{
	"id": "berkeley",
	"name": "Berkeley (Rent Stabilization Ordinance)",
	"schema_version": "1.0",
	"refreshed": "2026-04-25",
	"statute": {
		"short": "Berkeley Rent Stabilization and Good Cause for Eviction Ordinance — Berkeley Municipal Code Chapter 13.76",
		"citation": "Berkeley Municipal Code (BMC) Chapter 13.76 — Rent Stabilization and Good Cause for Eviction Ordinance — administered by the elected nine-member Berkeley Rent Stabilization Board (rentboard.berkeleyca.gov). The Annual General Adjustment (AGA) is published by the Rent Board no later than June 30 of each year, takes effect the following January 1, and applies for the calendar year. The base formula under Rent Board Regulation 1271 is sixty-five percent (65%) of the increase in the Consumer Price Index for All Urban Consumers (CPI-U) for the San Francisco-Oakland-Hayward Bay Area MSA over the period from July of the prior year to June of the publication year. The AGA may be DENIED to a landlord under BMC §13.76.110(B)(2) if the unit has not been registered, the landlord has failed to comply with a Rent Board order, the unit has habitability violations, or required annual security-deposit interest has not been paid to the tenant.",
		"url": "https://rentboard.berkeleyca.gov/rights-responsibilities/rent-levels/annual-general-adjustment"
	},
	"cpi_source": {
		"name": "BLS CPI-U, San Francisco-Oakland-Hayward, CA metropolitan statistical area, all items, not seasonally adjusted, 12-month change measured July of the prior year to June of the publication year. The Berkeley Rent Stabilization Board takes 65% of that CPI percentage change, rounds to the nearest tenth of a percent, and uses that as the AGA for the upcoming calendar year. The Rent Board publishes the figure each year before June 30; the Order takes effect the following January 1.",
		"url": "https://rentboard.berkeleyca.gov/rights-responsibilities/rent-levels/annual-general-adjustment"
	},
	"statewide": {
		"cap_pct": 1.0,
		"formula": "65% × (CPI-U San Francisco-Oakland-Hayward MSA all-items, July-to-June). The Rent Board publishes the figure each year before June 30 for the upcoming calendar year. Pre-1980 multi-unit residential buildings are covered. Single-family homes (unless the tenancy commenced before January 1, 1996), condominiums lawfully separable from the residential property, and new construction with a first certificate of occupancy issued AFTER February 1, 1995 are exempted by the Costa-Hawkins Rental Housing Act (Cal. Civ. Code §§ 1954.50 — 1954.535) and instead governed by AB 1482 (Cal. Civ. Code §1947.12) at the higher 8.8% (2026) statewide cap. The 2026 AGA may NOT be applied to a tenancy where the initial rent was first established between January 1, 2025 and December 31, 2025 — those tenancies become eligible only on January 1, 2027 (eligibility cutoff under BMC §13.76.110(B)(1)).",
		"year": 2026,
		"rates_by_regime": [
			{
				"regime_id": "berkeley_2025",
				"label": "Calendar Year 2025 (January 1, 2025 — December 31, 2025)",
				"cap_pct": 1.6,
				"cap_formula": "65% × CPI-U(SF-Oakland-Hayward MSA, Jul 2023 → Jun 2024) ≈ 65% × 2.4% = 1.56%, rounded to 1.6%",
				"cpi_pct_used": 2.4,
				"effective_window_start": "2025-01-01",
				"effective_window_end": "2025-12-31",
				"eligibility_tenancy_commenced_before": "2024-01-01",
				"notes": "The Berkeley Rent Stabilization Board adopted the 2025 AGA Order on June 17, 2024. Applies to fully covered units with tenancies commencing on or before December 31, 2023. Tenancies established in 2024 became eligible only on January 1, 2026. Notice period under Cal. Civ. Code §827(b) — 30 days for any increase under 10%; 90 days for any increase of 10% or more (only possible by combining catch-up rent-ceiling shortfalls)."
