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2 <br /> <br />Comment #4: Likewise, five business days to respond to the request for additional information is not <br />sufficient time. I recommend at least 15 business days to locate and provide the additional <br />information. <br /> <br />Chapter 3: Fair Rate of Return Appeal Administrative Fee <br /> <br />1. The Appeal Fee will be determined based on the fully burdened hourly rates of the staff and <br />contracted rates of the appeal officer performing the service. <br /> <br />Comment #5: Please consider that many landlords have modest means and their expenses <br />associated with a rental property (insurance, maintenance, property taxes, etc.) have all been <br />increasing significantly in recent years and are not limited by government ordinance. As drafted, the <br />appeal fee is an undefined cost. I suggest that an expense cap be defined (e.g. $1,000) such that the <br />landlord will have the ability to understand the expense exposure. <br /> <br />Chapter 4: Standard for Approving a Fair Rate of Return Rent <br /> <br />1. As drafted, the Standard for Approving a Fair Rate of Return Rent does not consider a market survey <br />of rental rates for similar properties in the area. <br /> <br />Comment #6: I recommend that the Standard for Approving a Fair Rate of Return Rent should also <br />include an evaluation of rental rates for comparable properties in the area. <br /> <br />2. Article 6 of the “Verified Substantial Remodel Cost (VSRC)” indicates that “Any forgone income <br />during the substantial remodel is not included in the VSRC calculation”. <br /> <br />Comment #7: The forgone income during the remodel is a very substantial cost burden for the <br />landlord. It is not fair or reasonable to exclude this cost from the VSRC calculation. <br /> <br />Thanks again for the opportunity to comment. <br /> <br />Regards, <br />Richard Dalton <br />(415) 265 4813 <br />8.A. - Page 81 of 85 <br />339