BILL ANALYSIS                                                                                                                                                                                                    






                             SENATE JUDICIARY COMMITTEE
                           Senator Ellen M. Corbett, Chair
                              2009-2010 Regular Session


          AB 761 (Calderon)
          As Amended March 24, 2010
          Hearing Date: June 29, 2010
          Fiscal: No
          Urgency: No
          BCP:jd
                    

                                        SUBJECT
                                           
                              Mobilehomes: Rent Control

                                      DESCRIPTION  

          This bill would provide that, upon the sale, assignment,  
          transfer, or termination, of a mobilehome tenancy in a  
          mobilehome park, the management may increase the rent by a  
          minimum of 20 percent or $100, whichever is greater (thereby  
          permitting "partial vacancy decontrol"), as specified.  

                                      BACKGROUND  

          Enacted in 1978, the Mobilehome Residency Law (MRL) governs the  
          relationship between park owners or managers and the residents  
          of the 4,800+ mobilehome parks and manufactured housing  
          communities in California.  In most of those parks, residents  
          own their home but lease the land on which their home is  
          installed.  Although they have historically been called  
          "mobilehomes," it is very difficult to actually move a  
          mobilehome once it has been installed in a park.

          To protect mobilehome park residents from rent increases on the  
          property underlying their home, over 100 jurisdictions in  
          California have enacted some form of rent control.  Those rent  
          control ordinances are a proper exercise of the local  
          government's police power if their provisions are "reasonably  
          calculated to eliminate excessive rents and at the same time  
          provide landlords with a just and reasonable return on their  
          property." (Birkenfeld v. Berkeley (1976) 17 Cal.3d 129, 165.)   
          Although mobilehome parks are not subject to the Costa-Hawkins  
          Rental Housing Act (which restricts the use of rent control in  
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          other residential properties), the MRL does limit the  
          application of rent control in certain circumstances, including  
          if the lease agreement is greater than 12 months, or if the  
          mobilehome is not the owner's principal residence and is not  
          being rented to another party. 

          There are three main types of rent control ordinances - vacancy  
          control, vacancy decontrol, and partial vacancy decontrol.   
          Vacancy control ordinances generally prohibit a rent increase  
          when a mobilehome is sold and new tenants occupy the space.   
          Vacancy decontrol ordinances permit management to increase the  
          rent upon "vacancy" and then place the new rental rate under  
          control of the rent control ordinance.  Partial vacancy  
          decontrol, a variant of vacancy decontrol that is used by some  
          jurisdictions, also permits a rent increase upon "vacancy," but  
          limits the increase to a specified amount (usually a percentage  
          of the previous rent).

          In the case of sale, assignment, transfer, or termination of an  
          interest in a mobilehome, this bill would allow park management  
          to employ "partial vacancy decontrol" to set the initial rent at  
          an amount in excess of the maximum rent established by the rent  
          control ordinance by a minimum of 20 percent or $100.

                                CHANGES TO EXISTING LAW
           
           Existing law  requires local governments to make adequate  
          provision for their share of the regional need for housing for  
          all income levels, including the need for housing affordable to  
          households of very low income and low income. (Gov. Code Secs.  
          65580 - 65589.8.)

           Existing law  , the Costa-Hawkins Rental Housing Act, prohibits  
          "vacancy control" rent control laws for residential real  
          property, excluding mobilehome parks.  That Act requires a local  
          rent control law for residential real property to permit the  
          owner to raise the rent upon the termination of a prior tenancy  
          and the creation of a new one, as specified. (Civ. Code Sec.  
          1954.50 et seq.)

           Existing law  provides that rental agreements between management  
          and a mobilehome owner that are in excess of 12 months are  
          exempt from local rent control if specified requirements are  
          met.  (Civ. Code Sec. 798.17.)

           Existing law  exempts all newly constructed mobilehome spaces  
                                                                      



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          held out for rent after January 1, 1990 from local rent control.  
           (Civ. Code Sec. 798.45.)

           Existing law  exempts mobilehomes that are not the principal  
          residence of the homeowner and that are not rented to another  
          party from local rent control.  (Civ. Code Sec. 798.21.)

