2026-10-14 - Rent Board Workshop

# transcript-source: whisper; whisper.cpp=1.9.5; model=ggml-small.en-q5_1.bin; vad=ggml-silero-v6.2.0.bin; language=en; transcribed=2026-11-11T06:45:36.897Z; job=tx-1794363538255-martpz;

source=https://portlandme.portal.civicclerk.com/event/9731/media (https://cpmedia.azureedge.net/portlandme/926e2975-5f6c-41b2-b9c1-0106d77238c5.mp4)

00:04.23] Alright then, hi everyone. Welcome to the October 14th, 2026 special meeting of the Portland Rent Board.

00:20.77] I'm your chair, Matthew Lacks, and let's call Roll. Kristen? Here. Jonas? Here. Anne-Lore? Here.

00:37.90] And Buddy isn't here yet, but it's expected. And I'm obviously here. Alright, I don't think we have any communications.

00:54.18] So, let's talk about the new Business One, the annual report update. Anne-Lore, you can take it away.

01:12.07] Great. Can you approve me to share my screen? You should be all set now.

01:20.99] Great. Thank you, Dylan. And full transparency, I have not looked at this, except a quick refresher today since I put this together in early September.

01:32.36] What I did was I followed, for the most part, the annual report for 2024. If you look in the code itself, it doesn't ask for anything crazy, I'll just skip ahead.

01:47.11] But the main thing it asks for is a summary of rents within each of the five wards, also known as districts.

01:53.11] So, I made sure to include that, and I've included most of the same analysis that Matt did last year.

01:59.26] So, talked about simple, has all of us, has the background. This is the same letter that we see at the top in all of the other reports.

02:10.37] For the data, I have an Excel that's linked here. You have to, and I've noted this here, you have to actually download it and open it in Excel in order for all of the calculations to work.

02:21.84] It won't work only in Google Sheets. I broke down the board activities, and this is just by using the regular updates that we get from Jessica Hanscom.

02:35.53] So, we heard a total of 46 applications. 18 were approved, one denied, and 23 tabled.

02:43.65] And then I broke those down again by their category, which Matt had done last year as well. So, rent increases, complaints or other.

02:56.54] I also have this slide on the rent control inspections, and there was a big jump in inspections this year compared to last year.

03:04.57] There was a 113% increase, I'm gonna write this by the numbers. Oh yeah, 113% increase in properties inspected, and then 96% increase in units inspected year over year.

03:18.48] Once again split those up by the kind of inspection, so complaints, audits versus quality control.

03:26.84] Here, I think this is the only litigation we had that was relevant to include, but it's on the Trelawney Tenants Union 655 Congress and 59th State Street case.

03:45.53] And then I just have the March 2026 update that the Superior Court affirmed our ruling. I didn't think there was anything else from 2025. Does anyone remember anything?

03:58.30] All right, great. Yeah, and I was I was going through the meeting minutes and things just to make sure I wasn't missing anything and also looking up with the press herald because they're

pretty good at covering things.

04:13.45] This slide, once again, very similar to previous reports, so it relies on the timeline from November 2023 to November 2024. So the reports are actually a year behind the year that is on

them. So this is the 2025 report, but it talks about the rental conditions through November 2024.

04:35.45] So I did a breakdown of the covered versus exempt registrations. There was a total of twenty one thousand three hundred and sixty five registrations this year.

04:50.20] And the none of the above category is the category of covered units. So that's a little over twelve thousand units.

04:59.79] I then broke them down by district. The way that I did this was there was many units. I can't think of their number right now that weren't registered last year.

05:13.87] And so I was able to get a GIS map of our city districts and I was able to help me map most of the address addresses with a really high rate of confidence to a district where it had issues

is, for example, if there is a small street that covers two districts

05:30.90] or goes between two districts, you know, one under the streets, district one, the other is district two, it would raise those to me and then I would it would make a guess and then I would

verify those by hand to make sure that the right district was assigned.

05:42.86] And we see the majority of units are in district one and two, which I think is pretty similar to last year.

05:51.13] And then district five trails with only one thousand eight hundred units, which is much less than I had anticipated. I thought it would be a little more equal.

06:01.62] I then broke down covered versus exempt units by district. So we see for districts one, two, three and five, they have pretty similar ratios are covered to exempt, but district four has a

much lower ratio where exempt units outnumber covered units.

06:18.41] I then broke it down units by rent costs all both covered and exempt, similar to how Matt had done it last year. And then I graphed that out as well. And we see that because all are

included here, thirty four point five percent of units had zero rent reported.

06:38.46] So those are exempt units that didn't have to report and then breaking it down further just to look at the rent cost for covered units and that distribution and three quarters of our units

fall under twenty five hundred and only six percent are actually at three thousand and above.

06:58.73] I then also similar to last year what Matt did is looked at the median rent statistics. And what I did was I removed the zero rents here. So this is all units or no, this is all covered and

exempt units, but I removed the zero rents and I removed nine plus bedrooms.

07:21.31] And we see the overall median rent is seventeen hundred. And we also see that they rise steadily from zero to four bedrooms. And then once we hit five bedrooms, we start to get into this

weird pattern.

07:35.20] It becomes less consistent. I also graphed that out. Every other graph here, even if you can't click it, it exists in the Excel. So you can clearly see how the graph has been made.

07:50.09] The only graphs where I used an outside tool to make them are these median rent graphs because I didn't find that Excel had a nice way to capture the median rent and then the range at the

same time.

08:02.08] I'm really not sure how Matt did it last year because it seems like he was using Excel.

08:06.29] And there is one. I need to flag this to Dylan. There's one unit that has three bedrooms that is recorded as thirty thousand dollars rent. I think maybe it's supposed to be three thousand

dollars. And that's the one inconsistency I've seen or the one really big outlier.

08:28.28] Then I broke down median rent just for covered units. Once again, removing any zero rents and nine plus bedrooms. So that overall number is a little lower. And we see pretty similar

medians.

08:47.88] Then for the big hurrah, this very complicated table that breaks down median rents for covered units by district. And once again, removing the zero rents and nine plus bedrooms.

08:58.97] So you can really get down to the nitty gritty of bedroom district median rent. And then I also tried to graph that out. Once again, this was using an outside tool because I didn't find a

neat way to do it with Excel.

09:16.51] And we see that most of our rents are clustering up to four bedrooms. And then we start to get a little wonky past that point, which makes sense because those could be dorms or other unique

living situations.

09:28.60] And then finally, I looked at the rent changes for covered units with initial rents of zero dollars removed. So these are units that had a rent in for November twenty twenty three and broke

down by the increase.

09:48.24] So we see vast majority of units are under a 10 percent increase, but that three hundred and forty five units, which comes out to three point one percent exceeded the 10 percent rent

control limit. So something to flag.

10:03.45] I'm sure the city is already on it. And then I got that out as well. So to say most of our increases, we can see we're in that zero to five percent range. Most overall, 97 percent were

under 10 percent increase. But there are still some who are increasing beyond the allowable amount.

10:21.57] Some of those, of course, we could account to an application that maybe went through the rent board, but not all three hundred could be accounted for in that way.

10:29.50] So that's how I broke down the numbers. Like I said, I tried to replicate for the most part, Matt's report for last year.

10:39.17] But if there's anything in particular that you think is missing that you would want to see, I can spin that up pretty quickly because I have all the data in the Excel and it's easy and it's

cleaned now at this point.

10:50.58] So it's pretty easy to work with any questions or concerns or other things that you would want to see added here. Great work and more. I know this is like a lot of data crunching, but just

great.

11:05.17] Thank you, Christian. Yeah, the hardest part was getting a high quality map of the districts for Portland.

11:14.72] And then from there, it got a lot easier. Yeah, it's great.

11:26.12] I wonder if do we just drop the like six, seven and eight bedroom units too, because the data seems so unreliable.

11:40.47] I was thinking that they've been included in previous years. And I know Matt's take last year was like, there's no outliers, right?

11:50.33] Everything should be included. But as you can call that, it gets pretty wonky. We'll pass that five bedroom point.

11:58.54] I wonder if the cutoff should be like anything above five bedrooms or...

12:04.23] Can you go back to the slide right before? Yeah.

12:07.20] So I'm sorry, you had one by number of units and I thought like seven and eight, there was only one per number of bedroom units.

12:19.66] Maybe I'm looking at the wrong spot. Yeah, here.

12:22.66] Yeah, so seven and eight, just with one unit, maybe we keep it at 623 seems like a fair amount, but you know, that's just my two cents.

12:32.04] So, you know what I'm wondering? So, Dylan, are sober houses required to register as long term rental units?

12:44.08] Yes, they are. Because I'm looking at the six bedroom at a median rent of 50 and that sticks out to me that that is so likely to be...

12:56.33] I'm not saying it's solely that, but I suspect there's a lot of sober houses that are being captured in that and those other like rooming house dormitory type of...

13:05.06] And I don't know like what the board thinks, but I think we're kind of concentrated on what was the typical rental picture.

13:16.79] And so, I don't know, I almost kind of think the five bedroom, like we cut it off at five bedrooms and maybe just have a slide, like an appendix slide that says, you know, data that was

removed and maybe why it was removed.

13:37.46] You know, that it's, it does skew the data quite a bit and I don't know that we're getting anything useful out of it because it's not following, you know, like a one, two and three bedroom.

13:46.70] I mean, that's more the typical rental landscape.

13:49.66] What I can do with whatever number we decide is I'll just archive these slides and put them in an appendix so that people can see the fuller picture if they want.

13:58.87] And then I can make a note on whatever slide we end up with of you can go to this, you can go to the archive slide and see it. We've decided to cut off at this number because we thought

this was the most relevant.

