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HomeMy WebLinkAbout20 - Setting the Fair Market Value Rent for Moorings Located Upon Tidelands in Newport Harbor - CorrespondenceReceived After Agenda Printed January 26, 2016 Item No. 20 From: Mulvey, Jennifer Sent: Monday, January 25, 2016 5:06 PM To: Mulvey, Jennifer Subject: FW: Mooring Rates/State Lands Commission Attachments: 01-19-16MooringSLCinfo.pdf, 12-05-11SLC Bench markUpdate.pdf; 01-19-16SLCdockSurveys.pdf From: Brian H Ouzounian [mailto:brian.oci@sbcglobal.net] Sent: Friday, January 22, 2016 1:12 PM To: Dept - City Council; Kiff, Dave Cc: Miller, Chris Subject: Mooring Rates/State Lands Commission Dear Mayor, Council Members, and Mr. Kiff: As I had wanted to meet with each of you individually to no avail, please find the information attached that relate to new information I have obtained from the State Lands Commission on my own time and dime. Hopefully we can have a productive discussion at the next CC meeting. Based upon this new information, z recommend that you move on the resolution to accept transferability of moorings and suspend the fee resolution pending further analysis into this information by staff along with "suspending" the 2016 billing for moorings. Please contact me if you so desire. Best Regards, Brian Ouzounian 310-466-7960 (cell) January 9, 2016 Dear Mayor Dixon, City Council Members and Mr. Kiff: This memo is intended to provide you with information that I personally obtained from the State Lands Commission (SLC) after the close of the city council meeting on June 16, 2015, This information supports my previous testimony at the Harbor Commission and City Council Meeting on June 16. My purpose in contacting the SLC was to find mooring rates that the SLC had in its possession along the California coast similar to that of private dock rates that they disclosed previously, a survey if possible. I must say the weaving journey throughout the SLC bureaucracy was an arduous and time consuming exercise but produced quite startling information. In the end, it came from Sheri Pemberton, Chief, External Affairs Division and her assistant, Nina Cloutman. I have attached a copy of her email and attachments for your review. Please note that my testimony to you all, both in writing (attached) and orally at both Harbor Commission meetings and the city council meetings has been a rental rate based upon the shadowing of the moored boat over State lands, similar to the docks in our harbor and an annual rate of $.50/SF. So as it turns out, the annual rate received for the benchmarks for Southern California is $.331/SF, supporting my previous recommendation. This standard of care index, therefore, must be considered in our working out the right rate to charge the public since we as a city are required by law to operate the harbor for the benefit of ALL citizens of the state. This is about keeping a public harbor facility open and available to the public at large. It is not based upon Newport Beach Real Estate values nor fund raising for city projects as some have suggested, since nearly all Californians cannot afford Newport Beach real estate or anything else that is priced based on our local real estate values. On this issue, my understanding is that the SLC's mandate is virtually the same as Newport's under the Tidelands Grant. It requires a balance of two competing forces, one that drives the fee up, and the other that drives the fee down. *Down: Newport must charge a fee that makes mooring facilities on the bay available to ALL Californians, without regard for the price of real estate surrounding the harbor. *Up: Newport cannot charge a fee that is so low that a mooring permit could be construed as a "gift" of public property. So how is the balance struck? The only rational way is to consider mooring rates along the State coastline. Any fee that is "above average" is contrary to the goal of making moorings available to all Californians. Any fee that is "below average" can be construed as a "gift" of public property. Therefore, the standard of care on this subject comes from the benchmarks from the SLC, which routinely surveys moorings around the state, provided to you below directly from the SLC (see their charts). It is quite obvious that the SLC would look at our existing rate and say that we are way beyond the upward limit of fair rates and a huge adjustment must be made downward to comply with keeping our public harbor open and available to the public at large. Also if I may say, the City could potentially have a liability for overcharging mooring holders for so many past years but that is not the subject nor the objective of the delivery of this information. Thank you for your time and efforts on this subject as it is a difficult one to resolve. 1, hope I have assisted in the resolution constructively. Please contact me if you have any questions or comments. Best Regards, Brian Ouzounian CALIFORNIA STATE LANDS COMMISSION BENCHMARKS NORTE $I$KiYOU MODOC HUMBOLDT SHASTA LASSEN TRINITY TEHAMA PLUMA5 MENDOCINO GLENN BUTTE SIERRA SAN FRANCISCO} COLUSA YUBA '—" LAKE .,SJFTR N VA6R " BAY AREA���.. kcA' TOM LES Br�Y rA>[ni3 S ��M16 - FR CIS BLACK POINT SANDY BEACH SANM TAHOE SACRAMENTO RIVER DELTA AREA MONO ,-At AVE AS TUOLUMNE +r STrT'tknCiFUS MARIPOSA .= MERCED INYO MADERA SAN BONITO FRESNO TULARE KINGS MONTEREY SANLUIS KERN OBISPO SOUTHERN SANTA BARBARA CALIFORNIA; HUNTINGTON SOLANA BEACH SAN BERNARDINO t' 7. RIVERSIDE *hr8l>r �4k�� see State (..ands Commission Benchmarks 05/12/2015 G:/i_MD/Benchmarks Category i $ 0.146 January 2012 2017 colorado River Area $ 0.166 August 011 2016 San Francisco Bay 12 July zo12 2017 Lake Tahoe Berths $ 0.79 1 uly 2012 2017 Lake Tahoe Buoys* $ 377 March 2015 2020 Sacramento River $ 0.214 March 2015 2020 Delta Area $ 0.165 r 2011 December 2016 _ ..._ ._,__ Southern californla ,_...__..__0.178,--_ iii $ 0.331 $ _._ October 2010 _.._... ... 2015 T lamo�es B s October 2010 2015 Tamales Bay Mooring Poles * $ 250 Category2 $ 2.16 May 2013 2018 Sandy Beach** $ 0.35 May 2015 2020 Blade Point** $ 5.40 December 2011 2016 Huntington Harbour December 2011 2016 Solana Beach $ 12.38 *per each_ These benchmarks do not reflect any contributory value that may be applied when applicable. * * dotes Benchmarks are generally updated every five years. 05/12/2015 G:/i_MD/Benchmarks BENCHMARK METHODOLOGY OVERVIEW Benchmarks Benchmarks are used to establish uniform rental rates in specific geographic areas with large concentrations of similar facilities, mostly private recreational improvements. These benchmarks are generally updated every five years. The use of benchmarks not only improves consistency throughout that geographic region, it also improves staff efficiency in setting and adjusting rent for large numbers of leases. There are two general types of benchmarks: • Category 1, which are applied to private docks, piers, and buoys; and • Category 2, which are applied to cantilevered decks, sundecks, or other non -water dependent encroachments. Category 1 Benchmark Methodology • Category 1 benchmarks are based on the principle of substitution. For example, if a waterfront homeowner did not have a dock, then where would the owner dock his or her boat? The answer to this is most likely at a nearby marina. • Staff uses the following general process to establish and update a Category 1 benchmark: • Survey nearby marinas (and buoy fields) as to docking & mooring sizes and rates; • Slip rates usually expressed as a rental rate per linear foot; • Extrapolate results from survey (rent per linear foot) into a rent per square foot; • Calculate the rent due to the State using a 5% annual rate of return for use of tide and submerged land. Category 2 Benchmark Methodology • Category 2 benchmarks are based on nearby upland land values because the improvements (cantilevered decks, sundecks, or certain other non -water dependent encroachments) are ostensibly used as an extension of the private backyard of the upland residence — a purpose unrelated to the docking and mooring of boats. • Staff uses the following general process to establish and update a Category 2 benchmark: • Research is conducted into recent nearby upland land values. The data is analyzed and a per -square foot value is determined as being representative of the area. • The determined value may be discounted to- reflect the fact that the tide and submerged land being leased may not have the same utility as the upland properties from which the data was drawn, due to topography or other physical characteristics, the nature of the use of the tide and submerged land, or certain legal constraints. The rental rate, also expressed on a per -square foot basis, is then calculated using 9% of the appraised value of the leased land per the California