of its provisions. The rent administrator shall issue notice of the biennial review and submittal deadline to the resident representative (or if no representative, posted pursuant to Section 15.20.060) and advertised once in the local legally adjudicated newspaper.
K.
Document:
Administrative Rules Sections 1.0001, 1.0002, 1.0003, 1.0004, 1.0005,
1.0006, 1.0007(E)
Issue:
The use of the term "meetings" is a carryover from when the former Commission had meetings and should be updated to reflect the change to a hearing officer proceeding.
Recommendation:
Amend Sections 1.0001, 1.0002, 1.0003, 1.0004, 1.0005, and 1.0006 replacing the word "Meeting(s)" with "Hearing(s)"
L.
Document:
Administrative Rules Section 1.0007, 1.0007(D)(3) and 1.0007(D)(5) Issue:
Section needs to be modified to include fair return rent adjustments, which are available under Ordinance Section 15.20.100(C) — Rent Increases by Application to the Hearing Officer.
Recommendation:
Amend the last sentence in the initial paragraph of Section 1.0007 to read as follows:
decreases in services or amenities adjustments, and net operating income adjustments and fair return adjustments.
Amend 1.0007(D)(3) as follows:
decrease in services or amenities, or net operating income, or fair return adjustment provisions.....
Amend 1.0007(D)(5) as follows:
particular application (capital improvement, reduction or decrease in services or amenities, Of net operating income or fair return adjustment) shall be granted
M.
Document:
Administrative Rules Section 1.0007(C)(2)
Issue:
Section needs to be modified to clarify that the Rent Administrator has the right to legal and expert representation in relation to Ordinance Sections 15.20.080, 15.20.090 and 15.20.100
Recommendation:
Amend Section 1.0007(C)(2) to read as follows:
2. The RA, in the case of any application before the Hearing Officer, may will be assisted and advised by experts and legal counsel.
However, experts and legal counsel representing the staff RA shall not communicate with the Hearing Officer concerning the application under consideration, except concerning procedural matters, such as the dates and locations of public hearings, and except during the public hearing.
N.
Document:
Administrative Rules Section 1.0007(D)(4)
Issue:
The current language restricts consideration of irrelevant evidence and additional language is needed to establish the Hearing Officer's ability to rule on the evidence.
Recommendation:
Amend Section 1.0007(D)(4) to read as follows:
The Hearing Officer has the right and the responsibility to rule on the admissibility and relevancy of Aa11 evidence, whether it be in the form testimony documents, is to
of oral or written which not relevant enable
the Hearing Officer to determine is
offered whether a park owner
entitled to the increase being sought in the application, or the decrease being sought by the residents in the application, under the operation of the YMC and these Administrative Rules. shall be excluded from the ,
Hearing Officer's
consideration.
O.
Document:
Administrative Rules Section 1.0007(D)(7)
Issue:
Clarification change
Recommendation:
Amend Section 1.0007(D)(7) as follows:
7. Requests for Production of Evidence. The Hearing Officer or RA staff member may request the attendance....
If any evidence requested by the Hearing Officer or staff member RA is not available.....
P.
Document:
Administrative Rules Section 1.0007(G)
Issue:
Clarification change
Recommendation:
Amend Section 1.0007(G) as follows:
shall articulate, his or her theif findings of fact, reasoning, and conclusions for his or her theif decision on.....
Q.
Document:
Administrative Rules Section 1.0008(B)
Issue:
The Hearing Officer has replaced the former Commission, therefore the use of the word "Resolution" "should be replaced by the use of the word "Decision."
Recommendation:
Amend Section 1.0008(B) to replace the word "Resolution" with "Decision".
R.
Document:
Administrative Rules Section 1.0009
Issue:
Additional text required to clarify process.
Recommendation:
Amend Section 1.0009 as follows:
Administrative Rules shall be in the form of a draft resolution prepared made by the RA resolution and shall be submitted to the City Council for review and approval.
S.
Document:
Administrative Rules Section 3.0001(B)(3) & (4)
Issue:
Clarification change
Recommendation:
Amend Section 3.0001(B)(3) & (4) as follows:
3. The CPI used in the prior Annual Adjustment shall then be subtracted from the current CPI. The resulting sum difference shall be multiplied by 100 divided by the prior CPI. The resulting sting percentage (in decimal form) then be divided by the CPI. The
shall prior resulting sum
shall -then -be multiplied by 1000% and presented with up to 2 decimal places as a `%' sign (converting to whole number form). The result or 4% is less, be to the
of current space rent, whichever shall referred as
"CPI Increase".
4. Each space rent, as determined pursuant to the last approved adjustment, shall be first multiplied by the CPI increase percentage and the resulting number (the rent increase) should then be added to the prior Dace rent to arrive at the new rent for the space.
T.
Document:
Administrative Rules Chapter 4
Issue:
Clarification change
Recommendation:
Amend Chapter 4 Title to read as follows:
Chapter 4. SPECIAL RENT ADJUSTMENTS INCREASES BY
APPLICATION
U.
Document:
Administrative Rules Section 4.0003
Issue:
The reference to Section 15.20.100 is erroneous because that is the very section, which provides for rent increases based on a maintenance of net operating income ("MNOI") formula. For the sentence to make sense it must refer to sections of the Ordinance which provide for rent increases which are not based on an MNOI formula.
Recommendation:
Amend the initial paragraph of Section 4.0003 as follows:
.park on the grounds that the rent increases described in Chapter 4 of these Rules and YMC Sections 15.20.080400, and 15.20.085 do not provide a just
V.
Document:
Administrative Rules Section 4.0003(D)(3)(e)
Issue:
Owner -performed labor rates have not been adjusted since 2008.
Recommendation:
Amend 4.0003(D)(3)(e) and adjust the hourly rates by January's CPI index 2008 to 2025.
General Maintenance: $10.3 8 16.68/hr.
Skilled Labor: $19.28 30.98/hr.
W.
Document:
Administrative Rules Section 4.0007
Issue:
Clarification language
Recommendation:
Amend Section 4.0007 Title and last sentence of paragraph as follows:
4.0007 ALLOWABLE RENT ADJUSTMENTS AND
APPLICATIONS FOLLOWING MNOI, FAIR RETURN
OR VOLUNTARY MEET AND CONFER
ADJUSTMENTa)
MNOI adjustment based on a readjusted base year NOI1-ef fair return adjustment or a special rent adjustment by voluntary meet and confer.
X.
Document:
Administrative Rules Section 6.0001 and 6.0002(A) & (B) Issue:
If park owner is successful in an appeal to the Hearing Officer from the Rent Administrator's decision pertaining to a Capital Improvement or Emergency Capital Improvement the park owner should be entitled to a temporary rent adjustment. Currently, the Rules are unclear if the park owner is entitled to recover these costs.
Recommendation:
Amend Section 6.0001 and 6.0002(A) & (B) to include Capital Improvements as follows:
6.0001 submitted under Sections 15.20.085 or 15.20.100 of.....
6.0002 (A) special rent adjustment under Sections 15.20.085 or
15.20.100 of the Ordinance
6.0002 (B) Hearing Officer pursuant to YMC Sections 15.20.085 or 15.20.100 based on the factors.....
CONCLUSION:
Based on the direction provided by the City Council, revisions will be made to the Ordinance and Resolution and be brought back before the Council for final approval.
