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Attachment F <br />clear, objective standards and predictable timelines, the appeal <br />mechanism may function more as a barrier than a viable <br />solution. <br /> <br />Request – <br />- Establish clear, objective, and transparent criteria for <br />determining a fair rate of return <br />- streamline the appeal process with deflned <br />timelines and reduced administrative burden. <br />3 It is also important to recognize that small “mom and pop” <br />housing providers operate under very different conditions than <br />large corporate entities. Many rely on rental income to cover <br />mortgages, property taxes, insurance, and maintenance, and <br />often have limited margins. A one-size-flts-all regulatory <br />approach does not adequately refiect these differences. In light <br />of these concerns, I respectfully request that the City Council <br />consider the following prior to flnal adoption: Consider tailored <br />provisions or exemptions for small housing providers. <br /> <br />The formula-based approach used in the FRR appeal Guidelines was <br />developed to provide a standardized and objective process for a variety <br />of housing types/sizes. However, the appeal officer has the discretion to <br />consider other extenuating circumstances in their decision. <br />4 I would recommend an Annual Review of Administrative Costs. <br />The City should publish an annual report on how much these <br />regulations increase the cost of operating rental housing in <br />Redwood City and how many units per year fell into this <br />category. Also report on how much was paid annually by <br />housing providers in order to comply with the ordinance, (to <br />include all fees such as application fees, noticing fees, permit <br />fees, etc...). The report should also include the cost to <br />administer this policy, staff time, consultant time and any other <br />third party such as an administrative contractor, etc. <br /> <br /> <br /> <br /> <br />“Chapter 7: Annual Reporting” has been added to the Administrative <br />Regulations to address this request. <br /> <br />City staff shall prepare and publish a report annually to provide certain <br />data on the implementation and administration of the TPO. This report <br />shall contain a summary of the following information, if available: <br />a) Number and types of notices of termination for no -fault <br />received by the City <br />b) Number of relocation assistance applications (including <br />number of approvals, denials, appeals, and proof of <br />payment from landlords) <br />c) Number of Fair Rate of Return Appeals <br />d) Amount of costs incurred by City for implementation <br />8.A. - Page 69 of 85 <br />327