           This bill  would provide that, notwithstanding any contrary  
          provision of law, upon the sale, assignment, transfer, or  
          termination of an interest in a mobilehome or mobilehome tenancy  
          in a mobilehome park, the management of the park may offer a new  
          rental agreement containing an initial rent in excess of the  
          maximum rent established by an ordinance, rule, regulation, or  
          initiative measure adopted by a city, county, or city and  
          county, by a minimum of 20 percent or $100, whichever is  
          greater.  That increase would be added to the base rent and  
          shall be the base rent for purposes of applicable provisions of  
          law concerning rent regulation.

           This bill  would provide that no increase in the rent that may be  
          charged pursuant to the above provision shall be permitted  
          within 36 months of the last increase pursuant to that  
          provision.

           This bill  would prohibit a rent increase upon a sale or transfer  
          if the sale or transfer is either to a trust, provided that all  
          members of the trust are homeowners, or to a member of a  
          homeowner's immediate family, and the mobilehome becomes the  
          principal place of residence for the immediate family member.

           This bill  would provide that its provisions do not apply if any  
          of the following circumstances exist:
                 An assignment of a rental agreement that is exempt from  
               rent control under existing law due to being in excess of  
               12 months. 
                 The mobilehome space is already exempt from rent control  
               because it is either: (1) not the principal residence of  
               the homeowner and not rented to another party; or (2)  
               because it is new construction. 
                 A rental mobilehome park is converted to resident  
               ownership, as specified;
                 The sale, assignment, transfer, or termination of an  
               interest in a mobilehome or mobilehome tenancy in a park is  
               not subject to an ordinance, rule, regulation, or  
               initiative measure adopted by any local government entity  
               that establishes a maximum amount that a landlord may  
                                                                      



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               charge a tenant for rent.
                 Any applicable ordinance, rule, regulation, or  
               initiative measure adopted by any local governmental entity  
               that establishes a maximum amount that a landlord may  
               charge a tenant for rent authorizes a greater increase than  
               that provided above.

                                        COMMENT
           
          1.   Stated need for the bill 

          According to the author:

            AB 761 allows partial vacancy de-control which would be a  
            20% (or $100) increase in rent when there is a turnover in  
            the tenancy.  The bill also prohibits an increase if a home  
            is sold or transferred within a 36 month period.  AB 761  
            would only apply to rent control jurisdictions that have a  
            more restrictive policy than 20% or $100.  For example, some  
            jurisdictions allow for full vacancy decontrol (rent raised  
            to market upon turnover) and this bill would not affect  
            those ordinances.  The $100 component is essential in areas  
            where the rent has been held so artificially low that 20%  
            would be a minor increase in relation to actual market rent.  
             For example, Capitola's rent control ordinance has been in  
            place since 1979 [and] has some of the lowest rents in the  
            state, approximately $200 a space, yet the jurisdiction  
            right next door has rents in the $600-$800 a month range.   
            Last year one park owner in Capitola was granted a 28-cent  
            rent increase.  However, a mobilehome park owned by the City  
            of Capitola raised its own rent on "second home" owners to  
            $600, still well below the market rents of $1500, but still  
            far above the $200 mobilehome parks are allowed to charge.  

          2.    Opposition's concerns  

          By permitting partial vacancy decontrol in mobilehome parks,  
          this bill would preempt local rent control ordinances that  
          currently restrict the ability of management to set a higher  
          base rent upon vacancy.  As a result, that initial rent - which  
          may exceed the maximum established by the rent control ordinance  
          by either 20 percent, or $100 - would be imposed despite a  
          decision on the local level to cap rents at a specified amount.   
          The opposition, including numerous residents of mobilehome  
          parks, express concern about the potential loss of equity as a  
          result of this bill, and that rents for those new residents will  
                                                                      



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          increase to a point where they are no longer affordable.

            a.   Drop in housing values  

            Unlike a traditional stick-built home, the value of a  
            mobilehome is based upon not only the home itself, but the  
            land upon which it sits and the rental price that will be  
            charged.  As a result, the actual value of the home depends in  
            some part on the amount of the rent that will be charged by  
            park management.  Individuals on a fixed or low-income must  
            ensure that they are able to pay not only their loan payment,  
            but also the rental payment for the space.

