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Attachment F <br />Summary of Feedback and Proposed Changes to the Tenant Protection Ordinance Administrative Regulations and Fair <br />Rate of Return Appeal Guidelines <br />Below is a summary of the public comments that had actionable requests related to the Tenant Protection Ordinance (TPO) <br />Administrative Regulations and Fair Rate of Return Appeal Guidelines (FRR Guidelines). Full copies of the public comments submitted <br />during the public comment period are included as Attachment G to the staff report. Several of the comments received asked for changes <br />to the TPO itself and did not provide direct feedback on the Administrative Regulations or FRR Guidelines. Since changes to the TPO are <br />not being considered at this time, those comments were not included in this summary table. <br /> <br /> # Comment / Request Response and Updates <br />1 First, the draft administrative regulations are complex and may <br />be difficult for small housing providers to navigate. As a result, <br />even well-intentioned owners may struggle to fully understand <br />and comply with the requirements, increasing the risk of <br />unintentional violations and added costs. <br /> <br />Request - Simplify the Administrative Regulations to improve <br />clarity and usability <br />Staff have clarifled timelines and extended some of the timelines (see <br />comments # 8 and # 9) in the following sections: <br />Administrative Regulations: <br />• Added a new Chapter 5.5: Relocation Assistance Application <br />Process Timeline <br />• Chapter 5.6: Alternative Mitigation to Relocation Assistance <br />Requirements <br />FRR Guidelines: <br />• Chapter 2: Application for Fair Rate of Return Appeal <br />Additionally, Project Sentinel is available to answer questions and <br />provide education to tenants and landlords alike. <br /> <br />2 Second, the requirement that displaced tenants be offered the <br />right to return at the same rental rate, subject only to limited <br />state-allowed increases, raises serious concerns regarding <br />flnancial feasibility. Substantial remodels often involve <br />signiflcant costs, including construction, labor, materials, <br />flnancing, and insurance. If rents cannot adjust to refiect these <br />investments, many necessary improvements may be delayed or <br />not undertaken at all, ultimately impacting the quality and <br />safety of the housing stock. While the Fair Rate of Return appeal <br />process is intended to address this issue, the current framework <br />places the burden entirely on housing providers and appears to <br />involve a potentially lengthy and uncertain process. Without <br />The Fair Rate of Return Appeals process was developed to provide a <br />standardized and objective process by utilizing a formula-based <br />methodology in order to allow landlords to understand upfront how <br />appeal determinations will be made. <br /> <br />As noted above, Staff have clarifled timelines and extended some of the <br />timelines in Chapter 2: Application for Fair Rate of Return Appeal (see <br />comments # 8 and 9 for additional information). <br />8.A. - Page 68 of 85 <br />326