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1 <br />CLK-Crystel Tuifua <br />From:Brian Ponty <brianponty@yahoo.com> <br />Sent:Saturday, April 4, 2026 12:50 PM <br />To:Council-Elmer MartinezSaballos; Council-Kaia Eakin; Council-Isabella Chu; Council-Jeff <br />Gee; Council-Diane Howard; Council-Marcella Padilla; Council-Christopher Sturken <br />Cc:Fernando Pena; Rhovy Lyn Antonio <br />Subject:Redwood City's Tenant Protection Ordinance - Draft Administrative Regulations & Fair <br />Rate of Return Appeal Guidelines <br />Dear Mayor Saballos and Members of the Redwood City Council, <br />I am writing to provide public comment on the draft Administrative Regulations and Fair Rate of Return <br />Appeal Guidelines associated with the Tenant Protection Ordinance (TPO), currently under review. <br />I appreciate the City’s efforts to promote housing stability and protect tenants. These are important and <br />worthwhile goals. However, as a local small housing provider, I would like to share several concerns <br />regarding the practical impacts of the proposed regulations on those of us who provide the majority of <br />rental housing in the community. <br />First, the draft Administrative Regulations are complex and may be difficult for small housing providers to <br />navigate. Unlike large institutional operators, most local property owners do not have access to legal <br />teams or compliance staff. As a result, even well-intentioned owners may struggle to fully understand <br />and comply with the requirements, increasing the risk of unintentional violations and added costs. <br />Second, the requirement that displaced tenants be offered the right to return at the same rental rate, <br />subject only to limited state-allowed increases, raises serious concerns regarding financial feasibility. <br />Substantial remodels often involve significant costs, including construction, labor, materials, financing, <br />and insurance. If rents cannot adjust to reflect these investments, many necessary improvements may <br />be delayed or not undertaken at all, ultimately impacting the quality and safety of the housing stock. <br />While the Fair Rate of Return appeal process is intended to address this issue, the current framework <br />places the burden entirely on housing providers and appears to involve a potentially lengthy and <br />uncertain process. Without clear, objective standards and predictable timelines, the appeal mechanism <br />may function more as a barrier than a viable solution. <br />Additionally, the combined effect of just-cause eviction requirements, relocation assistance obligations, <br />and rent limitations creates a layered regulatory structure that significantly increases financial risk and <br />reduces operational flexibility. Over time, this may discourage small housing providers from continuing <br />to offer rental housing, leading to a reduction in supply—an outcome that runs counter to the City’s <br />broader housing goals. <br />It is also important to recognize that small, “mom-and-pop” housing providers operate under very <br />different conditions than large corporate entities. Many rely on rental income to cover mortgages, <br />property taxes, insurance, and maintenance, and often have limited margins. A one-size-fits-all <br />regulatory approach does not adequately reflect these differences. <br /> You don't often get email from brianponty@yahoo.com. Learn why this is important <br />8.A. - Page 74 of 85 <br />332