			},
			{
				"regime_id": "berkeley_2026",
				"label": "Calendar Year 2026 (January 1, 2026 — December 31, 2026)",
				"cap_pct": 1.0,
				"cap_formula": "65% × CPI-U(SF-Oakland-Hayward MSA, Jul 2024 → Jun 2025) ≈ 65% × 1.5% = 0.98%, rounded to 1.0%",
				"cpi_pct_used": 1.5,
				"effective_window_start": "2026-01-01",
				"effective_window_end": "2026-12-31",
				"eligibility_tenancy_commenced_before": "2025-01-01",
				"notes": "The Berkeley Rent Stabilization Board adopted the 2026 AGA Order at its October 16, 2025 meeting (RSB Item 8E). Applies to fully covered units with tenancies commencing on or before December 31, 2024. Tenancies established in 2025 become eligible only on January 1, 2027. The 2026 AGA of 1.0% is the LOWEST allowable rent-increase percentage in the RentCeiling catalogue — lower than SF (1.6% RY 2026-27) and substantially lower than AB 1482 (8.8% statewide, 2026). Notice period under Cal. Civ. Code §827(b) — 30 days for any increase under 10%; 90 days for any increase of 10% or more (only possible by combining catch-up rent-ceiling shortfalls)."
			}
		],
		"regime_switch_date": "2026-01-01",
		"banking_model": "rent_ceiling_accumulation",
		"banking_max_per_year_pct": null,
		"banking_max_per_notice_pct": null,
		"annual_unit_fee_usd": 280,
		"annual_unit_fee_passthrough_usd": 0
	},
	"prior_rent_control_year": 1980,
	"age_exemption_year": 1980,
	"cert_of_occupancy_exemption_date": "1995-02-01",
	"local_overrides": [],
	"scope": {
		"covered_buildings": "Multi-unit (two or more residential units) buildings in the City of Berkeley, regardless of when first constructed, are subject to the Rent Stabilization Ordinance's good-cause-eviction protections under BMC §13.76.130. The price-control provisions (the AGA and the rent-ceiling regime) apply only to multi-unit buildings whose first certificate of occupancy was issued ON OR BEFORE June 30, 1980 (the BMC §13.76.050 effective date) AND for which Costa-Hawkins does not preempt. Coverage includes apartments, flats, in-law / accessory dwelling units in covered properties, residential portions of mixed-use buildings. The price-control regime attaches to the unit, not the tenancy — a vacancy resets the initial rent to market under Costa-Hawkins (Cal. Civ. Code §1954.53), and the new tenancy is again subject to the AGA going forward, with the rent ceiling rebuilding from each subsequent annual AGA Order.",
		"excluded": "Single-family homes (unless the tenancy commenced before January 1, 1996, in which case the unit remains rent-controlled), condominium units lawfully separable when sold to a bona fide purchaser, and multi-unit residential buildings whose first certificate of occupancy was issued AFTER February 1, 1995 are exempt from the Berkeley rent cap under the Costa-Hawkins Rental Housing Act (Cal. Civ. Code §§ 1954.50 — 1954.535) — but AB 1482 (Cal. Civ. Code §1947.12) governs them at the higher 8.8% (2026) statewide cap unless they meet AB 1482's own carve-outs. Owner-occupied buildings of three units or fewer where one of the units is the primary residence of the owner; certain government-subsidized units (HUD Section 8 project-based, Berkeley Housing Authority public housing, USDA rural rental); units in hospitals, dormitories of educational institutions, religious institutions, monasteries, convents, asylums, and short-term medical-care or recovery facilities; transient lodging (hotels, motels, inns where occupancy is for less than 14 continuous days); units rented to a tenant by the City of Berkeley itself under a regulatory agreement; non-profit-charitable-organization-owned units under a regulatory agreement with the City. The good-cause-eviction protections of §13.76.130 reach a broader set of units than the price-control provisions — a single-family home tenant may be Costa-Hawkins exempt from the rent cap but still protected by good-cause eviction.",
		"notice_form": "California Civil Code §827(b) governs the form and timing of all residential rent-increase notices in California (the Berkeley Rent Stabilization Ordinance does not displace state notice rules). The notice must be in writing and must state the amount of the new rent, the effective date, and the unit address. Under §827(b)(2)(A), increases of less than 10% may take effect 30 calendar days after service; under §827(b)(3), increases of 10% or more require 90 calendar days. Service is per Cal. Code Civ. Proc. §1013 — personal delivery, or post-and-mail (add 5 days for mail), or substituted service. SEPARATE FROM the rent-increase notice, BMC §13.76.080 requires a landlord to register every covered rental unit with the Rent Board within 15 days of the commencement of any new tenancy, on a form prescribed by the Board, and to provide the tenant a copy. UNREGISTERED units are not eligible to receive an AGA increase — BMC §13.76.110(B)(2). Conservative practice on the rent-increase notice itself is to include the BMC §13.76.110 citation, the AGA percentage and order date, the prior rent ceiling, the new rent ceiling, and a statement that the unit is registered and current with the Rent Board."
