Resolution Number 90-12-4-4RESOLUTION NO. 90-12-4-4
MAKING FINDINGS AND DETERMINATION -
SAN JUAN MOBILE ESTATES RENT PETITION
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
SAN JUAN CAPISTRANO, CALIFORNIA, MAKING FINDINGS
AND A DETERMINATION IN THE MATTER OF SAN JUAN
MOBILE ESTATES RENT PETITION PROTESTING A RENT
INCREASE OF 268 BY THE SAN JUAN MOBILE ESTATES
PARK OWNER, SAN JUAN INVESTORS, LTD.
WHEREAS, San Juan Investors, Ltd., owner of San Juan
Mobile Estates, seeks a monthly rental increase of approximately
268 over and above the average monthly rental for each space in
the mobile home park; and,
WHEREAS, this rental increase was imposed on park
residents in a two-part form, namely, a 5.18 increase, plus
additional flat amount of $70.00 per rental space per month; and,
WHEREAS, the City of San Juan Capistrano has enacted
rent control ordinance regulations for mobile home parks found at
San Juan Capistrano Municipal Code Section 2-2.901 et seq.; and,
WHEREAS, the residents of this park filed a timely
petition with the City of San Juan Capistrano invoking the rent
review procedures of the Municipal Code; and,
WHEREAS, the park owner submitted several reasons for
the large 268 increase found in the "Data and Information" sheet
marked as Exhibit 3 in the Administrative Record; and,
WHEREAS, the owner's reasons set forth in the data and
information sheet included: a) that real property tax expenses
were a basis for the increase; b) that governmental assessments
were a basis for the increase; and c) that a need for fair return
on property was a basis for the increase; and,
WHEREAS, City, Park Owner, and Residents have stipulated
that 5.18 of the total 268 increase is allowed under the CPI
formula of Municipal Code Section 2-2.902(d); and,
WHEREAS, it is further agreed that the issue to be
resolved is whether the $70.00 portion of the rent increase which
exceeds the maximum allowable increase under the CPI formula of
the Code should be affirmed, modified, or reversed; and,
WHEREAS, this rent review is governed by the provisions
of Municipal Code Section 2-2.902 et seq.; and,
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WHEREAS, pursuant to Municipal Code Section 2-2.905(c),
Hearing Officer Drosman recommended to the City Council that the
$70.00 portion of the increase be disallowed as set forth in his
findings of September 25, 1990; and,
WHEREAS, pursuant to Municipal Code Section 2-2.905(d),
the Mobile Home Park Review Committee adopted a resolution making
the same finding of Hearing Officer Drosman; and,
WHEREAS, the City's rent control ordinance provides for
full vacancy decontrol, that is, the park owner is free to raise
rents without limitation with respect to new lessees coming into
the park; and,
WHEREAS, the City Council has carefully considered the
Hearing Officer report, Mobile Home Park Review Committee
Resolution, oral and written arguments of the park owner and park
residents, and all evidence submitted to the Hearing Officer
during the Hearing Officer proceeding, all of which documents are
set forth in the Administrative Record dated November 20, 1990.
NOW, THEREFORE, BE IT RESOLVED, by the City Council of
the City of San Juan Capistrano as follows:
Findings.
A. The Park Owner's
rn on Investmen
(1) The Park Owner submitted evidence showing that
in 1990 the Park Owner extinguished his ground
lease with the owner of the land by purchasing
the land, and in so doing, incurred an
additional $194,256.00 in additional interest
expense per year. Had the owner not purchased
the land from the landowner, the owner would
have faced an additional lease expense of
$209,000 since the lease term was up.
The park owner sets forth his own "return on
investment" formula, by arguing that this
additional land expense plus the value in his
capital tied up with the purchase has now
substantially reduced his return on
investment.
The owner also argued that this expense should
in fact be treated as a "pass through" that
is, that he should automatically be given a
rent increase by passing this cost along to
the park residents.
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The City's Municipal Code provides for a non-
exclusive set of criteria to guide the Council
in making a final determination as to whether
the rent increase is fair and reasonable.
Increased land costs is one factor the City
Council does consider. It is also an element
affecting fair return on property. However,
the park owner did not submit any evidence,
such as a current verified income and expense
statement, demonstrating the current
profitability of the park. The Hearing
Officer found that he could not award a
portion or all of the $70.00 increase because
it was unclear as to the degree to which the
purchase of the land (or in the alternative
the lease increase) would affect the
profitability of the park. The hearing
officer noted that "while it is reasonable to
deduce an impact on rate of return caused by
higher expenses, such an increase does not
automatically render the rate of return as
less than adequate."
