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Attachment F <br />the displaced tenant(s) the flrst right to return to the rental unit <br />upon completion of the substantial remodel. <br />Comment #1: I suggest that this right to return obligation be <br />conditioned on the requirement that the displaced tenant(s) <br />were in compliance with the previous existing lease terms. <br />landlords may have other just causes to address non-compliance of <br />prior lease terms. <br />7 Chapter 2.1 FRR Guidelines - All Fair Rate of Return Appeals <br />must be received by the City Clerk's Office within ten (10) <br />calendar days after the substantial remodel is completed. <br />Comment #2: It is important to allow adequate time to compile <br />cost data and perhaps communicate with tenants, etc. Ten <br />calendar days does not seem reasonable. I recommend 20 <br />business days as a more reasonable time period. <br />The 10 calendar day requirement to submit appeals is included in <br />Section 42.5(B)(2)(d)(iv)(IV) of the Tenant Protection Ordinance and <br />would require amending the TPO. Amendments to the TPO are not being <br />considered at this time and therefore no changes are included in the <br />Administrative Regulations. <br /> <br />Note, during the development of the TPO, staff received input from <br />focus groups with landlord and tenant representatives, and both sides <br />expressed a desire to keep the right to return timeline as short as <br />possible to limit the time that units remain vacant. <br />8 Chapter 2.8 FRR Guidelines – If an appeal is found incomplete in <br />its current form, the City will mail a notice (and a courtesy copy <br />will be sent by e-mail) of this flnding, and an explanation of the <br />defects to the landlord. A landlord will have flve (5) business <br />days from the date of the City notice to resolve any identifled <br />defects or provide the missing documents. If the City does not <br />receive a response from the landlord within the deadline, the <br />appeal will be rejected as incomplete. <br />Comment #3: Five business days is not sufficient time. I <br />recommend at least 15 business days to resolve any identifled <br />defects or provide missing documents. <br /> <br />Edit to Chapter 2.8 of the FRR Appeal Guidelines: <br />The timeline for landlords to resolve identifled defects or provide <br />missing information for appeals has been increased to 14 calendar <br />days. By making this change, staff seeks to strike a balance between <br />providing landlords with enough time to address defects or providing <br />missing information and limiting the amount of time a unit remains <br />vacant. <br /> <br />The 15 business days requested by the commenter has the potential to <br />result in more than a three-week delay depending on when weekends <br />and holidays fall. <br /> <br />9 Chapter 2.10 FRR Guidelines - The appeal officer may request <br />additional information from the landlord. The landlord will be <br />required to submit such additional information within flve (5) <br />business days of such request. <br />Comment #4: Likewise, flve business days to respond to the <br />request for additional information is not sufficient time. I <br />Edit to Chapter 2.10 of the FRR Guidelines: <br />The timeline for landlords to provide additional information requested <br />by the appeal officer has been increased to 14 calendar days. By <br />making this change, staff seeks to strike a balance between providing <br />landlords with enough time to provide additional information and <br />limiting the amount of time a unit remains vacant. <br /> <br />8.A. - Page 71 of 85 <br />329