DATE: September 3, 2025
TO: Honorable Mayor and City Councilmembers
FROM: Housing and Neighborhood Services Department
TITLE: TENANT PROTECTIONS: CONSIDERATION OF AN ORDINANCE REGARDING LOCAL TENANT PROTECTIONS TO ADDRESS NO-FAULT JUST CAUSE TERMINATIONS OF TENANCY AND ACCEPTANCE OF A REPORT ON OTHER MEASURES FOR RESIDENTIAL TENANT PROTECTIONS
RECOMMENDATION
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Staff recommends that the City Council:
1. Introduce and place an ordinance on first reading to add Chapter 14D to the Oceanside City Code entitled “Residential Tenant Protections.” (First Reading); and
2. Accept a report on other local measures to address tenant protections, including rent stabilization and eviction protection programs, and provide further staff direction as necessary.
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BACKGROUND AND ANALYSIS
California is home to some of the nation’s most rent-burdened individuals and families, with San Diego at the forefront of California’s affordable housing crisis. In its September 2024 Rental Housing Market Report, Zillow listed San Diego as one of the least affordable metro areas for renting in the entire country, surpassed only by Miami, New York, Los Angeles and Riverside.
Assembly Bill (AB) 1482, which went into effect on January 1, 2020, created a statewide limit on rent increases for certain residential rental properties and strengthened eviction protections for renters. While AB 1482 sought to protect residents, due to the high demand for housing, loopholes in the law resulted in some landlords moving tenants out only to bring rental units back on the market at higher rental rates. Subsequently, Senate Bill (SB) 567, effective April 1, 2024, enhanced tenant protections through greater enforcement tools and addressed specific potential loopholes related to tenancy terminations in California rental housing. Collectively, AB 1482 and SB 567, are known as the California Tenant Protection Act (CTPA) and regulate residential tenancy terminations statewide. The CTPA also permits local governments to adopt requirements consistent with state law for just cause termination of a residential tenancy that are more protective.
On April 9, 2025, staff received direction from the City Council to return with a future item to consider the adoption of a Tenant Protection Ordinance to enhance the CTPA, a report on tools available to address residential tenant displacement such as rent stabilization, and eviction protection programs.
Staff is presenting for City Council’s consideration the adoption of a local residential tenant protection ordinance for termination of residential tenancies which would provide for an expansion of tenancies benefiting from such protections and additional restrictions and requirements for certain no-fault tenancy terminations (see Attachment 2). This staff report also provides a framework for a potential local rent stabilization ordinance, should the City Council decide to formally initiate consideration of such a program. Finally, options for enhanced tenant eviction protection programs are also presented for further consideration.
CA Tenant Protection Act of 2019 (“CTPA”) (AB1482 and SB 567):
AB 1482
Recognizing the high cost of housing and the impact of these costs on many Californians’ housing stability, the state established the California Tenant Protection Act of 2019 or AB 1482, as codified in California Civil Code Sections 1946.2, 1946.12, and 1946.13 (the “Act”). A summary of AB 1482 and SB 567 is provided as Attachment 3.
AB 1482 codified tenancy protections statewide for residential tenants, regardless of income level, in continuous and lawful occupancy of residential real property for a minimum 12-month period. It sets specific conditions for ending a residential tenancy: terminations must be based on Just Cause, which can be classified as either At-Fault or No-Fault. Tenancy terminations based on At-Fault Just Cause means the tenant took actions (or lack of actions) that warrant ending their tenancy. Typical reasons are nonpayment of rent or violations of the terms of the lease. No-Fault Just Cause tenancy terminations are allowed for limited reasons even when the tenant has not violated the lease and has paid their rent. No-Fault Just Cause reasons for terminating a tenancy include: (1) owner or owner’s family member move-in; (2) substantial remodel or complete demolition of the rental property; (3) taking the property off the rental market (Ellis Act); and (4) a court order or other law forcing the closure of the rental property.
AB 1482 also gives tenants certain rights and benefits when their tenancy is ended based on Just Cause. These include:
§ Receiving a notice of tenant protections as an addendum to the lease or other written notice;
§ Notice and opportunity to cure, for curable lease violations, a violation that is the basis for an At-Fault Just Cause termination of tenancy;
§ Written notice at least 30-60 days prior to termination specifying the cause for the termination of tenancy; and,
§ 1-month’s rent or waiver of last month’s rent for relocation assistance for a No-Fault Just Cause termination of tenancy.