Attachment(s):
A. Alex
B. MHET
C. WMA
D. Conway
E. YMRA
F. Dyer
Exhibits
I. 2025 Summary of High and Low Rents
II. Capital Improvement Log
III. MNOI/NOI/Fair Return Log
ATTACHMENT A
30 Received
City of Yucaipa
JAN '3 0 2025
Dunex, Inc. TEL: (714) 385-1516
1940 W. Orangewood Ave., #209 General Services/ FAX: (714) 385-1519 Orange, CA 92868 City Clerk's Department email: dunex(&,dunexmhp.com January 29, 2025
City of Yucaipa
Attention: Jennifer Crawford
34272 Yucaipa Blvd.
Yucaipa, CA 92399
RE: Mobile Home Stabilization Ordinance
YMC § 15.20 Biennial Review
Dear Ms. Crawford:
In reference to your letter dated December 4, 2024, regarding the Biennial Review of the Mobile Home Stabilization Ordinance, YMC § 15.20, we manage Knollwood Mobile Estates in Yucaipa. I have read comments from some of the other park owners/operators in Yucaipa that the CPI increases proposed this year under YMC §15.20 don't accurately reflect the increased costs of insurance, labor, materials and utilities which I certainly agree with. But there is a much more serious issue that is not being addressed in this process.
I'm relatively new to the mobile home industry, unlike many of my peers that have been in the business for decades. My background is in traditional residential homes sales. In a traditional sales transaction, after price and terms are negotiated, buyers do thorough third -party investigations of all the major systems in the property including electrical, gas, plumbing, Bing, HVAC, foundation, roof, pest control, windows and doors. Once the inspections are complete, the buyer will typically submit a . repair request for the items discovered during the inspections to the seller. This allows the parties to negotiate reimbursements and/or terms to remediate the outstanding issues In the mobilehome industry, particularly in rent -controlled parks where space rents are approximately 25% to 30% of fair market as they are in Yucaipa, this sales -inspection process is subverted. Buyers are purchasing the low space rent without consideration of a property's condition or potential health and safety issues.
Of the 116 spaces in our Knollwood park, 87 homes were manufactured in the 1960's that were not built to last 60+ years. Consistently we see issues of soft floors, roof leaks, mold, deteriorating home support piers, issues with the aluminum wiring, peeling paint and malfunctioning HVAC systems in these older homes. We have had several fires of older homes at Knollwood. Recently at another park we manage, with the same overly restrictive rent control, a 1969 home caught fire due to old wiring which burned down the neighbor's 1971 home with no insurance which we're still having to deal with months later as park operator. Yet, buyers are continuing to purchase these homes that have no actual value outside of the low space rents in the attempt to find some sort of • affordable housing.
Page One (1)
31 While the California Mobilehome Residency Law and California Health & Safety Code attempt to address some of the issues of older robilehonres, they fall woefully short on the ability of a park operator, the City(s) and/or HCD to properly enforce the issues of substandard housing in mobile home parks. California Mobilehome Residency Law Section 798.73 states the following:
REMOVAL OFMOBILEHOME UPON SALE TO THIRD PARTY The management shall not require the removal ofa mobilehomef •om thepark in the event ofthe sale ofthe mobilehome to a third party during the tern of the homeowner's rental agreement or in the 60 days following the initial notice requited by paragraph (1) ofsubdivision (h) of Section 798.55. However, in the event ofa sale to a .third party, in order to upgrade the quality of the park, the management may require that a mobilehome be removed from the park where:
Item (d) It is in a significantly rundown condition or in disrepair, asdeterminedby the general condition of the mobilehome and its acceptability to the health and safety ofthe occupants and to the public, exclusive of its age. The management shall use reasonable discretion in determining the general condition of the rnobilehonte andits accessotystr-uctures. The management shall bear the bznden ofdemonstratingthat the mobilehome is in a significantly rundown condition or in disrepair:
Furthennore, California Health & Safety Code 18550 Unlawful Occupancy states the following:
It is unlawfil for any person to use or cause, or permit to be used for occupancy, any of the following manufactured homes ormobilehomes wherever the manufactured homes or mobilehonzes are located, or recreational vehicles located in mo.bileh.orne parks:
Item (c)Any manufactured hone, mobilehome, or recreational vehicle in an unsafe or unsanitary condition.
Item (d)Any manufacturedhome, mobilehome, or recreational vehicle that is structurally unsound and does . not protect its occupants against the elements
The question is, if management is to bear the burden of demonstrating that a mobilehome is in significantly rundown, unsafe or in unsanitary condition, how is that possible if limited to an exterior inspection ofthe home only? The important health and safety components (gas, electric, water, smoke/carbon detectors) of the home are on the interior. And while we recognize an individual owner's right to sell their home and move on, what about the right to health and safety of the new buyer, surrounding neighbors, park operator and the public at large once that sale closes? Of the 116 spaces at Knollwood, we have 4 vacant spaces that we would like to put new homes on.
The average new mobilehome price on homes that would work for Knollwood range from $110,000 to $160,000. if we take a loan out of S 130,000 to purchase a new home at the current rate of 7%, the payment would be $865. With average rent -controlled spaces at $450, the return on investment is negative S415.
It is apparent this is not a viable business model. At some point in the near future, the Yuciapa mobilehome parks will lose "critical mass." (a system that has fallen below the minimum required level of participation, activity, or size needed to sustain itself) What happens to homes that are 65 years old, is they become 75 and 85-year-old homes. Attrition will continue to remove these older homes from serviceability. At some point, the Yucaipa parks will no longer be able to sustain themselves and much of the affordable housing inventories the Mobile Home Stabilization Ordinance, YMC §15.20 is trying to protect, will no longer exist.
Page Two (2)
32 Another issue our residents of older homes are encountering is the difficulty in obtaining homeowner's insurance. Some insurers are requiring homeowners to make costly repairs, others are not renewing coverage and other insurers have left the state entirely. Coincidentally, our manager of 33 years just received notification from the insurance company she's had for 33 years. They are requiring her to replace her entire water supply system at an estimated cost of 54500= prior to the renewal of her policy. These issues related to obtaining insurance will further exacerbate what we believe is a potential health and safety crisis of substandard housing.
While there are no easy answers to this situation which has been decades in the making and the City of Yucaipa must adhere to certain HCD mandates, a first step under the City's control would be to consider some measure of vacancy decontrol. While the current rent control ordinance is noble in its purpose, the unintended consequences of the policy are clear and obvious.
We have little doubt that other park owners/operators in Yucaipa face the same problems with aging inventory and severely restricted rent -controlled revenue streams which are more reflective of 1995, than of 2025. As a group, we are still confronted with the massively elevated expenses of the last 30 years and the ongoing challenges of maintaining park infrastructure under the current system.
In summary, we understand the dual mandate the City of Yucaipa has in providing safe and affordable housing. But in many ways, you can't have both if there is no mechanism in place to determine the health and safety of a home upon transfer or sale. We believe the City can take steps to avert what we think is an inevitable outcome under the current system, but will require some difficult choices with all parties involved.
Pleasefeel to contact me should you have questions or would like to discuss.
Sincerely,
Matthew Alex
CEO-Dunex, Inc.
