[Updated Friday, March 20] This week, the City of Springfield is holding two meetings to present its “Residential Rental License and Inspection Pilot Program” [PDF] in the West Central Neighborhood. (Inspections have long been demanded by Springfield Tenants UNite (STUN), which finally persuaded the City Council to launch this pilot.)

The pilot program includes only about 1,500 single-family homes and duplexes (including homes that are now divided into two or more rental units). The West Central Neighborhood was chosen for the pilot because it contains many homes that are more than 100 years old, with a high rate of violations reported.

I was wondering about the relative costs for inspections of single-family homes and apartments, but then learned that the pilot program does not include other multi-tenant residential apartment buildings and complexes within the same area. (Score one for the affluent corporations.)

We attended the landlord meeting on Tuesday, because we own a 110-year-old rental house on West Central Street. We then discovered that West Central Street is north of Chestnut Blvd., which is the northern boundary of the West Central Neighborhood. Since it’s likely that any expansion of the pilot program will include our rental home, we stayed, and of course I have some thoughts to share.

First: landlords are being asked to share the personal email addresses and phone numbers of each tenant — with that information being public, and available to anyone who submits a public record request. The city will use that contact information to reach out to tenants, to obtain their consent to the inspection and also to follow up with surveys regarding the pilot program.

Of course, none of the landlords have received tenant consent to share this information. Perhaps going forward, landlords will incorporate the tenants’ consent to share this information this into their leases.

The West Central Neighborhood includes much of the downtown area, with a wide mix of property conditions and relatively low rental rates for many of these residential units. Many of the tenants are “vulnerable,” and will likely be concerned how this private information is collected and shared (or leaked). I’m sure that many of these tenants don’t want their personal information shared with ICE.

I’m also curious about how consent could be obtained from “off-lease” tenants. Also, if a rental unit is occupied by multiple unrelated tenants, there might be locks on the interior doors, for which neither the primary tenant nor the landlord might have access.

Several times, the city staff mentioned that much of their data on rental units came from the vendor who provides the portal that they are using; that data was scraped from public city and county records and other sources, but the city says the company has promised to keep the tenant information confidential.

I don’t trust that promise. I’ve done consulting for several clients who relied on third-party portal vendors which promised to protect their confidential data — but in every single case, the data was later stolen and resold by an unscrupulous consultant whom the portal vendor had contracted with for IT or database services.

The city’s PDF includes a list of 25 specific conditions, which seems reasonable, but incomplete. The list does not include Carbon Monoxide detectors (which are required for building with gas utilities, and we were told that the inspector will check this). The current list also doesn’t include “food preparation areas,” although the inspector will apparently check if proper fixtures are available for that purpose. (Yes, folks, it appears that a single inspector is responsible for doing 1,500 initial inspections in 365 days, plus the enormous preparatory and follow-up work).

I quickly wondered: what additional inspection issues will be identified as the first properties are inspected, and will those be added to a publicly-available checklist that inspector will use? If not, I expect that the inspector will maintain his own list of “special issues” to include in inspections.

City inspectors are not able to test for air quality or black mold.

I’m not sure what resources the city has to identify rental units within the pilot area, for landlords who have not obtained a business license (not always required).

Yes, the inspector is expected to notice and report obvious health and safety violations that they observe in neighboring properties that are not rentals.

Of course, landlords at the meeting were upset about being “singled out” for this program, and by the costs to comply; those costs would be passed on to tenants. One possibility is that if compliance costs are high, landlords may remove more units from the city’s rental inventory (selling or leaving them unoccupied pending an expensive renovation).

Update, March 20: On Thursday night, I attended the meeting for tenants, which was similar but also included some “tips for tenants.” Attendance was much smaller than the landlord meeting, and included several landlords who missed the Tuesday meeting.

My first concern was that the city plans to allow only 14 days notice to tenants in advance of inspections. Many student tenants are likely to be absent for long periods during the summer, and thus not receive the notice or consent form. This could lead to substantial expense for the city, which plans to seek court orders to perform searches if the tenant does not respond.

I also recognized that the entire process is driven by landlords, not tenants. Even if a “bad actor” landlord registers, they will likely work to delay inspections of any units they know are problematic. As I left, I wished the inspector luck during the winter months, which will likely include more troublesome inspections than the earlier months.

I wonder how the inspection data might be legally shared by the city: for example, the city could identify landlords who have a high rate of inspection failures, or who don’t correct violations promptly.