In addition to requiring At-Fault or No-Fault Just Cause for terminating a tenancy, AB 1482 imposes state-wide rent stabilization, setting a rent cap at 5% a year plus the percentage change in the regional cost of living (referenced as the Consumer Price Index or CPI) from the previous year, but not to exceed 10% for the year. Rents can be increased twice in a year so long as it does not exceed the rent cap for that year. For San Diego County, for those rent increases that take effect on August 1, 2025 through July 31, 2026, the maximum rent increase is 8.8%.
SB567
SB 567 was introduced to close “loopholes” in AB 1482 that some landlords were exploiting by evicting tenants without fulfilling the stated reasons listed in the termination notice, such as substantial remodel of rental units and owner move-in provisions. Effective April 1, 2024, SB 567 modified two specific No-Fault bases for termination to add required conditions, noticing, and remedies. This included tenancy terminations for substantial remodel and based on owner or owner’s family move-in. A property owner's failure to comply with any provision of this section for tenancy terminations renders the written termination notice void (Civil Code §1946.2(g)).
SB 567 also created new consequences for violations of the Act (Civil Code §1946.2(h)).
1. An owner who attempts to recover possession of a rental unit in material violation of the law is liable to the tenant in a civil action for actual damages and, in the court’s discretion, reasonable attorney’s fees and costs.
2. Upon a showing that the owner has acted willfully or with oppression, fraud, or malice, an owner is liability for up to three times the actual damages, in addition to punitive damages.
3. Authorizes the Attorney General and the City Attorney to bring actions for injunctive relief.
The CTPA allows local jurisdictions to create their own ordinances to provide greater tenant protections as long as the just cause for termination of a tenancy in the local ordinance is consistent with the CTPA. In instances where a local jurisdiction enacts an ordinance that is more protective than the CTPA provisions, the local protections supersede the CTPA.
Local Tenant Protections
On April 9, 2025, the City Council directed staff to prepare a local tenant protection ordinance, consistent with the CTPA and to specifically address the following key areas of tenant protection law:
§ Applicability of tenant protections for certain properties and timeframe for tenancy;
§ Further defining what qualifies as a Substantial Remodel;
§ Enhanced Relocation Assistance;
§ Noticing requirements for residential tenants and filing with the City;
§ Right to return for previous tenants;
§ Disclosure of residential tenants’ rights, including manufactured home residents under OCC Chapter 16B;
§ Rent stabilization of a 5% yearly rent increase with 8% to support facility improvements; and,
§ Increasing access to legal services for tenants.
Staff recommends introducing an ordinance adding Chapter 14D to the Oceanside City Code entitled “Residential Tenant Protections” that is responsive to the direction provided by the City Council and provides for greater tenant protections than the CTPA. Table 1 provides a summary of the issues specific to tenant protections for Just Cause Terminations of Tenancy and provides details of how staff have addressed these areas in the attached ordinance.
A discussion of the framework for rent stabilization and programs related to assist tenants with issues of termination of tenancy are presented later in this staff report. Staff would request additional Council direction to proceed on those items in the event further Council action is desired.
Table 1: Summary of Enhancements to CTPA
|
CITY COUNCIL COMMENTS |
PROPOSED LOCAL ENHANCEMENTS |
|
Applicability of TPO |
Expands tenant protections to newly constructed housing (defined as housing that has been issued a certificate of occupancy within the previous 15 years).
Housing units constructed within the past 15 years are exempt from CTPA under CA Civil Code Section 1946.2(e)(7). |
|
Length of Tenancy for Protections |
Expands benefits of tenant protections to tenants who have occupied the residential unit for at least 6-months.
The CTPA applies to tenancies established for 12-months or more under CA Civil Code Section 1946.2 (a). |
|
Relocation Metric of U.S. Department of Housing and Urban Development (HUD) Small Area Fair Market Rent (SAFMR) |
It is proposed to use the small area Fair Market Rents (SAFMR) published by HUD annually (see Attachment 4 for the SAFMRs for the five zip codes of Oceanside). With market rents increasing, SAFMRs would provide more flexibility in financial assistance for displaced tenants to obtain housing. CA Civil Code Section 1946.2 provides that relocation assistance for those tenancies terminated based on a no-fault just cause be provided equal to one month of the tenant’s rent that was in effect when the owner issued the notice to terminate the tenancy. |
|
Substantial Remodel |
Narrows the definition of substantial remodel by revising the requirement that such remodel cannot be reasonably accomplished in a safe manner with the tenant remaining in place for at least 60 continuous days. CA Civil Code Section 1946.2 (b)(2)(D) defines the time period as a minimum of 30 consecutive days.
