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MEMORANDUM <br />TO: Redwood City City Council <br />FROM: 112 Vera Ave., L.P. <br />DATE: June 8, 2026 <br />RE: Impact of Proposed Fair and Affordable Housing Ordinance <br />(Chapter 42) on Low-Income Housing Developments with Long- <br />Term Affordability Restrictions <br /> <br /> <br />I. PURPOSE <br />This memorandum provides notice that the proposed Redwood City Fair and Affordable <br />Housing Ordinance (Municipal Code Chapter 42, the "Ordinance") contains no <br />exemption for privately-owned low-income housing developments operating under long- <br />term affordability restrictions. If adopted as written, the Ordinance will impose significant <br />compliance obligations on these properties — obligations that conflict with or duplicate <br />existing regulatory agreements and that may adversely affect the financial feasibility of <br />affordable housing development in Redwood City. <br />II. BACKGROUND <br />Low-income housing developments with long-term affordability restrictions include <br />properties financed through the Low-Income Housing Tax Credit (LIHTC) program, <br />HOME Investment Partnerships funds, Community Development Block Grants, tax- <br />exempt bond financing, and similar programs. These properties are governed by <br />regulatory agreements with federal, state, and local agencies that already impose strict <br />controls on rents, tenant eligibility, lease terms, and eviction procedures. <br />The Ordinance establishes a comprehensive Rent Stabilization and Tenant Protections <br />Program applicable to "all residential rental units in the City of Redwood City except <br />those units that are exempted" (Sec. 42.5.D). The exemptions are enumerated in <br />Sections 42.3(B) and 42.4. A careful review of all exemption language confirms that no <br />provision exempts affordable housing developments with regulatory agreements from <br />any part of the Ordinance. <br />III. FINDINGS: NO EXEMPTION EXISTS <br />The Ordinance enumerates three categories of units fully exempt from all provisions <br />(Sec. 42.3.B): <br />• Hotels, motels, and inns renting primarily to transient guests for fewer than 30 days; <br />• Hospitals, convents, monasteries, extended medical care facilities, non-profit homes <br />for the aged, and accredited higher education dormitories; and <br />• Units that are the landlord's primary residence where the landlord shares a bathroom <br />or kitchen with the tenant.