COVID-19 Industry-Supported State and Local Policy Proposals
The following is a list of apartment industry-supported state and local policy proposals, adapted from our friends at the Chicagoland Apartment Association. Please note that this is not an exhaustive list.
Shelter in-Place/Stay at Home Exemption
- Ensure that property management and construction of housing are explicitly exempt from any “shelter in place” or “stay at home” requirements to ensure the viability of our industry. This may include exemptions for property management, maintenance and social service coordinators for certain properties.
- Also, consider suggesting a direct citation to the U.S. Department of Homeland Security, Cybersecurity and Infrastructure Security Agency (CISA) guidance, “Advisory Memorandum on Identification of Essential Critical Infrastructure Workers During COVID-19 Response.” The memorandum contains an updated “Essential Critical Infrastructure Workforce” advisory list that identifies workers who perform operations and services essential to protecting state and local communities and ensuring continuity in critical functions. It includes “Residential/Shelter Facilities and Services,” specifically identifying as essential:
- Workers responsible for the leasing of residential properties to provide individuals and families with ready access to available housing.
- Workers responsible for handling property management, maintenance, and related service calls who can coordinate the response to emergency “at-home” situations requiring immediate attention, as well as facilitate the reception of deliveries, mail, and other necessary services.
- Workers performing housing construction related activities to ensure additional units can be made available to combat the nation’s existing housing supply shortage.
- Workers supporting the construction of housing, including those supporting government functions related to the building and development process, such as inspections, permitting and plan review services that can be modified to protect the public health, but fundamentally should continue and serve the construction of housing (e.g., allow qualified private third-party inspections in case of government shutdown).
Taxes, Fees and Government Services
- Defer street or sanitation citations assessed on owners due to resident behavior.
- As they face shortfalls in rental income, provide reduction in fees or charges assessed on owners and operators for essential services.
- Reduce water fees as owners and operators pay for water bills while residents remain at home per government requirements.
- Suggest implementing a water usage credit or discount according to the number of tenants possibly staying home.
- Request the City or State to broker agreements with lenders regarding interest only payments; deferred mortgage payments; deferred foreclosure; waived late fees.
- Extend the deadline or halt property tax collection.
- Consider waiving or reducing:
- Water and sewer taxes
- Trash and recycling fees or charges
- Sales and use taxes
- Parking fees and taxes
- Canopy/planter/sidewalk vault fees
- LIHTC fees for records and inspections
Development, Inspections and Permitting Specific
- Waive of ‘Right of Way’ permits (i.e. scaffolding permits).
- Defer inspections or citations.
- Dismiss building code violations that are not immediate, emergency, life-safety issues.
- Waive applicable construction related fees (I.e. impact fees, sewer connection fees, inspection fees, permitting fees for properties undergoing emergency work, licensing and certification fees, landscaping deposits where applicable
- Defer certain tax payments (I.e. property taxes, transfer and transaction taxes, etc.)
Eviction Moratoriums, Financial Assistance
- Dedicate funding in the form of direct emergency financial assistance for rental housing providers, industry professionals (many of whom are renters themselves) and renters to mitigate financial impacts of COVID-19.
- Establish short-term bridge loan programs to ensure continuity of operation for properties awaiting federal relief.
- Permit evictions for actions that threaten the health and safety of staff and other residents or lead to direct harm.
- Permit actions to recover possession in cases of abandonment of the unit.