HomeMy WebLinkAboutA002 - Council Action Form, October 21, 980 COUNCIL ACTION FORM
NO: 10-21-80
SUBJECT: Staff comments regarding Revised Rental Housing Code
BACKGROUND:
The City staff has reviewed the proposed Rental Housing Code and would offer the
following comments and recommended changes to this proposal.
13.9 INSPECTIONS (5) (c) pages 7 & 8
Comments: The staff questions the need in providing prior notice to the general
public as indicated in this subsection, since prior notice of an inspection now
is given in writing to the landlord of each property which will be inspected by
the Housing Inspector. Furthermore, the State of Iowa Tenant-Landlord Bill
requires each landlord to give prior notice to tenants of an upcoming inspection.
Recommendation: Since it is believed that adequate notification is being given
to all parties affected by the inspection, it is recommended that this additional
procedural hurdle not be included in the final code.
13.17 HEARING page 13
Comments: The staff takes exception to the proposed amendment which would require
the $20 filing fee be returned to an appellant who prevails at a Appeal Board
hearing. The $20 filing fee is designed to recoup the actual administrative
costs involved in the appeal process, including duplication of appeal materials,
publication of notice of hearing, and postage.
It should be emphasized that fees for appealing before the Zoning Board of
Adjustment or for petitions for rezoning before the Planning and Zoning Commission
are not forgiven any reasons. According to State Law, these types of fees are to
be reasonable in the context of the cost of the service being provided.
Recommendation: Since this $20 fee is designed to recoup the actual costs incurred
by the City Clerk's Office in processing this appeal, it is believed that this fee
should not be returned to an appeallant who receives a successful ruling before the
Appeals Board. Therefore, it is recommended that this provision be stricken from
the proposed ordinance.
13.22 CONSTRUCTION (2) (1st paragraph) page 15
Comments: The first paragraph of the second section adopts similar tie-down and
ground anchor requirements as those specified in the Mobile Home Park Ordinance.
Since the City Staff does not possess the technical skills to handle these types
of inspections, the State Building Commissioner will be responsible for enforcing
the Mobile Home Ordinance. As you know, this ordinance deals only with the
construction and installation of new mobile homes, while the anchor requirements
proposed in the Rental Housing Code deals with all mobile homes which are utilized
as rental property. The State Building Commissioner, however, is not empowered to
enforce this type of restriction on existing mobile homes.
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Recommendation: The approval of this paragraph creates an inconsistency with
the Mobile Home Park Ordinance in that the MHPO pertains only to new installations
while this section of the rental housing code pertains to all existing rental
mobile homes. This inconsistency, coupled with the fact that our City personnel are
not sufficiently knowledgable in this technical area, and the State Building
Commissioner cannot assume responsibility for these inspections, leads us to
recommend that this section of the proposed Rental Housing Code be eliminated.
13.29 ELECTRICAL (5) page 17
Comments: The proposed language reads "Each habitable space or room shall have
at least two electrical outlets, and an overhead light may be counted as an
electrical outlet". It is staff's opinion that all habitable rooms or spaces
should be able to be lit instantlywhen an individual enters a room in the interest
of occupant safety. Therefore. it is crucial to require more than two electrical
outlets. A more preferable requirement would call for- the existance of either
overhead lights and switched electrical outlets.
Recommendation: From a safety standpoint, the language in this section should
read, "Each habitable space or room shall have at least two electrical outlets,
with one being an overhead light or a switched electrical outlet, and the other
being a switched or unswitched electrical outlet".
13.33 SMOKE DETECTORS ULA APPROVED (2) page 19
Comments: The proposed language specifies that smoke detectors will be required
only in those areas "containing an intended sleeping area". The word "intended"
is sufficiently ambigious to create an element of uncertainty in enforcement.
It is not uncommon to obtain a response from a landlord or tenant that a certain
sleeping area is not "intended", but rather temporary in nature.
Recommendation: It is the staff's opinion that if a tenant routinely sleeps in
a certain area, be it intended or not intended, protection should be provided
by installation of smoke detectors. Therefore, it is recommended that either
the word "intended" be stricken from this section because of its ambiguity, or
that specific guidelines be created to assist the staff in determining what
circumstances would qualify as intended or not intended.
The staff would also like to offer revisions to two sections which were not
altered by the Rental Housing Committee.
13.28 PLUMBING & HEATING (3) page 17
Comments: It is believed that the existing provision is not sufficient enough to
protect the inhabitants of rental units. Even though risks are minimized somewhat
through the present requirement of outside combustion air and automatic shutoff
devices for fuel feeding, the staff believes that fuel burning space heaters offer
a potential hazard to the occupants.
Recommendation: Realizing that many individuals throughout the City are utilizing
this type of heating apparatus, and the effect of a total ban would have far reaching
effects, the staff would prefer that all non-electric space heaters be banned from
use in these rental units.
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13.35 MINIMUM REQUIREMENTS, FIRE, SAFETY (1) page 19
Comments: The existing language in this section stipulates that the Appeal
Board may grant variances to Fire Safety standards for rental units established
by the State Fire Marshal. This individual promulgates fire safety standards
for structures such as apartments, lodging houses, dormitories, etc. It is the
staff's belief that when dealing with these types of structures, only the State
Fire Marshal can grant variances.
Recommendation: It is recommended that the wording of this section be altered
to reflect the Appeal Board's limited authority to grant variances for one and
two family dwellings.