714-385-1516 office
949-584-9021 mobile
malex(adunexnnhp.coni
Page Three (3)
33 ATTACHMENT B
34 J JE j i
Manufactured Flouring Educational
1 BOARD OF I)u,rc'rons
E.rccalfec liorrrrl
Pasidu:t
Ch::d l';{acahis: r
Lire P, y ,ddr 1
ne,Lecsa ftel:elo
'rrcy Sharlian
Si;rrlm:y
Natalie co;n:J!o
Pug f' frteul
l:v.1 I1 rnburg
itodnc,Y Andr•r: an
Jerr2/.1neobicat
Stauler ]1aill. Arc
William L. hl!Ile.r
.loin Sp!rtia
Board .Iteinbers
Phillip ansluai
Bob i!rl:dnitl
}Incur:a Daugin.wy
Clark, F;:Irbro:hut
L;uuml Fist�li r
Jay Gceenir;;
llyd f1lll
Gr::ig Mouser
J:unc: Jotrn-
CIint L u'
Crc,; o'na;;an
l`Nliatn l'r, cott
:Srlcisorp Coutntiltec
Gri!:13carlIL n
flay Gib>'.In
.Inlna Pentecost Fag.
�l rk Mahler
,mall 4loud:
Frank T-'.In17110
P,.'5 'residents
L`d Eorn:;
111. Mti!lirs
William L. :,111!r:r
I!ohrto!ecdzrr.
William f.. hllll:rr
Gnat' Unughor. Sr.
1'aa!la:;tlzic::
Janet (7ilbcrr
Clarke F:it1 rorhi r
Royce -fonds
Cliehr •fcavic u
Lanz al^.\don
.IAIaCS le!:C:
Keith
Craig Irou., r
IWbrrt Mader II
S5 Illcy Jr.hl:l;:ill,
I:il:!en Grillo
Wynn Homburg
\sLllf Co:;;u:fa
Pbdnc; Antic:-un
l'alliarn L.?Iillcr
Eileen Cirillo
hsa llornbu rg
li(atirue achievement
Award Recipients
Ni: i i !,!eAtl':n drny Golden
,Tnhr. Crean nary E. r;zr. lr.0
li.f. fsr:mdes .le., Many
I;eberl N. Wt-F,r. C:,IP,
Lu :ut A. ea.;
:floc, anti Beyond
,card Recipients
MM.: }011c•r hint: f rtir,
Sb.nlcy Clielu'rrr,ric ti
1So,ts1e:. Kcilh (:arenhisar
l'. Ilrcel ti„ an;::n ,I; rx II. ilectic!;
noyec.Lnm;
!.tCca(ire llirccfor
Vic!;in Taller
Inland Empire ileprc..cn!alive
Nuhr:rt. I•lv.nc
ass0elute
January 30, 2025
Via Email to
Received
City of Yucaipa
JAN 3 0 2025
General Services/
's DepartmenJenntfer
Jd@iaverk
Kim kmetzlerGYucago
Jennifer Crawford
Assistant City Manager/Rent Administrator
City of Yucaipa
34272 Yucaipa Boulevard
Yucaipa, CA 92399
Re: 2025 Biennial Review of Mobile Home Rent Stabilization Ordinance Dear Jennifer:
The Manufactured Housing Educational Trust (MHET) is a non-profit organization which serves the three Southern California Counties of San Bernardino, Riverside and Orange. MHET has for over 40 years served as an educational resource regarding the mobile home park industry and issues, and in the resolution of public policy issues affecting the manufactured housing industry and mobile home parks. MHET, on behalf of the mobile home park owners of Yucaipa, appreciates the opportunity to provide a few suggested changes to the Ordinance that we feel would be a solid step forward in assisting in the continued viability of the mobile home parks in the City, improve the quality of life for the residents, and in particular, limit the need for MNOI applications.
Initial Overview
MHET feels it is important to fully appreciate what makes up a mobile home park. It is not just a bunch of spaces to be rented. It is essentially a mini -city with many of the same infrastructure challenges and costs the City of Yucaipa faces. Costs that continue to rise and those cost increases are not under the park owners control. A park has streets, sewer lines, electrical infrastructure for each home, street lights and other common area lighting, club houses that are like community centers with activities, pools, and more. All of these need to be maintained as does the City's infrastructure, and like the City, this costs a lot of money to do. As is the case with the City, when revenue gets restricted, this decreases the ability to do what may need to be done to maintain the quality of life the residents expect and deserve. Also, if the restriction of City income continued over a long period of time, the infrastructure would begin to deteriorate. The same is true for mobile home parks.
Additionally, you are all familiar with the laws surrounding MNOI increases, and the expense and difficulty surrounding the application processes for everyone. All of the stakeholders; the residents, the City and park owners agree the best course is to find ways to avoid MNOI applications and the resulting larger rent increases. You have before you the ability to take a reasonable, full stride forward in achieving the goal of limiting and maybe removing the need for any further MNOI applications by taking a few key steps. 2524l Pasco do rllfcic, ,S',rilc 12O • Inpli'ntt hills; Oa:Trn:in P.554 ^ Phone: (9219) • 8O-5:iO3 • Fax (949) 80-32IC' Etna :[email protected]. ({e1,estc:,c,sw.inhel.rwa
Sold/ova. California 1IHJsT Sss s'irr(,r Orange Riverside G:)Ki Sru'n. Bernardino Counties . 1;rtee 1982 ll,g1:inin Kelly
35 MEET Letter
January 30, 2025
1. Rent Increase Caps — 2% Minimum and 6% Maximum
100% CPI is a reasonable increase that will help fund ordinary operations and aid in savings toward long-term capital improvements. However, we oppose the 4% cap with no floor. It is not fair or reasonable to have a ceiling and not a floor. We support a modification to include a minimum 2% floor and maximum 6% cap to eliminate the unanticipated volatile peaks and valleys that we experienced in recent years. Adding a floor of 2% and adjusting the ceiling to 6% will lead to less MNOI adjustments in the future.
2. Vacancy Decontrol
The primary goal of the ordinance is to protect existing residents from excessive rent increases.
Vacancy decontrol allows new residents to negotiate a rent agreement with the park owner that is mutually acceptable, but it does not affect the rents of existing residents. This approach allows new tenants to choose an initial rent that is reasonable and fair, while existing residents remain fully protected under the rent control guidelines.
Additional Information Supporting Vacancy Decontrol
Vacancy decontrol provides a solution for financing park rehabilitation without raising rents for existing residents. The revenue from new residents helps fund necessary capital improvements, reducing the need for park -wide rent increases through the MNOI process. Dr. Barr, in the 2017 biennial review, noted that allowing vacancy decontrol could "reduce fair return applications and rent adjustments."
Importantly, the state's progressive rent control law, AB 1482, includes provisions for vacancy decontrol to ensure the continued viability of affordable housing. It is essential that Yucaipa adopt a similar approach, which would allow for both park rehabilitation and long-term rent stability for all residents.
3. Pre -Approval of Capital Improvement Pass-Throughs
Currently, when capital improvements are made, tenants must approve any pass -through of these costs, and park owners are often forced to seek approval for a rent adjustment through the MNOI process. We propose amending the ordinance to allow pre -approval for capital improvement expenses, which would streamline the process and reduce administrative burdens for park owners and tenants alike. One specific example is pass thru of insurance expenses. Insurance costs have increased substantially in California and should be an automatic pass through.
