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Orozco, Norma <br />From: Shane Phillips <shanedphillips@gmail.com> <br />Sent: Tuesday, September 21, 2021 2:11 PM <br />To: eComment <br />Subject: Agenda item #33 -- city council meeting, 9/21/2021 <br />Hello, <br />I am writing as a housing policy researcher in support of agenda item #33, the City of Santa Ana's rent <br />stabilization proposal. <br />Rent stabilization is not a panacea, and must be paired with housing supply policies to promote the production <br />of sufficient homes to meet growing demand, but it should be viewed as a complement to housing production <br />rather than a competitor. Rent stabilization helps residents stay in their homes and provides much -needed <br />certainty about where they will live and the prices they will pay in the future. Adequate housing production (in <br />addition to subsidies for rental assistance and income -restricted development) is necessary to ensure long-term <br />affordability, but tenant protections like rent stabilization offer short-term relief while longer -term strategies are <br />pursued. Just as addressing homelessness requires both permanent supportive housing (long-term) and shelters <br />(short-term), a well-rounded housing policy requires building more homes and tenant protections. <br />In the past, rent control has been designed in ways that lead to negative outcomes for many households. The <br />policy features most likely to produce poor outcomes are vacancy control and applying rent control to new <br />housing. Both of these options are forbidden by the Costa -Hawkins Rental Housing Act, dramatically lowering <br />the chances that rent stabilization will reduce housing production or otherwise harm the City of Santa Ana. The <br />most likely unintended consequence is that some landlords will choose to convert their buildings to owner - <br />occupied uses like condos or tenancies -in -common, and the city should at a minimum provide some mitigations <br />against uncompensated eviction of tenants for such conversions. Most importantly however, as noted above, the <br />best policy to discourage conversions of rental housing is to encourage abundant production of new housing, <br />not to leave tenants vulnerable to rent increases of 5-10% per year (subject to AB 1482 limitations). <br />I would offer one policy recommendation, and that is to strike the 3% cap on annual rent increases. Limiting <br />rent increases to 80% of CPI should be sufficient. By setting a 3% cap you run the risk of having years in which <br />inflation is very high, possibly 6% or above, with costs to landlords increasing much faster than revenues. This <br />in turn could put you afoul of legal restrictions relating to a "reasonable rate of return." The City of Los Angeles <br />approved its rent stabilization program in the 1980s, when inflation was very high, and as such set a floor of 3% <br />on annual rent increases (rather than a cap of 3%, as the Santa Ana council proposes). Santa Ana should avoid <br />making a similar mistake, though in reverse, by not assuming that inflation rates will be at low levels <br />indefinitely. <br />Thank you, <br />Shane Phillips <br />Housing Initiative Project Manager <br />UCLA Lewis Center for Regional Policy Studies <br />