Agda Pkt 2026.05.11 Joint SA PFA

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Attachment F recommend at least 15 business days to locate and provide the additional information. The 15 business days requested by the commenter has the potential to result in up to a three-week delay depending on when weekends and holidays fall. 10 Chapter 3. FRR Guidelines - The Appeal Fee will be determined based on the fully burdened hourly rates of the staff and contracted rates of the appeal officer performing the service. Comment #5: Please consider that many landlords have modest means and their expenses associated with a rental property (insurance, maintenance, property taxes, etc.) have all been increasing signiflcantly in recent years and are not limited by government ordinance. As drafted, the appeal fee is an undeflned cost. I suggest that an expense cap be deflned (e.g. $1,000) such that the landlord will have the ability to understand the expense exposure. While the FRR Appeal Guidelines do not include a fee amount, the City is proposing a deposit-based fee where a landlord will be required to deposit an amount of $4,500 with the City when submitting an appeal. Since the City intends to capture the full cost of this service, fee amounts will vary based on the actual time and costs of processing an appeal. 11 Chapter 4. FRR Guidelines: As drafted, the Standard for Approving a Fair Rate of Return Rent does not consider a market survey of rental rates for similar properties in the area. Comment #6: I recommend that the Standard for Approving a Fair Rate of Return Rent should also include an evaluation of rental rates for comparable properties in the area. The City did not consider including an evaluation of rental rates for comparable properties in the standard for approving a fair fate of return rent for the following reasons: 1. Comparative practice – The City did not flnd that other jurisdictions do this 2. Added costs – conducting an analysis of comparable rents in the area would add to the cost of processing the appeal that the landlord must pay 3. Cap rate methodology – while the City’s process does not compare rents for other properties, we do use a Bay Area speciflc cap rate which provides a standardized metric for measuring return on investment locally. 12 Chapter 4.1.J.6 FRR Guidelines - Article 6 of the “Verifled Substantial Remodel Cost (VSRC)” indicates that “Any forgone income during the substantial remodel is not included in the VSRC calculation”. Comment #7: The forgone income during the remodel is a very substantial cost burden for the landlord. It is The City is not considering including forgone income into the Verifled Substantial Remodel Cost calculation for the following reasons: 1. The City recognizes that forgone income is a factor in a landlord’s investment decision however the remodel work can also provide landlords with additional beneflts such as tax advantages, interest deductions, and long-term equity appreciation which are also not 8.A. - Page 72 of 85 330