Code of Regulations.' ' Title 2, Administration, Division 3, State Property Operations, Article 2 Section 2003(a)(1). "151OZ/1Z/L https://us-mg4.maii.yahoo.com/neo/launch?.partner=sbc&.ran(i= aypp&'.':. Subject: CSE: State Lands Commission Inquiry From: Pemberton, Sheri@SLC (Sheri. Pemberton@sic.ca.gov) To: brian.oci@sbcgiobal.net; Date: Wednesday, July 8, 2015 2:12 PM Hi Brian — In response to your inquiry, most of the benchmark rental rates are on a dollar per square foot basis ($/SF) as indicated on the page. There are two with asterisks that are on a "per buoy" basis as indicated by the asterisk. With the $/SF rates, they are applied to the use and impact area to obtain a rent value. That is an annual rent value. The answer to your specific question is no; we do not have a survey of California coastal port mooring fees. Your email states that you desire more information about offshore mooring fees from coastal ports. I would encourage you to contact the various Southern California ports and the Santa Catalina Island Company, which has large two-point mooring fields, to obtain this information. Thank you, -Sheri Sheri Pemberton Chief, External Affairs/Legislative Liaison California State Lands Commission (9t6) 574-1800 Sheri.peinbertoii@slc.ca.gov From: Brian II Ouzounian[mailto:brian.oci@sbcglobaI.net] Sent: Tuesday, June 30, 2015 3:57 PM To: Pemberton, Sheri@SLC Subject. Re: State Lands Commission Inquiry dt: pesa.s aels� iau�red'Lu, �un�tl/oau/uao� ootl�h ;}suct,�ru-sn//:sdutl 7/2 i/2W 5 12:'--" A o °r�Nc -�'� 44 AMUMA- RN u W^ w- qmo�h�� %WaP cog 91, BRIAN.R. ®UZ®UNIAN 1222 East Balboa Blvd., Newport Beach, CA 92661 310-466-7960 Email: brian.ociPsbc_global.net June 15, 2 1 , ... _ 11 Re: Mooring Permits: Item II.1.a on CC Agenda 06/16/15 Dear Newport Beach City Council Members: I am a mooring permittee and how pleased I am that you are reviewing, taking comments, and considering changing the mooring fees in Newport Harbor. Such consideration is very welcomed and overdue. After being deeply involved with the Dock Tax Issue, the election of Team Newport, and attending all the past Harbor Commission meetings on mooring fees, I am compelled to send this memo, specifically with regards to my position on the fee structure. During the dock tax issue debates, many mooring permittees requested equal treatment and that time has come! I am in favor of a significant reduction however, I am in opposition to the Newport Mooring Association's fee recommendation, of which I am a member, as it a) it does not go far enough in reduction, b) it does not comply with the requests of permittees during the dock tax debate and, c) it is out of touch with the precedent recently`- established with regards to the dock tax. Permit -Fees: As we are all aware, there is no. formula (standard of care) set by any autharity as to the how the fees are to be structured, which includes the State and the City. Therefore we have a wide open opportunity to set our own reasonable and fair rate structure in' Newport Harbor. As I have testified and offered up numerously in the recent Harbor. Commission meetings, here is my request and recommendation. a. Charge $.50 per square foot of the shadow of the vessel in the mooring since each mooring must have a boat registered to the mooring even though it may not be in the mooring full time. b. Add a charge of $2.00 per foot of bow and stern line to each mooring can from the boat. c. Example for a 50 foot mooring: Boat is 25'x 8' =192 sf x .$50/sf = $100.00 50' mooring - 25' boat = 25 ft of line x 2.00 = 50.00 Total Permit Fee= 150.00 The $.50 per square foot rental rate came from the recent city council action regarding the private piers and relates to the shadowing of the bay bottom. It has been established as a harbor precedent, albeit for private piers, the basis is the same. The line charge seems fair and justifiable. As different size boats come in and out of a mooring, the adjustments to the permit fee can therefore be easily calculated by the Harbor Master. Note that the area in this formula is a rectangle measured by the length of the boat times the beam, not taking into account the curvature shape of the hull, this for simplicity. In comparison to docks, there is obviously and much testimony has been provided with regards to the moorings being difficult to access, take much more effort to enjoy, clean, maintain and protect from sea lions. The vessels and the mooring cans are also more likely to be damaged byharbor vessels and also the Harbor Patrol placed visitors, whereby damages go unreported. Further discounting may be warranted as you review the fee due to this but considering consistency with the Tidelands perception, the `shadowing' is the most reasonable driver in this formula. Additionally, if a mooring is and.intends.to be vacant for a long term, establish a minimum of $100/year fee, considering that empty moorings provide visitors and transient boaters to moor their boats as they visit the Harbor, which a plus for public access and harbor friendliness. ' = ``i As for the mooring rental fees by the. City for visitors and transient vessels, which generates about $88,000/year, it is recommended that you include an.annual credit factored into the annual rate for all permit holders. The credit amount should be half -of the previous year's revenue, which if you consider 2014 would be 1h of $88,000=$44,000 distributed in equal amounts to each permittee as a credit on their annual bill, repeated yearly. If a credit balance occurs on the annual bill, it would be carried. forward from year to year. The,credit would provide minimal relief for the required maintenance that the permittees are required to perform every two years. Thank you in advance for your consideration and hopeful concurrence with the above. Best Regards, Sniadt .d�r�acu�2ai 2 State of California To: Brian Bugsch, Chief F@& Land Management Division From, Larry Bellucel Public Land Management Specialist Appraisal Section, LMD Subject, Benchmark Update General Lease — Recreational Use Southern Cartforrila State Lands Commission Date: December 5, 2011 As requested, I have updated the benchmark for General Lease — Recreational Use for Southern California. The benchmark vis last updated by staff of the California State Lands Commission (CSLC) in February 2005. The current update follows the same methodology as the prior benchmark. Reference is made to the 2006 study for additional background material that may be needed for the reader to more fully understand what the benchmark is used for and how A is set. The recommended benchmark is summarized in the following table with the 2005 benchmarks. It should be noted that this research does not constitute an appraisal as defined by either the Uniform Standards of Professional Appraisal Practice (USPAP) or the Appraisal I netitute. Rather, this research represents a correlation of a range of market rents Into a single annual lease rate to be used as the benchmark for Southern California. The res"reh Is Intended to be used by CSLC staff in negotiations with applicants and lessees. I General Lease — Recreational Use leases are typically issued by the California State Lands Commission (CSLC) for private docks and piers and other mooring related facilities. These privately -owned facilities offer many of the same amenities as a commercial marina, such as a place for boat storage or the loading and unloading of equipment and passengers, Because such privately -owned facilities are a substitute for a commercial marine slip, the method of valuation used In estimating a fair return and a fair rental value In this analysis is based on what an individual would pay for a comparable substitute site in a commercial marina. The real estate principle that this method of valuation Is based upon is known as the'Principle of Substitution". The principle of substitution states that "when several similar or commensurate commodities, goods, or services are available, the one with the lowest price will attract the greatest demand and widest distribution. Since a State Lands lease site for a privately -owned pier or dock is a fairly good substitute for a marina slip, the lessee of the State land should pay an equivalent amount for the leased site as the State would receive for leasing the land to a commercial marina. The scope of the research included the folirfiMng: * identifying marinas in Southern California. * Surveying the marinas as to the number of berths/slips, occupancy rate, mooring sizes and rates, * Compiling the survey results into averages for slip size and rate, ® Using the Layout and Design Guidelines for Marina Berthing Facilities publication (July 2005) from the State Department of Boating and Waterways to determine the amount of submerged land area necessary to accomm odaie a given berthing size. * Calculating the annual rental rate(s) using the above information and State valuation guidelines. A total of 103 marinas in Southern Cardomis were Identified. Of these, staff collected data from 53, Others either declined to respond or were excluded because these facilities were for the exclusive Erse of members of the military and had subsidized rates. In addition, the short time frame In wfich the Information was collected precluded staff from surveying more marinas. 