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reason is that such indexing accounts for the fact that a landlord's return on investment is not limited to the revenue from rent rolls, but also includes increases to the landlord's equity in the property and overall appreciation of the property. Another reason is that a major component of the CPI is determined by increases in housing costs, which are often driven by speculation rather than maintenance costs, and thus these costs unduly influence the rise in the overall CPI. Over the last 40 years, the change in the CPI for the Los Angeles -Long Beach -Anaheim region for "All items less shelter" was approximately 80% of the change in the CPI for "All items." The People of the City of Santa Ana find that indexing the MNOI standard at 80% of the change in the CPI for "All items" is reasonable and will guarantee that landlords will obtain a fair rate of return on their investments. (ff) The Tenant Protection Act of 2019 (AB 1482) caps the statewide rent increases to 5% in addition to CPI, which will not greatly benefit Santa Ana residents who are experiencing displacement even with increases at or below this level due to the high levels of low income renters who live in Santa Ana. Additionally, the Tenant Protection Act excludes many Santa Ana residents from just cause eviction protection, including new tenants who have resided in a new apartment for less than a year. Furthermore, it currently exempts rent stabilization to renters living in mobile home parks, duplexes, and triplexes, who comprise 18.5 percent of Santa Ana's population per the 2019 American Community Survey (ACS). (ee) In the City of Santa Ana, Mobilehome Parks comprise approximately 5.2 percent of all housing in the City of Santa Ana. There are twenty-nine Mobilehome Parks containing three thousand nine hundred thirteen spaces. Six of the Mobilehome Parks and one thousand twenty spaces in the City of Santa Ana are currently age -restricted to persons 55 years of age or older. (gg) There exist substantial differences in the rent charged for space in the Mobilehome Parks in the City of Santa Ana. In April 2019, the City of Santa Ana conducted a phone survey to assess Mobilehome Park rents. The seven Mobilehome Parks surveyed had monthly rents between $594 and $2,200. In April 2019, the City of Santa Ana obtained data from the Santa Ana Housing Authority on assisted Mobilehome Owners and found that monthly rents in nine Mobilehome Parks ranged from $550 to $1,400. (hh) In the City of Santa Ana Assessment of Existing Conditions of Mobilehome Parks, all but two of the surveyed seven main Mobilehome Parks in the City of Santa Ana have consistently adjusted rents each year. Some of these monthly rents reach up to $1550 per month28 (ii) The Mobilehome Parks in the City of Santa Ana are currently experiencing drastic increases in rent. For example, there are 34 spaces at Bali Hi Mobilehome Lodge (Bali Hi), an age " See Staff Report filed a Santa Ana City Council on May 21, 2019, citing City of Santa Ana Mobilehome Parks Assessment of Existing Conditions and Policy Options, p. 65A-12 to 65A-13, available at https //santaana.uanicus com/MetaViewer bhp?view id-2&clin id=2346&meta id=89043, last visited on December 13, 2019. 12