14:13.23] Buddy? Also welcome, Buddy.

14:17.14] Thank you. Sorry.

14:18.14] Let's show that Buddy is here now.

14:21.46] Yeah, I actually, I just agree. I think that's good. The researcher in me is like we either present the data as is with caveats or we remove the data and say why we remove the data.

14:38.11] And I think either of those is valid approach. So I think that's great. I agree with Kristin and Laura there.

14:46.59] Thanks, Buddy. Gordon. Yeah, I also agree. And I'd be happy to if it's easy to pull up the list of those twenty three six bedrooms, I'd be happy to go and try and verify how many are that

sort of a situation.

15:04.83] I'm just curious. Yeah, I mean, that might be.

15:19.28] I'm I'm for either way, to me, beyond five bedrooms, like when have we ever, you know, the other side is like we just don't see it on the board side either.

15:29.47] So it's kind of it's also not representative of what we're seeing.

15:34.95] But if it seems like because there's 23 units there that we should include six.

15:41.39] I think the idea of trying to verify in some way and check that but that that could be difficult. I feel like that gets us into the weeds of them are being selective about what for why.

15:53.50] So, yeah, I almost feel like it's better to just include it or not. So do we is the consensus to stop at five or to stop at six.

16:05.59] I'm comfortable with five style like as five being our last number of bedrooms that we consider. And I know, Kristen, you said the same. I'm just looking at the median rent and what that

kind of tells us right.

16:18.13] I mean, I think I feel like we glean a lot of understanding of the market by looking at the median rent of the one to like four bedrooms because that's what we that's what we see in the

market and what comes to us.

16:37.29] And I think when we start to get into those five and above, we're seeing different types of housing arrangements that follow a different, just a different need, not that we're and not that

we're not making a, I guess a conclusion about how the ordinance

17:02.42] has been. But more it's just, it's just a different category of living situation, whether that's, you know, a group group living situations, I can just think of a lot of specialized and I

don't, I don't think it doesn't need to be included.

17:17.14] I just think maybe it's, it's not exactly what we want to call out in the report. So that's just my opinion. Yeah, thanks, Kristen.

17:28.32] Thank you. Thank you. Yeah, just kind of going off that from experience with registering all these it's most likely Yeah, these are sober houses or rooming houses boarding houses where

they're, they're not paying for a full unit, they're paying

17:44.43] for a bed essentially in a shared space. So yeah, the housing situation is very different even though they're, they're all registered long term because the city just has long term or short

term.

18:03.19] Yep, I guess in that kind of a typical situation I'd be for putting it archived and if anyone wants to see that data we collected it it's there but for the purpose of kind of the rent

control board sticking to five bedrooms feels natural to me at any rate.

18:22.51] It seems like we're in consensus there. Other items from this report out buddy. I guess just a quick question. Mr. Chair, whoever's doing the slides you might just going back to that last

one or me, this one.

18:40.40] What, uh, how, how do you know off the top of your head how many of the like sample of six bedrooms are closer to the median. I mean I'm assuming most if the median is, yeah, like,

coalescing around there.

19:03.27] Okay. Yeah, I'm just wondering, because I mean it makes sense, just curiosity is all. Thank you.

19:19.02] Anything else. Yeah, any other items. No, I mean this is the first one of these obviously I've seen I thought, I mean I'm just surprised that the 96% compliance on all covered units feels

very good.

19:37.32] I mean, I guess I wasn't expecting that. So, yeah, I think that's up from last year yeah.

19:46.69] Thank you. I'm not just content wise, but I know and Lori said you used a I to help with it do is it disclaimed anywhere within the report. No, great call.

19:59.94] Yeah, that's just all from the city side way. It's fine to use it just needs a disclaimer in there. I'll just break off a whole message.

20:15.02] Oh, it looks great though. Any other thoughts, comments, wants. Awesome. Thanks so much and more. Of course, I'll make those edits, and I won't be at the regular rent board this month

because I have to travel for work in Seattle that whole week.

20:57.06] But I can have this ready by the next regular rent board or likely before then, and I can email to you Matt. Oh yeah, let's send it to me and Dylan and then we'll pass it around in that

way.

21:07.14] We've all looked at it and we can approve it at that meeting. Great. I'll get that done. All right.

21:24.25] Well, then let's move on to new business item B the public accessibility rule revision like me to share screen. Yeah, this is your yeah, if you want to share screens that works for

everyone, we might as well. Yeah. Well, we're in workshop and it's really just all of us.

21:51.46] There's literally no one here. Can everyone say that? Yes. Yes.

22:11.64] So my understanding from the board when we discussed that there was a consensus that we don't need to scrap this public access rule, but rather just refine it to address this situation that

the board has encountered where information that has been publicly posted has been misused.

22:37.68] And my understanding from the board was that at least for now your preference would be for the only thing that is publicly posted online to be the summary sheet and then a copy of the rent

increase application form with contact information redacted.

23:02.49] And, you know, with any other appropriate reductions that would otherwise be required by law. My sense also was from the board that you folks wanted to include in the rule something that

makes the public aware that they can request any supplemental documentation that's included with an application

23:26.62] from the city, if, if a member of the public wants to, to have that information. So, the, the, again, the methodology here or the approach here was not, not to scrap what you have, but

rather to just tailor it to what I understood the board's preference to be.

23:52.26] Are we, are we intending that the request for the supplemental information would be through the FOA process? I would look to Dylan, I think that's typically how it's been treated.

24:07.23] I don't know if, you know, like if someone reaches out to staff, if for, you know, like supplemental materials that were submitted with an application, if that stuff is just like not fed

into the FOA pipeline, but would just be emailed by, by Dylan or someone else in his department.

24:25.73] But I think my understanding is it typically goes into the pipeline, although I could be incorrect about that. Dylan, do you want to chime in there?

24:40.55] Yeah, I can. Yeah, typically, yeah, if it's not an interested party, it would go through the FOA process. Any tenants, I mean, it's going to be sent to tenants in its entirety already, and

the other property managers.

24:57.90] But yeah, in terms of anyone coming in and just asking for it, it would have to be forward. Thanks, Dylan. Jonas? I guess I'm just wanting maybe a little bit more of a definition on

interested party.

25:15.97] Obviously, all of, I think what we are concerned about, right, is just the tenants themselves getting access to this document. And from there, they could share it with whoever they want,

including the Portland Tenants Union. I guess I'm just, do we consider Portland Tenants Union to be an interested party?

25:39.64] Yeah, I think that's a good question.

25:42.56] Yeah, I mean, I guess I'd kind of trust the city with that. But I think that's, I don't know if we want to try and define that it's hard because I think, right, we define a specially

interested party, we accept them in the meeting during the public hearing in terms of that side of things.

26:04.65] So how do they get designated such beforehand, but I do feel like to your point, that makes sense that it's like, well, all the tenants could be provided. So if the tenants are agreeing,

because the Tenants Union doesn't really have standing without the tenants wanting them involved, I think it would be found.

26:23.33] So that does make sense to me that a tenant could share it at that point. I don't know if anyone else has concerns there, buddy.

26:35.66] I mean, I guess I, it's my understanding that like, it's publicly available information. So if it's given to someone, that person has or is within their rights to share it around anyway.

26:53.55] So like, if it's given to someone who's on the application, even if they're a tenant, that tenant can show it to whoever. It's just, if you want to get it outside of that, if you are a

member of the public kind of looking in, you got to go through the process.

27:12.86] I mean, I might be wrong there in a legal sense, but it's publicly available information, so it can be shared without consequences for an applicant or a tenant potentially or complainant.

27:34.57] Thanks, buddy. Thoughts, any like, is there actual, so it seems, I don't feel like we're asking for any wording change here.

27:47.74] Yeah, it seems like it's okay. Everybody feels it's okay as written. Like I said, I can move for it, but look for a motion to accept this.

28:14.73] Great. Does it seem like there's any objections here? So I would move to accept the changes to the rent boards rules of procedure as drafted by council planned.

28:27.73] Second. Wonderful. Any further discussion there. Great. I'll call it to vote. The motion is to accept the amendments to the changes to the rent boards rules of procedure as drafted.

28:49.63] Kristin. Yes, Jones. Yes, and Laura. Yes, Gordon. Yes, buddy. Yes, and I also vote yes. Wonderful. Thank you so much.

29:14.57] Mr. Chair, so I would just add.

29:18.59] If you folks recall, as I've always understood your rules of procedure.

29:28.13] I recommend the rules. There is a requirement that the proposed amendment must be presented in writing at a regular special meeting, proceeding the meeting at which the vote is taken.

29:40.70] So I think, I think what that requires is another, of course, another vote at a subsequent meeting. And then as you folks know from here, I, my opinion is that this is a change to your

rules that needs to be approved by the council.

30:00.64] Like, and thank you for that catch. I had it in my head and then was like, oh, no.

30:06.61] So great. So we'll do a second reading this at the next meeting. We'll vote on again and then we'll send it to city council.

30:12.61] But I don't think any changes are needed. It seems like as we just voted. Wonderful. Thank you then.

30:24.09] All right. The other item we have on the agenda is just updating the maintenance of net operating income application. But I did. Jonas had brought up a question that I didn't get agenda.

30:41.05] And I was hoping, yeah, we could take a few and just touch on it. That's all right with everyone. So, Jonas, if you at least want to present and you can present the question if it's

something people want to talk about.

30:58.90] You don't need some time to think about or want to think about before discussion. We could at least agenda elsewhere but let's Jonas take the floor.

31:09.24] Yeah, absolutely. Thank you, chair. So, and this is feels like a good forum to chat about it. I know how busy we are during actual meetings so it's always kind of felt a little

inappropriate to bearing up as you know, we're deciding cases.

