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The proposed Ordinance significantly exacerbates this problem. By imposing an <br />additional cap on annual rent increases (60% of CPI, maximum 5%) and by rolling back <br />rents to October 29, 2025 levels, the Ordinance further limits the revenue available to <br />affordable housing owners at exactly the time when operating costs continue to escalate <br />unconstrained. The practical consequences of this worsened compression are <br />predictable and serious: <br />• Staffing Reductions: On-site management and maintenance staffing reductions, <br />diminishing the quality and responsiveness of resident services. <br />• Reduced Community Amenity Hours: Curtailment or elimination of community <br />room, computer lab, and other resident amenity hours as payroll and operating costs <br />are cut. <br />• Deferred Maintenance: Deferral of capital repairs and preventive maintenance, <br />leading to deteriorating physical conditions that ultimately harm the low-income <br />residents the Ordinance seeks to protect. <br />• Reserve Shortfalls: Failure to fund required replacement reserves at contractually <br />mandated levels, potentially triggering defaults under regulatory agreements and <br />loan documents and jeopardizing the long-term viability of the development. <br />Unlike market-rate landlords, affordable housing developers cannot respond to cost <br />compression by raising rents. Water bills, sewer charges, trash-hauling fees, and <br />insurance premiums arrive at market rates with no relief mechanism. The Ordinance <br />provides no offset for these costs, no hardship petition process that accounts for the <br />regulatory-agreement-constrained revenue structure of affordable housing, and no <br />exemption from the annual rental housing fee — a fee that, for affordable housing <br />owners, is an unrecoverable cost absorbed entirely from already-compressed operating <br />budgets. Over the 15- to 55-year term of a typical regulatory agreement, this steady <br />erosion of operating margin poses a fundamental threat to the financial stability of <br />properties that the City depends upon to house its lowest-income residents. Passage of <br />this Ordinance, without an exemption or meaningful relief for affordable housing, will <br />accelerate that erosion. <br />V. RECOMMENDED AMENDMENTS <br />We respectfully request that the Council amend Chapter 42 to add an express <br />exemption — or at minimum a harmonization provision — for low-income housing <br />developments operating under long-term affordability restrictions. Specifically, we <br />recommend one or more of the following: <br />• Exempt from all provisions of Chapter 42 any rental unit subject to a recorded <br />regulatory agreement with a federal, state, or local government agency that <br />restricts rents to affordable levels for a term of not less than 15 years and <br />requires just cause for eviction as a condition of the regulatory agreement. <br />• At a minimum, exempt from the rent stabilization provisions of Sections 42.6 <br />and 42.15 any unit whose rent is determined pursuant to a regulatory <br />agreement with a government agency, on the grounds that the regulatory