The Municipal Code does not guarantee that
increases of this type may be automatically
passed along to the park tenant. The Code
requires that all relevant factors be
considered in evaluating rent increases.
While acquisition expenses are relevant, a
number of other factors, such as total income
are also a part of the picture. The park
owner possesses current income/expense
statement information and could have easily
presented it. It is not enough to show an
increase in expenses without showing the
extent to which total expenses are offset by
operating income. The Review Committee made a
similar finding in its resolution in stating,
"The owner failed to present evidence giving a
complete financial analysis as to how his
increased costs would impact the profitability
of the park."
The Council further finds that the owner's
argument on "return on investment" financial
analysis is not binding on the Council in that
Municipal Code Section 2-2.9905(g)(3)(iii)
that a "return on investment" accounting
formula is not a mandatory standard.
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(2) The 5.1% increase will generate approximately
$62,600 in additional revenue (310 spaces x
$330.00 average rent x 5.1 = $16.83 per month
x 12) to the park owner by September 1991.
(3) The Hearing Officer found that the park owner
r-.
chose not to present current income and
expense statement evidence, or other evidence
of owner's profits.
(4) Under the City's rent control provisions, the
owner is free to raise rents without
restriction at the time of a space turnover.
This will provide additional rent revenue,
over time, to the owner to help defray his
land purchase interest expense, considering
that new rents for new tenants are
approximately $550.00 per month at this
park. Assuming for example a vacancy turnover
rate of only 5% of total spaces within the
next 12 months, the owner could realize an
additional $36,000 in rental income just from
that limited turnover of spaces.
B. Real Property Tax and Governmental Assessment
The Hearing Officer found that no evidence had been
presented showing the County Assessor has imposed
additional real property taxes, either through
reassessment on the sale of the property, or from
the City of San Juan Capistrano open space bond
assessments. Since the exact amount of those taxes
are unknown, the Council agrees with the Hearing
Officer that a rent increase award for these
reasons now is inappropriate. The owner is free to
propose a rent increase for these costs, pursuant
to either Municipal Code Section 2-2.902(d)(4) or
Municipal Code Section 2-2.905(a), at such time
that these taxes and assessments are incurred by
the owner.
II. Conclusions.
A. Decision. The Council has considered all of the
owner's arguments, including the owner's
November 13, 1990 submittal; the Council has
considered all factors in light of City's rent
ordinance provisions that require Council to
consider all relevant factors. Council finds that
in light of all facts, the 26% increase is not fair
and reasonable because the owner has not presented
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a complete financial picture as to the extent to
which the profitability of the park is in fact
impacted by land acquisition costs.
B. Rent Award. Pursuant to the CPI formula of the
Code, the park owner is awarded a 5.1% rent
increase from the date set forth in his notice of
rent increase.
The flat $70.00 per month/per space increase is
disallowed based upon the above -stated findings.
C. Excess Rents Refunded. Rents collected in excess
of the 5.1% shall be refunded to each park resident
within thirty (30) days from December 4, 1990.
Accordingly, each resident is obligated to pay only
the 5.1% increase henceforth.
PASSED, APPROVED, AND ADOPTED this 4th day
of December , 1990.
ATTEST:
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STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss
CITY OF SAN JUAN CAPISTRANO )
I, CHERYL JOHNSON, City Clerk of the City of San Juan
Capistrano, California, DO HEREBY CERTIFY that the foregoing is a
true and correct copy of Resolution No. 90-12-12-4
adopted by the City Council of the City of San Juan Capistrano,
California, at a regular meeting thereof held on the 4th
day of December , 1990, by the following vote:
AYES: Councilmen Buchheim, Bland and Mayor tlausdorfer
NOES: None
ABSTAIN: Councilmen Friess and Schwartze
ABSENT: None
(SEAL) 1t
CHERYL JOHNSON, CITY CLERK Q
CHECK LIST p
ORD. NO. RES. NO. 90
✓ Mayor has signed
�— Clerk has signed
T City Seal stamped
All blanks tyF
"Absent"
"Noes"
"Abstain"
Copies sent to
Legal Publication ordered to be published
(date)
No. Printed copies required
Remarks
Q.