31:30.36] But I guess one thing I've always wondered on is how the board has thought about banked rent and specifically when we grant banked rent deducting it from the remaining pool of banked rent,

I guess.

31:49.48] So, I went back to when kind of the board thought this through and had discussion about it in January of 2025. Listen to that conversation. Really, it's most of the same members just me and

Gordon who weren't there.

32:06.98] And I guess it, I guess it's never really sat right with me because on one hand, I think the arguments made a year ago, make sense, which are, if you have banked rent and you haven't been

taking your CPI, you've already determined through not increasing

32:25.40] your rent that you're getting a fair rate of return. So, I think that makes sense, kind of conceptually to me.

32:32.74] And in practice, kind of a year later, I feel like we're going to run into two situations and I guess I'm hoping, you know, the board can fill me in basically on their line of thinking

about this right.

32:46.17] And sometimes I've seen us give banked rent of, let's say $300 to keep the numbers round. It's going to take a landlord multiple years to realize that banked rent. But what if they need to

replace the roof in the interim and they haven't had the time

33:05.69] to realize all of their banked rent, but they need a new roof. It feels like there's not really a mechanism in place for a landlord to recoup that capital investment.

33:17.30] So that's one thing that I kind of anticipate seeing, I guess, down the road. And then on a more conceptual level, it feels like we're incentivizing landlords to take the 10% every year,

because we've often heard landlords say, "I don't intend to raise the rent, but I want to have the banked rent so that I can raise the rent should I want to be able to do that."

33:42.43] So I guess those are just kind of two things that haven't made sense to me readily. I'd be interested in kind of Gordon's perspective too, coming into this board, where there are certain

conversations that have been had and thought out before.

33:57.74] And I just, again, appreciate kind of a retreading of background.

34:05.57] Thanks, Jonas. Definitely. I like us getting to get all on the same page.

34:14.77] I mean, I guess what I would say is to the first point, I think there is a mechanism. It's our MNOI analysis that allows for recouping of capital investments.

34:30.35] And those rent increases are granted in perpetuity. So like, even after the full cost of that thing is recouped, that rent increase stays in place.

34:47.42] So if you math it out all the way into 20 years in the future, you're probably still outpacing inflation with that rent increase.

34:59.28] And that is something I'm happy, Jonas, to share with you. It's addressed in the research around rent control and sort of the legal perspective around it.

35:09.55] And also, the 10% is kind of just like a hard cap that is just in the law. And we don't really see any way of getting around, so to speak.

35:24.83] So that is something that just kind of exists outside of the rent board. We're not here enforcing the 10%. That's kind of on licensing housing safety to do. We just say this is how much you

get for this application.

35:46.26] And then how it's then implemented is either on the landlord or on LHSD to-- Yeah, and let me be, I guess, a little bit clearer as I'm certainly not saying anyone's trying to get around the

10%.

36:01.18] I'm saying a little bit weird to me if somebody has $70 bank rent and just did a whole ton of capital investment on their roof, that for now, they could end up in a situation where--

36:13.15] We had one a couple months ago where we were arguing over three-- not arguing, we were having a conversation over three sessions, ultimately only to award $4 in banked rent because we had

to back out something from it.

36:25.15] And I just had this real "what are we doing" moment here, where it just kind of felt like such a colossal waste of everyone's time.

36:33.18] And then I kind of went, "Look, I'm glad we're doing this." And I'm really not trying to be a jerk or anything. It just, again, to me, I kept coming back to this problem of us taking away

or backing out the banked rent.

36:46.40] And to me, that was the one thing where I was like, "It's not clicking for me." So again, I'm hoping--

36:52.36] Yeah, I mean, realistically, I think that should just be happening on the front end of things, not during the course of our meeting.

37:00.34] And I think there's a good conceptual reason and also just legal reason to do it that way.

37:10.75] And then, I mean, yeah, I'll stop there because other people's hands are up. But I mean, I think that what we're trying to do is determine whether a fair return is being realized by a

prudent landlord making those business decisions.

37:43.46] So it makes sense to me to back that out. And I think that's typically just kind of how MNOI is done because that is a decision that is made by the operator to not increase rent or increase

rent.

38:02.89] I worry about delving too much as the rent board into conversations around policy or around incentives. I don't think that we necessarily should be making our decisions based upon policy

outcomes or what are perceived policy outcomes.

38:23.92] So that's all I'll say.

38:26.27] Thanks, buddy. Yeah, so the incentivizing thing, I think, is like to the point is like in really just an effect of rent control, like of trying to cap increases, right?

38:48.09] Basically, like it kind of forces it. And it is an interesting thing that we see of like landlords being like, oh, well, I feel like now I realize I should have been increasing rent at this

slow and steady rate.

39:01.12] And that's just like the reality of capping things, I guess.

39:06.57] But on the actual backing out, so my at least like perspective has always been that, exactly that, that if you didn't increase rent, you were receiving a fair rate of return.

39:23.07] So like, to grant a rent increase when there was already like, because all we're granting is banked rent, right? So to me, I'm like, oh, we're saying if you had this much more rent, you

could make that money back.

39:37.72] They actually have some of it, they just didn't apply it in that case, in the applicant's case there. And so that's just always been the math making sense of it to me of that.

39:50.08] There's, it's like us, us not backing it out doesn't change the that they weren't making that fair rate back then they need to apply like they like to me the first thing is like well apply

your rent increase, because you have it there.

40:10.15] But it's not realized and so that's something that, to me, otherwise if we don't back it out is almost a loophole where theoretically you could not take any of your increases, say, oh, now

I need an increase because I'm not making this money.

40:27.56] If the banked rent wasn't backed out, then you get an increase as if you didn't have that banked rent but then you also have the banked rent so then over the next, then taking the max

increase or whatever you can over those times I think it's almost like it's easier

40:42.90] with smaller numbers to be like oh well if I didn't take that $10 back then, then, and I needed $20 to make a fair rate of return then then you really only needed 10 more in the bank

because the bank needed to be taken, if that makes sense.

41:01.69] So, I hear two, I hear two scenarios. So I think, okay so first of all when when most applicants come to us, and they're looking for an MNOI increase due to increased housing expenses.

41:22.26] I think the backing out of the rent is to avoid the double dipping because that's the rent that they should have used to keep up with those housing expenses. But what I hear Jonah saying is

for capital expenses and I honestly haven't.

41:44.23] I think we have but if I, but if we have a applicant, and I'm asking this is a question. If we have an applicant that comes to us specifically for a renovation let's say of a unit.

41:57.82] Even all of this capital. I'm not sure that wiping out the bank rent is is the same as the first scenario because the first scenario to me is to keep up with housing expenses as inflation

you know snow plowing gets to be more expensive.

42:15.79] But we need to maybe talk a little bit more that if you have a one off renovation. That's not the, the MNOI application doesn't that money is just to keep up with your annual expenses, it's

not really addressing a full capital infusion so maybe we do

42:33.43] a little bit more about do we keep being rent backed out of housing in expense increase applications because that's what it's meant for. Do we look at capital a different way. And I think

we may also want to consider that now that we're well into the MNOI application

42:52.45] is plausible that we can and we've seen this happen, where we're having the same applicant come back again for an increase. And so if we have granted somebody an increase. And again, I'm

asking this as an open scenario question.

43:07.49] If we have granted somebody an increase that they're not capable of taking over the course of the year because of the 10% cap, but they come the next year and we grant them another

increase, if we bank, if we back out the bank rent that we awarded them the

43:24.15] next year, and they weren't capable of taking it because the time hasn't passed and they can only take 10% at a time. Is that, is that how it's intended to work, and I don't know if this I

feel like this is going to start to happen like if we had a tenant that came

43:41.68] I mean I'm sorry a landlord that came to us last year and then two years from now, like let's say we gave him $300. Yep, this is my concern. Are we, are we starting to see scenarios as this

process is getting more mature that maybe we haven't

43:58.28] anticipated and maybe we do need to think about backing out bank rent in every scenario. So, I'll leave it at that.

44:10.72] But on that, I guess, I see the side of that the, the increases forever. So while you might not catch up in the short term like you might not be there in the short term.

44:25.75] To me it seems like we're, we're still just doing math on maintaining that like number over the, the really long term aggregate of maintaining the, the fair rate of return.

44:38.15] That's where I see I'm like, Oh, well, you might not have caught up, like so like in years one through three after an increase right you might not have caught up and you might even feel

like, Oh, I've spent more.

44:49.37] And it, it's in those years like in year two, you're still not caught up you're still not making the, the like fair rate of return right that you wanted because of capital investments that

that so the applicant puts in capital investments.

45:04.31] It's going to take them a few years to get the rent all the way up there.

45:09.31] It takes that time. But then there's a point so like there was that early gap where they weren't where the applicant wasn't catching up right the money, they weren't getting there because

of the minimum increase.

45:21.84] But then there comes a time where the capital improvements are paid off, but the rent increases still there. So like while there's the initial gap period of like, oh, it takes me some time

to catch up.

45:34.63] Then you catch up and it's fair. And then theoretically there's a period after that where everything's paid off, but the rent, the increase is still there and so the, the, there's like the,

the after catch up period from the initial lag period is how I see it.

45:53.15] What about the other scenario though what happens when we start awarding rent increases for increased housing expenses, and someone doesn't have the operates, let's say it takes at 10%

three years to be able to apply all of those rent increases,

46:15.02] but they come to us before that, and we award them another increase, I just, I just feel like we're going to get into this.