Staff proposes explicitly excluding work such as flooring replacement, cabinet replacement, counter replacement, window replacement, or improvements required to render a residential rental unit fit for human occupancy in accordance with California Civil Code Section 1941 from what is considered a substantial remodel. |
|
Noticing and Disclosure of Residential Tenant Protection Ordinance and Chapter 16B-Manufactured Home Fair Practices Act for manufactured home residents. |
Owners shall provide the following:
§ Notice of the termination of residential tenancies covered by the ordinance to the City within three (3) days.
§ Notice to tenant of the tenant protection provisions of the Ordinance as an addendum to the lease/rental agreement or a written notice signed by the tenant.
§ Owners would be required to provide a copy of a City Notice of Disclosure of Chapter 14D with the Notice of Termination of Tenancy for No-Fault Just Cause and upon entering/renewing a lease.
Amend the Administrative Guidelines for the implementation and enforcement of Chapter 16B to include a requirement for the owner/property manager to provide notification of Chapter 16B resident protections and to maintain a signed receipt with leases/rent agreements. This will be referred to the City’s Manufactured Home Fair Practices Commission for their review and recommendation to City Council. |
|
Right to Return |
CTPA provides for the right to return for those tenants that are displaced due to:
§ Substantial remodel or demolition (at the new market rate) or if the remodel or demolition never occurs (at the previous contracted rent)
§ An owner or family member move in where the owner or family member fails to move in within 90 days or occupy the residential unit as their primary residence for a 12-month period (at the previous contracted rent), along with reimbursement of moving costs.
Enhancements are proposed for those residential units removed from the rental market under the Ellis Act. A tenant would have the right to renew their tenancy, upon the tenant’s written notification to the owner of their desire to renew tenancy along with tenant’s address or email address for communication, in the event that the residential rental unit is offered again for rent or lease within two years of unit being withdrawn from the rental market. |
Staff Recommendation – Residential Tenant Protections
An ordinance adding Chapter 14D to the OCC has been prepared and is attached to this staff report for City Council’s consideration for introduction. If adopted at a subsequent meeting, the Ordinance would take effect 30 days thereafter.
Rent Stabilization in California and the Costa-Hawkins Rental Housing Act
The Costa-Hawkins Rental Housing Act, AB 1164, was signed into law in 1995 and codified as California Civil Code Sections 1954.50, et seq. It places limits on the ability of local governments to enact rent stabilization laws.
There are two key provisions of the Costa-Hawkins Act:
1. Exemptions: It prohibits cities from imposing rent stabilization on certain residential units, including single-family homes, condominiums, and newly constructed apartment units. Generally, 'new' means any building constructed after February 1, 1995. For cities with existing rent stabilization laws, 'new' refers to those buildings constructed after the enactment date of the local rent stabilization ordinance.
2. Vacancy Control: Costa–Hawkins also prevents “vacancy control,” which means that landlords have the right to set the rent for a vacant unit at any price (usually market rate) rather than be restricted by the prior rent.
Repeal of the Costa-Hawkins Rental Housing Act
Since 2017, California voters have had four opportunities to repeal the Costa-Hawkins Act.
1. Introduced in 2017, AB 1506, proposed a wholesale repeal of the Costa–Hawkins Rental Housing Act. This bill failed to pass, with opponents arguing rent stabilization may discourage new construction at a time when housing is needed the most.
2. Proposition 10, also seeking to repeal wholesale the Costa-Hawkins Act, was defeated in 2018 by a vote of 38% in favor and 62% against.
3. Proposition 21, on the ballot in 2020, was an attempt to have a more limited and partial repeal of Costa-Hawkins, but also failed, with 40% voting in favor and 60% voting against.