            Given that the result of this bill would be to permit a higher  
            rental rate to be charged to a subsequent owner of a  
            mobilehome - the net result would likely be to reduce the  
            value of those homes because part of the price of the home  
            necessarily reflects the amount of rent that may be charged to  
            the purchaser.  The Hayward Mobilehome Owners Association, in  
            strong opposition, states that:

               As the vast majority of mobilehome owners are elderly,  
               seniors and the disabled who subside on extremely limited  
               incomes, the anticipated future sale of our homes becomes  
               paramount as for many of us our mobilehomes constitute  
               our only substantial asset.

               All of us face the inevitability that one day we must  
               leave our mobilehome communities and move into assisted  
               living in order to receive the additional degree of care  
               we will require as we age.  As assisted care facilities  
               are extremely costly, any legislation which impairs our  
               ability to find buyers who will pay a fair dollar amount  
               for our homes will have devastating consequences with  
               regard to our future comfort and well-being.  The bottom  
               line is that if AB 761 becomes law, we will have to  
               substantially reduce the selling price of our homes in  
               order to compensate the new owner for the substantial  
               increase in rent.

            The Golden State Manufactured-Home Owners League (GSMOL), in  
            opposition, further notes that mobilehomes are significant  
            investments, potentially the most valuable asset owned by a  
            senior or person with fixed income.  GSMOL further asserts  
            that the direct consequence of the higher rents authorized by  
            this bill is "a devaluation in mobilehome equity at the time  
                                                                      



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            of resale, resulting in damage to the investments of tens of  
            thousands of low income and senior homeowners throughout the  
            state."

            As an example of the potential reduction in housing prices,  
            the author contends that a home that is valued at $20,000 can  
            sell for $60,000 or more, even though it is only worth  
            $20,000.  The author further notes that if vacancy decontrol  
            were in place, "the home may sell for only $20,000 or $30,000,  
            somewhere closer to the actual value." If that example were to  
            hold true, the effect of this bill would be to cause the  
            property to drop in value from $60,000 to $20,000, a loss of  
            $40,000 in equity that the owner may have been counting on as  
            part of his or her retirement.  That drop in value would  
            affect not only members, but those financial institutions with  
            loans secured by the property - Bay Federal Credit Union, in  
            opposition, expresses concern that under AB 761: "our ability  
            to protect our security interest in our mobilehome mortgages  
            will be seriously harmed [by AB 761] and it will cause our  
            members to lose a substantial portion of their investments in  
            their mobilehomes."

            Considering the recent economic downturn and the impact that  
            the loss of home equity has had on numerous Californians, the  
            Committee should consider whether the loss of equity resulting  
            from the passage of AB 761 might result in similar unintended  
            consequences.  From a policy standpoint, steps have been taken  
            on the state and federal level in an attempt to stabilize the  
            housing market, and this bill appears to run counter to those  
            efforts by acting to reduce resale values of homes in these  
            communities.

            b.   Increased rents  

            The California Commission on the Status of Aging, in  
            opposition, notes that: "Many older adults live on fixed  
            incomes - many of which have been greatly reduced in the  
            recent stock market declines.  The shortage of low-cost  
            housing already makes it very difficult for low-income adults  
            to find appropriate housing when they can no longer keep up  
            with the expense of a large family home.  Rent control affords  
            them an important protection based on local government's  
            commitment to keep housing affordable for elders and other  
            low-income individuals."

            The California Rural Legal Assistance Foundation (CRLA), in  
                                                                      



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            opposition, further contends that this bill would "change the  
            rules in the middle of the game" for homeowners who "bought in  
            a rent-control city paid a fair price for their home based on  
            the reasonable expectation that they would be able to re-sell  
            their homes under the same rules. "  In those jurisdictions  
            affected by AB 761, the bill would instantly devalue those  
            homes by removing a protection that the homeowner paid a  
            premium for when purchasing the property.