46:27.38] That's where I feel it has to be backed out. That's where I feel it always has to be backed out because the otherwise they could keep saying year after year right somebody could come back

and say hey they're, they're waiting you know like we granted them 40% worth of

46:45.61] increase the first time, but they can only take 10 a year. So it's like yes like in your two and three. It's not there but we can't grant more bank rent because they haven't been able to

realize it because of the 10% cap is my thought like that doesn't add up

47:02.98] Okay, can I throw one more monkey wrench in there. Yes, we're having okay so one more monkey wrench, and I'm not going to claim to be an expert in finance, it's everybody knows it's

healthcare, but an amortization schedule.

47:19.81] Right, we ask people to attach different amortization schedules to different types of improvement. And I equate that to useful life.

47:32.09] Right. So you amortize like a roof over 20 years because that's the use, that's the useful life of the roof. So while you get the increase in perpetuity.

47:48.21] In theory, 20 years later, you need to replace that roof again. So you're back to spending that capital. So I almost feel like it's, it's not that you get the rent increase in perpetuity

you get it, and then in theory, you're replacing those things

48:05.01] and spending the capital again to get it so I think that's how maybe philosophically it was mathematically or finance it was intended to work, I understand that that's not necessarily in

practice but I don't know that I necessarily agree with, as a landlord

48:23.13] getting the rent increase forever because my roof isn't gonna last forever. So I think it's more to get the increase over the expected useful life of the improvement with the anticipation

that you're going to have to re up that capital and do it all over

48:39.99] again. So, I'll just add that. Yeah, and I think buddy I'll get to in just a sec. But just to the let's, I think we should wrap this discussion pretty shortly and like come back with some,

you know, I think we could come back with some

49:00.72] examples of actually saying here's here's what I see the math looking like in this case or that case would be helpful now that we've kind of popped the cork on this at least, but I don't

want it to derail our agenda items too much.

49:16.41] But I do think clearly it's an important question we need to have that maybe comes into the MNOI discussion.

49:23.41] Yeah, I mean this kind of came up like way back in the day, and we did kind of map it out and like you actually like tend to recoup it before the useful life is up anyway, because of those

rent increases based upon the bank rent with the cap

49:45.47] of 10% on top of that, it's not only that you have to redo the roof you then get another rent increase as a result of it. So like you're getting that in perpetuity rent increase, then plus

another one for the other work that you do.

50:04.43] Like what most of like the rent control experts say is that you either allow for landlords to include the applicants to include the interest and the financing on it, right, and then it

sunsets.

50:26.76] But after the useful life that rent increase gets taken away and if you want to redo your roof, then you can and you can come ask for another rent increase, or you don't include the

financing, and you don't sunset, right, and you take that forever

50:48.12] and the math, essentially sort of like works out very similarly in practice, as it stands right now, we allow for financing, and we don't sunset. So like, even to me, like this is an

advantageous thing for applicants, like the way it's set up right now.

51:10.26] I just want to put that out there I'm happy to share with other board members, the, the, the articles and the research around this.

51:19.70] I think it's something that's important to talk about.

51:24.37] But I just want to note that the way that we have it structured right now is pretty advantageous to applicants in the long term, as far as MNOI rent control ordinances go.

51:42.91] I think you just brought up something that's really important. What if we, as the board members move on right and we have new people, we should create an archive of like literature,

because, you know what I mean buddy if you can put if you can find

52:00.06] those and put it into a common folder on the drive that could live well past us I think it would help as we, every time this comes up, we have a just a source of white papers and literate

just research that we can go back and review and new

52:18.06] members can read through so they can understand some of the history because, I mean, it just, it just probably saves the conversation so that I, not to put it on you but since you kind of

volunteered, if you do that I got a look at my old computer because it's like

52:35.72] a hard drive, but yeah I shared it with folks in the past, I think it's good, just in terms of understanding like what the quote unquote experts say obviously like it is kind of different

like depending on where you go, and it, and how it's implemented

52:55.16] is different based upon the specifics of a municipalities ordinance that has to then adapt to sort of the theory of and then a lie, but I would be happy to do that so yeah, yeah that seems

like maybe so.

53:11.96] What I thought is that will next time we have a workshop because it seems like we're gonna need another one. And this is functional for us, and if not next month, the following or something

that let's let's collect stuff so buddy if you want to send stuff

53:29.35] and then same like Jonas, and I think I have an example myself of like, you know, let's, let's get some examples gathered together, get them to me and Dylan, we can put them in a folder for

the next time we agenda this on a workshop and let's actually

53:47.14] put this onto a workshop, look at you know look at a set of materials together and that way we can look at some some hard examples because I do think it's both exactly like referencing the

research and some other municipalities how they're doing

54:02.81] it just even to see relatively so we can say oh well even if we think this is tight, it's less tight than where this is implemented and been mature some other places just even as a

comparison of like, you know, sanity check or whatever.

54:19.59] Same I think it would be nice to look at the, you know, true math examples of like oh here's, here's what this person's fair rate of return looks like in years one through 20 or something

like that and some different examples.

54:36.05] Awesome.

54:39.11] Thanks guys. Thanks for the little detour there.

54:45.36] We launched the draft them and a lie regs. I will just say, I don't know if you folks have had a chance to review the draft that is in the drive and it will live there so you guys can look

at it periodically as time goes on, but the, the specific situation

55:07.22] that Kristin and Jonas discussed you know if you have a previous increase that has been approved, and thus the current year and that petition becomes the base year, and there is bank rent

resulting from that rent increase approval.

55:27.43] That is addressed in in the current draft of the regulations. I know the board, I think for the first time, address that situation within the past couple months where you had an increase

that was approved in 2023 or 2023 or 2024 and then someone

55:45.76] who was coming for an increase in 2025. And the question really is, you know, if the board has decided in a prior year that an increase was necessary for a landlord to receive a fair return

on investment.

56:02.85] If you have made a capital expenditure and that's the primary driver of your increase in a subsequent year. If you're applying bank rent that resulted from the prior increase to essentially

like potentially wipe out the increase that a landlord would otherwise

56:19.69] be entitled to for that capital improvement. Is that ensuring a fair return on investment and a subsequent current year. My understanding from the boards prior resolution of that particular

petition was that it did not want to basically apply

56:41.44] that bank rent resulting from the prior increase to the increase that a landlord would otherwise be entitled to. If the primary driver is a capital improvement, but I'm just flagging that

that is a sort of a feature of your rules and I think the board

57:01.60] will need to discuss, obviously this issue, but it's on the list. And we're probably not going to get to it tonight, but it is. Yeah, it's definitely on the agenda.

57:21.21] But with that, let's get into looking at the application. Can I just request like a one minute brief item C fix a technical issue I will be back in like just one second.

57:37.93] If you just give me bear with me for a minute here, we'll take two.

59:27.91] Thank you, Mr. Chair.

59:29.91] And I will take the draft up that will share screen just bear with me one moment here.

60:26.95] You folks can see that? Yep. Okay, great. Well, I think just in terms of an approach, what myself and the subcommittee were thinking is that from one workshop to the next, what I can do is

redline changes that we've discussed and upload progressive drafts into the drive.

61:00.06] So you folks can see what changes have been made from one meeting to the next. I think at the workshops we can discuss the changes and if it makes sense, I can accept those from one

workshop to the next.

61:14.94] But I just want to kind of develop a methodology for keeping you folks sort of aware of what changes have been made from one draft to the next.

61:27.11] I thought maybe a good place to start the workshop tonight would be with proposed changes relating to the issues that the board discussed at the last workshop.

61:40.08] And I believe the first significant change that the board discussed was the evidentiary expectations and requirements for rent increase petitions.

61:56.29] My understanding from the feedback from the board at the last workshop was that essentially the board would like for sort of like the documentary evidence that is included with the rent

increase application to be documents, records that are substantiating

62:16.85] what a what a landlord's gross annual income was in the base year in the current year. And then records that are substantiating, you know, what essentially the primary driver of the

application is whether that's capital improvements or some other significant expenditure.

62:34.93] So I've added a line in this section to clarify that the board is anticipating that landlords will present something that essentially demonstrates what their gross annual income was in both

of the years that are being looked at.

62:56.13] My sense also was from the board that you folks thought it would be helpful to include essentially like a non exhaustive list of the types of documents that would that the board would

consider sort of

63:15.69] an evidence to demonstrate, you know, what annual income was what operating expenses were. And so what I've included here is sort of this example paragraph that identifies, you know, here

are some records that might

63:32.96] substantiate what a landlord's gross annual income was and then here are some examples of records that would be that would demonstrate, you know, what, what an abnormal or regular expense

was capital expenditure, so on and so forth.

63:48.70] Questions, thoughts, comments.

64:07.34] Concerns or yeah changes with the language. It looks great. I feel like that captures a lot. Okay, I think what might be, might be the one of the more complicated changes so obviously

there's, there's been a lot of discussion about kind of relaxation

64:40.57] of this 2019 base year requirement, when you have a landlord who doesn't have the 2019 data, and my understanding from the board was that you folks did want to allow or create a rule that

relaxes the 2019 base year standard

65:04.02] if a landlord comes to you, and is able to demonstrate essentially that they can't get those 2019 records I think the example that you folks are seeing a lot is when you have a landlord

who's acquired a rental property sometime

65:20.90] after 2019 and just can't get those records from the prior landlord. And, you know, I certainly think from my perspective there may be a number of other reasons why, why a landlord might

not have those records or might not be able to get

65:36.88] those records that we might be able to anticipate at this moment just because we haven't seen it.

65:43.51] What I was thinking was, you know, potentially it makes sense to create a carve out for that as well but I think the primary example of course is when you have a landlord who's who

subsequently purchased the property after 2019 and can't can't obtain

65:59.75] those records. So let me just kind of, I'll dive into the components of this rule, and I just want to say that I think my sense, and at least one of the committee members sense from the

board was that perhaps the board wanted to frame this

66:19.76] as being like a little more, I don't know if permissive is the word, but I guess my sense was maybe you folks didn't want to establish a framework for, for this sort of relaxation of this

base year.