1 The Dictionary of Real Estate, Fourth Edition, page 281, Appraisal Institute, 2002. The responding marinas reported a total of 16,076 berths or slips, or an average of 303 berths/slips per marina. The average occupancy was reported at 87.5%, a significant decrease from the 97A% reported in 2005. Rent for berths and slips is commonly expressed in terms of dollars per linear fact. The survey Indicated average rental rates ranging from $9.25/LF to $42.00/LF. The lower rents Were generally found in marinas In Oxnard and Ventura, Ventura County, Wilmington, Long Beach and Ban Diego, San Diego County; and San .Pedro in Los Angeles County. The highest rents were found In marinas In Newport Beach In Orange County. The average surveyed rent is $18.09 per linear foot. This represents a 54% increase over the $11.72/LF used in the 2005 Benchmark Update. The State Department of Boating and WaterwaysWas contacted to determine If there had been any changes to their 2005 publication entitled "Layout and Design Guidelines for Small Craft and Berthing Facilitlee. This publication provides tables showing submerged kind area needed to accommodate various sized berths. The tables also differentate between powerboats and sailboats as well as single and double -berth layouts. And while the publication has been updated, the tables have not changed. The survey found that the average size of a berth or slip in Southern Califbmia was 36.3 feet. A 35 -foot average length was used in the 2005 Benchmark Update. For purposes of this update, the average berth size was rounded dowry from the surveyed 36.3 linear feet to 36 feet. Based on an raven mix of power and sailboats, and single and double - berth layouts, it Is estimated that a submerged area of 1,180 square feet is needed to accommodate a 36 -foot berth. Taking all of the aforementioned Inputs into account, the current benchmark rental rate and land value are calculated as follows: 36' averages berth size x $18.09/LF avg. berth rate = $651.24/berth/month $651.24/berth x 12 months = $7,814.88/berth/year $7,814.88 x 6°Qiag{of gross Income = py !�$390.74 $390.74 1,180 it sq. . = $0.331 sq, ft BENCHMARK RENTAL RATE $0,331/eq. ft $0.331/sq. ft. x 43,560 sq. ft, = $14,418/acre $14,418 + 0.09 State mandated rate of return w $160,200/acre BENCHMARK LAND VALUE = $100,200/acre The indicated benchmark rental rate is $0.334 per square foot. By contrast, the 2008 benchmark was $0.224 per square foot, The new benchmark therefore represents an overall Increase of less than 14 cents (,$0.407) over the 6 -year period between the two benchmarks. However, the two: benchmarks are not directly comparable. The current benchmark is based on a 36' average berth length and submerged land area of 1,180 square feet while the prior benchmark was based on a 35' average berth length and a submerged land area of 1,100 square feet, The net result is a 480/16increase in the rent per square foot between 2005 and the current update. RINASURVEY2011�.A uthern California No. Name Address Citi County Total Berths Occupancy Rate Occupied Berths Average Total Berth Average Length LF Rate 1 Bahia Cabrillo Yacht Landing 4200 S. Harbor Blvd, a Oxnard ' ' Ventura 84 66°% 55 37.5 3,150 $15,75 2 Channel Islands Harbor Marina 3850 Harbor Boulevard Oxnard Ventura 415 60% 249 38 15,770 $15.66 3 Peninsula Yacht Anchorage 3700 Peninsula Road Oxnard. Ventura 362 51% 185 35 12,670 $13.37 4 Vintage Marina 2950 S. Harbor Blvd. , Oxnard Ventura 385 70%, 270 44.5 17,133 $15.59 5 Ventura Harbor Village Marina 1583 Spinnaker Drive Ventura Ventura 167 70°% 117 38 6,346 $11.74 6 Ventura tale Marina 1363 Spinnaker Drive Ventura Ventura 580 66% 383 38 22,040 $14.36 7 Venture West Marina 1198 Navigator Drive Ventura Ventura 550 80% 440 35 19,250 $12.83 8 Bay Club Marina 14015 West Tahiti Way Marina del Rey Los Angeles 230 96% 221 35 8,050 $15.43 9 The Boat Yard Marina 13555 Fiji Way Marina del Rey Los Angeles 108 100°% 108 32.6 3,521 $16.25 10 Marina City Club 4333 Admiralty Way Marina dei Rey Los Angeles 320 82% 262 35.5 11,360 $14.55 11; Pier 44 13575 Mindanao Way Marina del Rey Los Angeles 391 72°% 282 26:5 10,362 $12.63 12 Tshifi Marina 13900 Tahiti Way Marina del Rey Los Angeles 214 93% 199 30.3 6,484 $15.17 13 Port Royal Marina 555 N. Harter Drive Redondo Beach Los Angeles 338 90°% 304 28 9,464 $12.06 14 Cerritos Bahia Marina 6289 E. Pacific Coast Highway Long Beach Los Angeles 265 80°% 212 29 7,685 $9.50 15 California Yacht Marina Berth 202 #36 Wilmington Los Angeles 262 93°% 244 40.3 10,559 $10.84 16 Holiday Harbor Marine Berth 201 Wilmington Los Angeles 200 80°% 160 32.5 6,500 $9.88 17 Newmark's Yacht Centre Berth 204 Wilmington Los Angeles 250 750/6 188 35 8,750 $9.25 18 Yacht Haven Marina Berth 202 #35 Wilmington Los Angeles 165 88°% 145 42 6,930 $10.00 19 Cabrillo Way Marina 2800 Miner Street San Pedro Los Angeles 340 99% 337 47.9 16,286 $17.27 20 Holiday Harbor Marina 241 Watchorn Walk, Berth 34 San Pedro Los Angeles 287 95% 273 36.2 10,389 $13.57 21 San Pedro Marina 950 Sampson Way San Pedro Los Angeles 85 97% 82 45 3,825 $10.00 22 A Sunroad Resort Marina 955 Harbor Island Dr. San Diego San Diego 582 800/0 466 41.9 24,386 $20.11 23 Bay Club Marina 2131 Shelter Island Dr. San Diego San Diego 134 100°% 134 36.6 4,904 $17.28 24 Cabrillo Isle Marina 1450 Harbor Island Dc San Diego b: San Diego 411 60°% 247 39.5 16,235 $21.51 25 Chula Vista Marina & RV Resort 550 Marina Parkway Chula Vista. San Diego 531 70°% 372 35.5 18,851 $13.67 26 Glodette Bay Marina 1715 Strand Way Coronado San Diego 100 100% 100 37.8 3,780 $17.74 27 Harbor Island West Marina 2040 Harbor island Drive San Diego San Diego 577 80% 462 36.7 21,176 $16.70 28 Marina Cortez 1880 Harbor Island Drive San Diego San Diego 477 60% 382 38.1 18,174 $16.85 29 Marriott Marina 333 West Harbor Drive San Diego San Diego 405 100°% 405 44.3 17,942 $21.44 30 Shelter Cove Marina 2240 Shelter Island Drive San Diego San Diego 149 62°% 122 38 5,662 $18.43 31 Shelter Island Marina 2071 Shelter Island Drive San Diego San Diego 188 94% 177 46.2 8,686 $21.10 32 Sun Harbor Marina 5104 N. Harbor Drive San Diego San Diego 94 96°% 90 44.9 4,221 $17.03 33 Campland on the Bay 2211 Pacific Beach Drive San Diego San Diego 120 90°% 108 25 3,000 $11.63 34 Driscoll Marina 1500 Quivira Way San Diego San Diego 170 95°% 162 37.3 6,341 $11.44 35 Marina Village Marina 1936 Quivira Way San Diego San Diego '497 89% 442 30.4 15,109 $12,40 36 Sea World Marina 1660 South Shores Road San Diego San Diego 208 90°% 187 26 5,408 $10.50 37 Seaforth Marina 1677 Quivirs Road San Diego San Diego 232 96% 223 33.9 7,865 $11.91 38 Oceanside Harbor 1540 Harbor Drive North Oceanside San Diego 783 100% 783 32.1 25,134 $11.86 39 Dana West Marina 24500 Dana Point Harbor Drive Dana Point Orange 980 93°% 911 28.5 27,930 $16.10 40 Newport Dunes Resort Marina 101 North Bayside Drive Newport Beach Orange 450 92% 414 33 14,650 $29.00 41 Davenport Marina 4052 Davenport Drive Huntington Beach Orange 65 95% 62 29 1,885 $12.50 42 Harbor Marina 3335 West Coast Highway , , Newport Beach Orange 52 96% 50 40 2,080 $37.50 43 Swales Anchorage 2888 Bayshore Drive Newport Beach Orange 56 100°% 56 34 1,904 $17,50 44 Lido Marina Village 3400 Ya Oporto #14 Newport Beach Orange, 75 92% 69 52 3,900 $42.00 45 Bayshore Marina 101 Shipyard Way, St G Newport Beach Orange 134 98°% 131 40 5,360 $35.00 46 Villa Cove Marina 101 Shipyard Way, St. G Newport Beach Orange 42 98% 41 35 1,470 $31.50 47 Balboa Marina 101 Shipyard Way, St. G Newport Beach Orange 132 98°% 129 35 4,620 $34.00 48 Bayside Marina 101 Shipyard Way, St G Newport Beach Orange 102 98°% 100 40 4,080 $37.53 49 Lido Yacht Anchorage 101 Shipyard Way, St. G Newport Beach Orange 251 100°% 251 40 10,040 $40.00 50 DeAnza Bayside Marina 300 East Coast Highway Newport Beach Orange 219 80% 175 30 6,570 $24.00 51 Balboa Yacht Basin 829 Harbor Island Drive Newport Beach Orange 172 100°% 172 37 6,364 $24.03 52 Dana Point Marina Company 34555 Casitas Place Dana Point ' Orange 1,365 98% 1,338 -30 40,950 $16.77 MARINA SURVEY 2011 Southern California Total Occupancy Occupied Average Total Bertt- Average No. Name Address Ci CountyBerths 325 Rate 94°� Berths 306 Len th LF Rate 36.5 11,863 $14.00 53 Peters Landing Marian 16400 PCH 5t 108 Huntington each Orange 16,076 87.5°h 13,780 36 567,260 $18.09 Totals a-' ,2 ooT sf4e- L a 45 N m yo+ ss iot7 MARINA SURVEY Southern California Total Total Occupancy Occupied Average Berthing Average No. Name Address C' county Berfhs Rate Berths Length LF Rate 1 Anacapa tsland Marina 3001 Peninsula Road Oxnard Ventura . 