BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 2587
                                                                  Page 1

          Date of Hearing:   April 30, 2014

               ASSEMBLY COMMITTEE ON HOUSING AND COMMUNITY DEVELOPMENT
                                   Ed Chau, Chair
               AB 2587 (Hernandez) - As Introduced:  February 21, 2014
           
          SUBJECT  :   Mobilehome Parks: Rent Control.

           SUMMARY  :   Authorizes the legislative body of a local government  
          to conduct a regional mobilehome park rent survey and limit the  
          base rent amount for mobilehome space rent agreements meeting  
          certain conditions.  Specifically,  this bill  :  

          1)Authorizes local governments to conduct a regional mobilehome  
            park rent survey, after publishing a notice of preparation of  
            the survey in a newspaper of general circulation, and mailing  
            the notice by first-class mail to the management of each  
            rental mobilehome park in its jurisdiction.

          2)Defines "regional mobilehome park rent survey" or "survey" as  
            a written survey of mobilehome park rent levels within a  
            geographically relevant market area that compares and  
            describes the rent levels in mobilehome parks within the 12  
            months preceding the publication of the notice of preparation.

          3)Provides that a local government may publish a notice of  
            public hearing for considering the survey and hold the public  
            hearing at least 90 days following the notice of hearing.

          4)Requires that a copy of the rent survey shall be available for  
            public inspection within 15 days of publication of the notice  
            of public hearing.

          5)Authorizes a local government to consider, approve, or approve  
            with changes the information contained in the survey at the  
            public hearing, including the boundaries of the geographically  
            relevant market area.

          6)Requires a local government, within 30 days following the  
            approval of the survey, to mail a notice of its approval of  
            the survey and the base rent amount to the management of each  
            rental mobilehome park within its jurisdiction.

          7)Authorizes a local government to, within 12 months after the  
            approval of the survey, limit the base rent for the following  








                                                                  AB 2587
                                                                  Page 2

            types of mobilehome space rent agreements:

               a)     The rental of a mobilehome park space, whether  
                 occupied by a manufactured home or not, if the rental  
                 agreement is not extended and no new rental agreement in  
                 excess of 12 months' duration is entered into.

               b)     The rental of a mobilehome space if the space is  
                 vacant for a period of 30 days.

          1)Provides that an interested person may seek judicial review of  
            the approved survey and the limited base rent amount.


           EXISTING LAW: 

          1)Regulates, pursuant to the Mobilehome Residency Law (MRL), the  
            rights, responsibilities, obligations, and relationships  
            between mobilehome park management and park residents (Civil  
            Code Section 789, et seq.).

          2)Specifies that a rental agreement in a mobilehome park in  
            excess of 12 months' duration and meeting certain conditions  
            that is entered into between the management and a homeowner  
            for the personal residence of the homeowner is exempt from any  
            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 (Civil  
            Code Section 798.17).

          3)Provides that if a long-term lease expires and is not  
            extended, and no new rental agreement in excess of 12 month is  
            entered into, then the following occurs:

               a)     The space is no longer exempt from a rent control  
                 ordinance, if any; and

               b)     The last rental rate charged for the space under the  
                 previous lease shall be the base rent for purposes of any  
                 applicable rent control law.  

            (Civil Code Section 798.17)

          1)Exempts any mobilehome that is not the principal residence of  
            the homeowner and that has not been rented to another party  








                                                                  AB 2587
                                                                  Page 3

            from rent control.  (Civil Code Section 798.21)

           FISCAL EFFECT  :   None.

           COMMENTS  :   

           Background:  

          In the majority of mobilehome parks, residents own their homes  
          but rent the spaces on which their homes are installed.   
          "Mobilehome" is something of a misnomer in that once installed  
          in a park, it is very rare for a mobilehome to be moved.  This  
          is due to both the difficulty and cost involved, and also  
          because the supply of mobilehome spaces is very limited,  
          vacancies are rare, and most park owners do not allow the  
          installation of older mobilehomes in their parks.

          Over 100 jurisdictions in California have some form of local  
          rent control ordinance limiting the amount of rent or  
          establishing a maximum amount of rent that the management of a  
          mobilehome park may charge a tenant. Birkenfeld v. Berkeley  
          (1976) 17 Cal. 3d 129, provides that cities and counties have  
          within their policy and regulation powers the authority to enact  
          rent control laws so long as a fair return is assured to  
          property owners.  Under existing law, local governmental  
          entities are free to enact rent control laws regarding  
          mobilehome parks.  These local laws are not subject to the  
          state's Costa-Hawkins Act restricting permissible rent control  
          ordinances, but in certain circumstances the Mobilehome  
          Residency Law (MRL) exempts certain mobilehome park spaces from  
          local rent control.  Under existing law, rental agreements which  
          are twelve months or longer are exempt from local rent control.