66:41.69] 2019 requirement that would be similar to the framework for your base year net operating income adjustment, you know, where in that particular instance, it's, you know, it's a request.

67:00.99] The board goes through sort of a multi step analysis to decide whether or not to grant the request and then you're, you're obviously calculating the net operating income in the base year

from there.

67:15.74] So I think what I'm saying is this, this particular rule could look a lot more like that process if the board wants it to, but I think my sense from the board was that you, you might want

to be a little more permissive in in relaxing

67:32.28] this standard, and maybe not requiring as exacting an analysis as you do when you're considering a base year net operating income adjustment. So I'll just sort of as a high level thinking

on how this rule looks.

67:51.39] That was my, my understanding from the board the last go around, that's why it's drafted the way that it is but it can certainly be adjusted if the board feels differently.

68:00.68] So, in any event, my understanding from the board was you know if an applicant is is coming to you and telling you, I, you know, I don't have the records to calculate what what the net

operating income was in in the base year.

68:17.53] And then the board at its discretion can decide whether or not to allow for an alternative year. I think what I heard from the board at the last meeting was that if a landlord if if the

reason for not having that 2019 data is that the landlord

68:39.04] property at the time and subsequently acquired it I think the board's preference as I understand it would be for the base year to then be essentially the first year that the covered unit

was owned by by the new land board.

68:56.79] And I think my understanding there was it creates, you know, sort of creates a hard and fast rule and some certainty for for this particular situation in terms of what what the adjusted

base year will be if you will.

69:13.76] As you can see I've highlighted this here. It seems like one of like one of the more one of the, I guess the thornier issues you folks have bumped up against is oftentimes, you know, a

landlord is not quite acquiring a parcel on January one, they're acquiring

69:36.01] it at some point in the year, and may have unaccounted for operating expenses for the portion of the year that they did not own the rental property. And so one of the things that the

subcommittee has discussed is, you know, if we're saying that the base year

69:56.53] is going to be the first year that the, the new landlord owned the property, whether that's a full year or a partial year is the way to deal with that situation to sort of assume, make

assumptions concerning the, you know, the operating expenses

70:17.71] that were incurred in the portion of the year where the new landlord didn't own the parcel, you know, for instance, if you have operating expenses you know were incurred in the first six

months the property was owned by a different landlord like utility costs

70:35.97] and stuff like that. Would the board want to make assumptions about those numbers so you're looking at a sort of a full operating expense picture for the year, notwithstanding that this new

landlord didn't own it for the entire year.

70:51.82] So that's kind of a place for discussion on how the board might like to handle that. And then I'll just add the last last component of this rule is, again, you know, it seems to me like

there, there is the potential that for one reason or another you

71:13.39] know the landlord who's on the property since the 2019 base year, and doesn't have those records and, you know, I think there may be all sorts of reasons for that.

71:24.87] But I'm sure at some point the port will encounter that issue. And, you know, it, it at least seems reasonable to me that you could create a carve out for that particular circumstance and

of course like, you know, the rule that would apply

71:39.72] to a new landlord who's the property after 2019 couldn't be the rule that applies to, or can't be the rule that applies to a landlord who's owned it for that entire period but doesn't have

the 2019 records.

71:53.42] So at least what the committee discussed was that it seems sensible that the rule could be that, you know, if it's a landlord who's owned it for that entire period doesn't have the records.

72:07.84] Then the landlord would be able to select the last year post 2019 or I guess really the first year post 2019 that that landlord felt they were receiving a fair return on investment, which

is, as I understand it, the way that St.

72:24.69] Paul Minnesota has kind of handled this situation. And the thinking behind that is that, you know, the idea of M&OI is you're, you're looking at your base year, your base year being the

last year that that, you know, rental units, or at least the

72:44.89] rental unit and issue was not subject to rent control and you're assuming that that the landlord who owned that rental unit was reasonably prudent and was receiving a fair return on

investment in that year.

72:58.60] In other words, it's sort of like your North Star and the M&OI methodology. And so the thinking is if the data isn't there for 2019, then the landlord could select a year post 2019 or the

first year post 2019 they felt they received a fair return on investment.

73:17.39] So you're, you're using that as your starting point, and then, you know, obviously comparing it to the current year. I'll stop there for questions, comments, thoughts.

73:34.59] Thanks so much, Ben. I've got some questions, comments, thoughts.

73:42.34] And so I really like the part of this of like that the board may permit that like kind of like the base year adjustment that it's like we're not saying you definitely get this or that.

73:56.03] I do like that kind of check there. And then but like on both the other points I like the idea of this still being a little, a little hard and fast and what it suggests the applicant is

acceptable or something.

74:14.34] So like, for the, for the, when they don't own the property for the entirety of the year kind of, I, my take had been that like, oh, it'd be the first full year that they own the property

just because otherwise I feel like we're, we're like filling in a bunch of numbers.

74:41.02] But that doesn't necessarily bother me if that's what we're doing. And similarly, I'm not sure what the, the thought was.

74:55.05] Like that the, to me saying under these other they'll they will they shall use the most recent year that the landlord applicant received a fair rate of return on investment as the base year

is subjective.

75:17.43] And that like, I, you know, I think, oh, well, it's like, okay, the first year was covered or something but yeah I think it's hard like to me the check is, if you don't have 2019 and you

own the property that whole time.

75:34.33] Explain why you don't have the records and provide us the first year that you have the records for regardless that it's not about whether or not the fair rate of return was made because the

fair rate of returns already assumed by the ordinance for

75:49.64] 2019 and I'm sure there's a ton of landlords who weren't, you know, we see them weren't getting the fair rate of return there but it's just kind of assumed and requires the, you know, the

proof then happens in the application itself.

76:03.17] So that's, those are my, those are my thoughts, concerns comments. Yeah, and I'll just say, you know, one thing that the committee discussed is, you know, it seems like you'll have all

sorts of different iterations of a new landlord coming in, and, you know, having,

76:32.58] having acquired a property, you know, maybe in February of one year or in September, and it's, it's going to be all sorts of very folks have already seen some applications where you know

the landlord has is requesting that the board use that that partial

76:52.22] year, whatever portion they owned it as as the base year. And if, if the rule is that it has to be the first full calendar year, it does seem like that would be an inequitable result for

somebody who purchased the property like towards the beginning

77:11.36] of a year right whether it be February or March, but might be a little bit more reasonable for someone who had, you know, like acquired in November or December.

77:22.09] And I will say my, my other concern is, you know, if, if the, if the board were compelling a result, where the base year is has to be the first full calendar year that the new, the new

owner owns the covered unit, the building whatever

77:43.06] it happens to be, you know, is, is that essentially for instance resulting in the landlord being unable to request an increase under this particular section of the ordinance for, you know,

like a portion of the majority of a year where they did own

78:00.85] the building and incurred operating expenses, and is that generally consistent with the ordinance which does allow for obviously rent increase requests for, you know, in theory I guess each

year.

78:14.57] If a landlord wanted to file them on that I do I trust the subcommittee here I think whatever the final thought on it is comes out but like I guess to me the thing is well you haven't

experienced the full calendar year,

78:35.70] and therefore like we really don't know like you can't tell me what spring expenses might be like or something if you haven't had spring there.

78:47.08] But it's hard, you know, it as a tenant that may be hard for me to kind of, you know, think of in reality whereas landlords have experienced that year on year and that may be different

there that you know you really can if you're like oh you, you know from half a year you generally know what the cost of the whole year was but that that's

79:05.95] kind of one of my thoughts there is like well I totally it's it's particularly like right you buy it in the end of January or something, you have this full year you had a year after it that

was rough, and you want to start applying for increases.

79:20.95] But that doesn't somehow to me that still doesn't make a complete base year of of true expense to compare like what you to truly compare one to the other. If I'm saying here was a full year

here's a year that I'm kind of filling in half the numbers for from half

79:36.11] of it.

79:37.21] I don't know. That was my input, Kristen. Think about what you're saying and I mean, is, I mean is it, is it too restrictive to to expect that an applicant would would if they cannot

provide the 2019 expenses, then we would expect at least one full rolling

80:10.17] year of expenses I mean if you buy it in June, and you go to, you know, July 1 you would have a full rolling year of expenses, I mean I don't know that that's unreasonable right I mean

that's what you're saying is that we don't want to, we don't

80:27.55] want to necessarily try to take six months of expenses and extrapolate right we just would like rolling 12 of actual expenses I mean is that I don't know that that's unreasonable to expect

that.

80:47.91] So, so kind of like that, you'd fill in the first half of the year knowing the second like we wouldn't be full calendar year there or no I'm saying like, no because if you did it on a

rolling year right I mean we you can come for it.

81:02.67] You can come for an increase at any time in the year as long as you have 12 months of expenses. So whenever you have 12 months of expenses you can then proceed with.

81:11.90] So we're giving them an option, you either have the base year, right, 2019. If you're unable to get that, then you're able to apply for an increase after you have accumulated 12 months of

rolling a full 12 months of expenses it doesn't need

81:30.84] to be calendar, it can be June to June, but we just want to see a full complete year of expenses in order to mount I don't think that's unreasonable. I don't think it doesn't complicate the

application.

81:49.86] How so, not having, not being looking at it as a calendar year. I don't know. Oh, I see what you're saying because everybody calendar years, right. Okay. I don't know buddy buddy.

82:05.21] What do you think. Yeah, yeah, I mean this kind of came up, I think, I think like full calendar year is better because that's like usually how we like assess like people's operating income.

