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LOFTIN I BEDELL P.C. City of Santa Ana City Council c/o Office of City Clerk City of Santa Ana August 28, 2023 Page 4 of 10 one councilmember stating at the hearing that the first knowledge and notice was provided to the entire council four days prior to the hearing.7 As a general observation and objection to presentation of evidence and factual justification for the 2021 Ordinances and 2022 Ordinance, and the request before the Council in Agenda 21 to Amend the 2022 Ordinance, the footnotes 5, 6, 7, and 8 provide only web page connections for the public to access for review rather than the customary and ordinary method of providing the factual or other information upon which an Agenda item is based as an attachment to the Staff Report. By not providing the materials upon which the conclusions are purportedly based by attachment/exhibit, ready access to many people is excluded. This Opposition will follow the same method of reference to exhibits as "footnotes" utilized in the Staff Report but offer to anyone who requests, the opportunity to receive a full copy of the referenced materials via email by contacting Lauren Caggiano at Assistant@loftinbedell.com. As to Staff Report Footnote 5 ("SR Footnote"), the Biden Report supporting the adoption of rent control and acknowledging the City of Santa Ana as one of the cities adopting such ordinance fails to analyze the specific facts related to the specific jurisdictions or types of housing or confirm the compliance of said statutes with the state specific statutory and related case law. In the SR Footnote 7, the description information in the Staff Report for that document is misleading in that it states, "Accessed August 17, 2023," whereas the document specifically states, "Owner -occupied housing unit rate 2017- 2021" and does not include total employment, income or other financial/economic information. Lastly, the housing costs, it does not distinguish mobilehomes from other types of housing. The evidence submitted at the hearings for the 2021 Ordinances clearly established that the rent increases over five years in all parks averaged 34%. Housing costs cannot be resolved by the passing of rent control. Other participants creating excessive housing costs, e.g., governmental regulations, need to be addressed. The impact of rent control is not just on a big corporation, it is on its small investors such as retirees and retirement plans, and small business owners.9 Acknowledgment is due to the City that since the 2021 hearings at which time the City had an excess of funds in its tenant relieve fund, that the City appears to be focusing on using those and other governmental funds to assist financially challenged tenants. The Santa Ana Park owners would appreciate a like acknowledgment for its program to assist the financially challenged mobilehome owners. See, 2021 Record, and Video of September 21, 2021 Hearing, for focus, 6:25 to 6:50 p.m. s Staff Report, Footnote 7, Census, Quick Facts was identified by the computer accessed date August 17, 2023 which misrepresented the validity of the data for this hearing in that the date range for the data of 2017 to 2020 was not included. The housing costs category does not distinguish the costs nor rental amounts applicable to mobilehomes and mobilehome spaces from other types of housing. For example, there is no acknowledgement that in California there are mandatory statutory restrictions and protections related to evictions, the Tenant Protection Act and the Mobilehome Residency Law. 9 For an analysis of the historical and current issues related to housing and governmental action: Roderick Wright, California State Senator (Retired), "Politics of a Housing Crisis," California Rental Housing Association, June 1, 2022. (https:Hcal-rha.or/the-politics-of-a-housing-crisis/)