438 92% 403 32 14,016 $11.56 2 Bahia Cabrillo Yacht Landing 4200 S: Harbor Blvd. Oxnard Ventura 84 90% 76 35 2,940 $7.75 3 Channat islands Harbor Marina 3850 Harbor Boulevard c Oxnard. Ventura 500 96% 480 32 16,000 $7.65 4 Peninsula Yacht Anchorage 3700 Peninsula Road Oxnard Ventura 362 90% 326 35 12,670 $7.75 5 Vintage Marina 2850 S.; Harbor Blvd. Oxnard Ventura 395 99% 391 32 12,640 $9.38 6 Ventura Harbor Village Marina 1.583 Spinnaker Drive . Ventura Ventura 167 92% 154 50 8,350 $8,55 7 Venturadsie Marina 1363 Spinnaker Drive Ventura Ventura 560 90% 504 40 22,400 $11.50 • 8 Ventura West Marina 1198 Navigator Drive Ventura Ventura 550 96% 528 38 20,900 $9.95 9 Say Club Marina 14015 West Tahiti Way Marina del Rey Los Angeles 251 100°/6 251 35 8,785 $10.86 10 The Boatyard Marina 13555 Fiji, Way Marina del Rey Los Angeles 108 98% 108 35 3,780 $13.00 11 Marina City Club 4333 Admiralty Way Marina del Rey Los Angeles 354 98% 347 33 11,682 $10.90 12 Marina Harbor Anchorage 4422 Via Marina. Ste. 715 Marina del Rey Los Angeles 449 95% 427 45 20,205 $16.00 13 Pler44 13575 Mindanao Way Marina dei Rey Las Angeles 364 96% 349 24 8,736 $10.50 14 SMYC Marina 13589 Mindanao Way Marina del Rey Los Angeles 200 100% 200 30 6,000 $10.33 15 Tahiti Marina 15900 Tahiti Way Marina del Ray Los Angeles 214 98% 210 35.54 7,606 $17.43 16 Villa Del Mar Marina 13999 Marquesas Way Marina del Rey Las Angeles 209 100% 209 45 9,405 $15.67 17 King Harbor Marina 208 Yacht Club Way Redondo.Beach Los Angeles 827 90% 744 33 27,291 $9.85 18 Port Royal Marina 555 N. Harbor Drive Redorido Beach Las Angeles 337 92°A 310 .30 10,110 $11.60 19 Portofino 255 Portofino Way Redondo Beach Los Angeles 234 98% 229 35 8,190 $11.43 20 Redondo Beach Marina 181 N. Harbor Drive Redondo Beach Los Angeles 68 99% 67 35 2,030 $10.50 21 Alamitos Bay Marina 205 Marine Drive Long Beach Los Angeles 1,970 100% 1,970 30 59,100 $9.30 22 Cerritos Bahia Marina 6289 1 . ftc tic Coast Highway Long Beach Las Angeles 254 100% 254 28 7,112 $8.61 23 Long Beach Shoreline Marina 450 E. Shoreline Drive Lang Beach Los Angeles 11830 100% 1,830 35 64,050 $8.80 24 Rainbow Marina . 200 B Street Long Beach Los Angeles 97 100% 977 36 3,492 $9.25 25 California Yacht Marina Berth 262#W Wilmington: Las Angeles 266 85% 228 35 9,310 $9.50 26 Cerritos Yacht Anchorage Berth 205.0 Wilmington Los Angeles 90 100% 90 25 2,250 $7.75 27 Holiday Harbor Marina Berth 201. Wilmington Los Angeles 200 95% 190 30 6,000 $8.50 26 Island Yacht Anchorage #1 & #2 801 Henry Ford Avenue, Berth 205-D Wilmington Los Angeles 100 99% 99 39 3,900 $9.00 29 Leeward Bay . 611 Henry Ford Avenue, #1 Wilmington Los Angeles 180 100% 180 32 5,760 $7.50 30 Lighthouse Yacht Landing Berth 205-13 Wilmington Los Angeles 75 79% 59 35 2,625 $9.25 31 Paclfrc Yacht Lending Berth 203 (Pod of Los Angeles) Wilmington Los Angeles 180 100% 180 30 5,400 $8.50 32 Yacht Centre Berth 204 . woman" Los Angeles 240 95% 228 35 8,400 $6.00 33 Yacht Haven Marina Berth 202#36 WIlmington Los Angeles 168 98% 165 38 6,384 $9.00 34 AI Larson Marina 1046 S. Seaside Terminal Island los Angeles 128 99% 127 30 3,640 $7.00 35 Cabrillo Marina 224 Whalers Walk San Pedro Los Angeles 890, 97010 863 35 31,150 $13.00 36 Cabrillo Way Marina 2800 Miner Skeet San Pedro Los Angeles 530 95% 504 30 15,900 $7.50 37 Holiday Harbor- Cabrillo Marina 241 Watchorn Walk. Berth 34 San Pedro Los Angeles 284 98% 278 36.2 ' 10,281 $10.57 36 San Pedro Marina 950 Sampson Way San Pedro Los Angeles 95 100% 95 45 4,275 $9.50 39 Balboa Marina 101 Shipyard Way, Ste. G Newport Beach Orange 132 100% 132 35 4,620 $20.87 40 Balboa Yacht Basin 829 Harbor Island Dr. Newport Beach Orange 172 100% 172 35 6,020 $20.00 41 Bayshore Marina 101 Shipyard Way, Ste. G Newport Beach Orange 134 100% 134 40 5,360 $22.60 42 Bayside Marina 101 Shipyard Way, Ste. G , , Newport Beach Orange 101 100% 101 40 4,040 $29.37 43 DeAnza Bayside Marina 300 Fast Coast Highway Newport Beach Orange 220 100% 220 35 7,700 $17.00 44 Harbor Marina 3335 West Coast Highway Newport Beach Orange 52 100% 52 40 2,080 $25.00 45 Lido Marina Village 3400 Via -Oporto #104 Newport Beach Orange 75 100"A 75 50 3,750 $35.00 46 Lido Yacht Anchorage 101 Shipyard Way, Ste, G Newport Beach Orange 251 100% 251 40 10,040 $22.00 47 Newport Dunes Resod Marina 101 North Bayside Dr. Newport Beach Orange 450 100% 450 26 12,600 $16.75 48 Swaies Anchorage 2888 Bayshore Dr. Newport Beach Orange 56 100% 56 35 1,960 $18.00 49 Villa Cove Marina 101 Shipyard Way, Ste. G Newport Beach Orange 42 100% 42 35 1,470 $21.36 50 Davenport Marina 4052 Davenport Drive Huntington Beach Orange 65 100% 65 30 1,950 $9.25 51 Peter's Landing Marina 16400 Pacific Coast Highway, Ste. 108 Huntington Beach Orange 325 100% 325 35 11,375 $11.50 52 Sunset Aquatic Marina 2901-A Edinger Huntington Beach Orange 450 950/0 428 35 15,760 $17-00 MARINA SURVEY Southern California Total Total Occupancy Occupied Average Berthing Average No. Name Address City County Berths Rate Berths Leath LF Rate 53 Dana Point Marina Company 34555 Coultas Place 54 Dana West Marina 24500 Dana Point Harbor DL 55 A Sunmad Resort Marina 955 Harbor Island Dr. 56 -Bay Club Marina 2131 Shelter island Dr. 57 Cabrillo Isle Marina 1,450 Harbor island Dr. 58 California Yacht Marina 640 Marina Parkway 59 Chula Vista Marina & RV Resort 550 Marina Parkway 60 Glorletta Bay Marina 1715 Strand Way 61 Gold Coast Anchorage 2353 Shelter island Drive 62 Half Moon Anchorage 2131 Shelter island Drive 63 Harbor island West Marina 2040 Harbor island Drive 64.1Foews Crown isle Marina 4000 Coronado Bay Road 65'Marina Cortez 1680 Harbor island Drive' 66 Marriott Marina 333 West Harbor Drive 67 Shelter Cove Marina 2240 Shaker Island Drive 68 Shelter island Marina 2071 Shelter island Drive 69 Marina Kona Kai 1551 Shaker Island Drive 70 Sun Harbor Marina 5104 N. Harbor Drive 71 Campland on the Bay 2211 PadGc Beach Drive 72 Dana inn & Marina 1710 West Mission Bay Dr. 73 Dana Landing 2630 Ingraham 74 Driscoll Mission Bay 1500 Quivlra Way 75 lsiandis Marina 1441 Quivira Way 76 Marina Village Marina 1936 QriMm Way 77 Sea Worid Marina '' 1660 Seoul Shores Road 78 Seafath Marina - 1677 Qutvih Road 79 Oceanside Harbor 1540 Harbor Drive Nath Totals Dana Point Orange 11365' 100% 1,365 3286 44,8$4 $1212 Dana Pairit' Orange 980 100% 980 30.34 29,733 $11.96 San Diego San Diego BOB 93% 565 40 24,320 $18.00 SanVago San Diego 160 100% 160 35 5,600 $11.50 San Diego San Diego 450 99% 446 35 15,750 $16.09 Chula vista San Diego 355 90% 320 34 12,070 $10.00 Chula Vista San Diego 561 98% 550 35 19,635 $9.90 Coronado San Diego 100 98% 98 24 2,400 $10.25 San Diego San Diego 35 90% 32 50 1,750 $12.50 San Diego San Diego 165 100% 165 36 .5,940 $10.50 San Diego San Diego 620 100% 620 38 23ABO $1226 Coronado San Diego 81 100% 81 30 2,430 $13.50 San Diego San Diego 525 100% 525 35 18,375 $12.00 San Diego San Diego 446 91% 405 45 20,070 $15.49 San Diego San Diego 161 100% 161 35 5,635 $14.25 San Diego San Diego 189 9894 165 46 8,505 $11.98 San Diego San Diego 523 99% 518 40 20,920 $14.50 San Diego San Diego 100 100% 100 44 4,400 $13.50 San Diego San Diego 234 100% 234 26 6,084 $9.00 San Diego San Dego 140 100% 140 30 4,200 $7.90 San Diego San Diego 80 100% 8Q 38 3.040 $7.97 San Diego San Diego• 213 100% 213 40 8,520 $9.85 San Diego San Diego 187 i00% 187 40 7,480 $1200 San Diego, San Dego 634 95% 602 30 19,020 $9.90 San Diego .X San Diego 198 100% 198 24 4,752 $8.25 San Diego, } San Diego 232 100% 232 35 8,120 $8.75 Oceanside San Diego 950 100% 950 32 30,400 $9.60 27,055 97`Yo 26,350 34.35 929,242 $11.72 C ti SANtII B,1lRRARA NAR80R Sante Barbara Marina' VSKTURA.HARBOR: Ventura. hest Marina Phase 16,7 Venture West Marine Phase 27 Ventura lets xarfna Ventura llerbor.VII149.9 ;ubt0tais CBAMHEL 1W.M.S HARBOR Channel islands Marinal0 Vintage MwIna6 • Anocapp:l'sti Mirine6+T Peninsull Yecht Anabarape Channel islands Lendinv Ventura Co. Small Soil Marinas Venture Cs.Caemll Fishing Marinas Sakti Cabrilt* Marinab Pacific Corinthian Marina Subtotals MARINA DEL REY Tahiti ?tsrina10,7 lstetxisr Merinat • Neptune Marina Deauville Marinal0 Vlile dot lisp Marine Sar Harbor Merirmt Dolphin herlmle ' Tradwinds Karim Holiday Harbor Marina Mariners bay - Cats Line ay_Cations Yacht Anchorage SANTA BARBARA TO SAM DIEGO JANUAtW. 