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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 16 to 'unsafe,' to 'abandoned,' as a result of many factors, the most significant of which is rent control." Id., 374 N.Y.S.2d 520 at 525. The effect of rent control upon property owners included the deprivation of sufficient monies to enable the payment of real estate taxes. "Nonpayment of real estate taxes has created several problems. One of these is the loss of badly -needed revenue to the city, with total arrears now estimated at almost $600 million, and that does not include arrears in water rents and sewer rents. In almost all such cases, revenue from a building is simply not enough to encompass the required payments, and property owners cannot pay taxes." Id. Consequently, the "rent gap" (i.e., the difference between what landlords actually collect in rents and what is needed to even minimally subsist and to maintain housing units) made it impossible for the landlords under the rent control law to "...comply with building codes or to pay for the labor for proper maintenance among other things." Id. Would the proposed rent control regulation have an impact upon the quality of life, the environment, and the facilities and services offered in mobilehome parks in the City? Clearly, the ordinance portends such impacts and relationships, and concern for residents' physical welfare. If there are plausible environmental consequences which are arguably possible, the consequences must be evaluated by the preparation of an Environmental Impact Report. Does the ordinance potentially pose adverse environmental impacts? Yes. The nexus between the effects of the Ordinance and the impact on the environment is clear. Regulation of the reduction in services and facilities in mobilehome parks is necessary only if negative impact is expected by rent restrictions. The rent restrictions force mobilehome park owners to consider alteration or modification of the physical environment enjoyed by the residents. Such proposed or potential modifications as historically and scientifically documented, will obviously affect the living environment of the residents, and, consequently, constitute an adverse environmental impact as well. Certainly, it is not in the interest of any property owner to change or modify the appearance of a property so as to, potentially, reduce value. No property owner rationally and intentionally seeks to diminish the value of his property. But economic realities posed by government over -regulation causing potential adverse impacts necessitate such analysis. Again, this scenario is no mere speculation. The effects of stringent rent controls are too well documented to be controverted or debated. Historically, the well -established reality of environmental impact caused by rent control on real property has been clearly demonstrated: -16-