82:21.18] I guess like my and I, my concern is that like if somebody buys a property in March, or like February puts a bunch of money into it, and like is then like maybe they take a loan out or

something, and is expecting to, you know, be able to raise

82:47.05] rent to know that they can start recouping that cost. Like if it's in March and we do a full calendar year like they're gonna have to wait. Yeah, yeah you know like 2020 months.

83:00.41] And so like, like I, I do like kind of agree that like using a full calendar year like feels cleaner like on our end of things. I just want to like flag that it.

83:14.97] I wonder if there's like a scenario which it does feel like or comes off as a bit onerous to applicants.

83:22.76] And like, I do kind of walk like personally want to try to avoid that if we can. And we kind of talked about like, you know, trying to extrapolate, which also like is maybe a little crude

at times, because, you know, like you and like, even in that scenario like you do

83:46.50] kind of have to, I think if you're going to extrapolate your, you need to be pulling out or like separating costs that are like routine costs versus like unique right like it wouldn't

really make sense for you to like be extrapolating for like a capital improvement

84:10.91] because that's like a one, you know, like that's not a cost that was incurred for them. And it feels like unfair to like be like, Oh, like this, your operating income was this much or

whatever.

84:25.26] So I that's not like really an answer. I'm sorry.

84:29.58] No, no, you actually did answer for me I feel like. Yeah, because there I don't. Yeah, yeah, I guess what I'm saying is like, I mean we do have like a pre approval process.

84:41.55] And like, even though we maybe couldn't give them an exact number like the, the like sense of security that comes with being like this will be approved most likely when you have a full

calendar year to show us and you will be able to recoup that cost

85:03.41] and like the evidence is there, but we have to wait, I think is maybe helpful, but like, this is one of the things that I think you could kind of do it a few different ways that are valid.

85:14.91] And I'm not like I don't personally feel like super strongly about other one I just I worry about a scenario like that where someone buys a property dumps a bunch of money into it and then

has to wait 20 months before they can start recouping the cost at all.

85:33.02] Yeah, before they can even apply. No, that makes really good sense to me.

85:40.52] Yeah, and I think the reality that I'm realizing is like, we can always do what we want with that application we could say the, the months that you're missing are come from the year that

you have the full expenses and just copy over or something.

85:55.64] You know, there's that we have flexibility and that if we force the full year here, where we're creating bad situations like we are.

86:06.92] We are hurting those edge cases if they happen, where somebody could have bought a property and that's exactly like to have to wait.

86:17.34] Oh, basically two years before you could even start to recuperate costs is is not fair to the landlord. So, that makes good sense to me I fully solves my feelings about the full year.

86:33.05] So and I mean I think, yeah, probably fair to say that if the board, if the board has to make some assumptions about costs that were incurred by the prior landlord I think it'd be

relatively limited assumptions.

86:51.42] In other words like should be able to figure out real estate taxes.

86:56.83] It seems like the thing, the thing that probably one of the things that would need to be assumed as utility costs.

87:03.58] I believe the city has licensing and registration fee numbers.

87:13.93] And, you know, a lot of these other expenses are things that were incurred or weren't incurred.

87:21.49] And if the new landlord doesn't know whether those things were incurred then it's just I mean it's a blank essentially right.

87:28.55] And presumably it wouldn't be significant leaps that you folks would need to make in order to like extrapolate out the missing data for not a full year of ownership.

87:40.83] Yeah, yeah. All right, thanks for bearing with me guys. Sorry I lost my place here.

87:51.59] So is, is the board comfortable with sort of the subcommittee discussing like a methodology for making that those assumptions. Okay.

88:05.04] I'm not sure it needs to be hard coded even like I said I mean we do a lot of stuff we figure a lot of stuff out on the fly and it makes sense to me that we're not put backing ourselves

into that.

88:16.70] Yeah, I think, I think I agree. There needs to be sufficient flexibility here.

88:27.15] I also want to make sure that there's enough of a framework so that it isn't it isn't arbitrary how the, you know, how the assumption is, is made, and I have a couple thoughts about how we

can, you know, how we can commit that to paper, but know it, it does make sense to me that

88:45.59] there's there's got to be some flexibility here for you to address things on a case by case basis.

88:52.58] But before we move on from this I will just still call out that I do still think that the saying the landlord applicant, giving, giving the landlord applicant the choice of when they

received a fair rate of return doesn't line up with the ordinance to me, at least

89:08.05] of that in the ordinance, the fair rate of return is assumed.

89:12.05] And that's, that's my other call out there is that, to me, that doesn't line up that that last after the comma doesn't line up with the ordinance in that the ordinances.

89:23.94] There's an assumption there made versus, in other words, I mean, you know, I think in either event, like, you know, if you're allowing sort of the subjective determination by the landlord

of the, the year that they received a fair return on investment.

89:43.68] Or the first year, or the first year that they like to actually have their records to substantiate a full, a full year of net operating income, you are taking a face value.

89:55.01] What that particular landlord is telling you I mean there's, there's no way I guess to probe like to too deeply unless you wanted to, you know, to look at multiple years in order to assess,

for instance, like when you thought a landlord post 2019 was receiving a fair return on investment,

90:13.31] but it seems to me like that would be a very onerous burdensome analysis for the board.

90:18.56] It would require you to look at a lot of data.

90:22.62] So I think, I mean, certainly if the rule is it, you know, if you don't, for whatever your landlord you've owned since 2019 and for whatever reason, you can't present us with the 2019 data,

and we're willing to relax a standard for you.

90:39.48] I mean, I think a relatively hard and fast rule would be, bring us the first year that you do have the full operating expenses and income figures.

90:50.91] There is certainty there and if that's the board's preference then we can, we can definitely paper it that way.

90:57.23] Because that's what we're solving here, right.

91:01.23] It's intended to address a data gap, for sure.

91:08.23] I will just flag, I mean, thinking long term, you know, as it stands right now there are sort of three different, three different base years right there's, there's 2019.

91:23.58] There's base years, where, you know, a rent increase has been approved in the current year and that application has become the base year and then obviously if you're, if a market is

entering the unit, or excuse me if a covered unit is entering

91:39.08] the market for the first time after 2019 then that first year is, is the base year.

91:45.08] And I just want to mention that, you know, like I think, with respect to, with respect to be, you're, in theory, never going to have to worry about a data gap, because you've, you've had

that information presented to you in a prior petition.

92:02.04] As we move further away from 2019 I mean it seems like in theory, you know, you could have covered units that are coming on the market for the first time, you know, now, and as we get like

10 years down the road and someone else acquires that property

92:18.95] maybe they won't have the records for 2026, for instance, so I've, I've drafted the rule such that, you know, in the future, when that situation arises, you could relax that that base year

standard as well.

92:37.05] Okay.

93:15.70] All right, is the board okay moving on subcommittee members you think we have everything we need for the next round of revisions on this. I mean, I think we have everything we need. Right.

93:31.75] Number one, 2019 basic expenses number two full year of the first of expenses for the first year somebody owned it and then number three is if we have a partial like our rolling year then

we make assumptions about is that kind of where we're going, like that's the acceptable

93:51.90] Yeah, and I think the same landlord has owned it since 2019 doesn't have the data first year they have the data would be standard in that situation. Yeah. Okay. And I'll just, I mean, I

guess the other question that I do have for the board, again, like, this was intended to be relatively

94:11.20] permissive it could be framed as, you know, more of a multi step analysis like your base year net operating income adjustment rules. In other words, like, you know, first you've got to sort

of overcome that presumption that you have the data.

94:34.83] The board will consider that, you know, whatever your whatever you're presenting to us. It's necessary to demonstrate you don't have the data. And then if the board is is comfortable

relaxing the standard, then the analysis is like what is your base year based on your

94:53.30] analysis. So the rule could look, I guess much more like this. If the board would prefer that approach, or, you know, we can sort of leave it and leave it the way it is which again I think

is a little more permissive of relaxing the standard.

95:13.20] Any thoughts. It seems like we try and hammer this out like we haven't seen the cases for this one yet right we haven't I mean we've seen them some but we haven't seen them with this

applied.

95:27.03] It makes sense to me to have it be like this and if we see a few years go by and that board decides that they need to revise it and tighten it, they'll have a good idea of what needs to be

tightened right.

95:40.05] I guess like I will just say my like my thinking is with respect to base year net operating income adjustments like you've got pretty specific standards, and this presumption that exists

and it's a little bit more of a little bit more of an exacting analysis

96:01.50] and this particular circumstance I mean, you know you're you sort of got to take it face value I think that somebody doesn't have the data.

96:14.06] And, you know, I mean, I think we discuss this at the last workshop and certainly the subcommittee has discussed this, like, other than a landlord representing that to you I'm not sure what

else they can can show to demonstrate that they don't have

96:27.72] the data I think, you know, like the standard here isn't isn't as much of an analysis as, you know, your, your base year net operating income adjustment analysis for what it's worth.

96:41.12] So, yeah, if the board is sort of comfortable with this approach, the subcommittee will work on refining this a little bit and we'll come to you folks with with some additional revisions at

the next workshop.

97:02.27] Okay, I think where we where we left off in terms of in terms of discussing discussing the proposed rule changes the last workshop was specifically rules relating to specific operating

expense categories.

97:29.40] You know, I think the bigger ticket items are, of course, management expenses, owner performed labor.

97:37.91] The board's going to have to discuss legal fees as well.

97:42.54] But starting with management expenses for the subcommittee has had a pretty extended discussion on a proposed rule, and has has developed this framework and I mean maybe this is, is best

sort of imported up further in the rules but the the framework

98:10.48] that the subcommittee has discussed is in terms of allowable management expenses, the full cost of of a professional property management company would be allowed as as an operating expense

in other words whatever they charge to the landlord that is allowed as an operating

98:36.85] expense, where the landlord has performed its own management in either the, the base year or the current year, or both.