            Although this bill would permit an increase of 20 percent, or  
            $100, whichever is greater, the net effect would be to erode  
            away at rent control in mobilehome parks.  At some point,  
            every property would be transferred and every rent would be  
            increased.  The policy choice for this Committee is whether to  
            respect the authority of local governments to enact rent  
            control ordinances for mobilehome parks - if AB 761 preempts  
            those ordinances, the rent in mobilehome parks will increase  
            while the resale value of those units would decrease.  For  
            local communities that have made a policy decision to preserve  
            the affordable rents in their mobilehome parks, this bill  
            would disregard that local choice in favor of a broad approach  
            not tailored to their specific situations.

            It should also be noted that since AB 761 would permit the  
            rent to be increased by 20 percent, or $100, upon the sale of  
            the mobilehome, and that the value of the home decreases as  
            the rent increases, any purchaser is in the unique  
            circumstance of knowing that if they were to sell their  
            property, the property will be worth less due to the increased  
            rent that may be charged to the subsequent purchaser.  That  
            knowledge - that a house you are buying will be instantly  
            worth less upon purchase - could discourage individuals from  
            purchasing homes in these communities (potentially driving  
            prices down even more).

          3.   Rent control jurisdictions  

          Western Manufactured Housing Communities Association, sponsor,  
          provides the following information about the current number of  
          mobilehome rent control jurisdictions:
                 52 local jurisdictions employ full vacancy control  
               (rental rate remains the same upon turnover)
                 38 employ partial vacancy decontrol (rental rate is  
               adjusted to be a certain percentage of the previous rent  
               and then put back under rent control)
                 18 employ vacancy decontrol (rental rate is adjusted to  
                                                                      



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               market rent and is re-rent controlled)

          This bill would effectively remove vacancy control in those 52  
          jurisdictions.  For those that already have partial vacancy  
          decontrol, this bill would affect the vast majority which permit  
          an increase of far less than the proposed 20 percent, or $100.   
          (For example, Concord permits an increase of 10 percent, and  
          Modesto limits increases to 6 percent.)  As a result, this bill  
          would not only remove vacancy control, but permit rent increases  
          that are in excess of those permitted by local jurisdictions  
          that actually desire to impose partial vacancy decontrol, but  
          have elected to permit more modest increases.

          Western Center on Law & Poverty, in opposition, further asserts  
          that "[t]hese ordinances were not created in a vacuum, but in  
          response to local conditions, including rent-gouging attempted  
          by some park owners, knowing that mobilehomes cannot  
          realistically be moved.  Local governments are in the best  
          position to determine what kinds of rent controls, if any, are  
          needed."

          4.    Increase of a "minimum of 20 percent or one hundred dollars  
            ($100), whichever is greater"
           
          Western Center on Law & Poverty notes that "that the bill  
          requires any rent increase to be a 'minimum' of 20[percent] or  
          $100, whichever is greater, and no maximum (page 2, lines 9-10).  
           If the intent of the bill is to establish these figures as a  
          maximum, the bill should clearly state that."  Committee staff  
          notes that WCLP appears to be correct - the author's and  
          sponsor' background materials, including the above stated need  
          for the bill, all note the intent to have the increase be either  
          20 percent, or $100, whichever is greater.  That use of  
          "minimum" may at best create confusion, and at worst, permit an  
          increase greater than 20 percent. 


           Support  :  California Association of Realtors

           Opposition  :  AARP California; Bay Federal Credit Union;  
          California Commission on Aging; California Rural Legal  
          Assistance Foundation; City of Los Angeles; City of Santa Rosa;  
          Pueblo Springs Mobilehome Owners Association; Golden State  
          Manufactured Home-Owners League (GSMOL); GSMOL Members residing  
          in Desert Sands Mobilehome Community; Hayward Mobilehome Owners  
          Association, Inc.; League of California Cities; Western Center  
                                                                      



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          on Law & Poverty; hundreds of individuals

                                        HISTORY
           
           Source  :  Western Manufactured Housing Communities Association

           Related Pending Legislation  :  None Known

           Prior Legislation  :  None Known

           Prior Vote  :

          Assembly Housing and Community Development Committee (Ayes 4,  
          Noes 0)
          Assembly Housing and Community Development Committee (Ayes 4,  
          Noes 2)
          Assembly Floor (Ayes 38, Noes 27)
          Assembly Floor (Ayes 42, Noes 27)

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