	},
	"exemptions": [
		"Single-family homes — Costa-Hawkins exempt from the Berkeley rent cap under Cal. Civ. Code §§ 1954.50 — 1954.535 UNLESS the tenancy commenced before January 1, 1996, in which case the unit remains rent-controlled. Costa-Hawkins exempt single-family homes are instead governed by AB 1482 at the higher 8.8% (2026) statewide cap unless they meet AB 1482's own carve-outs (most commonly: SFR owned by a natural person — not LLC/REIT/corporation — with written exemption notice to tenant). Good-cause eviction protections under §13.76.130 may still apply.",
		"Condominium units lawfully separable from the residential property and sold to a bona fide purchaser — Costa-Hawkins exempt from the Berkeley rent cap. Instead governed by AB 1482 (8.8% for 2026).",
		"Multi-unit residential buildings whose first certificate of occupancy was issued AFTER February 1, 1995 — Costa-Hawkins exempt from the Berkeley rent cap (the §1954.52(a)(1) new-construction trigger date). Instead governed by AB 1482 unless AB 1482's rolling 15-year new-construction exemption also applies (AB 1482 exempts buildings less than 15 years old from each year's effective date).",
		"Owner-occupied buildings of three or fewer units where one of the units is the primary residence of the owner — exempt from the price-control regime under BMC §13.76.050. Good-cause eviction protections may still apply.",
		"Government-subsidized units (HUD Section 8 project-based, Berkeley Housing Authority public housing, USDA rural rental, BMR units under regulatory agreement) — rent for these units is set by the federal/state subsidy program or the regulatory agreement, not by the Rent Stabilization Ordinance.",
		"Units in hospitals, dormitories of any educational institution, religious institutions, monasteries, convents, asylums, and short-term medical-care or recovery facilities — institutional-housing exemption.",
		"Transient lodging (hotels, motels, inns, tourist houses) where occupancy is for less than 14 continuous days — Berkeley uses a 14-day threshold rather than the 32-day SF threshold.",
		"Units owned and operated by a qualified non-profit charitable organization under a regulatory agreement with the City of Berkeley restricting rent or income — exempt from the price-control regime by the regulatory agreement.",
		"Tenancies where the initial rent for the current tenancy was first established between January 1 of the prior year and December 31 of the prior year — these tenancies are not eligible to receive the upcoming AGA until the following calendar year (BMC §13.76.110(B)(1) eligibility cutoff). For 2026: tenancies established in calendar year 2025 are not eligible until January 1, 2027."
	],
	"notice_periods": [
		{ "rule": "Rent increase under 10% (which the 1.0% AGA always is, even when combined with catch-up unused-ceiling shortfalls under modest historical CPI conditions) — Cal. Civ. Code §827(b)(2)(A): 30 calendar days written notice, served per Cal. Code Civ. Proc. §1013. Add 5 days if served by mail.", "days": 30 },
		{ "rule": "Rent increase of 10% or more (only possible by combining multi-year unused ceiling catch-up at the once-per-12-months rule under §13.76.110(C)) — Cal. Civ. Code §827(b)(3): 90 calendar days written notice, served per Cal. Code Civ. Proc. §1013. Add 5 days if served by mail.", "days": 90 }
	],
	"twelve_month_rule": {
		"summary": "A rent increase under the Berkeley Rent Stabilization Ordinance may be imposed at most once per twelve-month period under BMC §13.76.110(C). The 12-month clock measures from the effective date of the most recent prior allowable annual increase on the unit. Unlike SF's §4.12 banking with hard 7%/year and 10%/notice ceilings, Berkeley's rent-ceiling-accumulation model has NO STACKING CEILING — the rent ceiling rises by each year's AGA whether or not the landlord applies it. A landlord who skipped prior AGAs may raise the rent to the current rent ceiling at any time, subject to the once-per-12-months rule and Cal. Civ. Code §827(b) notice. The rent-ceiling math is computed by the Rent Board's AGA Calculator (rentboard.berkeleyca.gov/aga-calculator) and posted in the Apparent Lawful Rent Ceiling Notice the Board mails periodically.",
		"citation": "BMC §13.76.110(C) (once per 12 months) and §13.76.110(B) (lawful rent ceiling)."