1992-\. Al! stips, End.Tles1 Effective Double Slips, Na Slips Avg. Site Hates/LP Mate 110, SURE Rates/LF Nean� 1,008 321 $ 5.61-S. 7.22 7-90 984 15.61-9 7.22 '$6.30. single stip03 Ra. Sthm Rate -RAE Kear 391 341 $ 8.51-S 9.49 &-91 0 - - - - - 387 t 8.51-5 9.49 49.04 j 164 ' 371 S 8.95-5 9.15 6-91 0 - - - » - - 140 S 8.95-S 9.15 $9.05 675 321 $ 8.20-S 9.10 &.91 0 - - - - - 650 S 6,20-S 9.10 $8.50 481 , i.7.304 8.03 , 6-87 ,-J$$ S 7.30-$ 8.03 $7,51 �0 -- 1.418 155. $7.51 1,177 ' $e.7 515 301 $ 6.76-S 8.21. 7-90 0 - - - - 455 t 6.76-5 7.63 $6.99 356 " 381 s 5.37-5 8.64 10-90 170 3 7.88-S 0.32 $5.05 176 S 5.17-S 8.64 $8.16 480. 321 S 9.25-510.95 6-91 0 - - - - - - 459 S 9.25-S1O.51 $9.67 369 - 301 5 7.OD 790 0 -•- - - - 35a $ 7.00 $7.00 38 251 S5.50 390 0 ' ' - •, - - 52 $ 5.50 55.50 120 221 S 6.42 10-91 120 $ 6.42 36.42 0 - - - - - - •� 67 341 $ 5.81 : 1-90 67 $ 5.81 $5.81' 0 • - - - - - 90 401 S 8.06-5 9.29 3-91 0 - - - . - - - - 03 # 8.0&-5 9.29 59.08 __15-2 351 S 7,50 7.91 n $ 7.50 ST -m - .$7.50 57.50 2,295 369 $7.10 1,715 $7.92 232 364 $13.57-$20.53 7.91 Of - • - - - 181 x13.57-316.67 $14.49 247 35b $10.00-516:52 4-91 0 - - - 230 $10.00-513.12 $11.11 199 301 x10.33-$14.17 5-89 0 - - - 184 S10.33411.38 110.54 466 321 310.50-$15.75' 5-90 0 . - - - - - - 395 510.50-514.75 $11.08 •205 321 $1b.80-515.00 4-91 '0 - - - - - - 186 $10,80414.00 ' $12.55 257 °'. 321 510.50.515.75 - 5-90 0 • - - - - - 237 SiO.50.615.00 •$11.94 47g 321 ,$ 9.60-515.75 !#10.00-$14.50 4-91 0 - - 408 S 9.60-$13.50 $10.83' 157 301 1 -in 0 _ - - - - - • •145 510.00413.50 510.78 19b 241 3 8.50411.00' 10-89 .0 - - _ _ - - 183 1'8.50-511.00 $9.28 404 A 310.30415.00 11-90 0 - - - - - - 369 510.30-614.75 $11.53 160 271 S 7.75.5 9.75 4-89 0 - - - - - - 148 S 7.75-5 8.15 $7.94 0 a r Ali slips, " Tiesi .' Effective gaubtt Stipa 5tn2ta stipis No. Ulm Avo, SSlza Rates/LF e e fig. Stipf RntealLF Keen ilioes _. StiRatealLF Kean MARINA DEL REY (Continued) Marina del Rey Hote17017 377 31* ;l10. 6=$t1i.15, 4.91 0, ^ - - 319 510.36413.86 111.07 Pier•44, 77 dct Rey? 414 260 $10.00412.66 4-91 203 5 8.33412.60 $8.50 164 S10.00-111.86 ' $10.38 SMYC Msr1tw7 192 300 510.67=x13.97 3-91 0 - _ - ^ .. 164 S10.67411.39 SIMS Aegis -Cat 115 310 510.00•$16.00 11-89 0 - - - - - - 105 S10.00-112.00 $11.46- 11.46.Haring MarineHarbor #1 L 0240 614 310 s10:10417.50 1-91 0 - - - - - $52 $10.10-515.50 $10.93 Marine City Ctub6,7,10 _R3_ 349. ;11.00-;17.00 5-91 Subtotals 5,048 210 U.5D 4,266 511.16 %IMO MOOR King Harbor Marina? 868 270 5 8.60-115.45 5-90 0 _ - ... 794 S 8.60-#15.43 $10.65 Port Royal Marine 336 290 $ 9.21-S10.00 6-90 0 - - ... 325 S 9.75410.00 S9.49 Portofino 232 320 $10.50-$14.50 4-91 0 ... - 207 x10.50.313.00 $11.53 Redondo Seach_Marina7*96 31' $10.15-$16.40 7-90 510.15-#15.53 Sif•02 p Subtotals 1,498 0 1,384 110.53 LOS AWLE6^LONE BEACH HARBOR Cabrillo Marinas 1,180 300 1.7.90 7-89 ' 0 - - . _ 11,132 $ 7.90 $T.90 Fteitz Brothers Marini 450 301 S 6.25 12.89 0 - - 375 $ 6.25 56.25 Holiday Harbor -set! Pedro 200 25' S &so-$ 6.80 8-91 ",l 0 - - - - • - 180 $640 $6.80 Sart Pedro Marine Lew"a say Marina 96 150 0 409 270 $10.50 S 8.00.5 B.Sp -89 8-91 0 ,0 • - - - - - _ - - - - - 78 $10.50 139 S 6.09-# 8.50 510.50 $5.16 Holiday Harbor-ltilmington 183 290 $ 8.25-5 8.50 191 4 S3.25 $5.25 158 S 8.25-S 6.50 30:11 Caltfamis Yacht Kerins 264 360 $ 8.60-#11.00 10-89 0 - - 244 5 8.60.511.00 19.53 Yacht Haven t 165 420 $ 7.50 1-89 95 s 7.5.0 17.50. 60' $ 7.50 *r.50 Pacific Yacht Landing 178 310 S 8.00-s 8.25 • 1.89 13 $ 8.00-S 8.25 $8.13 161 ' S 8.00-$ 8.25 38.13 Tacht Ctntre 256 410 S 0.00-11 9.00 11.90 0 - - - - 243 $ 8.00-S 9.00 #8.66 Colonial Yacht Anchorage 135 211 $ 8.00 11-90 0 - - - - - 125 $ 8.00 ' $4.00 Cerritos Yacht Anchorage '95 350. S7.35 1-91 0 ^ - - 93 $7.35 =7.35 Island Yacht Anchcraye-16 103 370 $ 8.82 1=89 0 - - - .. 93• $ 8.82 Se.82 Island Yacht'Anchorags-26 140 38* $8.32 1-84 0 - - - - - - 128 # Ben 38.82 Terminal Island Marine 250 320 5.7.00-S T.25 1-89 30. S 7.00 $7.00 210 S 7.0.0-5 7.25 $7.15 ' Lighthouse Yacht Landing 75 310 s 8.00 .10.87 0 - - - - - - 67 S 8.00 58.00 At'Lerson Marina 128'. 320 S 8.00 - 9-90 0 - - - - ^ - }28 $ 8.00 $8.00 Cabrillo Yacht Rosin 110 301 S 6.50 1-88 D ^ - - - - - 110- S 6.511 $6.50 Shetter Point Marina 7Si ,28�, ' - S 7,00 1-85 10 S 7.00 $7.00 62 $ 7:00 57.00 o' tam Marinas 1,693 _ 360 s 9:10-S 9.73. 7-91 1693 S 9.104 9.7,3 $9.19 0 - - - - shoretine Harbor Marira>3 131 3T!• ! 9.10 7-91 _ $ 9.10 19.10 1_10 • - - ' " Subtotals 6,055 1976 .$9.05 3,786 $7.88 ALAMITOS DAY Long Beach Marines Cerritos Bahia Marina6 Subtotals ANAHEIM BAY Smoot Aquatic Marinn6 Peter.!a Lsnd{tffib�a Huntington Harbor'say Clab subtotal: NEi1PORT BAY Lich Yacht Anchore966 , Harbor club Merinab 9ayshore Marina6 . Saates Anchorage Balboa 'Marina Balboa Yacht iss0-6 Bayside mar Ifta ,a De Anna Bayaido Karina6 K -Port D(m*s:11ar1ne6�11 SubtoLMtt DANA POINT HARBOR Dana Point Harina7 Dane *test Marina6,7 Subtotal. O!CEAN$t05• HARBOR Oceanside Martha$ MTSSIO4 BAY sea florid Marina at Perez Govt Dena Lending Islandia Marina Saatorth Marina Marina Vitlege6 Mission Nay Aar1na6 Bahia Hotel Marina Dam Inn Marina Caagtand Karinii ' Subtotals Alt 5tips, End T1e91 Effective Double SLipaZ Singte SLipe3 l No. Stipa &U. Sita Rates/LF date Ao: sties • RateslLP -meank Ro SURE atee mearA 2,001 3i 0. S a3tl3. 9-73 7-91 39' S 9.10 S9.t0 1,962 S 8.36-$ 9.73 $8.83 -- 1 28% $ 8.15•S 9.55. 1141 ♦•Q - - - 5 $ 8.15•$ 9.08 68.49 2,272 $14.07 0 - - - - - - 39 $9.10 2,221 0• $8.79 276 300 x 9.16-510.43 1x-91 . 10 S0.16 $9.16 24a S 9.16.510.43 $9.95 268 370 S10.64-512.64 2.91 0 - • - - - 248 510.64.512.64 $11.29 ,16-6 300 3 9.30-112.50 7-91 _Q - � i S 9,.50-S12.50 *11.7.0 710 $7.25 _ 1 270 10 19.16 650 $ 7.50 $10.76 285. 340 510.29.314.29 6.91 66 331 #13.40-x17.80 6-91 134 310 $12.00.$16:90 2-90 58 320 $12.03 -*16.00 1-91 132 320 $12.50 -*14.25 12-89 172 360 $12.54 7-91 93 350 510.65-S15.40 7-90 258 121S , $11.211.414.67 7.90 m 13A ,.511.70-$14.95 a-91 1,428 1,462 290 S 9.45-S 9.90 0-91 _F 310 S 9.13-x13.42 6-91 2,435. 0 - • - - , 225 $12.79-$14.ZP $13.25 0 - - - - - 62 $13.40-$17.80 $15.55 0, - - - - . 130 $12.00.516.50 513.73 310 $ 8.25-5-8.75 7-91 $12.03-x16.00 $14.07 0 - - - - - - 112 512.50-314.25 $13.54 0• - - 161 i12.54 $12.54 0 - - - - 58 514.40415.40 $15.04 10 7it14.50-#74.67 514.57 ,208 511.28.413.50 $13.25 $ 7.79 $7.79 47 300 S 7.25 10 :' $14.57 1.773• $7.25 $13.33 0 - - - ' 1,361 - $ 9.45-$ 9.90 19.77 •-• _ S913-311.37 34.75 0 873 • 310 S '6.60 . 849 0 198 250 $ 7.15 1-90 198 $ 7.15 $7.15 164 .300 S 6.00-$ 6.50 1-89 B4 S 6.00-S 6.50 56.27 205 310 $ 8.25-5-8.75 7-91 198. 3 8.25-5 8.75 $8.34 250 +' 320 5 7.25 6-90 230 S 7.25` $7.25 640 300 S 8.13-# 9.45 11-91 0 - - - - .225' 360 S 7.79-S 9.74 1-90 36 $ 7.79 $7.79 47 300 S 7.25 2-99 44 $ 7.25 $7.25 146 30, S 7.25 1-89 140 • $ 7.25 $7.25 _ 1 270 $ 7.50 11-91 Q $ 7.50 2.030 - - - --- 1050 $7.41 2,243 39.7b 7.68-S 8.60 $8.21 ,z 0 ---•-- 52 $ 6.00-5 6.50 $6.15 0 _ _ - • - 628 S 8.13.5 9.45 $3.60 153 S 8.34-5 9.15 $8.61 0 -•_ ... • _ l w DIEGO SAT Half Moon Anchorage Bay Club Hotel Marine Shatter•lstand,tm Marinal0 Kona Marina Korea Kai Club Marina6 Shatter Cove Marina Stat Harbor Kerins Marriott Marina6 ChulasYista`Marina6 Coronado Cays Msr1na6 Gtoriette Bay Marina Cabrillo'lsle Marina6,7 Marine eortst6 Harbor let" Nest Asrina6,7 sunroad Mar1na6 Catifornia' Yacht Marina6 Subtotal: ALL Stipa; Erx1•Tieal Effective Boubte Stipa? sin`gte Stipa's No, 51iFs dY„g, Size Rates/LF_to goofis ios Rates/IF Kearr4 go.' Mips Rates/LF i,{„e4l)7 170 33+ 17.44 8.95 154 34t $ 8.45-x 9.45' 187 36+ # 9.00510.00 260 w 341 S 8.25 264 $00 * 8.75 184 371 S 8.75 130 451 S 7.75-1 a 35 417 4331 510..01_S11.81 5S2 359 S 6.67-5 7.67 56- 40t $ 5.10 109 351 x•8.30 -S 9.75 450 39+ $ 9.42-$11.21 580 _ 341 s 9.00.510.15 604 37+ t 6.42-510.15 600 42+ S 4.24-513.14 '557 3a+ S 6.50^5 7.5q 5+074• ' 32=OZ4 • 8440 1ZT $ T.90-$ 8.05 1-91 162 S 8.45 11.90 152 $ 9.00 1.91 50 s 8.25 1-91 96 S 8175 5-91 166 18.75 7-91 126 S 7.75.5 8.25 5-91 6 $11.81 6-89 111 $ 7.11 1-83 51 $5.10' 6-91 20 S 8.304 9.75 5-91 0 - - - 11-91.. 0 - - - 7.91- ST:41 418 5-91 56.78 5-90 0 - - - . 1007 $8.74 78 LIM S8.74 67.932 5.8.60 $5.60 $5.45 , 8 ' $ 9.20 $8.45 49.90 0 - - •. • , $8.25 197 S 8.25 $3.25 58.75 166 S 8.75 $8475 58.75 6 S 8.75, 58.00 $7.97 •0 - - - $11.81 396 x10.01-510.71 $9.58 ST:41 418 S 6.67-S 7.31 56.78 $5.10. 0 - - - - $8.74 78 S 8.30-S 9.75 S8.74 .. - 1406 $ 9,42-510.14 59.68 - - - 554 S 9.00-5 9.90 59.15; - - - 545 s 9.44-S 9.65 $9.50 - - - 329 510.54-511,22 $10.60 . 347 s 6.50-5 7.15 Sb_65 1$�85�.113 59.03 X3[,6344 1 includes regular single slips, doubt• stips, end ties, and premium main channel slips; excludes bulkheod/seaaatt ttes.' 2 Doubts slips are xider'and have ewe, boats in such as, indicated on exhibit As in the Addends Section - 3 single *tips include only those 'having flotation on each aide as indicated on Exhibit A. 4 Based on the nu*er*of atips at each rata, or evertive stip size. . 