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work with property owners, specifically mobilehome park owners, to address the numerous deficiencies with the amended ordinance. In the past year, my organization, WMA, was never contacted to seek input into the final product under consideration. Some members of our industry have had to litigate to get concerns resolved. I refer to the September 30, 2022 letter from the Loftin Bedell Law Firm representing Kingsley Management in their lawsuit with the City of Santa Ana. In their very technical letter, the Loftin Bedell Firm outlines the numerous conflicts with state law applicable to mobilehome parks and Santa Ana's ordinance. WMA and mobilehome park owners join Kinsley Management's concerns about the requirement of a "tenant impact report" prior to a property sale and defining a sale as a "change of use" and the needed clarifications as to how Fair Rate of Return/MNOI and Capital Improvements applications will be determined with the application of the amended ordinance. Rent Board Make U One of the final outstanding items for the Council to consider is the make-up of the rent board. The only obvious solution would be same number of tenants to landlords, which uphold both party's due process. In fact, any quorum of the board should include a balance of tenants to landlords. The discussion at the September 6th City Council meeting to have more tenants than landlords will place a finger on the scale of balance. This biased approach permits a future council to stack the board with all landlords since impartiality and equity aren't principles at the center of Santa Ana's ordinance. Mobilehome park owners are not a required party to serve on the rent board, yet every other stakeholder is represented. Council gave direction that one of the tenant representatives should be from a mobilehome park. Yet, mobilehome owners are not to be included on the board? Owning and operating mobilehome communities is a unique and specialized form of rental property ownership and the City of Santa Ana and the future rent board would be well served with this expertise reviewing applications. Options like use of administrative law judges and hearing officers have never been discussed or considered. Also, perhaps mobilehome applications have a separate board to hear mobilehome matters? There are other options than a myopic solution currently offered. We respectfully request delaying this action to receive further input from various stakeholders —especially mobilehome community owners —to be considered by the city. Sincerely, Julie Paule, Regional Representative Western Manufactured Housing Communities Association Sacramento Office: 455 Capitol Mall Suite 800, Sacramento, CA 95814 1 (916) 448-7002 Regional Office: 40335 Winchester Rd. #E165, Temecula, CA 92596 1 (951) 704-2427 1 julie@pauleconsulting.com