           Purpose of the Bill:

           According to the author, as mobilehome rent continues to  
          increase, renters may believe it is in their best interest to  
          enter into long-term leases for over 12 months.  These leases  
          often have built in rental increases, which may end up costing  
          more than fair market value.  AB 2587 would allow a local  
          government to conduct a regional base rent survey.  After 90  
          days, the local government may consider, approve, or approve  
          with changes the information contained in the survey.  The base  
          rent amount will apply to rental space that has been vacant for  








                                                                  AB 2587
                                                                  Page 4

          30 days or more, to rental space with lease agreements shorter  
          than 12 months, and to rental space where a rental agreement is  
          not extended.  The author contends that renters will not feel  
          obligated to enter into long term leases for over 12 months if  
          the local government establishes a base rent limitation.

          The author cites a specific example in the city of El Monte  
          involving a mobilehome park that has a history of exorbitant  
          rent increases while failing to maintain the grounds.  The  
          author notes that the average annual household income for El  
          Monte residents living in non-mobilehomes is about $53,063. By  
          comparison, El Monte's mobilehome residents make about $33,958  
          annually, which is 64% of the average household income of  
          residents in non-mobilehomes.  In the author's view, this bill  
          will ensure fair market values for mobilehome rental spaces.

           Arguments in Support:

           Supporters contend that AB 2587 will ensure fair market values  
          for mobilehome rental spaces by allowing a local government to  
          survey the relevant market area in order to determine a fair  
          base rental rate.  Mobilehome parks are an important source of  
          affordable housing for many low-income households and senior  
          citizens.  In supporters' view, as mobilehome space rent  
          continues to increase, renters may believe it is in their best  
          interest to enter into extended leases that are exempt from rent  
          control.  Supporters contend that this bill will empower local  
          governments with rent stabilization to establish objectively  
          adequate base rent levels in accordance with current demographic  
          and economic data.
           
          Arguments in Opposition:

           Opponents argue that the bill will likely be declared  
          unconstitutional, as the base rent determination does not take  
          into consideration specific park attributes of the community or  
          ensure a fair rate of return.  Opponents contend that, in  
          addressing one bad actor in El Monte, this bill will adversely  
          impact park owners throughout the state.  In opponents' view,  
          there are already laws in place that may be used to enforce the  
          law against park owners who violate statutes or regulations, and  
          this bill is an overly broad remedy for an individualized  
          situation.  

           History:  








                                                                  AB 2587
                                                                  Page 5


          As noted above, this bill addresses a situation involving a  
          mobilehome park in the city of El Monte.  In July 2012, after  
          hearing complaints of excessive rents from residents of this  
          park, the El Monte City Council passed a resolution calling a  
          special election in November 2012.   At this election, voters  
          passed Measure F, which overturned a 1990 City ordinance that  
          prohibited the City from examining mobilehome rents or  
          implementing rent stabilization. On September 3, 2013, the City  
          of El Monte adopted Ordinance No. 2829, the Mobilehome Rent  
          Stabilization Ordinance. 

          There are two pending court cases involving the above-referenced  
          mobilehome park:

          1)Cortez v. Brookside Investments, Ltd., Los Angeles Superior  
            Court case no. KC057251 

          This is a case by past and present residents against Brookside  
          Mobile Country Club in El Monte. There are several causes of  
          action, including nuisance for poor park maintenance, breach of  
          contract, negligence, intentional infliction of emotional  
          distress, breach of statutes/interference with property rights  
          for interfering with mobilehome sales, unlawful retaliation, and  
          illegal eviction.  The complaint includes allegations that the  
          Plaintiff raised rents to unreasonable levels for residents who  
          were on month-to-month rental agreements, and only agreed to  
          reduce these rents if these residents agreed to sign long-term  
          leases which would be exempt from any future rent control. This  
          case was filed in November 2009 and is currently pending.

          2)Brookside Investments, Ltd. v. City of El Monte Los Angeles  
            Superior Court case no. BC503836

          This is a case brought by Brookside Mobile Country Club against  
          the City of El Monte to challenge the passage of Measure F in  
          2012, which overturned a 1990 City ordinance that prohibited  
          rent control.  The passage of Measure F resulted in the  
          subsequent passage of Ordinance No. 2829 in 2013, which  
          established mobilehome rent control in the City of El Monte.   
          This case was filed in March 2013 and is currently pending.   
          There is an upcoming hearing on the Defendant's Motion for  
          Summary Judgment on June 6, 2014.  

           REGISTERED SUPPORT / OPPOSITION  :   








                                                                  AB 2587
                                                                  Page 6


           Support 
           
          City of El Monte (sponsor)
          California Alliance for Retired Americans

           Opposition 
           
          Western Manufactured Housing Communities Association 
          California Association of Realtors
          California Mobilehome Parkowners Alliance 
           
          Analysis Prepared by  :    Rebecca Rabovsky / H. & C.D. / (916)  
          319-2085