5 Rates trictude $0.10 adjustment for possessory interest tax. 6 Rates include adjustment for uti}Iity fee, dock, box feet club dues or other required fat. 7 Anchorage has a fixed 'rant for each stip and overhangs are included or permitted. Cateutaticns to convert to a tinsal foot rate are based upon the • maxim a.bost size permitted. - 8 Total stip ccounj excludes those leased to yacht clubs or brokerages. + 9 Certain'stips rented to commercial users at varying rates; ween rate excludes such slips. 10 premium mein chamel'ireaular) slips sxot►ded farm singtes/doubte stip oount, rate, and mean calculation. N formerly Marina Dunes Yacht Anchoragat f nL Received After Agenda Printed January 26, 2016 Item No. 20 From: Torres, Michael Sent: Monday, January 25, 2016 12:00 PM To: Brown, Leilani Subject: Fwd: January 26, 2016 Council Meeting: Agenda Item No. 20 Attachments: City of Newport Beach 1-25-16.pdf, ATT00001.htm Begin forwarded message: From: "Pemberton, Sheri@SLC" <Sheri.Pemberton @slc.ca.gov> Date: January 25, 2016 at 11:54:00 AM PST To: "DDixon@NewportBeachCa.gov" <DDixon@NewportBeachCa.gov>, "TPetros@NewportBeachCa.gov" <TPetros@NewportBeachCa.gov>, "dduffield@newportbeachca.gov" <dduffield@newportbeachca.gov>, "KMuldoon@NewportBeachCa.gov" <KMuldoon@NewportBeachCa.gov>, "EdSelich@roadrunner.com" <EdSelich@roadrunner.com>, "SPeotter@NewportBeachCa.gov" <SPeotter@NewportBeachCa.gov>, "keithcurryl@vahoo.com" <keithcurrvl@vahoo.com> Cc: "mtorres@newportbeachca.gov" <mtorres@newportbeachca.gov>, "dkiff@newportbeachca.gov" <dkiff@newportbeachca.gov>, "Andrew Vogel (And rew.Vogel@doi.ca.gov)" <Andrew.Vogel@doi.ca.gov>, "Lucchesi, Jennifer@SLC' <Jennifer. Lucchesi @sic.ca.gov>, "Scheiber, Sharron@SLC' <Sharron.Scheiber@slc.ca.gov>, "iamesbnetzer@aol.com" <iamesbnetzer@aol.com>, "Connor, Colin@SLC" <Colin.Connor@slc.ca.gov> Subject: January 26, 2016 Council Meeting: Agenda Item No. 20 Dear Mayor Dixon and Councilmembers, Attached is a letter from the California State Lands Commission staff concerning Agenda Item No. 20 on the January 26, 2016 meeting agenda. Please contact me at (916) 574-1992 or (916) 574-1800. If you have questions or would like to discuss. Thank you, -Sheri Sheri Pemberton Chief, External Affairs & Legislative Liaison California State Lands Commission 100 Howe Avenue — Suite 100 South Sacramento, CA 95825 (916)574-1800 STATE OF CALIFORNIA EDMUND G. BROWN JR., Govemor CALIFORNIA STATE LANDS COMMISSION 100 Howe Avenue, Suite 100 -South Sacramento, CA 95825-8202 January 25, 2016 SENT VIA ELECTRONIC AND U.S.MAIL Mayor Dixon and Councilmembers City of Newport Beach 100 Civic Center Drive Newport Beach, CA 92660 JENNIFER LUCCHESI, Executive Officer (916) 574-1800 Fax (916) 574-1810 California Relay Service TDD Phone 1-800-735-2929 from Voice Phone 1-800-735-2922 Contact Phone: (916) 574-1800 Contact Fax: (916) 574-1810 File Ref: G 09-02 RE: Agenda Item No. 20; January.26, 2016 City of Newport Beach Council Meeting Dear Mayor Dixon and Councilmembers: This correspondence pertains to Agenda Item No. 20 on the Newport Beach City Council (City) January 26, 2016 meeting agenda, which addresses fair market rent for moorings located upon tidelands in Newport Harbor. Notwithstanding the City's staff report and as set forth below, the California State Lands Commission (Commission) staff has substantive concerns regarding the draft appraisal report prepared by Netzer & Associates that is the basis for setting fair market rent at $35.00. per linear foot for offshore moorings on tidelands and at $17.50 per linear foot for onshore moorings. Commission staff therefore requests that the City defer action on Agenda Item No. 20. As the trustee of state tidelands and, submerged lands located within the City of Newport Beach, including Newport Bay, the City is entrusted with considerable discretion and a commensurate fiduciary responsibility in determining how statewide public trust needs may best be met. This discretion operates within the parameters of the California Constitution, the common law Public Trust Doctrine, the terms of the statutory trust grant, and the duties set forth in Public Resources Code section 6009.1. Importantly, the City is entrusted to manage these state owned lands and resources in trust for the benefit of all Californians without subjugation of statewide interests to the inclination of local interests and affairs. Importantly, the City's specific legislative trust grant requires that the City receive fair market rent for the use and occupation of state tidelands. While the Commission is not typically involved in day-to-day management operations for legislatively granted public trust lands, it has oversight authority to review the management of public trust lands and assets by local government trustees to ensure consistency with the City's statutory trust grant and the relevant provisions of the law, including that fair market rent is received for the use of sovereign tide and submerged lands. Mayor Dixon and Councilmembers January 25, 2016 Page 2 Commission staff appreciates that the City accepted its suggestion to obtain an appraisal for its rental determination for moorings located on tidelands in the Newport Harbor. Unfortunately, based on our review the appraisal lacks important supporting discussion and analysis in a number of areas, which may affect the determination of fair market rent. Initial comments on the appraisal are enclosed and intended to help ensure that the City reaches a justifiable fair market rent determination. Staff comments and questions are limited to the valuation -related issues. A more detailed review would result in additional comments, questions and edits. Commission staff respectfully requests that the City defer.action on this item to ensure that the City has obtained a sound appraisal that will inform and support a fair market rent determination for on and offshore moorings located on state-owned public tidelands. Additionally, staff reserves the opportunity to comment further on the City's mooring transfer policies as staff is still reviewing those policies and their consistency with applicable law. Sincerely, SHERI PEMBERTON Chief, External Affairs Division Enclosure (1) Appraisal review comments and questions cc: Dave Kiff, City Manager, City of Newport Beach Michael Torres, Assistant City Attorney Jennifer Lucchesi, Executive Officer, State Lands Commission Andrew Vogel, Deputy Attorney General COMMENTS & QUESTIONS January 21, 2016 Property: Fair Market Rent, Offshore & Onshore Moorings, Newport Beach, California Appraiser: James B. Netzer, MAI Date. of Value: January 6, 2016 The following comments and questions pertain to the more important valuation -related issues noted during the review of the draft appraisal provided. The comments.and questions presented below do not represent a formal appraisal review of the draft appraisal and are intended to provide input to the City of Newport Beach. • Page 3, Scope of Investigation: No information is provided as to the scope of the appraiser's investigations and analyses. • Page 4, Specific Assumption: The specific assumption states that it is beyond the scope of the appraisal to assess the highest and best use of each submerged tideland property. Why is it beyond the scope and why isn't is disclosed on Page 3 under Scope of Investigation? • Page 10, Market Rent Survey: When were the rental rates for the two comparables set? • Page 12, CPI Analysis: The appraiser assumes that the 1976 and 1995 rents set by the City reflect Fair Market Rent. This assumption should be -included as an extraordinary assumption in the Assumptions and Limiting Conditions section of the report. Further, the appraiser should include some discussion as to how the 1976 and 1995 rates were set in order to substantiate that assumption. • Page 12, CPI Analysis: The appraiser should include discussion as to why the figure based on the trending of the 1995 figure is judged to be more reliable. • Page 13, Ratio Analysis: The appraiser states that the ratios derived from three marinas not used in the analysis have different user profiles and are not reflective of the ratio applicable to this analysis. The appraiser should. provide additional discussion as to how the user profiles differ from the subject and what is considered an applicable ratio. • Page 13 Ratio Analysis: How was the 14% of the Newport Harbor Marina Index established? Specifically, what is the basis for 14% and how were the seven marinas determined? • Page 15, last paragraph: The appraiser relies on the Newport Mooring Association's representation relating to dinghy storage rates. Is there data to support this representation? • Page 16, Reconciliation: Three of the four indications of value are based on analyses of different mooring sizes. The indication of value for the Comparable Rentals Approach is based on