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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 20 See also, Guidelines, 14 Cal.Admin.Code Section 15064(i) ("Where a physical change is caused by economic or social effects of a project, the physical change may be regarded as a significant effect in the same manner as any other physical change"). Moreover, an Environmental hnpact Report is required if there is a serious public controversy over the effects of a project -- the effect or the effects subject to the controversy shall be considered to be significant. No Oil v. Los Angeles (1974) 13 Cal.3d 68. There may be a difference of opinion on whether a particular effect should be considered significant or not, but again, this determination is of no moment. The issue is whether or not there is "substantial evidence" of the potential or possibility of a significant effect, whatever the contradictory or controverting evidence. For these foregoing reasons, the City of Los Angeles must prepare an Environmental Impact Report prior to the passage of any proposed rent control law. The potential environmental effects of rent control are as follows: 1. Services, amenities, facilities, and improvements to the residents will be significantly reduced by rent ceilings which deprive park owners of the ability to maintain the existing business operation. 2. No improvements to the mobilehome park can be planned or made in the future, except as necessary to comply with law, for many mobilehome park owners because of the impossibility of obtaining increased rents necessary to fund or secure construction and development. 3. Existing budgets for maintenance and personnel will be decreased 4. Existing budgets for repairs and replacements will be decreased. 5. The operating budget for recreational halls, clubhouses, and common facilities will be decreased. 6. The residents in the parks will reduce maintenance and serviceability of their trailers and coaches, and management may lack the resources to cover the business expense of requiring uniform compliance. The physical quality of life for the residents will therefore deteriorate. 7. The conversion rate of mobilehome parks in the city will increase. Under State law, new construction in mobilehome parks is entitled to a statewide exemption effective as of January 1, 1990. More mobilehome park owners will find an incentive to strive for such a new construction exemption and convert their properties accordingly. 8. Property adjacent and proximate to such mobilehome parks may also suffer the consequences of loss of value and deterioration due to the disincentive for maintenance by reason of the diminution in the services, facilities, and amenities in mobilehome parks impacted by the proposal. -20-