98:52.66] The, the allowed management expense would be basically equal to 10% of the gross annual income for, you know, either all of the covered units in the building or one covered unit, whatever

the case happened to be.

99:11.18] And I think having discussed this quite a bit, the subcommittees thinking was that sort of an easier rule to apply here would would make sense rather than like developing a rate structure

for management and trying to calculate based on that, you know, rate

99:37.24] structure and however many hours were devoted to management like what the allowable expense would be in a given year.

99:45.84] Additionally, at least as we understand it and the committee members myself are still sort of running this to ground but I think our general understanding based on what's been reported to

the board is that a lot of professional property management companies are charging

[100:02.02] landlords 10% of their gross annual income to manage units.

[100:09.30] So the thinking was is, you know, as a policy matter, you're putting landlords who have performed their own management, presumably on equal footing with with someone who's hired that out.

[100:23.96] And, you know, at least in theory, assuming that we are correct about that 10% figure.

[100:31.27] Maybe you'd have something that is, you know, relatively close I guess to what a prop excuse me a professional property management company would would charge.

[100:42.93] I'll let Kristen and buddy chime in here if they want to sort of add anything to what the thinking was behind the proposal, and then let the fallboard discuss your thoughts on approach.

[100:57.64] I think you summed it up and I think, and maybe this is somewhere else in the conversation but I think in addition to the language that you have here.

[101:12.88] We also need to differentiate, or at least define what a management expense is, because these get homing old or confused with owner performed labor, when it is a, an owner landlord.

[101:37.15] So I think in addition to saying what the cap is we need to say, an example of management expenses or something like that so that we're being very clear about what, what that is

encompassing and it also will help to make sure that the categories

[101:58.51] are being appropriately, you know, because if an owner landlord is doing snow removal and lawn care, and all kinds of other things that they're appropriately putting things in the right

categories. So, thanks Kristen Jonas.

[102:18.90] Yeah, I think this would be a great place for some examples under each for example of management duties, example of landlord applicant just so that applicants can see precisely which one

is a management.

[102:37.62] And then just a really small edit I would make is the wording right now is a landlord applicant that manages its own covered you in the base year, and or the current year.

[102:51.48] Should be permitted to include maintenance expenses that is equal to 10% shouldn't be that shall not exceed 10% because if they have their receipts and they want to go under 10% and it's

not 10% then fine. I just didn't want to be like an automatic each one, it is 10%.

[103:15.21] I think, Kristen was the was the term you use like almost akin to like a standard deduction for the for the 10%. Yeah, I mean, I assume nobody's going to want to know self report under

under 10%.

[103:33.45] I'm with you, totally. No, it's totally fair.

[103:38.86] Not fair of me to assume that's, that's going to be the case but yeah no I certainly think that makes sense. And I would just add, I agree that there does need to be.

[103:55.66] There does need to be clear definitions that differentiate between like management activities and owner perform labor. And my thinking sort of was you know, assuming the board is on board

with this approach.

[104:11.07] And this, you know this 10% approach for owner performed management, I think in the definition of owner performed I mean like that's something that's tied to gross annual income.

[104:21.29] So, there's like a relative amount of certainty there and like a cap, right, that isn't necessarily dependent on a definition, but when you are when you are examining allowable owner

performed labor.

[104:35.79] That's where you're going to have to differentiate between something you think is a management activity that's subject to that 10% allowance, and something that is like actual owner

performed labor that that a landlord is retired, excuse me, entitled to recover.

[104:52.40] So my thinking was that in in defining owner performed labor, that may be the appropriate place to kind of establish the dividing line if you will. Yeah, looks great. I definitely agree

the big, big, good set of examples here will be great.

[105:18.49] It's almost like, it's hard to say we'd give an exhaustive list and say oh this is only the things, but, you know, almost. Yeah, definitely make some fence make some guidelines and just

help.

[105:36.93] I feel like people. Yeah, and then we get into discussion about it, like nitpicking what somebody did.

[105:45.21] I think we just keep it. I think we just say, you know, activities related to the day to day management or ongoing operation of the covered unit, for example, right and give them a couple

of things but not make it an exhaustive list more just just differentiating

[106:03.64] between that and owner performed labor which is one time one off non repeating activities. Awesome. Other comments on the section. Okay, looks like free to scroll them.

[106:28.70] Yeah, I think that I mean I think that's a natural segue into into the owner performed labor section. And so, Kristen I mean I know that you had some thoughts about defining owner

performed labor, and what would constitute owner performed labor.

[106:53.61] So it seems to me, this has been a discussion amongst the committee is that there's sort of like three important distinctions.

[107:03.40] One is like what constitutes owner perform management to is what constitutes owner perform labor, and then three.

[107:16.01] What constitutes like an owner, an owner's performance of a capital improvement. I think the committee is thinking is that that that is something that is distinct from owner performed

labor, and should be treated a little bit differently.

[107:34.75] So, that is sort of one issue, that's, I think that needs to be addressed by by these are this section of the rules.

[107:45.51] Another is that, you know, that the board has seen landlords coming to it proposing a wide variety of rates for owner performed labor, and the committee has had some discussion about what

may be what may be sort of an appropriate tool to value owner performed labor.

[108:14.76] And, you know, I'll just say I mean the discussion that we've had is considering potentially using the the prevailing wage rates established by the state as a mechanism to value, different

types of owner performed labor, and I'll share screen and show you folks what those prevailing wage rates

[108:38.75] look like momentarily, just so that you're aware of them.

[108:44.77] And the third issue is whether or not the board wants to continue to main maintain excuse me a cap on owner performed labor.

[108:56.24] As it stands now that cap has applied, or sort of tied to a landlord's gross annual income, and there's been some committee discussion about whether or not as a as a policy.

[109:13.73] It makes sense for the limitation on owner performed labor to be tied to gross annual income I mean, certainly from my perspective, it's unclear what the policy rationale for that was.

[109:30.17] But those are kind of the three, three big ticket items that the committee has discussed in terms of framing this rule. I think the committee's thinking has been, you know, we'd like to

hear from you folks as to your perspective on those three issues,

[109:46.35] and then flesh out a draft of the rule for, for further discussion at the next workshop. Awesome. Thanks, Jonas I see there Kristin or buddy did you have any filler you wanted to throw in

first before we take jabs at it.

[110:09.62] I guess where do we want to start, I mean because I always starting with defining owner performed labor and then getting into like, I guess let's find out Jonas.

[110:31.49] I'm gonna start on something I felt like maybe we would all have a consensus on which is this, while just huge discrepancies and hourly rates. I mean, you know, I think it doesn't really

matter if we're hard capped at the 10%, but, you know, putting $100 an hour for

[110:52.68] something to me is just, I don't know. So I kind of like the idea of standardizing this using a table of main labor rates, I think that's totally fine.

[111:07.16] Do it. I'm sorry, do we, do we really want to get that detailed though or do we just want to use a blended rate because I mean I'm still, maybe this is me just being a little obtuse but I

feel like this is handyman level work and those that usually is just

[111:24.31] a blended rate I feel like this is maybe a lot a little bit too granular. I don't know. I mean is this for all labor or for like capital improvements because maybe for capital improvements

I would have a different opinion.

[111:42.33] That was the other thing I was going to talk about is I don't love that we consider owner performed labor the same, even if they're doing a huge capital improvement it always to me and

then that goes into the 10% capital maybe it should be tied toward the capital

[112:00.74] itself, but I was going to tie into that as well but on handyman thing again I just thought some standard consistency across it for each use case rather than this person saying it's $100

to install a dishwasher and this person saying it's 35.

[112:17.20] Yeah, and I would just say I think I mean the board has to establish a rate that can be applied uniformly it's just a matter of what you folks think is appropriate. And, you know, I think

that I think the committee feels strongly that there does need to be a differentiation

[112:34.97] between owner performed labor and then labor to perform a capital improvement, because those things are distinct. Traditionally, labor costs associated with capital improvements have been

or amortized with the capital improvement.

[112:49.09] And I think the committee's thinking is, and you know I don't want to speak for Buddy and Kristen but that, you know, owner performed capital improvement labor would be treated the same

way.

[112:59.79] And, yeah, I mean, I think this could certainly be, you know, like, in looking at these categories and sort of the minimum wage rates for all these different types of labors and labor

could be something you apply to both I mean I think it would cover most

[113:29.53] types of capital improvements and then a decent amount of the owner perform labor work that you folks will see, but ultimately, it's up to you folks to decide approach.

[113:46.68] Approach wise what you think will work best I will say, I think the board will have to consider, I mean, with, with respect to like owner performed labor for instance, if you wanted to

establish a blended rate.

[114:02.71] Presumably, you know, you might want to consider including some sort of automatic escalator year over year.

[114:11.72] And or, you know, it would be a rate that would need to be considered, maybe on a yearly basis, although that's a little bit impractical just because I'm sure you don't want to have to

have these rules continue to go back before the council, each year a new.

[114:26.76] So just, you know, from like a practical perspective, something to think about and I think part of the committee's thinking was that these fair minimum wage rates are revised by the state,

year over year, and continue to go up.

[114:44.14] So you've got some, like, sort of a built in automatic escalator if you will.

[114:50.75] I'll stop there, buddy I know you've had your hand up.

[114:53.82] And, and Laura to have buddy, and Laura, you don't want to go funny. I was just gonna say, I've been kind of covered what I was going to say so I think that just like the standardization

of it and the fact that it's already like it already escalates it saves

[115:16.55] us from having to like determine the rate and potentially have that like open to scrutiny I think just like tying it to this thing that exists that has already been determined as a

government document is like the cleanest way long term and easier for like subsequent

[115:35.01] boards, but that's it. Thanks buddy. That makes sense and Laura, you can go ahead Matt now I'm thinking.