4. More recently, in November 2024, California voters considered the Justice for Renters Act, Proposition 33. By repealing Costa-Hawkins, the Justice for Renters Act would have allowed local governments to impose rent stabilization on newer apartments, condominiums, and single-family homes, and eliminate the state’s ban on vacancy control. Additionally, this measure would have prohibited the state from limiting the right of local governments to maintain, enact, or expand residential rent stabilization laws. Proposition 33 failed, with 38% voting in favor and 62% voting against.
Local Rent Stabilization
While cities may adopt local rent stabilization laws, these laws must follow the parameters of the Costa-Hawkins Act. Therefore, any law adopted today cannot allow for vacancy control, setting limits to rent increases upon vacancy and rental to a new tenant, and cannot extend rent stabilization to any condominiums, single-family homes, or any housing built after 1995. Today, 32 out of 482 California cities have enacted rent stabilization laws. A summary of these local rent stabilization laws is provided in Attachment 5.
Currently, in the San Diego County region, no jurisdiction has adopted broad rent stabilization policies, with the exception being regulations that apply specifically to manufactured home communities. The San Diego region relies on the statewide rental rate cap. With 98 percent (98%) of Oceanside’s housing stock older than 15 years, most rental housing would be subject to the state rent cap. Jurisdictions in California with rent stabilization are primarily in Los Angeles County and the Bay Area including the cities of Los Angeles, Unincorporated Los Angeles County, Beverly Hills, Culver City, West Hollywood, Inglewood, Santa Monica, Berkeley, Campbell, East Palo Alto, Fremont, Hayward, Los Gatos, Oakland, Oxnard, Palm Springs, San Francisco, San Jose, and Thousand Oaks.
Oceanside adopted a rent stabilization ordinance in 1982 for manufactured homes, OCC Chapter 16B-Manufactured Home Fair Practices Act. Chapter 16B provides a relevant framework for consideration of a rent stabilization ordinance for all residential rental properties.
In addition to complying with relevant law, such as the Costa Hawkins Act, rent stabilization ordinances require significant resources to implement and enforce.
Rent Increases
In general, of those communities with rent stabilization for rental housing, the rent increases are calculated at a percentage of change in the Consumer Price Index with a maximum rent increase set anywhere from 2-3% and as high as 8-10%. Current rent increases across the state for those with local rent stabilization is around 3%. For San Diego County under the CTPA, an 8.8% rent increase is allowed for the period of August 1, 2025 through July 31, 2026.
In establishing a local rent stabilization ordinance, the following factors would be considered:
§ Limiting rent increases to a certain percentage based upon regional data for cost of living (e.g. CPI);
§ Limiting the number of annual rent increases;
§ Establishing processes for rent increases based upon a just and reasonable return;
§ Local sanctions and penalties for failure to comply; and
§ Fees to support the local program.
Under OCC Chapter 16B, park owners are authorized to adjust rents in July of each year based upon the lesser of 8 percent or 75% of the increase in the Consumer Price Index (CPI) for the San Diego-Carlsbad Metropolitan Statistical Area (MSA). The current annual permissive rent adjustment for 2025 is 2.33%.
Just and Reasonable Return
Both the United States Supreme Court and California Supreme Court have held that rent stabilization is a proper exercise of a local government’s police power if it is calculated to eliminate excessive rents, as long as it provides landlords with just and reasonable returns on their property. A just and reasonable return has been described as one that is high enough to encourage good management, reward efficiency, and discourage the flight of capital; and is commensurate with returns on comparable investments, but not so high as to defeat the purpose of preventing excessive rents.
For a local ordinance with an annual increase provision that is more restrictive than that provided by the CTPA, there must be a procedure by which an applicant can seek an additional increase on the basis the annual increase is insufficient to provide a just and reasonable return. Generally, a landlord who believes they are not receiving a fair and reasonable return may appeal to the city or county to implement an increase greater than the amount otherwise applied.
Rent stabilization ordinances can provide the following methods to increase rents including:
§ Capital Improvement Program: Landlords can recover costs for improvements to the rental unit or common areas for items that benefit the tenant.
§ Below Market Rate Increases: For residential properties below current market rate rents (e.g., 80% below Fair Market Rents), rents may be adjusted to reflect the market.
§ Just and Reasonable Rent Increase: A landlord can apply for a rent increase when their net operating income adjusted for inflation is not sufficient to cover the property’s operating costs.