If the capital improvement is a health and safety risk the rent administrator can approve it, however only after the improvement has been completed. Property owners should not be put in a position to wait until there is a health and safety situation to make a capital improvement. We suggest that the ordinance should allow the park owner to submit a capital improvement bid to the rent administrator for approval of a capital improvement project when it is a replacement 36 MHET Letter
January 30, 2025
project at the "end of its useful life". The approval should be done prior to the park owner paying for the project to be completed.
4. Property Tax Pass -Through Upon Sale of Park
Recent property sales in mobile home parks have led to significant increases in property taxes, which park owners must absorb or pass through to residents. We recommend amending the ordinance to allow for a fair and reasonable method of passing these increased taxes through to residents. For example, one solution could involve phasing in property tax increases over two years, or allowing park owners to pass through the tax increase without the need for a full MNOI increase application.
Conclusion
MHET appreciates the Commission's careful consideration of these proposals. We believe these changes will help minimize the time, cost, and challenges associated with MNOI applications, while ensuring the continued stability and success of mobile home parks in Yucaipa. These adjustments will create a fairer, more sustainable environment for both residents and park owners.
We look forward to discussing these recommendations further at the upcoming hearing, and we are available to answer any questions you may have.
Sincerely,
Robert Evans
Inland Empire Representative
37 ATTACHMENT C
38 *AO
Received
City of Yucaipa.
JAN 2 9 202:.i
. Western
Manufactured Housing CommunitiesGeneral services!
'°eS:iilC;icitl 09
City Clerk's Department
January 30, 2025
Ms. Jennifer Crawford
Deputy City Manager/Rent Administrator
City of Yucaipa
34272 Yucaipa Blvd.
Yucaipa, CA 92399
Dear Jennifer:
Thank you for the invitation to provide suggestions to amend Yucaipa's Mobile Home Rent Control Ordinance through the 2025 Biennial Review process.
Annual Rent Caps: The city should adjust the annual rent cap to 6% and add a floor or minimum of 2%
In a recent Biennial Review, the Rent Review Commission increased the annual permitted increase to 100% of CPI. Without any data or study or staff support the cap was arbitrarily reduced from 5% to 4%. For instance, in 2022 CPI was 8.7% and in 2023 it was 4.7%. Each year parkowners were capped at 4% which requires us to absorb cost increases far beyond the allowable increase. Yet residents had Social Security and pension increases for the full cost of living amount. We aren't advocating for no cap but rather raising the cap to 6%. This will allow parkowners to maintain our properties, so they remain sustainable, safe housing for the future.
Only having a cap without a floor is very unfair. Why should only one stakeholder have protection from spikes upwardly? What about the dips below 2%? There are years where the CPI is negligible. In those years, a floor or a minimum of 2% would allow parkowners to "ride out" the years that the CPI is over 6% (our suggested new cap).
Amending the ordinance to allow for permissible annual rent increases to be no more than 100% of CPI with a cap of 6% and no less than 2% will provide Yucaipa mobilehome park residents and parkowners with a low predictable increase that allows both stakeholders to keep up with inflation. Not addressing this discrepancy will lead to more MNOI or special rent increases which is largely agreed a miserable, expensive, and divisive process that should be avoided at all costs.
Capital Improvements: The city should amend the process that promotes capital replacements to improve the parks' living conditions for the residents. 40335 Winchester Rd. #E-165
Temecula, CA 92591
39 Parkowners desperately want to make improvements to their property. The current process stifles any reinvestment to improve the conditions in Yucaipa's mobilehome communities. Currently, there are two ways a parkowner can pursue reimbursement for capital projects. First, the residents can approve it with a vote of 51 %. I'd be interested to learn if in the history of the ordinance if any capital improvement has ever been supported by a resident vote. My guess is not many. Second, if it is dangerous or a health and safety risk the rent administrator can approve it but only after the improvement has been made. There is no guarantee the improvement will be approved.
The city should amend the ordinance to allow a parkowner to petition the rent administrator to approve a bid for a capital replacement at the "end of its useful life" before the parkowner lays out the costs of the project. Making parkowners and residents wait until the situation is "dangerous" is an absurd standard. The parks deserve better and this should be addressed this year to allow for crumbling infrastructure to be replaced.
Insurance Increases: The city should create a pass -through process for property insurance increases.
Insurance for our communities is 1) extremely difficult to come by and 2) costs are skyrocketing. Many insurance carriers are leaving California or are not writing new policies in the state due to the risk. It was a crisis before the LA wildfires this month.
Having a process that allows a parkowner to petition for the increase in property insurance may avoid an MNOI application and the costs associated with those applications and hearing processes. The city can be proactive instead of reactive relating to this ever-growing crisis.
Thank you for providing a draft red -line version to the Mobilehome Community Committee last November. It was valuable to hear from city staff which items need to be addressed regarding clean-up and updating language to address inconsistencies in the ordinance. We appreciate the dialogue.
We look forward to the City Council meeting when these items will be discussed. Please feel free to reach out if you have any questions about our recommendations.
Sincerely,
Julie Paulo, Regional Representative
40335 Winchester Rd. #E-165
Temecula, CA 92591
40 ATTACHMENT D
41 January 28, 2025
ID City of Yucaipa
34272 Yucaipa Boulevard
Yucaipa, California 92399-9950
Via Email: kevertyucaipa.org
Received
City of Yucaipa
.11-\N � t; 2023
General Services/
City Clerk's Department
Bel Aire Mobile Estates, LLC
Post Office Box 760, Alpine, CA 91903
Phone: (909) 797-9085
[email protected]
RE: Biennial Review of the Mobilehome Rent Stabilization Ordinance (Yucaipa Municipal Code [YMC]
15.20) and Administrative Rules
Dear City of Yucaipa,
We are writing this letter to discuss some concerns with the ordinance that should be mutually beneficial to all parties involved. Most provisions of this ordinance are beneficial to the City and are only short-term beneficial to the resident, leaving the park owner with little to be desired, and with little room in the budget for community improvements that would benefit the resident in the long run. • The years post COVID have shown especially burdensome inflation on all, which has greatly affected our ongoing maintenance expenses when the only ability to recoup our increases costs in rent increases has been capped at 4%. With this cap, we request the ability to either recapture the leftover percentage in future years with inflation under 4% or to add a reasonable 3% floor to make up for the decades at 80% CPI leaving rents far below market. The 4% cap in 2022 and 2023 resulted in increases of nearly 50% of CPI. If we could recapture in future years, it could be written like, "Should the increase in the "Consumer Price Index" otherwise cause the rent to exceed 4% in any given year, park owners should be entitled to recapture the difference over future years that the increase in the "Consumer Price Index" would otherwise cause the monthly rent to increase by less than 4% per year." This would benefit the park in being able to increase our rents reasonably, and the resident by making it happen a little slower in high inflation years. Alternatively, a floor of 3% could be added to recoup the loss of rents from prior years.
• The ordinance is entirely written to benefit the resident and the city, and as such, all rent control fees should be passed on I00%, not 50%, to the resident. These fees are substantial now that nearly every home is on rent control with the park having to write a substantial check to the city each January for burdensome rent control to be imposed upon the park. • Insurance in California has been a largely expensive problem and has increased two and three fold for our community. We request an easy process to increase rent for these large increases in our operating expenses or to be able to list as a separate line item to bill to residents for the increases.
