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REDWOOD CITY FAIR AND AFFORDABLE HOUSING ORDINANCE <br /> <br />Economic & Planning Systems, Inc. 29 Cumulative Impacts <br />Property managers and owners also noted that staffing costs have increased due <br />to wage growth, labor shortages, and increased compliance responsibilities. <br />Several stakeholders indicated that additional requirements of the proposed <br />Ordinance may require more staff time or outside professional assistance. <br />While reliable data on property maintenance, repair, and management costs is not <br />readily available, it is likely that they generally track with the Consumer Price <br />Index (CPI). As documented in the initial 9212 Report, market rents in Redwood <br />City have generally not kept pace with CPI adjusted inflation over the last ten <br />years, a trend that was particularly acute during the pandemic. This suggests that <br />for many building owners, general property maintenance, repair, and management <br />costs may be increasing faster than rental revenue. <br />In addition to routine maintenance, the cumulative financial impacts described <br />above, and the proposed Ordinance may reduce property owners' ability to <br />finance substantial capital improvements, including soft-story seismic retrofits, <br />roof replacements, and other major investments necessary to maintain the safety, <br />resilience, and long-term preservation of the City's older rental housing stock. <br />Increased Legal Complexity and Uncertainty <br />Administrative Complexity <br />Stakeholders consistently identified administrative complexity as a central <br />concern. The proposed Ordinance would create a new local compliance system <br />that extends beyond rent stabilization. The burden is greatest where owners <br />either do not currently interact with a local rent program or already operate under <br />complex affordable housing compliance systems. <br />Stakeholders raised concerns about expanded enforcement remedies, private <br />litigation, treble damages, anti-harassment provisions, and uncertainty about how <br />the proposed Ordinance would be interpreted. This concern was especially <br />pronounced among smaller “mom and pop” owners and affordable housing <br />providers. These smaller scale operators often lack legal capacity or financial <br />resources and may settle claims to avoid litigation costs even where they believe <br />they acted appropriately. Affordable housing providers may face a different <br />problem: they operate under complex regulatory agreements and may be exposed <br />to claims if local requirements of the proposed Ordinance conflict with federal, <br />State, tax credit, voucher, or public financing rules. <br />Several stakeholders emphasized that inadvertent errors are more likely when <br />multiple regulatory systems overlap. Examples include rent calculations for deed <br />restricted units, utility allowance adjustments, over-income tenant issues, unit <br /> <br /> <br />8.A. - Page 88 of 168 <br />98