§ Tenant Buy Out Agreement: A landlord and tenant can mutually agree for the tenant to vacate the residential unit in exchange for compensation.
§ Vacancy De-control: Landlords are allowed to increase rents to market rate upon vacancy of a residential unit previously under vacancy control.
Under OCC Chapter 16B, additional processes are available for park owners to seek rent increases above the annual permissive rent adjustment, such as rent adjustments based upon Net Operating Income and Fair Rate of Return.
Rent Stabilization Staff and Commission
Appeals and approvals to the adjustment of rents may be initially reviewed by staff or by a separate commission or hearing officer with expertise in the local rent stabilization ordinances. For Chapter 16B, the Manufactured Home Fair Practices Commission serves as a quasi-judicial body implementing and administering Chapter 16B. In addition to a commission or hearing officer, dedicated staff is needed for the administration and enforcement of a rent stabilization ordinance.
To cover operational costs of the program, a registry of all residential units subject to rent stabilization is implemented and requires a registration fee. Under Chapter 16B, all manufactured home spaces (approximately 2,580 spaces) within 17 manufactured home communities register with the City and pay a fee of $183 per space. Half of this fee is passed on to the resident. Fees charged by California cities for rent stabilization of residential units range from $30 per residential unit upwards of $240 per unit. Many pass through half of such fees to residential tenants.
The impact of administration and implementation of rent stabilization on staff resources can be significant. For example, the Fiscal Year (FY) 2025 budget for the City of Pasadena Rent Stabilization Department is approximately $4.7 million with a Full Time Equivalent (FTE) of 17 employees and is not inclusive of a Deputy Assistant Attorney dedicated to rent stabilization. Pasadena regulates just over 31,300 residential rental units. For Santa Monica, approximately 26,650 rental units are registered. The FY 2025 budget of approximately $6.8 million covers 24 FTEs. With an anticipated 26,791 residential rental units in Oceanside, of which 18,185 rental units were built prior to 1990, it is anticipated that operational costs would be in the range of approximately $2.7 million with the number of FTE staff positions to be determined.
Current Legislative Efforts
Several bills were proposed in early 2025 to address rent stabilization and tenant protections. AB 1157 aimed to lower rent caps to 2% plus inflation with a maximum rent increase of 5%, expand tenant protections to single-family homes, and make tenant protections permanent, beyond the 2030 sunset. While the author withdrew AB 1157, it is a two-year bill and could be brought forward in the 2026 legislative session. SB 262 sought to provide incentives to those local governments adopting rent stabilization policies through the pro-housing designation program and the associated funding priorities. While ultimately, these bills did not move forward, rent stabilization and tenant protections are still being considered at the state level.
Staff Comments on Rent Stabilization Program
Consideration should be given to the staffing and financial resources necessary for implementation of a local rent stabilization ordinance, especially in light of ongoing discussions at the state level that may ultimately result in enhanced tenant protections that could negate the need for further local action. While the City has experience in the implementation of rent stabilization for the manufactured home community, administration, implementation and enforcement of a broader rent stabilization program would require significant resources of time and staffing to establish and maintain. Because responsibility of establishing a rent stabilization program would likely fall on the Housing and Neighborhood Services Department, the creation of a rent stabilization program at this time could divert staff time and resources away from other critical housing programs including those related to homelessness prevention and the production of affordable housing (at least in the near term). Immediate resources and additional Council direction would be needed to proceed if further Council action on Rent Stabilization is desired.
Eviction Prevention Programs
While a Tenant Protection or Rent Stabilization Ordinance provides formal mechanisms to benefit residential tenants and contains enforcement provisions, other programs such as community education and training regarding the rights and the obligations of both landlords and tenants could be considered. In April 2024, the City Council received a report on the CTPA and allocated $25,000 to provide a proactive education and outreach program regarding the CTPA carried out by the City’s current fair housing and landlord-tenant provider, CSA San Diego. CSA San Diego continues to provide these services Monday to Friday at the Chavez Resource Center and Libby Lake Resource Center, in addition to providing information and education at specific community events and workshops and training of staff.