moorings under 30 feet and up to 54 feet. The Ratio'Analysis is based on 30-31 feet. The Tidelands Approach is based on 40 Comments & Questions Page 2 Fair,Market Rent; Offshore and Onshore Mooring Rates feet. The CPi An method is not based on a specific mooring size. The appraiser should discuss this and take it into account in the Reconciliation. • Page 16, Reconciliation: Why is there no dinghy adjustment for the Tidelands method? • Page 17, 3`d paragraph: The appraiser states that the Ratio Analysis is not judged to be a reliable measure of Fair Market Rent. He states that ratios'can vary dramatically, but his analysis was based on one ratio. The appraiser should provide more discussion on why this approach is not reliable. • . Page 17, 0 paragraph: The appraiser states that there are merits to the Tidelands analysis, but does not discuss them. The appraiser should provide more discussion on the merits. • Page 17, 5t" paragraph: The appraiser gives most weight to the Comparable Rental and CPI approaches, with the CPI Analysis setting the low end of Fair Market Rent and the average of the Comparable Rental Approach setting the high end. As the appraiser states on page 12, "'The application of the CPI method over a long period reflects general price trends, but does not take into consideration changes in market conditions for a specific good or service within a market area." Because the CPI may not accurately reflect trends in real estate market rents and because it is not known how the 1995 rent was set, this indication may not be a reliable indicator of market rent. • The draft appraisal report provided did not contain the Addenda, As stated above, these comments and questions reflect only the more important valuation -related issues. There are additional comments, questions, and edits that would be noted in a more detailed review. ITEM 20 NETZER & ASSOCIATES / - Real Estate Appraisal & Consulting DATE g January 26, 2016 File No. 2015-024 Chris Miller Harbor Manager City of Newport Beach, Harbor Department 829 Harbor Island Drive Newport Beach, CA 92660 Re: Appraisal Services Fair Market Rent — Off -shore & On -shore Moorings Newport Beach, California Dear Mr. Miller: I am in receipt of the letter form Sheri Pemberton, Chief, External Affairs & Legislative Liaison with the California State Lands Commission, which is dated January 25, 2016 and applies to the above referenced matter. In accordance with your request, I have reviewed the "Comments & Questions" enclosure that is dated January 21, 2016, and have the following responses: • Page 3, Scope of Investigation: There is no specific appraisal standard as to the length or the extent of the description of the "Scope" of the appraisal and a Statement of the "Scope" is included on Page 3. I believe that reading the report assists the reader in understanding the Scope of the assignment. Page 4, Specific Assumption: The Purpose and Function of the appraisal is very specific — estimate the Fair Market Rent of the respective moorings. The underling assumption is that the on -shore and off -shore moorings represent the Highest and Best Use of the associated tidelands; therefore, there is no analysis of an alternate Highest & Best Use. Page 10, Market Rent Survey: On the basis of my interview with the Dockmaster at the Balboa Yacht Club (BYC), the exact date the rental rate was established was not available, but was reported to be the 2010-2011 time frame. As set forth in the narrative of my report (Page 11)), The operator noted that the rental rates are dictated by the Unified Port of San Diego and the last increase was in 2007. • Page 12, CPI Analysis: I do not know the specific steps taken to establish the "market" rental rates in 1976 and 1995. I discussed the rates with Chris Miller. With respect to the 1976 rates it was noted that there is a "general agreement" that the 1976 figure of $6.00 per linear foot was the "market". The 1995 rate was established by Resolution 95-77, which states: 170 E. Seventeenth Street, Suite 206 ♦ Costa Mesa, CA 92627 ♦ Phone (949) 631-6799 ♦ FAX (949) 6314631 Chris Miller January 26, 2016 Page 2 WHEREAS, the City Council of the City of Newport Beach has considered the fees recommended by the Harbors and Beaches Committee and finds them to be fair, equitable and reasonably consistent with charges for mooring permits of a similar nature in other locations. In addition, the Grand Jury Report in 2006/2007 notes that the rates established in 1995 is "equivalent to the Fair Market Value for the use of said Tidelands. " On the basis of the above, I am of the opinion that the assumption that the 1975 ($6.00/LF) and the 1996 ($20.00/LF) mooring rates reflect "fair market rent" is well supported and reasonable. • Page 12, CPI Analysis: I believe this is discussed in the report. The "market rent" established in 1995 trended by the CPI to the current date is more reliable as the rent was established at a period closer to the date of value and trended over a shorter time period. • Page 13, Ratio Analysis: The user profiles of the harbors excluded from the Ratio Analysis (Pillar Point, Monterrey & Morro Bay) are more commercial in nature. As such, the payment of the slip fee as compared to the mooring fee (ratio) is more of a business decision, compared to Newport that has a high percentage of pleasure craft and the slip/mooring decision is more a function of discretionary income. As set forth in the report (Pages 13 & 14) I concluded that a ratio of 25 -percent is appropriate. This was based on the analysis of the slip/mooring fees reported by the operator of the marina and moorings in America's Cup Harbor (San Diego), which is primarily a pleasure craft harbor similar to Newport Harbor. • Page 13, Ratio Analysis: The 14% figure is included "as a point of reference" only and not used in the analysis. The seven marinas included in the "Newport Harbor Marina Index" were established by a prior City council with input from the City staff and the harbor users. Combined, they are considered to reflect the "Average" slip fees in Newport Harbor. • Page 15, last paragraph: As set forth in the appraisal (Page 15) the city charges $25 for dinghy storage, the American Legion charges $35 or $45 and Bayside Village charges $80.00 (dry storage); therefore, I concluded that $50.00 was bracketed by the market data and was reasonable for adjustment purposes. • Page 16, Reconciliation: As set forth in the analysis, the moorings in San Diego accommodate a "range" in boat lengths but rent for the same absolute price regardless of vessel length; therefore, the table presents the price per linear foot for the maximum vessel length. In the analysis I used the range reflected, but focused on the 30 -foot length as a measure of central tendency. This length was Chris Miller January 26, 2016 Page 3 used in the Ratio analysis as I had information on both 30 -foot slips and 30 -foot moorings. There are no guidelines for the square feet of Tidelands required to support a "typical" mooring field; therefore, I relied on the moorings (40 -feet) in a specific row in the J Field as delineated in the report presented by the NMA. If a 30 -foot mooring is assumed, and the row would accommodate the same number of moorings (16) the annual rent would increase to $29.47/LF from $26.53/LF. This difference would not change my conclusions. • Paragraph 16, Reconciliation: The Tidelands Analysis assumes the tidelands are rented to a specific user and no longer available for public use. The user could decide to leave the area "unimproved" and the rental rate does not reflect a specific use; therefore, I did not make an adjustment for dinghy storage. In retrospect, the analysis probably does warrant an adjustment for dinghy storage as the rental rate is for tidelands associated with an upland parcel that has access. • Paragraph 17, 3rd paragraph: The analysis is based on a single ratio because only one of the data points uncovered was judged to be applicable to the subject. See two comments above regarding Page 13. • Page 17, 4d' paragraph: The primary merit is that it is based on the premise that there is a rental market for tidelands that can be encumbered for use by a private party; however, in estimating the Fair Market Rent for individual moorings the merits are outweighed by the number of assumptions (rent, typical mooring Sq.Ft., etc...) that need to be made. • Paragraph 17, 5t' paragraph: See comments above regarding Page 12 and the CPI Analysis. Overall the questions appear to be concerned with the amount of explanation included in the report, rather than the analysis and the conclusions presented. I put more focus on researching the applicable market data and presenting supportable analysis and conclusions based on the market data uncovered; therefore, the amount of boilerplate and narrative included may be somewhat abbreviated. On the basis of the comments and the above, I believe my analysis and conclusions are well supported and reliable and I see no reason to re -think the analysis or amend my report. Respectfully submitted, James B.Wet~zer, MAI Califomia 6qleral Appraiser No. AG003143 STATE OF CALIFORNIA CALIFORNIA STATE LANDS COMMISSION 100 Howe Avenue, Suite 100 -South RECEIVED AFTER AGENDA PRINTED 1 ITEM NO:4-!L2:0 JR., Governor _ . [D TE :JENNIEER.L000MESI, Executive Officer (916) 574-1800 Fax (916) 574-1810 Sacramento, CA 95825-8202 ter,, f I } ,, * California Reloy Service TDD Phone 1-800-735-2929 s from Voice Phone 1-800-735-2922 Contact Phone: (916) 574-1800 Contact Fax: (916) 574-1810 Cdfir��f�r�a >9.