We request some reasonable changes and considerations to the ordinance so that we may continue to operate an maintain our very large investments. We take pride in maintaining our community and it shows in inspections conducted by the city, but it has been very difficult in recent years with the decades of under market rents and rising cost of doing business. Currently banks are benefiting from large loans that residents have to obtain in purchasing very expensive old and inflated homes due to extremely low rents (significantly lower than the average car payment), where it would benefit the community for the park to make a fair return on their investment to be able to reinvest into the community. We request options for fair rent increases through being able to recapture CPI in years where it is over the 4% cap, fair fees and special insurance adjustments. Thank you for your time and consideration and should you have any questions please call or email so that we may better explain our proposals.
Sincerely,
,1
7C��^ '`•tit1 i
Jordan Conway P1ursglove
For Bel Aire Mobile Estates, LLC
42 ATTACHMENT E
43 v
-'i8C�.'I cC:
City of
JAN 28 2025
General Services/
TO: Rent Administrator City Clerk's D.::. irti-flent
FR: David Devin, YMRA Recording Secretary
RE: Ordinance 15.20.060 - Resident Representatives
Currently pursuant to YMC 15.20.060 "Resident Representatives": The residents of each mobilehome park in the City shall annually elect by majority vote, with one vote per space, a resident representative to receive all notices required by this chapter.
It was discussed at a Yucaipa Mobilehome Residents Association (YMRA) Board meeting and consequently voted unanimously by the members present at the January 2025 YMRA monthly meeting, to recommend a change to the Ordinance regarding the number of signatures / votes needed to be a "Resident Representative".
YMRA would like to recommend for your consideration that the Ordinance change the number of signatures / votes needed per Park to 10 or 10% of the spaces which are under rent control, whichever is less.
Reasons cited include but were not limited to: 1/4 of the Parks have more than 100 spaces under rent control, and with 1 having almost 300, it is difficult to get the requisite majority vote. 1 of the Parks are designated Senior and therefore there is a diminished capacity for mobility and interaction with other residents. With only 6 resident representatives to date, it would increase the likelihood of more participation.
Thank you for your consideration. For any follow up please feel free to contact David Devin 35218 Fir Avenue Space 87 (El Dorado Palms Mobilehome Park) 781-640-3081 44 ATTACHMENT F
45 Received
City of Yucaipa.
JAN 6 2 2024'•
Fronr: tan Dyer
To: Kim J f•letzler, Cf•IC. CPt•I; Jennifer Crawford; Chris tdann• Bobby Duncan; Jon Thorp; Judy Woolsey; Chris Venable: Justin t3eaver Bob Miller (:;enerai Services/
.y Clerk's Department
Cc:
Subject:
Date:
RE: Yucaipa RSO Biennial review - 2 WIN -WIN changes to make to RSO Saturday, December 21, 2024 12:4S:26 Pf•1
Also: Insurance on our parks went up TWENTY PERCENT (actually 20.2%) per year in 2024-2025, while YRSO rents will rise 1%. CPI increases don't come close to covering the actual expenses parks face each year. That's not a "fair return".
From: Ian Dyer
Sent: Saturday, December 21, 2024 12:40 PM
To: Kim J Metzler, CMC, CPM ; Jennifer Shankland ([email protected]) ; Chris Mann ; Bobby Duncan
; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]
Cc:
Subject: Yucaipa RSO Biennial review - 2 WIN -WIN changes to make to RSO Rent control is the best way to destroy a city, other than bombing.
Assar Lindbeck, Nobel Prize Committee Chair
Rent control limits the funds available to improve inobileltome parks. So, rent control 46 means parks don't get upgraded.
This can be changed. As mobilehome parks in Yucaipa improve, crime will drop, schools will be safer and the city will be nicer.
The goal is for all sides to benefit. And no unhelpful insults. Park owners aren't evil or greedy. Park residents aren't lazy or selfish. The best solutions help everyone.
Here are two win -win solutions to improve parks:
1. Full vacancy decontrol
Full vacancy decontrol hurts no one and helps everyone. It means that only when a space goes vacant or the park buys it, the space rent can be raised to market. a. It does not affect the rent of existing residents at all. b. Park residents get higher prices when they sell, because the park has an incentive to pay more than anyone else, raising the sales prices. c. The park owner has an incentive to make the park nicer, so it attracts market rate tenants who invest in their home and care about their community. This benefits all Yucaipa residents.
Mobilehome residents often oppose vacancy decontrol because they fear it will lead to other changes. But in reality, vacancy decontrol benefits existing residents, because without raising rent on any existing tenant, it gives the park owner more funds to improve the park, and more reason to do so. It justifies installing nicer, newer homes, which improves home values for all residents in the park, and makes the park nicer. And it causes mobilehome values to rise.
2. 100% of CPI
Space rents should increase at CPI with no cap, so parks can be maintained. a. Rents will still be FAR below market rents, because the increases are on space rents that are already 60% to 250% below market rents. b. CPI increases far slower than actual rents in SoCal, so at CPI space rents will still be increasing far slower than market rents.
c. The current law limiting increases to 4% even when inflation is higher, means that while actual park expenses rise by CPI (electric, water, wages for maintenance, asphalt, lighting, repairs, much more), each year, the park recovers less than that, so things deteriorate, because the money isn't there to maintain and improve.
d. Allowing CPI increases will still leave rents 60% to 250% below market. e. Full CPI increases will benefit all of Yucaipa, because nicer parks attract nicer residents, who live and work and go to school with all the other residents of Yucaipa. Everyone benefits.
These two solutions together will also save the whole city money, because park owners will have less need to file MNOI & Capital Improvement rent increase applications, which often lead to major expense and lawsuits.
47 Four years ago in the News Mirror, a councilperson said "I don't think the park owners care at all about the people that live there." That's false. We need to give the council more accurate information. Park owner actions have proven consistently that we care about our residents. We care about making the parks better, safer & nicer for the residents. We care about attracting residents who care about their neighbors and contribute to the community with courtesy, not crime. I've poured 21 years of my life into these properties. Our companies have upgraded hundreds of homes, retail and offices in Yucaipa. The two parks we operate were terrible and crime -ridden when we took over. We've worked so hard with the Sheriff to get out the bad tenants who ruin things for their neighbors. After 21 years of careful effort by our hard-working staff, our parks are so much nicer. It's unfair to say we don't care. It's counterproductive. The facts show otherwise.
Now, let's choose solutions that benefit everyone, park residents and all Yucaipa residents. Nicer mobilehome parks benefit all Yucaipa residents. The nicer the parks are, the lower the crime, and the better the schools. This benefits all Yucaipa residents.
Yucaipa residents who don't live in mobilehome parks are affected too. If mobilehome parks are deteriorated for lack of funds, they attract problems and problem tenants. If mobilehome parks are nicer, they attract residents who care about their homes and their neighbors and contribute to healthier schools and a healthier city. Full vacancy decontrol benefits everyone. 100% CPI increases benefit everyone, including the park residents.
Even with vacancy decontrol and full CPI, space rents will still be way less than half of market rents, but parks will have more funds to manage, maintain and improve. With vacancy decontrol and full CPI, parks can afford to stay up with inflation to make the parks nicer, attracting residents who care, which makes the schools, the streets and the city safer and nicer.
48 EXHIBIT I
49 2025 CITY OF YUCAIPA
General Services/CityClerk Dept.