[115:47.43] So my, I, I kind of, I agree that like this, using the prevailing wages is great because it's going to maintain itself, and it's official, and my only concern about it is that it's wages,

not the cost of doing that thing.

[116:07.16] And those can really differ, right so like the wage of the, of somebody might be only $30 an hour but the actual cost of getting that repair person in there or something is 75 or something

like that.

[116:24.10] And that's my only concern there like, is that we're, we're not truly representing the opportunity cost there we're saying like oh you got you get paid as if you're an employee doing it

not the person who had all the tools and the means and did it, I don't

[116:40.64] know, but I don't really have a better solution, because I think it is hard to like, oh just pick something and then escalate it is tough. But that was my only thought there, so that even

maybe if we did take this we take like something slightly over it or something

[116:59.84] over, but the point of doing owner performed work is to save money. So it's not going to cost the same amount. Right. So the reason owner performs their labor is because a plumber will

cost you $100 an hour.

[117:16.45] So you don't want to pay the $100 an hour so a capital improvement that you bid out may cost you $5,000 but if you do it yourself maybe it's only $3,000.

[117:24.45] So we're really just awarding the appropriate cost, right, I wouldn't, unless I'm not thinking about this correctly and, but I wouldn't peg owner performed labor to, to what you can get

out on the market because it's marked up.

[117:44.93] So that's the point. Right. So I, I, I'm of, I'm of the persuasion to I know we're at time but I'm of the persuasion that for owner performed labor, we peg it to a handyman rate, a blended

handyman rate, I like 50 bucks an hour.

[118:07.48] Because that's, that's the most typical I mean you could certainly get more data points on that it's definitely not 100 but it's somewhere between 50 and probably I mean here in Portland

is probably between 50 and 75.

[118:19.59] And we can kind of noodle that, but I think when we get into capital performed labor I mean if if we may need to just think about, do we want to get so granular that if they did plumbing

work that they get plumbing wage or do we just want to put a blended

[118:40.53] there as well or do we just want to, you know, mean, we'll have to, I think there's a little bit more thought that has to go into the capital but I think, to me we can kind of solve for

the owner performed management and the owner performed labor more quickly.

[118:59.79] And I think we see that more commonly, because when you get into capital expenses I mean you've got building permits and code and inspection so I think we see less and like, it's less

common, similarly we got some direction there any can like other particular

[119:30.76] concerns within that type of methodology from board members, at least just for you know feedback to the subcommittee beyond that. I'm fine with a standardized blended rate I guess the one

thing I just don't want to be doing this each and every year coming up what the new standard

[119:55.13] rate is so whatever the solution is, if it has a built in mechanism.

[120:00.03] We're not re-adjudicating it every year. That would be preferable.

[120:07.86] Would it be out-of-bounds to just apply the same CPI rate to the blended rate? I mean,

[120:12.90] is that is that one possibility? I mean, if we're saying like what was this year was like

[120:17.01] 2.6 or something? I mean, do we just automatically apply the same rate at the blend to the owner

[120:24.91] performed labor rate to keep it standard?

[120:27.38] Yeah, it would work for me.

[120:31.73] That works for me. We're basing it off of the prevailing wages. Makes sense to me too.

[120:36.67] And Laura?

[120:37.77] I was just going to say to Kristin's point, I think I've just been going through other

[120:42.09] ordinances for other cities. In Berkeley, what they do is they just follow the CPI year

[120:49.38] to year. I think they set the initial one in 1979 and they've just been doing CPI increases

[120:54.44] since then. Something else they do is a skilled versus an unskilled rate. So a skilled rate,

[121:01.71] the landlord would have to show experiences and skills comparable to specialized workers,

[121:05.91] and then an unskilled rate would be like a blended, less specialized labor rate. I

[121:12.01] guess it's the way we approach it. Maybe like the handymane rate as you said. I don't

[121:15.69] know if that's being too generous to some landlord skills, but that's another way to

[121:20.46] think about it. But I think CPI is a great way to increase year to year. We could also

[121:24.76] think about doing a skilled versus unskilled rate. The one thing I've been struggling

[121:31.42] with or thinking about before I wanted to suggest this was, then we would have to go

[121:36.26] through the labor of determining what's skilled and defining what's skilled. And that becomes

[121:42.71] tricky for landlords. And that's just more evidence we have to collect. If I'm saying

[121:47.57] I'm skilled at plumbing, how true is that? I don't know how to prove that.

[121:53.87] That makes sense. But I think that is good. We have had landlords, we do have them break

[121:59.98] down their labor usually when we say, what was your owner perform labor? So to be able

[122:05.85] to look at it and say, oh, well, here, this falls in this category or whatever. So maybe

[122:10.40] that's something. Yeah. If you adopt it to define it clearly, really good suggestions.

[122:19.87] Thanks, Sandler. So as stated, we are at time, but I want to make sure if there's more items

[122:27.22] for here and then otherwise, before we adjourned, I was thinking maybe if there's some items

[122:34.27] for thought, like the particular next like Ben and, or Kristin or Buddy, if you guys

[122:39.25] want to call out, like, here's what we definitely need to like be thinking about and talking

[122:44.40] about and getting opinion from the board for next time that are like unanswered items

[122:49.43] from this, this meeting. I don't know if there's particular ones you want to touch

[122:54.45] on there. Yeah, sure. I mean, I think one, one thing the board should be thinking about

[123:03.17] is what's what you would like to define as allowable and unallowable legal expenses in

[123:11.58] the past. There have been situations where the board has excluded certain legal expenses.

[123:17.01] For instance, expenditures related to like resolving violation notices that have been

[123:25.70] issued by the city. I don't think as it stands now that your rules have sort of a clear definition

[123:34.49] of what would and wouldn't be allowed in terms of the legal expense. So I think it's something

[123:39.88] there's some suggested language here. But I think it's something the board members should

[123:43.78] be thinking about. I think one of the bigger ticket items that's coming up is refining

[123:52.93] your net operating or your base year net operating adjustment rules. Obviously, there's

[124:00.19] been a lot of discussion. I think not so much on step one, which is like rebutting the presumption,

[124:08.25] but how to like essentially calculate what the adjustment should be. So that is another

[124:18.36] issue that I would flag for the board members to consider for the next workshop. Additionally,

[124:27.71] I think this may have been briefly discussed at the last workshop. I know it has been discussed

[124:34.52] during your consideration of rent increase applications. But one of the rules proposed

[124:41.64] here is intended to address like, you know, if you have an operating expense that's reported

[124:48.30] in the current year, that you know was incurred in the base year, but was not also reported

[124:56.89] there. What is the methodology for addressing that? As you folks know, what it's been for

[125:04.86] the past couple of years is zeroing out those cost categories in the base and current year.

[125:13.79] What's been proposed here is, you know, a rule that would basically work backwards and

[125:21.90] would assume that, you know, for instance, the operating cost in the base year, the

[125:30.51] unidentified operating cost increased consistent with inflation to whatever is reported in

[125:36.63] the current year. So something to think about, you know, I think it's obviously been an issue

[125:44.40] that the board is grappled with. And I'll just flag it for you folks for consideration

[125:49.33] the next go around. Awesome. That's one and I know we just talked

[125:59.89] that out to in a meeting right in our last regularly scheduled or the one before it.

[126:05.61] Yeah, I mean, you know, I think it's these are extended discussions on all these issues.

[126:12.31] I mean, obviously, much later on in these rules is, is the bank rent stuff. And of

[126:20.72] course, I know you folks already thinking about that. But I don't know if we will get

[126:27.12] to that discussion at the next workshop, but something else for for everyone to consider

[126:34.70] come to the next meeting. Great. Thanks so much, guys. Any Kristen buddy, was there anything

[126:49.86] else you wanted to note just for us to be thinking about in the meanwhile or then when

[126:58.48] you re upload that could you check the way it displays in the Google Doc just because

[127:06.53] like, I don't get any of the red line or red text in the Google Doc. And I don't know

[127:12.11] if it's just how it imported or whatever. But I always noticing that we look right.

[127:17.87] Yeah, I was like looking I'm like, am I even looking at the same copy? Where in the folder

[127:24.51] is it? The public access rules were kind of funky looking too. I think I think like

[127:34.91] the best way to to be able to see the changes is going to be to download the word doc from

[127:45.91] I wish there was like a better way. But I think it just ends up like looking like red

[127:54.53] lines just end up looking wonky on Google Docs. Dylan, was that all your words?

[128:04.17] Pretty much. Yeah. So yeah, then it was from like, it goes from a Mac to me downloading

[128:10.93] as Microsoft Word to uploading as a Google Doc. So that's just the formatting I can

[128:16.37] play with it a little more to see if I can find the best way to make it true to the original.

[128:25.19] Yeah, don't kill yourself on it. Just downloading as a solution to because I see it's showing

[128:32.35] it to me that it is the word doc format. So I'm sure if I downloaded it's fine. Thanks

[128:39.89] everything else from anyone. Thank you all. I imagine at our next regularly scheduled

[128:49.71] meeting will probably schedule another workshop. And otherwise, somebody have a motion to adjourned

[128:59.33] motion to adjourn. Second. There it is. So we have a motion to adjourn and call to vote

[129:07.48] Kristin. Yes. Jonas. Yes. And Laura. Yes. Gordon. Yes. Buddy. Yes. And I also vote yes.

[129:20.22] And I hope everybody has a most wonderful rest of their day and we'll all be back in

[129:28.10] two weeks. Correct. Yes. See you guys. Alright, have a great one everyone. Thanks so much.