|
Economic & Planning Systems, Inc. 49 Conclusion
<br />6. Conclusion
<br />This supplemental analysis finds that the proposed Ordinance would likely create
<br />impacts beyond the direct application of rent stabilization. While Costa-Hawkins
<br />limits which units can be subject to local rent caps, the proposed Ordinance
<br />includes several non-rent control provisions that may apply more broadly,
<br />including expanded just cause protections, relocation assistance, right-to-return
<br />requirements, tenant safety plans, registry requirements, legal services for low-
<br />income tenants, fees, petitions, appeals, and enforcement. These provisions may
<br />affect property operations, repair decisions, redevelopment feasibility, affordable
<br />housing preservation, and City administrative costs.
<br />The potential impacts would not be uniform across the rental housing stock.
<br />Older multifamily buildings, master-metered properties, pre-1995 rent-restricted
<br />units, smaller scale operators, and deed restricted affordable housing providers
<br />are likely to have less flexibility to absorb new costs or administrative burdens.
<br />For older buildings, the main concern is that routine repairs or system
<br />replacements may trigger more complex compliance, tenant safety plan,
<br />relocation, or right-to-return obligations. For affordable housing providers, the
<br />concern is that additional costs may reduce funds available for resident services,
<br />maintenance, replacement reserves, residual receipts payments, or preservation
<br />rehabilitation.
<br />Smaller scale operators may face disproportionate impacts because they have
<br />fewer units and less administrative infrastructure over which to spread compliance
<br />costs. A tenant safety plan, hearing, relocation payment, registry obligation, or
<br />program fee can represent a significant cost relative to annual property cash flow.
<br />The proposed Ordinance may also affect rehabilitation, redevelopment, and
<br />affordable housing preservation. Relocation assistance, right-to-return
<br />obligations, successor-owner requirements, and tenant safety plan requirements
<br />could increase uncertainty for projects requiring temporary relocation, substantial
<br />renovation, or when units are demolished or withdrawn from rental market. These
<br />impacts may be especially important for affordable housing re-syndication and
<br />preservation rehabilitation projects, which often rely on fixed financing sources,
<br />limited reserves, and carefully phased construction schedules.
<br />The City would also face significant implementation responsibilities. The proposed
<br />Ordinance would require a new fee-funded program with staffing, registry,
<br />enforcement, hearings, legal services, reporting, and data management functions.
<br />The analysis indicates that the stated fee levels may be substantially below the
<br />amount needed to recover full program costs, particularly when tenant legal
<br />
<br />8.A. - Page 108 of 168
<br />118
|