P
PARK SPACES
Source: 2025 Annual Registration
BASE RENTS
PARK OWNED SPACES
Source: 2025 Annual Registration
BASE RENTS
RENT CONTROL SPACES
(*"Source: 2025 Adjusted Space Rents [CPI Increase])
Mobilehome Park
Address
Total
Spaces
Park
Owned
Rent
Control
Vacant
Pads
Vacaant
Coaches
Van t
Coaches
PO High
Base Rent
PO Low
Base Rent
PO Average
Base Rent
RC
High
Base Rent
RC
Low
Base Rent
A RC
Base Rent
Aladdin Mobilehome Park *
12813 7th Street
96 39
57 0
3 0
$1,850.00
$517.00
$1,215.11
$416.04
$341.79
$400.23
Avalon Mobilehome Park *
35011 Avenue E
85 39
44 2
1 0
$2,000.00
$600.00
$1,144.24
$447.74
$406.61
$439.16
Bel Aire Mobilehome Park
13060 2nd Street
111
14 95
2 0
0 $735.62
$511.42
$613.90
$745.50
$369.52
$469.46
Bonanza Mobilehome Park *
13645 5th Street
83 7
75 1
1 0
$1,900.00
$850.00
$1,556.25
$447.59
$386.43
$440.87
Caravan Mobilehome Park *
12656 2nd Street
70 0
69 1
0 0
$0.00
$0.00
$0.00
$391.27
$322.58
$343.16
Carriage Trade Manor MHP *
12874 California St
97 18
74 5
1 0
$1,356.75
$619.39
$766.83
$430.76
$395.40
$411.70
Crafton Hills Mobilehome Park
31816 Avenue E
159
2 157
0 0
0 $371.73
$371.73
$371.73
$489.02
$377.50
$439.87
Crestview I Mobilehome Park *
12220 5th Street
145
1 144
0 0
0 $0.00
$0.00
$0.00
$417.91
$369.27
$398.96
Eldorado Mobilehome Park 1 *
35218 Fir Street
217
2 214
1 0
0 $597.08
$597.08
$597.08
$604.38
$438.62
$513.06
Executive Mobilehome Park
10622 Bryant Street
152
3 149
0 0
0 $1,736.44
$1,196.18
$1,556.35
$582.73
$455.34
$525.83
Fremont Heights Mobilehome Park*
12151 Fremont St
114
2 112
0 1
0 $750.00
$750.00
$750.00
$711.97
$605.18
$648.40
Grandview East Mobilehome Park 1
12655 2nd Street
99 2
96 1
1 0
$0.00
$0.00
$0.00
$583.95
$319.57
$457.61
Grandview West Mobilehome Park*
12700 2nd Street
51 0
51 0
0 0
$0.00
$0.00
$0.00
$485.75
$412.27
$440.67
Green Valley Mobilehome Park
12414 4th Street
109
102
7 0
18 0
$1,370.00
$615.00
$1,079.19
$393.13
$379.56
$387.83
Hidden Valley Mobilehome Park *
12680 4th Street
60 0
60 0
0 0
$0.00
$0.00
$0.00
$405.98
$390.95
$400.53
Hidden Village Mobilehome Park*
12582 2nd Street
81 0
81 0
0 0
$0.00
$0.00
$0.00
$527.27
$447.86
$479.60
Hide -Away Mobilehome Park
34447 Yucaipa Blvd
46 20
26 0
2 0
$1,895.00
$1,012.54
$1,588.40
$1,037.72
$434.86
$557.74
Hillcrest Mobilehome Park *
33600 Calimesa Blvd
196
51 126
19 2
0 $1,700.00
$650.00
$1,223.26
$623.18
$516.94
$545.78
Hitching Post Mobilehome Park
34642 Yucaipa BLvd
110
29 76
5 11
0 $2,443.50
$900.00
$1,636.13
$477.48
$280.61
$373.89
Holiday Mobilehome Park
34184 County Line Rd
128
92 36
0 3
0 $2,100.00
$854.70
$1,427.28
$370.69
$295.54
$343.37
Knollwood Mobilehome Park
12941 2nd Street
124
39 79
6 1
0 $2,100.00
$465.00
$1,041.25
$606.94
$377.66
$459.63
Lakeview Mobile Estates
11050 Bryant Street
297
1 296
0 0
0 $542.09
$542.09
$542.09
$608.99
$511.94
$570.20
'Denotes Non -Profit Status
* Senior Park
** Base rents subject to change with City approval of annual CPI increases that take place throughout the year Updated 5/19/2025
https://yucaipa.sharepoint.com/sites/GeneralServices/Shared Documents/General Services_City Clerk/MOBILEHOME FILES/Linked Spreadsheets/2025/2025 Summary
2025 CITY OF YUCAIPA
General Services/City Clerk Dept.Annual
PARK SPACES
Source:2025 RegistrationPARK
BASE RENTS
OWNED SPACES
Source: 2025 Annual Registration
BASE RENTS
RENT CONTROL SPACES
(**Sourer. 2025 Adjusted Space Rents [CPI Increase])
Mobilehome Park
Address
Total
Spaces
Park
Owned
Rent
Control
Vacant
Pads
VacOant
Coaches
VacOaut
Coaches
PO High
Base Rent
PO Low
Base Rent
PO Average
Base Rent
RC
High
Base Rent
RC
Low
Base Rent
C
Average
Base Rent
Las Casitas Mobilehome Park
33848 Avenue G
70 3
65 2
1 0
$800.00
$696.89
$748.45
$795.07
$300.40
$672.06
Melody Lane Mobilehome Park
12688 California St
32 1
31 0
0 0
$1,352.00
$745.00
$1,048.50
$395.83
$301.34
$347.07
Mission Valley Oaks Mobilehome Park *
12367 4th Street
76 1
16 0
1 0
$0.00
$0.00
$0.00
$759.75
$645.90
$692.20
Mount Vista Mobilehome Park
13061 2nd Street
56 25
31 0
0 0
$1,951.00
$954.00
$1,388.40
$434.66
$317.35
$328.51
Mountain View Mobilehome Park
12726 California St
77 6
71 0
1 0
$1,550.00
$577.00
$1,000.83
$395.83
$298.15
$342.27
Northview Mobilehome Park *
10675 Bryant Street
129
13 116
0 2
0 $1,900.00
$800.00
$1,325.64
$436.09
$278.88
$392.07
Park Terrace Mobilehome Park *
12177 3rd Street
73 0
73 0
0 0
$0.00
$0.00
$0.00
$374.74
$374.74
$374.74
Patrician Mobilehome Park *
34480 Countyline Rd
137
21 116
0 1
0 $2,272.00
$1,005.68
$1,635.05
$435.31
$367.68
$410.24
Rancho Del Sol Mobilehome Park'
12361 4th Street
110
0 106
4 0
0 $0.00
$0.00
$0.00
$577.36
$383.33
$528.24
Skyline Village Mobilehome Park*
12650 California St
77 10
66 1
0 0
$1,411.00
$312.00
$776.44
$676.00
$337.46
$409.55
Twin Pines Mobilehome Park
12300 5th Street
93 82
11 0
13 0
$1,500.00
$795.00
$1,121.96
$705.36
$385.11
$423.73
Valley Breeze Mobilehome Park*
13576 California St
87 20
63 4
1 0
$875.00
$350.00
$704.06
$460.57
$432.41
$452.43
Valley View Mobilehome Park'*
12995 6th Street
75 13
61 1
0 0
$1,158.00
$450.00
$924.54
$487.93
$390.10
$440.04
Westwind Mobilehome Park
12380 4th Street
86 72
14 0
4 0
$2,200.00
$833.00
$1,601.01
$422.16
$241.18
$314.62
Wildwood Canyon Mobilehome Park
34111 Wildwood Cyn
147
1 146
0 0
0 $351.71
$351.71
$351.71
$415.14
$320.96
$361.93
Wishing Well Mobilehome Park*
