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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 8 of 10 is still true is a false statement based upon the evidence presented. Further, housing instability and the resulting hardships are related to a lot of factors, many of which were created by the City and State, excessive regulations, fees; by the City's failure to provide the rent subsidies for which it had funds; more recently, the rapid and substantial increase in interest rates; rising costs of utilities, insurance and other taxes. As Councilmember Phan would say, there are a lot of tools the City can use to address the homelessness and related issues rather than pass Ordinances which violate settled law and the actions of the City in failing to work with the very people who provide the housing — the owners of the housing. D. This is a descriptive statement of the action taken to study the regulatory framework. E. The Amendments to and Consolidation of the RSO and JCEO into one Ordinance did not result in "efficient and effective program services to rental property owners," specifically mobilehome park owners but did substantially increase services to the renters in all types of rental properties. It is not the scope of this Opposition to reiterate the legal deficiencies and violations of statutes, you are referred to the Record in the hearings related to adoption of the ordinances and pending litigation. The Staff Report for October 4, 2022 had the same issues related to a lack of credible evidentiary backing and a continued refusal to include the owners of the rental units in the meetings, discussions and considerations of the proposed and then adopted amendments. Specifically, as to mobilehome residents and park owners, the mere addition of a provision that states (sort of) if any provision of the Ordinance conflicts with the Mobilehome Residency Law, California Civil Code sections 798 et seq., then the Mobilehome Residency Law controls. The mobilehome residents and Mobilehome Park owners are then left with obligation to determine what does and does not apply. Further, there is no reference to the other controlling Federal and State Statutes including their implementing regulations and case law interpretations. F. There is no evidence or other factual materials provided to support this Finding. Assuming an owner is not complying with the RSO-JCSO Ordinance, the mechanism for requiring enforcement is contained within the Ordinance. Therefore, this Finding is irrelevant to the proposed Amendment to the Ordinance in that these Amendments will not change or alter the City's current enforcement privileges. The remedies for these complaints are within the City's "tools" already- G. This is a conclusory statement which sounds politically well placed but stability is dependent upon the City passing procedurally and substance appropriate Ordinances, availing itself of other "tools" (e.g., reducing regulations and costs related thereto, implementing the ordinances and/or permitting by State statute the increase in housing via ADUs and JADUs, providing the funding available to it for the benefit of the residents and other similar actions). If by "stability" the intent is to "never change," that is not possible given the right of the Federal and State governments to change laws and interpretations of existing law by judicial decision. Further, this limits the rights of the citizens, both tenants and owners, to exercise their rights to request changes. Lastly, as