	},
	"vacancy_rule": {
		"summary": "On a LEGAL vacancy (voluntary tenant move-out, lease expiration without renewal, or a good-cause eviction under BMC §13.76.130), the Costa-Hawkins Rental Housing Act (Cal. Civ. Code §§ 1954.50 — 1954.535) permits the landlord to reset the unit's rent to market for the next tenancy. The 12-month one-increase clock and the AGA then apply going forward to the new tenancy starting from the new market rent — the rent ceiling rebuilds from each subsequent AGA Order. Vacancies caused by UNLAWFUL eviction (§13.76.130 violations), tenant harassment under §13.79, owner move-in evictions that fail their statutory requirements (e.g. owner doesn't actually move in within 3 months, or moves out within 36 months without a relative replacing), or violations of the Ellis Act re-rental restrictions do NOT qualify for the Costa-Hawkins vacancy-reset. The Rent Board can order rent rollbacks to the prior tenancy's lawful rent and impose civil penalties.",
		"citation": "Costa-Hawkins Rental Housing Act, Cal. Civ. Code §§ 1954.50 — 1954.535; BMC §13.76.130 (good cause), §13.79 (tenant harassment)."
	},
	"capital_improvement_surcharge": {
		"summary": "BMC §13.76.110(F) and Rent Board Regulations 1257-1273 provide petition-based mechanisms for rent increases above the AGA — Individual Rent Adjustment (IRA) petitions for capital improvements and operating-and-maintenance hardship, plus the AGA itself. The IRA petition is the primary above-AGA mechanism and requires Rent Board approval through a hearing process. Capital improvement passthroughs amortize the cost of qualifying improvements over a period set by the Rent Board (typically 5-10 years), with the tenant's monthly share added to the rent ceiling. Operating-and-maintenance hardship petitions are rare — the landlord must demonstrate that the AGA does not afford a fair return on the property as a whole. Self-help passthrough surcharges added to a notice without Rent Board approval are unlawful and subject to wrongful-increase petitions, refunds, and per-unit civil penalties under §13.76.150.",
		"citation": "BMC §13.76.110(F) (IRA petitions). Rent Board Regulations 1257-1273 (IRA procedures)."
	},
	"faq": [
		{
			"q": "What is the Berkeley Rent Stabilization Ordinance and who enforces it?",
			"a": "Berkeley's Rent Stabilization and Good Cause for Eviction Ordinance, codified at Berkeley Municipal Code (BMC) Chapter 13.76 and originally enacted by Berkeley voters as Measure D in June 1980. It provides two distinct protections: (1) a price-control regime — annual rent increases on covered units are capped at the Annual General Adjustment (AGA) percentage published each year by the Berkeley Rent Stabilization Board for the upcoming calendar year (1.0% for 2026); (2) a good-cause-eviction regime under BMC §13.76.130 — covered units may only be terminated for one of fifteen enumerated good causes (non-payment, breach of lease, nuisance, owner move-in, Ellis Act withdrawal, etc.). The Berkeley Rent Stabilization Board — an elected nine-member board — administers both regimes. It publishes the annual AGA, hears tenant petitions for wrongful-increase refunds (decreased services, habitability, overcharge), hears landlord petitions for capital-improvement passthroughs and Individual Rent Adjustments above the AGA, and investigates harassment complaints under §13.79. Penalties include rent rollback and refund orders, civil penalties up to three times the unlawfully-collected portion, and attorney fees in tenant-prevailing actions."
		},
		{
			"q": "What is the 2026 Berkeley rent cap?",
			"a": "The 2026 Annual General Adjustment (AGA) is 1.0%, adopted by the Berkeley Rent Stabilization Board on October 16, 2025 (RSB Item 8E) and effective January 1, 2026 — December 31, 2026. The AGA is computed as 65% of the percentage increase in the BLS CPI-U for the San Francisco-Oakland-Hayward MSA over the period July 2024 — June 2025 (approximately 1.5%): 65% × 1.5% ≈ 0.98%, rounded to 1.0%. The 2025 AGA was 1.6%. The 2026 figure is the LOWEST allowable rent-increase percentage in the RentCeiling catalogue — lower than SF (1.6% RY 2026-27, 1.4% RY 2025-26), substantially lower than AB 1482 (8.8% statewide, 2026), and lower than every other CA-overlay jurisdiction. The lower Berkeley AGA applies to covered units; Costa-Hawkins exempt units (single-family with post-1996 tenancy, condo, post-Feb-1-1995 construction) are governed by AB 1482 at 8.8% instead."