13063 5th Street
73 35
34 4
3 0
$2,986.90
$603.27
$1,465.56
$365.75
$270.07
$286.71
Yucaipa Crestview Mobilehome Park
12821 4th Street
55 36
19 0
0 0
$2,950.00
$781.67
$1,509.82
$543.74
$326.72
$426.54
Yucaipa Valley Mobilehome Park
12710 3rd Street
104
82 22
0 6
0 $2,084.50
$739.62
$1,384.81
$1,024.42
$428.53
$582.10
Yucaipa Village Mobilehome Parr
12830 6th Street
82 0
82 0
0 0
$0.00
$0.00
$0.00
$606.02
$424.91
$443.88
Total Spaces:
4,269
884
3,267
59 78
0 Total RC Averages: $539.46 $381.98 $445.77
All Age/Family Park Spaces: 2,165
Senior Park Spaces: 2,104
'Denotes Non -Profit Status
* Senior Park
** Base rents subject to change with City approval of annual CPI increases that take place throughout the year Updated 5/19/2025
https://yucaipa.sharepoint.com/sites/GeneralServices/Shared Documents/General Services_City Clerk/MOBILEHOME FILES/Linked Spreadsheets/2025/2025 Summary
EXHIBIT II
52 City of Yucaipa Mobilehome Capital Improvement Log
YEAR
PARK
TYPE
OUTCOME
DATE
AMORTIZED COSTS
MONTHLY AMOUNT
EXPIRATION DATE
2023
MOUNTAIN VIEW
MOBILEHOME PARK
STREET IMPROVEMENTS
ADMINISTRATIVE DENIAL
04/20/23
$0.00
N/A
2018
EXECUTIVE MOBILE
HOME ESTATES
STREET IMPROVEMENTS
ADMINISTRATIVE APPROVAL
11/29/18
$24.00
3/31/2034
*Should not be reflected on
the 4/1/2034 invoices
2017
CARRIAGE TRADE
MANOR
STREET IMPROVEMENTS
ADMINISTRATIVE APPROVAL
02/07/17
$15.16
5!31 /2032
*Should not be reflected on
the 6/1/2032 invoices
2015
CARAVAN ESTATES
ASPHALT WORK
ADMINISTRATIVE APPROVAL
$15.28
10/31/2030
*Should not be reflected on
the 6/1/2032 invoice s
2010
PARK TERRACE
SECURITY WALL, SIDEWALK AND DRIVEWAY APRON ALONG
PARK FRONTAGE, SEWER CONSTRUCTION PROJECTS (2006-2009), STREET AND CARPORT RESURFACING (2008-2009)
DENIED (UPHELD THE RA'S DECISION)
2010-27 MRRC
07/15/10
$0.00
N/A
2004
SKYLINE VILLAGE
RESURFACING OF STREETS
APPROVED
2004-01 MRRC
04/01/04
$2.32
3/31/2019
*Should not be reflected on
the 4/1/2019 invoices
Confirmed with P.O. no
longer reflected on invoices
effective 4/1/2019
2003
WESTWIND
INSTALLATION OF A CATHODIC GAS LINE PROTECTION SYSTEM
ADMINISTRATIVE APPROVAL
03/01/93
$1.00
5 YEARS
2003
YUCAIPA VILLAGE
PLUMBING WORK
ADMINISTRATIVE DENIAL
10/28/03
$0.00
N/A
1999
KNOLLWOOD MOBILE
ESTATES
UTILITY LINES
99 02 MRRC
2005-01 MRRC PURSUANT TO THE CPUC RULING
(DECISION 04-05-056)
7/6/1999
$1-7A0
10/31/2019
*Should not be reflected on
the 11/1/2019 invoices
4/29/05
$10.78
1999
FREMONT HEIGHTS
REPLACEMENT OF TWO 5,000-GALLON WATER STORAGE TANKS
DENIED
99-01 MRRC
01/14/99
$0.00
N/A
1998
FREMONT HEIGHTS
REPLACEMENT OF TWO 5,000-GALLON WATER STORAGE TANKS
ADMINISTRATIVE APPROVAL
08/01/9800
(Appealed)
(Appealed)
5 YEARS
(Appealed)
1997
WISHING WELL
VARIOUS WORK COMPLETED 1992-1997
ADMINISTRATIVE DENIAL
07/16/97
$0.00
N/A
City of Yucaipa Mobilehome Capital Improvement Log
YEAR
PARK
TYPE
OUTCOME
DATE
AMORTIZED COSTS
MONTHLY AMOUNT
EXPIRATION DATE
1997
FREMONT HEIGHTS
REPLASTER AND RETILE POOL, INSTALL CYCOLAC MAIN
DARIAN RING AND COVER
ADMINISTRATIVE APPROVAL
RESCINDED BY RA
08/12/97
$0.3-2
(Rescinded)
5 YEARS
(Rescinded)
(Rescinded)
1996
GRANDVIEW WEST
REPLACEMENT AND BUILDUP OF REC HALL ROOF AND
INTERIOR REPAIR OF REC HALL CEILING AND WALLS
ADMINISTRATIVE APPROVAL
01/31/96
$0.90
3,3 I /2006
*Should not be reflected on
the 4/1/2006 invoices
1995
BEL AIRE MOBILE
ESTATES
STREET IMPROVEMENTS
APPROVED
1995-01 MRRC
05/04/95
$11.99
8/31/2010
*Should not be reflected on
the 9/1/2010 invoices
1995
MT. VISTA
STREET IMPROVEMENTS
$4.14
7/1/2005
*Should not be reflected on
the 7/1/2005 invoices
1995
VALLEY VIEW
DOORS TO REC HALL
ADMINISTRATIVE APPROVAL
09/20/95
$0.71
8/31/2005
*Should not be reflected on
the 9/1/2005 invoices
1993
CRAFTON HILLS
ESTATES
SEWER
APPROVED
1993-01 MRRC
02/25/93
$13.83
4/30/2008
*Should not be reflected on
the 5/1/2008 invoices
1993
HOLIDAY MOBILE
RANCHO
STREET PAVING
ADMINISTRATIVE APPROVAL
11/16/93
$1.20
12/31/2008
*Should not be reflected on
the 1/1/2009 invoices
1992
FREMONT HEIGHTS
STREET PAVING
DENIED
92-01 MRRC
3/49/92
$0.00
N/A
1992
HIDDEN VILLAGE
STREET IMPROVEMENTS
MRRC GRANTED A MODIFIED RENT INCREASE AT THE
2/20/1992 MRRC HEARING
02/20/92
$9.63
5/31/2005
*Should not be reflected on
the 6/1/2005 invoices
1991
VALLEY VIEW
INSTALLATION OF A CATHODIC GAS LINE PROTECTION SYSTEM
ADMINISTRATIVE APPROVAL (84 MONTHS)
11/16/91
$1.68
4/30/1999
*Should not be reflected on
the 5/1/1999 invoices
EXHIBIT III
55 City of Yucaipa Mobilehome NOI Log
YEAR
PARK
TYPE
OUTCOME
DATE
RESO. NO
MONTHLY
AMOUNT
APPROVED
AMORTIZED COSTS
GALLAND
KAVANUA
TOTAL
EXPIRATION
DATE
TOTAL
INCREASE
2019
VALLEY VIEW MHP
MNOI/READJUSTED BASE YR NOI
APPLICATION
APPROVED
9/22/2020
2020-54
$60.21
$15.66
$0.00
$15.66
12i 31 /2025
*Effective
1/1/2021 (Park
noticed residents on
9/25/2020)
$75.87
2019
VALLEY VIEW MHP
VOLUNTARY MEET AND CONFER
RENT ADJUSTMENT
DENIED - 10/15/2019 (PRECENTAGE OF VOTES NOT IN
10/15/2019;
11/13/2019
N/A
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
FAVOR = 55%)
DENIED - 11/13/2019 REVOTE (PRECENTAGE OF VOTES NOT
IN FAVOR = 52%)
2017
NORTHVIEW MHP
VOLUNTARY MEET AND CONFER
RENT ADJUSTMENT
APPROVED (Administrative)
12/18/17
N/A
$95.00
$0.00
$0.00
$0.00
N/A
$95.00
2017
CARRIAGE TRADE
MANOR
NOI APPLICATION
APPROVED
07/18/17
2017-35 MRRC
$95.94
$10.45
$0.00
$10.45
1 1r30,2022
*Effective 12/1/2017
Confirmed with P.O.
