Monday, 3 June 2013

[WardFive] Fw: OTA Regulatory Update --PUBLIC COMMENT invited on proposed Construction Code changes

FYI from the Office of the Tenant Advocate. Looking for Comments on Proposed Rulemaking.
 
Albrette "Gigi" Ransom

----- Forwarded Message -----
From: "Cohn, Joel (OTA)" <joel.cohn@dc.gov>
To: "Cohn, Joel (OTA)" <joel.cohn@dc.gov>
Sent: Monday, June 3, 2013 7:19 PM
Subject: OTA Regulatory Update --PUBLIC COMMENT invited on proposed Construction Code changes

All:
 
On Friday May 31st, DCRA published a Second Notice of Proposed Rulemaking to amend the DC Construction Code at Title 12 of the DC Municipal Regulations. This proposed rulemaking follows a First Notice of Proposed Rulemaking published on December 7, 2013.  The deadline for public comments is 12 noon on Friday, June 14th.  Comments should be sent to:
 
Helder Gil, Legislative Affairs Specialist
DC Dept. of Consumer and Regulatory Affairs
1100 Fourth Street, SW
Room 5164
Washington DC  20024
 
… or via email to ConstructionCodes@dc.gov
 
Context:  The CCCB is a board appointed by the Mayor which works in three-year cycles.  Its purpose is to review model international construction and building codes, and then make recommendations to the Mayor and the Council for updating the relevant District regulations.  For more information about the CCCB go to:
 
 
The topics covered by the proposed rulemaking include codes for Buildings; Residential; Electrical; Fuel Gas; Mechanical; Plumbing; Property Maintenance; Fire; Energy Conservation; Existing Building; Fees; Green Construction; Swimming Pool and Spa.
 
To review the rulemaking:  Go to the following link for Part 2 of the D.C. Register published on May 31st, which includes the entire proposed rulemaking:
 
http://dcregs.org/Notice/NoticeListForPublic.aspx?type=Issue&CategoryName=Proposed Rulemaking&IssueID=398
 
Key OTA issues:  Of particular concern to the OTA is Subtitle 12 G, the Property Maintenance code.  In 2012 the OTA joined the CCCB's Property Maintenance "Technical Advisory Group" (TAG) and raised two issues in particular.  
 
1.       Pest extermination (Subtitle 12G, section 309.5):  One of OTA's major concerns was regarding a previous proposal to shift extermination responsibilities away from landlords and towards tenants.  The OTA believed this proposal was counter-productive, not balanced, and unfair to tenants. 
 
The CCCB reconsidered that proposal and instead, under the current proposal, the housing provider of a multi-family dwelling continues to be responsible for pest extermination where more than one rental unit is infested.  If only one unit is infested, the tenant can only be charged for the cost of extermination if evidence exists that the occupant is responsible for unsafe or unsanitary conditions (under the current regulation, by contrast, if it is the only unit infested the tenant is strictly liable for the extermination).
 
Also the revision sets forth certain tenant and landlord responsibilities in a more explicit way. The housing provider is responsible for providing regular extermination services, which tenants may utilize upon reasonable request.  The tenant or occupant is responsible for maintaining occupied areas in a safe and sanitary condition, and for reporting any infestation to the owner.
 
2.       Duration of AC service if provided (Subtitle 12G, section 608.1):  The other major OTA concern is the absence of a minimum time-frame for air conditioning in the existing regulations (vs. the existing requirement at 12G DCMR 602.3 that heat be provided from October 15th to May 15th).  This has resulted in numerous complaints each year from tenants for whom AC is supposedly a provided service, but for whom AC is denied because the landlord fails to switch the AC on even late into the summer.
 
The landlord is already required to maintain AC in good repair if it is a provided service.  But there is neither a date certain for when the housing provider must turn a central AC system on, nor through which AC must be kept on.  Under the proposed rule, if AC is a provided service, the landlord must turn on the AC no later than June 15th and then keep it on at least until September 15th.  This provides tenants with a minimum AC timeframe, while giving the landlord time to switch central HVAC systems to and from heat or AC (given the existing heat timeframe requirement of Oct. 15th to May 15th).
 
The purpose of this revision is to establish a minimum AC timeframe, not a maximum AC timeframe. Thus, if it has been the landlord's practice to provide AC for a longer period of time, this revision is not intended to affect that practice in any way. 
 
Share your thoughts:  The OTA plans to submit comments and welcomes your input and ideas, whether regarding the two issues discussed above and/or any others.  Also please let me know if you would like to receive a pdf of any part of the proposed rulemaking or existing regulations.  I'd also be happy to discuss any aspect of this rulemaking individually or with a group. 
 
The OTA would appreciate being cc'd on your comments.  However, as noted above, comments should be made directly to DCRA.  Again the deadline for all public comments is 12 noon on Friday, June 14th.
 
Thanks,
Joel
 
Joel Cohn
Legislative Director
District of Columbia Office of the Tenant Advocate      
2000 14th Street, N.W., 3rd Floor North
Washington, DC 20009
Phone: 202-719-6568
Fax:   202-719-6585
 
 
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