		},
		{
			"q": "Is my Berkeley property covered by the Rent Stabilization Ordinance?",
			"a": "Probably YES if you own a multi-unit (two or more residential units) building in Berkeley AND the building's first certificate of occupancy was issued ON OR BEFORE February 1, 1995 AND the building is NOT owner-occupied with three or fewer total units. The cap-rate provisions apply to the building, with vacancy resetting the rent under Costa-Hawkins. You are likely COSTA-HAWKINS EXEMPT from the Berkeley rent cap (and instead governed by AB 1482 at the higher 8.8% 2026 cap) if: (a) your unit is a single-family home AND the current tenancy commenced on or after January 1, 1996, (b) your unit is a condominium that was lawfully separable when sold to a bona fide purchaser, OR (c) your building's first certificate of occupancy was issued AFTER February 1, 1995. Even if Costa-Hawkins exempt from the Berkeley cap, the BMC §13.76.130 good-cause-eviction protections and the BMC §13.79 anti-harassment rules may still apply. Owner-occupied 3-or-fewer-unit buildings, government-subsidized units, BMR-regulated units, hospital/dormitory units, and transient lodging are excluded entirely from the price-control regime."
		},
		{
			"q": "What notice do I give the tenant?",
			"a": "California Civil Code §827(b) governs all residential rent-increase notices in California — the Berkeley Rent Stabilization Ordinance does not displace state notice rules. The notice must be IN WRITING and must state the amount of the new rent, the effective date, and the unit address. For increases of less than 10% — which the 1.0% (2026) Berkeley AGA always is, even when combined with catch-up rent-ceiling shortfalls under modest historical CPI conditions — the notice takes effect 30 calendar days after service. For increases of 10% or more (only possible by combining multi-year unused ceiling catch-up at the once-per-12-months rule under §13.76.110(C)), the notice requires 90 calendar days. Service must be per Cal. Code Civ. Proc. §1013 — personal delivery, or post-and-mail (add 5 days for mail), or substituted service. SEPARATE FROM the rent-increase notice, BMC §13.76.080 requires a landlord to register every covered rental unit with the Rent Board within 15 days of any new tenancy, on a form prescribed by the Board, and to provide the tenant a copy. UNREGISTERED units are NOT ELIGIBLE to receive an AGA increase under BMC §13.76.110(B)(2)."
		},
		{
			"q": "How does Berkeley's banking work compared to San Francisco?",
			"a": "Berkeley uses a RENT-CEILING-ACCUMULATION model — fundamentally different from SF's §4.12 banking with hard 7%/year and 10%/notice ceilings. Under BMC §13.76.110(B), the lawful rent ceiling for each covered unit AUTOMATICALLY rises by the AGA each January 1, regardless of whether the landlord applies the increase to the actual rent. If a landlord skipped the 2024 AGA (5.0%) and the 2025 AGA (1.6%), the rent ceiling has still risen by approximately 6.7% (5.0% + 1.6% with cumulative compounding) over those two years. With 2026's 1.0% added, the cumulative rent-ceiling rise from the 2024 baseline is approximately 7.7%. The landlord may raise the actual rent up to the current ceiling at any time, subject to: (a) the once-per-12-months rule under §13.76.110(C); (b) Cal. Civ. Code §827(b) notice (30 days for <10%, 90 days for ≥10%); (c) the unit being registered and current. There is NO stacking ceiling like SF's 7%/year and 10%/notice limits — the math is whatever the rent-ceiling history says. The Berkeley Rent Board's AGA Calculator at rentboard.berkeleyca.gov/aga-calculator computes this for any unit by Apparent Lawful Rent Ceiling on file."