In addition to education and outreach, some communities have added legal service support to their programs. The City of San Diego, through the San Diego Housing Commission’s contract with the Legal Aid Society, provides education and public awareness and emergency legal assistance. Through the Emergency Legal Assistance program, lower-income San Diego households with a rent payment obligation may receive full legal representation through the pre-eviction and eviction process, in settlement negotiations and through trial, if necessary. Legal services and assistance are also provided through clinics, hotlines or appointments (virtual or in person). San Diego has operated this program in conjunction with the COVID eviction moratoriums at budget of approximately $3 million a year.
In FY 2025, Pasadena will be developing a legal services program in conjunction with its rent stabilization and tenant protection programs. The program would include legal representation for lower-income tenants and small landlords at eviction hearings, guidance and advice through the eviction process, and settlement and mediation support for tenants and small landlords. The initial budget allocated is $100,000 and may be increased upon success of the first year of implementation.
The County of Los Angeles has taken a more formal approach by adding a right to counsel ordinance to work in conjunction with its rent stabilization and tenant protection ordinances.
Most jurisdictions implementing rent stabilization or tenant protection ordinances do not provide a dedicated eviction prevention program but refer residential tenants to community providers and services. As previously noted, the City currently contracts with CSA San Diego to provide education, information and guidance in the area of landlord tenant relations. Other resources include the San Diego Superior Courts Self Help Center, volunteer lawyer programs, California Western Community Law Project, and Legal Aid Society of San Diego. A list of available resources is available on the Landlord-Tenant page of the Housing and Neighborhood Services website and provided as Attachment 3.
Staff Comments on Eviction Prevention Programs
Staff will continue to make available information regarding landlord tenant issues at community events and workshops, on its website and through City facilities. The City continues to contract with CSA San Diego through its Community Development Block Grant (CDBG) funds to provide fair housing and landlord-tenant services.
Should the City Council wish to provide an enhanced public awareness campaign on the CTPA or local laws for tenancy, the City Council could consider supplemental funding at the previous level of $20,000 for FY 2025/26 to enhance CSA’s efforts. A more direct delivery of legal services for tenants could also be considered for $100,000. Under that scenario, a Request for Proposals would be issued for legal services. Based upon the regulations governing funding sources from the Housing and Neighborhood Department and the limited availability of such funding, Department funds are not available for appropriation for enhanced public awareness efforts or legal services for tenants. Therefore, such monies would likely be paid from the City’s General Fund. Council direction would be needed to proceed if further Council action on Eviction Prevention Programs is desired
FISCAL IMPACT
There is no current year fiscal impact to the General Fund as a result of this action. Costs associated with development of this staff report and ordinance are included in the Housing and Neighborhood Services Department budget.
The fiscal impacts associated with implementation of the Tenant Protection Ordinance is unknown at this time but it’s anticipated that there will be ongoing indirect costs for staff time to collect data, respond to and educate residents, particularly in the first months and/or year of implementation, monitoring and enforcement, if necessary.
There would also be a fiscal impact to the City associated with the establishment and the operation of a rent stabilization program including, but not limited to, the costs associated with staff resources required to manage and to operate the program and facility and equipment costs necessary to house such staff. Such costs could ultimately be offset by the collection of a per-unit annual rental registration fee, similar to those assessed by other cities that have rent stabilization programs. In the event that the City Council directs staff to proceed with a rent stabilization ordinance and/or a more robust eviction prevention program, staff would develop a proposed budget for consideration at that time.
COMMISSION OR COMMITTEE REPORT
The Housing Commission received a report on July 23, 2024 on rent stabilization measures, specifically the Costa-Hawkins Rental Housing Act and the Justice for Renters Act, also known as Proposition 33 for the November 2024 ballot and expressed their support for a broader rent stabilization policy for the City.
CITY ATTORNEY’S ANALYSIS
The City Council is authorized to hold a public hearing in this matter. Following the hearing, the City Council shall affirm, modify or reject staff’s recommendation. The City Attorney has reviewed and approved as to form the City Code amendments consistent with the staff recommendation.
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Prepared by: Leilani Hines, Housing and Neighborhood Services Director
Submitted by: Jonathan Borrego, City Manager
ATTACHMENTS:
1. Staff Report
2. Residential Tenant Protections Ordinance
3. Summary of California Tenant Protection Act and Available Landlord-Tenant Resources
4. 2025 U.S. Department of Housing and Urban Development Small Area Fair Markert Rents for Oceanside CA
5. Department of Justice, Office of the Attorney General’s Consumer Alerts on Local Rent Stabilization Laws