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DOWDALL LAW OFFICES A PROFESSIONAL CORPORATION ATTO R N EYS AT LAW City Council of the City of Santa Ana City of Santa Ana September 16, 2021 Page 15 In order to consider all substantial evidence, public notification is required so that the public can intelligently weigh the environmental consequences of any contemplated action and have an appropriate voice in the formulation of any decision. Karlson v. City of Camarillo (1980) 100 Cal.App.3d 789, 804, as cited at Concerned Citizens, etc. v. 32nd District, etc. (1986) 42 Cal.3d 929, 938. The public participation should assist the agency in weighing the mitigation measures and alternatives to a proposed project. Public Resources Code §§ 21100, 21151. Approval of a project involving mobilehome parks, particularly for all mobilehome parks within a city as would be impacted by a mobilehome rent control ordinance, raises the possibility (if not the certainty) of numerous negative and adverse environmental effects. In People v. Dept. of Housing and Community Development ("HCD") (1975) 45 Cal.App.3d 185, the court held, for example, that a single mobilehome park construction permit was a clearly discretionary act and therefore subject to CEQA. As discussed in Friends of Westwood, Inc. v. City of Los Angeles (1987) 191 Cal.App.3d 259 at 271, the construction and the maintenance of a mobilehome park involves all aspects of a living environment for a large number of residents. In this case, of course, the impact on the residents would be of a City-wide scale, which is a far greater undertaking than a project on just one parcel. In HCD, the court held that impact on the environment must be considered based on the mobilehome park's facilities such as water supply, ground drainage, sewage disposal, artificial lighting, and grading. Of course, environmental impact is no less significant during the existence and on -going operation and maintenance of a mobilehome park than it is at the inception of the project. When modifying that course of continuing operation, the legislative scrutiny should be, a fortiori, even more greatly magnified. This is especially imperative when every mobilehome park would be affected by the proposed ordinance. Altering or modifying the course of existing operations or maintenance of all on -going projects gives rise to precisely the concerns, issues, and public debate which are relevant at the inception or initial consideration of one project. A rent control law impacts all mobilehome parks in a far more dramatic fashion than planning determinations about the initial construction of the facilities and improvements of just one parcel. That rent control holds the potential for explosive environmental impact is no mere speculation. Historically, rent controls have had devastating impacts on whole neighborhoods. Rent controls have caused calamitous environmental consequences, including deterioration of buildings, structures, facilities, together with the social fabric of entire communities. In Housing and Development Administration v. Community Housing Improvement Program (1975) 374 N.Y.S.2d 520,the court extensively noted the severe deterioration and destruction of neighborhoods proximately resulting from the effect of rent controls on landlords. "There was testimony that rental property is being abandoned at a rate exceeding 30,000 units a year, but the generally agreed -upon number by housing and planning agencies is 30,000. While cities without rent control may be suffering abandonments, it is clear however that in cities with rent control, housing units are being pushed over the brink and abandoned because of rent control. Housing units are now regressing from 'stable,' to 'deteriorating,' to 'dilapidated,' to 'vacant,' -15-