		},
		{
			"q": "How is the Berkeley AGA computed each year?",
			"a": "Under Rent Board Regulation 1271, the Berkeley Rent Stabilization Board takes the percentage change in the BLS CPI-U for the San Francisco-Oakland-Hayward, CA metropolitan statistical area, all items, not seasonally adjusted, measured from July of the prior year to June of the publication year. It multiplies that percentage by SIXTY-FIVE PERCENT (65%) and rounds to the nearest tenth of a percent. The result is the AGA for the upcoming calendar year. The Rent Board adopts the Order each year before June 30 (typically at the Board's June or October meeting); it takes effect the following January 1 and applies for that calendar year. For 2026, the AGA is 1.0%, derived from approximately 1.5% Bay Area CPI growth July 2024 — June 2025: 65% × 1.5% ≈ 0.98%, rounded to 1.0%. The 65% multiplier is HIGHER than SF's 60%, but the SF formula uses March-to-March CPI (one quarter later than Berkeley's July-to-June anchor), which produced a higher CPI reading for 2026 — net result, SF's 2026-27 cap (1.6%) is HIGHER than Berkeley's 2026 (1.0%) despite the lower multiplier."
		},
		{
			"q": "Can the AGA be denied to my unit?",
			"a": "Yes. BMC §13.76.110(B)(2) lists FOUR conditions under which a landlord may NOT impose the AGA, irrespective of whether the unit is otherwise covered: (a) the unit has not been REGISTERED with the Rent Board on a current basis, including filing of the annual rent-roll registration form; (b) the landlord has failed to comply with a Rent Board order (a final IRA decision, a wrongful-increase order, an arrears assessment); (c) the unit has substantiated HABITABILITY VIOLATIONS not cured by the AGA effective date — health, safety, or building-code violations affecting the unit; (d) the landlord has failed to pay required ANNUAL SECURITY-DEPOSIT INTEREST to the tenant under BMC §13.76.070. Any one of these conditions blocks the AGA increase for that calendar year on that unit. The Rent Board's Apparent Lawful Rent Ceiling Notice flags units it believes are in this status. Landlords cure by registering, paying the annual unit fee (~$280 per unit), curing habitability defects on file, and remitting back deposit interest. Tenants who receive an AGA notice on a unit they believe is non-compliant may petition the Rent Board for a wrongful-increase determination."
		},
		{
			"q": "What happens on vacancy?",
			"a": "On a LEGAL vacancy (voluntary tenant move-out, lease expiration without renewal, or a good-cause eviction under BMC §13.76.130), the Costa-Hawkins Rental Housing Act (Cal. Civ. Code §§ 1954.50 — 1954.535) permits the landlord to reset the unit's rent to market for the next tenancy. The 12-month one-increase clock and the AGA then apply going forward to the new tenancy starting from the new market rent — and the rent ceiling rebuilds from each subsequent annual AGA Order. Vacancies caused by UNLAWFUL eviction (§13.76.130 violations), tenant harassment under §13.79, owner move-in evictions that fail their statutory requirements (e.g. owner doesn't actually move in within 3 months, or moves out within 36 months without a relative replacing), or violations of the Ellis Act re-rental restrictions do NOT qualify for the Costa-Hawkins vacancy-reset. The Rent Board can order rent rollbacks to the prior tenancy's lawful rent and impose civil penalties. Conservative practice on owner move-in or relative move-in evictions is to document occupancy with utility bills, voter registration, and property-tax homeowner-exemption filings."
		},
		{
			"q": "What happens if I overshoot the cap?",
			"a": "A rent collected above the Berkeley lawful rent ceiling is unlawful. The tenant may file a Rent Board petition for a wrongful-increase determination under BMC §13.76.150. The Rent Board can order: (a) rent rollback to the lawful rent going forward; (b) refund of the unlawfully-collected portion (with interest in some cases); (c) ongoing-overcharge findings that block future allowable increases until cured; (d) per-unit civil penalties; (e) treble damages where the violation was willful or in bad faith — three times the unlawfully-collected portion. Tenants prevailing in actions under BMC §13.79 (anti-harassment) are entitled to attorney fees and statutory damages. Tenants may also raise the overcharge as a defense to an unlawful-detainer (eviction) action for non-payment. The Berkeley Rent Stabilization Ordinance has an attorney-fee-shifting provision in tenant petitions where the violation was willful — distinct from SF's no-fee-shifting petition framework. Repeated or pattern violations may be referred to the Berkeley City Attorney for civil enforcement."
		}
	]
}