no longer reflected
on invoices effective
12/1/2022
$106.39
2011
YUCAIPA VILLAGE
NOI APPLICATION
APPROVED
08/10/11
2011-52 MRRC
$81.29
$11.61
$0.00
$11.61
11/30/2016
*Effective
12/01/2011
$92.90
2010
GRANDVIEW WEST
PARK OWNER APPEALED CC
DECISION TO SUPERIOR COURT
CC RESCINDED RESOLUTION NO. 2009-20, ADOPTED
RESOLUTION NO. 2010-09, AFFIRMED THE COMMISSION'S
DECISION TO AWARD
05/24/10
2010-16 CC
$60.62
$27.57
$13.60
$41.17
08'31!2015
*Effective
09/01/2010
$101.79
2009
GRANDVIEW WEST
MRRC DECISION APPEALED TO CITY
COUNCIL (FILED BY PARK OWNER
AND YMRA)
CITY COUNCIL OVERTURNED THE MRRC DECISION,
GRANTING THE APPEAL OF YMRA, DENYING THE APPEAL
OF GVW, DENYING A RENT INCREASE FOR GVW
06/08/09
2009-20 CC
$0.00
$0.00
$0.00
$0.00
N/A
$0.00
2009
GRANDVIEW WEST
NOI APPLICATION
APPROVED
04/01/09
2009-10 MRRC
$60.62
$10.03
$0 00
(Appealed)
$10.03
5 YEARS
$70.65
(Appealed)
(Appealed)
(Appealed)
(Appealed)
2008
VALLEY BREEZE
NOI APPLICATION APPEALED TO THE
CITY COUNCIL
APPROVED
($68.80+$4.33 to account for CPI Increase Adjustments and adjusted Galland and Kavanua to account for additional time)
09/22/08
2008-45 CC
$73.13
$17.67
$44.13
$61.80
01/31/2014
*Effective
02/01/2009
$134.93
2008
VALLEY BREEZE
2006 NOI APPEALED TO SUPERIOR
COURT; REMANDED TO RETURN TO
THE MRRC
ADOPTED RESO 2008-09 (RESCINDING RESO 2006-01);
APPROVED NOI
06/26/08
2008-29 MRRC
$68.80
$15.81
$45.91
$61.75
10/31/2013
$130.55
(Appealed)
(Appealed)
(Appealed)
(Appealed)
*Effective
(Appealed)
11/01/2008
2006
VALLEY BREEZE
NOI APPEAL TO CITY COUNCIL
DENIED
03/27/06
2006-08 CC
$0.00
j
$0.00
City of Yucaipa Mobilehome NOI Log
YEAR
PARK
TYPE
OUTCOME
DATE
RESO. NO
MONTHLY
AMOUNT
APPROVED
AMORTIZED COSTS
TOTAL
GALLAND
KAVANUA
TOTAL
EXPIRATION
DATE
INCREASE
2005
VALLEY BREEZE
NOI APPLICATION
DENIED
Incomplete and Insufficient Information re Claimed Expenses 02/02/06
2006-01 MRRC
$0.00
r
//
$0.00
2005
EXECUTIVE
NOI APPLICATION
APPLICANT FAILED TO COMPLETE APPLICATION PROCESS
N/A
N/A
$0.00
$0.00
2004
WISHING WELL
NOI APPLICATION
DENIED
11/09/04
2004-02 MRRC
$0.00
/
/
$0.00
1998
VALLEY BREEZE
STIPULATION FOR SETTLEMENT
Case N. SCV 50163
APPROVED
$20.00 per space/per year over a period of 4 years for a total of $80.00 01/15/99
(Per
N/A
Refer to Outcome
Stipulation for Settleinent)
$80.00
$0.00
$0.00
$0.00
N/A
$80.00
1998
VALLEY BREEZE
NOI APPLICATION
APPROVED
$20.00 per space/per year over a period of 3 years for a total of $60.00 06/02/98
1998-01 MRRC
Refer to Outcome
(Appealed to Court)
$60.00
$0.00
$0.00
$0.00
N/A
$60.00
1996
MELODY LANE
CITY COUNCIL REQUESTED MRRC
TO REHEAR NOI APPLICATION DUE
TO LITIGATION INITIATED BY PO
APPROVED
05/29/96
1996-01 MRRC
$48.00
$0.00
$0.00
$0.00
N/A
$48.00
1996
MOUNTAIN VIEW
CITY COUNCIL REQUESTED MRRC
TO REHEAR NOI APPLICATION DUE
TO LITIGATION INITIATED BY PO
APPROVED
05/29/96
1996-01 MRRC
$48.00
$0.00
$0.00
$0.00
N/A
$48.00
1995
MELODY LANE
NOI APPLICATION
DENIED
09/26/95
1995-02 MRRC
$0.00
///r/i/
$0.00
1995
MOUNTAIN VIEW
NOI APPLICATION
DENIED
09/26/95
1995-02 MRRC
$0.00
$0.00
1995
CRESTVIEW II
NOI APPLICATION
NOI APPLICATION DEEMED INCOMPLETE
N/A
N/A
$0.00
$0.00
1994
PARK TERRACE
NOI APPLICATION
APPROVED
05/26/94
1994-01
$34.00
$0.00
$0.00
$0.00
N/A
$34.00
1991
ALADDIN
NOI APPLICATION
APPROVED
Reference Section 5 of MRRC Resolution No. 1991-03. Calculated the 5 RC spaces based on the middle rent of $118.42 and divided by
0.66983, resulting in RC increases between $55.69 and $61.15 (Average of $58.37)
10/03/91
1991-03 MRRC
$58.37
$0.00
$0.00
$0.00
N/A
$58.37