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DOWDALL LAW OFFICES <br />A PROFESSIONAL CORPORATION <br />ATTO R N EYS AT LAW <br />City Council of the City of Santa Ana <br />City of Santa Ana <br />September 16, 2021 <br />Page 13 <br />3. ENVIRONMENTAL CONSEQUENCES STUDIED? NO. <br />Decline in building maintenance is unavoidable. While it appears the city has declined to <br />review the environmental consequences of stringent rent controls in any form of robust analysis, <br />other cities have undertaken the responsibility to understand and evaluate what rent control does <br />on existing populations and on property maintenance. This is one reason why, indeed, the city of <br />Los Angeles which neighbors Santa Ana (as recognized by the Ordinance) did undertake an <br />environmental impact report to check on the significant effects upon the environment caused by <br />rent control. Since the environment is of foremost concern to many, that direct and immediate <br />impact caused by the ordinance cannot be simply disregarded. <br />Increasing the frequency of rent increase hearings while at the same time encouraging <br />the diminution in quality of life and housing services by reducing maintenance as a natural <br />consequence of reducing cash flow, will affect the environment. It has been shown that rent <br />controls also increase commute time because tenants will not move closer to their work if the <br />rent is maintained at artificially low levels. The increase commute time for those in the working <br />population is significant. The city has recognize that a significant portion of the residents that <br />live in mobilehome parks in the city of Santa Ana are in food service. Restarting employment <br />with restaurants that have not been shut down and going out of business will require travel. It is <br />natural to live near one's work. Rent control will stop that from happening. The effect on the <br />types of automobiles driven, the mileage, the length of time on crowded freeways, and the <br />impact on air quality have not been studied by the city. <br />This proposal is clearly a project which requires an environmental impact report. Again, <br />the City of Los Angeles ordered preparation of an environmental impact report for the original <br />RSO in the 1970s. City attorney Claudia McGee stated that the city had a legitimate concern <br />regarding the environmental impact created by the rent control law (at a well -attended seminar <br />for attorneys regarding rent controls in the early 1980s). This threat to the environment is even <br />greater when the city is precipitating an onslaught of rent increase applications. This was not <br />formally the case, when the environmental impact report was commissioned. The case for an EIR <br />is more compelling now. <br />An EIR Is Required in Order to Address the Significant Effects of the Proposal <br />Proximately Resulting in Reduction of Housing Maintenance and Services. <br />The proposal for this form of old-fashioned rent control immediately hits maintenance of <br />housing services, buildings, cleaning, and labor. History is clear that the forced reduction of <br />revenue takes away revenue needed to maintain property. Coupled with increased travel to the <br />city for administrative hearings by thousands of landlords and their experts, attorneys, <br />accountants, managers, and tenants, even the travel patterns are within the city will be <br />detrimentally affected in a significant way by reason of the spiking frequency of administrative <br />hearings trying to obtain rent adjustments to maintain the status quo of economic returns. <br />-13- <br />