Oppose City of Pittsburgh Rental Registration

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Dear members of the City Council, Department of Permits, Licenses and Inspections, members of the public, and media:

As a residential property landlords in the City of Pittsburgh, we would like to voice our concerns with the current draft of the Rental Registration program.  This proposal will impose unnecessary and undue hardship to landlords and inflict a detrimental impact on the availability of affordable housing.  While the legal implications of this proposal are currently being litigated, we would like to bring to your attention other important aspects that lead us to oppose the proposal as it currently stands.  Specifically, these include the following:    

  • Inequitable application of building inspections
  • Dysfunctional inspection process
  • Ambiguous compliance requirements
  • Cost of registration, and compliance
  • Stifling competition, favoring large property owners
  • Increase in rents and decrease of affordable housing   
  • Solution to non-existent problem

Inequitable application of building inspections

Current proposal requires property inspections for rental properties only.  Owner occupied properties and vacant properties, which form overwhelming majority of properties in the City of Pittsburgh, are not required to undergo inspections.  Given the advanced age of residential housing in the City of Pittsburgh, it is a public safety issue to forgo inspections of majority of properties and only target a minority.


Dysfunctional inspection process

City of Pittsburgh Department of Permits, Licenses, and Inspections (PLI) has faced countless challenges and experienced many failures in recent years.  The cadre of inspectors underwent a significant turnover. Specialty inspections such as electrical inspections were temporarily outsourced to third-party inspectors as PLI was unable to handle this responsibility.  Inspections are frequently delayed, inspectors are often late or fail to show up to scheduled appointments, and are generally unreachable.  Consequently, PLI will not be able to undertake the proposed responsibility unless significant improvements are implemented to address leadership, process, and accountability.  


Ambiguous compliance requirements

A proposed compliance checklist is ambiguous and as a result, any property can fail an inspection. Consequently, these will be a subjective determinations preventing the landlord from ensuring that the property is compliant prior to the inspection.  For example, what constitutes sidewalks and driveways as being “in a proper state of repair, and maintained free from hazardous conditions” (302.3)?  How many cracks or missing mortar will result in a failed inspection (per 304.5 and 304.6).  How much leeway will be given to the chimneys to be “structurally sound, in good repair” (per 304.11) ?  Will the landlord fail the inspection because the tenants are neglecting their cleaning chores – “All interior surfaces maintained in good, clean and sanitary condition” (per 305.1)?


Cost of registration, and compliance

While the cost of registration can add up for landlords with multiple rental units, it is the compliance process that will be excruciatingly costly.  First, there will be initial expenditures to make properties compliant with the inspection requirements, which no other homeowners have to complete.  Second, there be additional inspections and expenses since the compliance requirements are ambiguous and it is impossible to ensure full compliance prior to the initial inspection.  Since PLI has a history of missing appointments and arriving late for inspections, there will be significant time lost for actual inspections when these do occur.  Finally, proposed registrations fees and “Good Landlord” training discounts cannot possibly defray the costs of the program.  So the fees initially proposed will be a Trojan Horse for fee increases in subsequent years.


Stifling competition, favoring large property owners

Single family homes account for a third of all occupied rental units and are generally owned by so-called “mom and pop” operators.  They are are not professionals in construction or home remodeling industry and will be the hardest hit with the cost of compliance.  Large businesses with in-house property management personnel will be able to leverage economies of scale, industry knowledge, and access to specialty skill sets and trades.  Therefore the cost of compliance with proposed rental registrations and inspections will result in undue hardship for small landlords and may force many of them to exit the rental market altogether.  


Increase in rents resulting in decrease of affordable housing

With the little guys unable to compete against the larger rental companies, the number of available rental properties will diminish.  Dwindling supply and the cost of compliance being passed on to the renters, the rental rates will skyrocket.  Moreover, major developments and renovations of large multi-unit rental properties in the last few years created new rentals with higher than market rental rates.  Unable to find affordable housing, some will try the homeownership route, further inflating the cost of housing.


Solution to non-existent problem

Proposed rental registration attempts to fix a problem that does not exist.  From the standpoint of public safety, it does not address the vast majority of homes in the City of Pittsburgh.  From the standpoint of being able to contact property owners in cases of building code violations, most of the information requested through the rental registration process is already available through the county assessor’s office and recorder of deeds.  If this still is insufficient, then certainly it must be made a requirement for all property owners in the City of Pittsburgh, not just the landlords. The rental market currently presents a wide range of options for the prospective tenants.  They can choose to rent an older property or a recently renovated one based on their priorities and budget, and can take action within the existing system to report unsafe living conditions.  The rental registration proposal does nothing in terms of safety for those currently owning and occupying unsafe properties, their neighbors, or the countless vacant and dilapidated properties throughout the city.  Rental registration effort will artificially spike the rental rates and rid the consumer of the ability to make their own rental decisions and have access to affordable housing.


We, as residential property landlords in the City of Pittsburgh, have made many sacrifices, taken great financial risks, and invested incalculable time and effort in creating, fixing, and improving the housing stock in the City of Pittsburgh.  We are committed to continue our efforts in playing a major part in the revitalization and growth of our great city and our region.  However, we feel that the proposed rental registration program will be extraordinary detrimental to our goals and efforts and will result in an overall negative impact to our city and our community.   

 

 

Referenced materials:

City of Pittsburgh, Department of Permits, Licenses and Inspections (PLI). Rules and Regulations pursuant to the Pittsburgh City Code, Title VII Business Licensing, Article X Rental of Residential Housing, Chapter 781, Residential Housing Rental Permit Program. (link)  Accessed 01/27/2018

Inspection Checklist Draft (link) Accessed 01/27/2018

Comprehensive Housing Market Analysis, Pittsburgh, Pennsylvania (link) Accessed 01/27/2018

Pittsburgh Pennsylvania Residential Rent and Rental Statistics (link) Accessed 01/27/2018

 

 

 

 



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