CC 06-17-2025 Item No. 15. Anti-Displacement BMR Policy_Staff PresentationThis section may
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Nicky Vu, Senior Housing Coordinator
June 17, 2025
Below Market Rate (BMR) Anti -
Displacement Policy
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Agenda
●Background on displacement
●Alternative strategies studied
●Review the 2024 Housing Commission
meeting study session
●Below Market Rate Anti-Displacement
Policy
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Background
●Below Market Rate Inclusionary Policy
●Market rate housing development must
provide 15% of units as affordable
●Expiration date of (35) years (now 99
years)
●Rental units that expire risk displacement
for tenants if landlords increase rent to
market rate
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Expiring Rental Units
Apartment
Building Units
Restrictions
Expire Property Owner
Aviare 20 7/8/2026 Legacy Partners
Forge
Homestead 15 7/15/2026
De Anza
Properties
Park (City
Center)4 7/31/2026 Prometheus
Hamptons 34 10/20/2027 Irvine Company
Arioso 20 1/29/2028 FPI Management
Biltmore 2 8/30/2029 Prometheus
Aviare 2 7/8/2038 Legacy Partners
Markham 17 11/4/2039 Prometheus
TOTAL 114
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Tenant Data
5
17
2467
Age
29 and under 30 - 39
40 - 49 50 and Above
0
5
10
15
20
25
30
35
40
45
Household Size
1 2 3 4 5 6
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Unit Data
[0, 4](4, 9](9, 13](13, 18](18, 22](22, 26]
0
10
20
30
40
50
60
Years Lived in Unit
96
17
Quality of Unit
Good Needs Upgrade
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Housing Element
Strategy HE 3.3.2
●Ensure proper legal and noticing
procedures for properties with expiring
rental BMR units
●Attempt to preserve units. If not feasible,
work with tenants or organizations to
mitigate displacement
Strategy HE 3.3.6
●Study rent stabilization and other potential
Anti-Displacement policy and create new
policy to protect 100 households
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Concurrent Actions
●Redwood City
●East Palo Alto
●Menlo Park
●San Leandro
●Mountain View
●Sunnyvale
●Santa Clara County
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Alternatives Explored
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Acquisition Preservation
●Buy buildings to preserve 15% BMR
●McClellan Terrace $66.7 million
●To purchase all expiring BMR
buildings: $525 million
●Not financially feasible
Purchase units and re-restrict as BMR
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Rent Stabilization
●AB1482 exempts expiring BMR units
from 5% + CPI increase limit
●Explicitly states expiring BMR units
to return to reestablish initial rent
●Not legally permissible for BMRs,
but could still be studied for city -
wide Anti-Displacement Strategy
Limit rent increases of expiring BMR units
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Deposit/Fee Regulations
●Require primary source documentation
before charging tenants maintenance costs
●Could lower housing costs overall
●Doesn’t address the disproportionate high
rent increase of expiring BMR units
●An issue that effects all tenants, could still be
studied for city-wide Anti-Displacement
Strategy
Add requirements for charging unexpected fees
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Eviction/Legal Defense
●Enact ordinances that expand just cause
eviction protection or reinforce no net loss
●Fund low-income legal aid orgs to
represent evicted tenants/enforce laws
●Doesn’t address the disproportionate high
rent increase of expiring BMR units
●An issue that effects all tenants, could still
be studied for city-wide Anti-
Displacement Strategy
Prevent eviction and defend tenants
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County BMR Waitlist
●Add Cupertino Displaced BMR Tenants as
priority for replacement into County list
●The County does not have a BMR list
●Negotiating with developers requires $$$
●Rehoming low-income Cupertino
households outside of the City would be
an exclusionary fair housing concern
Rehome tenants in the County waitlist
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Anti-Displacement Incentives
●Negotiate with developers to extend
affordability for development incentives
on future projects
●Depends on developer’s desire for future
projects in Cupertino
●Agreements executed prior to expiration
●Potential for some success as part of staff
workplan, supplemental to BMR Anti-
Displacement Policy
Offer development incentives for extensions
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BMR Anti-Displacement Policy
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Development
●Consulted RISE Housing and WVCS
●Consulted neighboring cities
●Redwood City, Campbell, Sunnyvale,
Santa Clara County, Menlo Park, San
Leandro, Mountain View, San Mateo
●Dec 19 Housing Commission Study Session
●April 21 Housing Resource Fair – Public
Outreach
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BMR Waitlist Priority
●City’s BMR waitlist has a system that awards
priority points for:
●Cupertino residents
●Cupertino employees
●Cupertino public workers
●Add three additional points for “Displaced BMR
Renter” Category – if one was a tenant of a BMR
rental expiring within 12 months
●Allow Displaced BMR Renters to reapply anytime
Rehome tenants in the City waitlist
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Example Priority List
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Relocation Assistance
●Costs of relocation are high: deposit, first & last
month of rent
●Add responsibility of property owners to:
●Pay tenant 3 months of Fair Market Rent, if
tenant moves from BMR to market rate unit
before or after 12 months of expiration (1
additional month for special circumstance)
●Provide notice of new rental rate and
relocation assistance (120) days from
expiration
Offset costs of rehousing, prevent homelessness
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Per Unit Assistance Payment
2024 Santa Clara County Fair Market Rent
Unit Size Studio
1
Bedroom
2
Bedroom
3
Bedroom
4
Bedroom
5
Bedroom
6
Bedroom
Fair Market Rent $2,383 $2,694 $3,132 $4,011 $4,425 $5,089 $5,753
3x $7,149 $8,082 $9,396 $12,033 $13,275 $15,267 $17,259
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Comparative Relocation
Assistance Policies
City Term of Assistance Activation Notice Eligibility Time Available Service Agency Service Enforcement
Redwood
City
3 months FMR and 1 month
special circumstance
Eviction/With
draw
30 days after
filing application
80% or
lower
Within 30 days 3rd-party
escrow
60 day
subscription
Void
Application
East Palo
Alto
$9,444.11 in unit <2 years,
$12,592.14 for 2+ years
Eviction/With
draw
120 days prior to
withdraw
80% or
lower
Immediately
upon notice
City
escrow
None Void
Application
Menlo Park 3 months FMR and 1 month
special circumstance
Eviction/With
draw
30 days after
filing application
80% or
lower
Within 30 days 3rd-party
escrow
60 day
subscription
Affirmative
Defense
San
Leandro
3 months FMR and 1 month
special circumstance
Landlord
Termination
90 days/at time
of rent increase
All AMI Within 5 days Direct None Affirmative
Defense
Mountain
View
3 months FMR and 1 month
special circumstance
Eviction/With
draw
30 days after
filing application
120% or
lower
Within 30 days 3rd-party
escrow
60 day
subscription
Affirmative
Defense
Santa Clara
County
3 months FMR and 1 month
special circumstance
Eviction/Haza
rd
Immediately
upon application
All AMI Within 15 days Direct None Affirmative
Defense
Sunnyvale 3 months FMR and 1 month
special circumstance
Eviction/With
draw
30 days prior to
termination
All AMI Within 15 days Direct None Affirmative
Defense
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Staff Analysis
●Waitlist Priority provides a long-term structural
solution, but is dependent on new units coming
available
●Relocation Assistance provides short -term
assistance as emergency intervention, but does
not provide a long-term solution
●Pursuing both options would provide the most
comprehensive tenant protections, but it is still
important to construct new restricted affordable
housing
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Motion
Adopt Resolution No. 25 -00X (Attachment A)
approving amendments to the BMR Admin
Manual to create an anti -displacement policy for
tenants residing in expiring Below Market Rate
units.