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Ms. Bennett October 3,2006 Page 4 Section 907.11— Uwr�er/Agenx Responsibility Section 907.11 states that three violations of this section at any particularlocation may result in loss of property registration. It is not clear whether this language means three violations of the statute and ordinances listed in this section or three instances of the owner not taking appropriate action in response to a violation of the statutes. We are assuming that you meant three violations of the specified laws, and we have proposed revising the language to make that clear. Section 907.14 —Rental Appeals Board The draft Ordinance provides that the Rental Appeals Board sha11 hear appeals relating to applications and appeals arising from a correction order. The draft Ordinance, however, does not specifically provide for an appeal when a properiy owner challenges the suspension or revocation of his/�er registration. We recommend that an appeal process be provided in such a situation. We have proposed language to Section 907.14 to provide for an appeal process in these circumstances. Section 907 .l5 — Appeal Process For the same reason as our suggestion in regard to Section 907.14, we have added language to Section 907.15 to provide for an appeal process when a property owner challenges the suspension or revocation of l�is/her regis�ation. Section 907.15 provides that the appellant sha11 have the right to appear and be represented by counsel in an appeal proceeding, but it does not extend the same right to the compliance officer. We have added language that provides the same right to the compliance officer. Section 907.17 — Inspection Access It is our understanding that the City does not intend to conduct inspections in connection with the registration of the properiy. Rather, it is the City's intent to only conduct inspections upon a complaint from a tenant or a neighbor of the property. We have revised the language in Section 907.17 to provide when inspections may be conducted. The proposed language allows the City to conduct inspections when it receives a credible complaint and recognizes the City's discretion to conduct inspections in other appropriate circumstances. The first sentence of Section 907.17 states, in relevant part, that "�p�rc�p�rty owners and their agents shall permit the compliance officer to inspect all premises governed by this section." Although this Section later provides that if an awner/agent refuses to permit access