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(bb) The Consumer Price Index (CPI) is an accepted measure of the general change over time in prices and therefore the cost of living and doing business. Since 1984, increases in the CPI (All items, All Urban Consumers, Los Angeles -Long Beach -Anaheim region) have been generally under four (4%) percent per year, with the latest increase at 1.5% for February 2021. Meanwhile, the counties of Los Angeles and Orange are in the midst of a rapid increase in rent index. The cost of renting in Los Angeles and Orange counties rose at a 5.8% annual rate in June 2019 vs. 4.7% a year earlier. Wage increases have trailed rather than stimulated general cost increases. A cap on rent increases tied to the change in the CPI generally will protect low -wage tenants without limiting landlords' fair return on investment. (cc) Since the mid-2000s, residents in the City of Santa Ana have proactively expressed their concerns to the City Council regarding displacement, gentrification, and rising rents in the City of Santa Ana. During this same period, residents in the City of Santa Ana held educational forums for residents on the issues of rent control and just cause eviction protections. (dd) Advocates for and members of the tenant community in the City of Santa Ana have advocated City Council to set emergency protections due to a rapid spike in evictions and rent increases due to the just cause and rent cap protections under Civil Code sections 1946.2 and 1947.12, respectively. Housing advocates in the City of Santa Ana saw the rush by landlords to evict tenants or raise their rents ahead of the protections before they became law.17 There have been active discussions in Santa Ana City Council meetings regarding rent control since 2015. In 2016, there was a discussion about the City of Santa Ana attaching a potential rent stabilization ordinance to the sanctuary city ordinance for the City of Santa Ana. In 2017, multiple advocates have commented in City Council meetings about the need for this Ordinance. In late 2017 and through the rest of 2018, members of the Santa Ana City Council have heard remarks, met with several individuals, and actively discussed the implications of such rent caps and potential just cause eviction ordinances. The City Council was split in favoring the potential new ordinance. After hearing the possibility of rent caps as early as Fall 2017, several landlords in the City of Santa Ana increased the rent in anticipation of this potential Ordinance. (cc) In unusual cases where a cap on rent increases poses difficulty for a particular landlord, the legal requirement for a fair return is satisfied so long as an adequate process is established for the landlord to seek an individualized adjustment. Courts in California have long upheld the constitutionality of the maintenance of net operating income (MNOI) standard in these individualized determinations. The MNOI standard typically indexes increases to those found in the CPI, including indexing the MNOI standard at less than 100% of the change in the CPI. One " See Santa Ana Residents Say Landlords are Evicting Them Ahead of New State Law, City Council Balks on Emergency Tenant Protections Voice of O.C., https://v0iceofoc.ore/2019/11/santa-ana-residents-say-landlords-are-evictine-them-ahead-of-new-state-law city coup cil-balks-on-emergency-tenant-protections/ (Last accessed on May 17, 2021). 11