�J' January 25, 2016 File Ref: G 09-02 SENT VIA ELECTRONIC AND U.S.MAIL Mayor Dixon and Councilmembers City of Newport Beach 100 Civic Center Drive Newport Beach, CA 92660 RE: Agenda Item No. 20; January 26, 2016 City of Newport Beach Council Meeting Dear Mayor Dixon and Councilmembers: This correspondence pertains to Agenda Item No. 20 on the Newport Beach City Council (City) January 26, 2016 meeting agenda, which addresses fair market rent for moorings located upon tidelands in Newport Harbor. Notwithstanding the City's staff report and as set forth below, the California State Lands Commission (Commission) staff has substantive concerns regarding the draft appraisal report prepared by Netzer & Associates that is the basis for setting fair market rent at $35.00 per linear foot for offshore moorings on tidelands and at $17.50 per linear foot for onshore moorings. Commission staff therefore requests that the City defer action on Agenda Item No. 20. As the trustee of state tidelands and submerged lands located within the City of Newport Beach, including Newport Bay, the City is entrusted with considerable discretion and a commensurate fiduciary responsibility in determining how statewide public trust needs may best be met. This discretion operates within the parameters of the California Constitution, the common law Public Trust Doctrine, the terms of the statutory trust grant, and the duties set forth in Public Resources Code section 6009.1. Importantly, the City is entrusted to manage these state owned lands and resources in trust for the benefit of all Californians without subjugation of statewide interests to the inclination of local interests and affairs. Importantly, the City's specific legislative trust grant requires that the City receive fair market rent for the use and occupation of state tidelands. While the Commission is not typically involved in day-to-day management operations for legislatively granted public trust lands, it has oversight authority to review the management of public trust lands and assets by local government trustees to ensure consistency with the City's statutory trust grant and the relevant provisions of the law, including that fair market rent is received for the use of sovereign tide and submerged lands. Mayor Dixon and Councilmembers January 25, 2016 Page 2 Commission staff appreciates that the City accepted its suggestion to obtain an appraisal for its rental determination for moorings located on tidelands in the Newport Harbor. Unfortunately, based on our review the appraisal lacks important supporting discussion and analysis in a number of areas, which may affect the determination of fair market rent. Initial comments on the appraisal are enclosed and intended to help ensure that the City reaches a justifiable fair market rent determination. Staff comments and questions are limited to the valuation -related issues. A more detailed review would result in additional comments, questions and edits. Commission staff respectfully requests that the City defer action on this item to ensure that the City has obtained a sound appraisal that will inform and support a fair market rent determination for on and offshore moorings located on state-owned public tidelands. Additionally, staff reserves the opportunity to comment further on the City's mooring transfer policies as staff is still reviewing those policies and their consistency with applicable law. Sincerely, SHERI PEMBERTON Chief, External Affairs Division Enclosure (1) Appraisal review comments and questions cc: Dave Kiff, City Manager, City of Newport Beach Michael Torres, Assistant City Attorney Jennifer Lucchesi, Executive Officer, State Lands Commission Andrew Vogel, Deputy Attorney General COMMENTS & QUESTIONS January 21, 2016 Property: Fair Market Rent, Offshore & Onshore Moorings, Newport Beach, California Appraiser: James B. Netzer, MAI Date of Value: January 6, 2016 The following comments and questions pertain to the more important valuation -related issues noted during the review of the draft appraisal provided. The comments and questions presented below do not represent a formal appraisal review of the draft appraisal and are intended to provide input to the City of Newport Beach. • Page 3, Scope of Investigation: No information is provided as to the scope of the appraiser's investigations and analyses. • Page 4, Specific Assumption: The specific assumption states that it is beyond the scope of the appraisal to assess the highest and best use of each submerged tideland property. Why is it beyond the scope and why isn't is disclosed on Page 3 under Scope of Investigation? • Page 10, Market Rent Survey: When were the rental rates for the two comparables set? • Page 12, CPI Analysis: The appraiser assumes that the 1976 and 1995 rents set by the City reflect Fair Market Rent. This assumption should be included as an extraordinary assumption in the Assumptions and Limiting Conditions section of the report. Further, the appraiser should include some discussion as to how the 1976 and 1995 rates were set in order to substantiate that assumption. • Page 12, CPI Analysis: The appraiser should include discussion as to why the figure based on the trending of the 1995 figure is judged to be more reliable. • Page 13, Ratio Analysis: The appraiser states that the ratios derived from three marinas not used in the analysis have different user profiles and are not reflective of the ratio applicable to this analysis. The appraiser should provide additional discussion as to how the user profiles differ from the subject and what is considered an applicable ratio. • Page 13 Ratio Analysis: How was the 14% of the Newport Harbor Marina Index established? Specifically, what is the basis for 14% and how were the seven marinas determined? • Page 15, last paragraph: The appraiser relies on the Newport Mooring Association's representation relating to dinghy storage rates. Is there data to support this representation? • Page 16, Reconciliation: Three of the four indications of value are based on analyses of different mooring sizes. The indication of value for the Comparable Rentals Approach is based on moorings under 30 feet and up to 54 feet. The Ratio Analysis is based on 30-31 feet. The Tidelands Approach is based on 40 Comments & Questions Page 2 Fair Market Rent, Offshore and Onshore Mooring Rates feet. The CPI Analysis method is not based on a specific mooring size. The appraiser should discuss this and take it into account in the Reconciliation. • Page 16, Reconciliation: Why is there no dinghy adjustment for the Tidelands method? • Page 17, 3`d paragraph: The appraiser states that the Ratio Analysis is not judged to be a reliable measure of Fair Market Rent. He states that ratios can vary dramatically, but his analysis was based on one ratio. The appraiser should provide more discussion on why this approach is not reliable. • Page 17, 4th paragraph: The appraiser states that there are merits to the Tidelands analysis, but does not discuss them. The appraiser should provide more discussion on the merits. • Page 17, 5th paragraph: The appraiser gives most weight to the Comparable Rental and CPI approaches, with the CPI Analysis setting the low end of Fair Market Rent and the average of the Comparable Rental Approach setting the high end. As the appraiser states on page 12, "'The application of the CPI method over a long period reflects general price trends, but does not take into consideration changes in market conditions for a specific good or service within a market area." Because the CPI may not accurately reflect trends in real estate market rents and because it is not known how the 1995 rent was set, this indication may not be a reliable indicator of market rent. The draft appraisal report provided did not contain the Addenda. As stated above, these comments and questions reflect only the more important valuation -related issues. There are additional comments, questions, and edits that would be noted in a more detailed review.