HomeMy WebLinkAboutRental Housing Advisory Board Full Agenda 12.9.20Rental Housing Advisory Board
December 9, 2020
3:30 PM
Due to the current COVID-19 emergency, this meeting will be conducted virtually only. There will be no
general public comment at this meeting of the Rental Housing Advisory Board. Citizens are encouraged to
consider submitting written comments. Written public comments may be sent via mail addressed to
amaier@ci.oshkosh.wi.us or placed in the City Hall dropbox. Written comments will be distributed to the
Rental Housing Advisory Board and made part of the public record of the meeting. This meeting will be
available live on Channel 10 in the City of Oshkosh, live streamed on oshkoshmedia.org, live on WOCT
radio station 101.9 FM, live through Roku, Apple TV and Amazon Fire Stick. You may also view the
meeting later on oshkoshmedia.org and the Oshkosh Media YouTube channel. If anyone requires other
reasonable accommodation, please contact the Community Development Office at
amaier@ci.oshkosh.wi.us or 920-236-5055.
Meeting Information:
Link: https://tinyurl.com/y2mhow2l
Password: RrQ6wX4p9tH (77769947 from phones and video systems)
Phone Number: 1-510-338-9438 Access Code: 126 964 0892
To Whom It May Concern:
Please note the City of Oshkosh Rental Housing Advisory Board will meet on Wednesday, December 9,
2020 at 3:30pm via WebEx to consider the following agenda:
A. Call to Order
B. Roll Call
C. Citizen Statements
D. Approval of Minutes – October 14, 2020
E. Discussion Regarding Wisconsin Rental Assistance (WRAP) Program with Lu Scheer from
ADVOCAP
F. Winnebago County Eviction Prevention Task Force Update
G. Approve Tenant Bill of Rights
H. Approve 2021 Strategic Plan and Action Plan
I. Affordable Housing Study Update
J. Adjourn
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Rental Housing Advisory Board Meeting Minutes
October 14, 2020
Present: Alec Gulan, Lynnsey Erickson, Timothy Ernst, Linda Jevaltas, Donn Lord
Excused: Danny Garcia, Agnes Payne, Todd Hutchison, Katrina DeGroot
Staff: Allen Davis, Community Development Director
Call to Order
Mr. Ernst called the meeting to order at 3:32 PM.
Citizen Statements
No one appeared for citizen statements.
Approval of Minutes-August 12, 2020
The minutes of the August 12, 2020 meeting were approved as distributed. (Jevaltas, Erickson)
Discussion Regarding Wisconsin Rental Assistance Program (WRAP) with Representative from
ADVOCAP
Ms. Scheer stated that ADVOCAP has spent $1,142,247 and helped 683 separate households. For
Winnebago County, they have spent $688,254 and assisted 396 households. $83,000 has been spent this
week and they have a remaining balance of a little over $100,000. The numbers are current as of last
Wednesday. Governor Evers approved another five million until November 25th. ADVOCAP will be
requesting additional funds because they are currently spending between $75,000 and $100,000 weekly.
They will probably have a cut-off date of November 9th because it takes time to process the paperwork.
They are pretty much up to date and the waitlist is going well, although some people have yet to
receive their unemployment. ADVOCAP is able to pay December rent, so they are going to help as
many households as they can until the end of the eviction moratorium. They are working on projects
to help people beyond December. They will be requesting between $150,000 and $250,000 for the
communities that they serve.
Ms. Jevaltas asked for confirmation that there are hardly any people on the waitlist currently.
Ms. Scheer replied affirmatively, adding that each of her twelve staff is working with around ten
people currently. As far as the wait list is concerned, people are waiting hours instead of weeks for a
response. They are also now applying for energy services dollars. Additional CARES money also went
into that program.
Ms. Erickson asked how much ADVOCAP would be receiving out of the five million announced by
the governor.
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Ms. Scheer replied that they will be requesting between $150,000 and $250,000. They are going to be
conservative with their request because they do not want to hold money they are not spending. Some
counties are having difficulty spending all of their money.
Mr. Ernst asked how many more households ADVOCAP will be able to service with the remaining
balance.
Ms. Scheer replied that they have around $120,000 remaining, which is about a week or a week and a
half at the rate they’re going. They are still fighting some landlords who need confirmation that their
tenant is working with ADVOCAP and some landlords who are choosing to evict.
Ms. Jevaltas asked if ADVOCAP is able to assist with mortgage payments.
Ms. Scheer replied that the money can only be used for rental assistance, adding that around 100
people have already met the $3,000 maximum.
Ms. Jevaltas asked if there are any problems in the community with people being unable to pay their
mortgages and if ADVOCAP has received any inquiries about this.
Ms. Scheer replied that they have received a few calls and that the county is operating a program. A
lot of local banks are working with people for loan modifications. Some banks are doing a
modification with a six-month balloon, meaning they will be required to pay in full in six months,
which is a hardship for a lot of people. Right now they are looking toward next year and what funding
is available.
Ms. Erickson stated that county assistance for mortgages is available through Human Services. The
deadline for accepting applications is October 15th. She is not sure if they are extending the deadline or
how the program is going, but it has been available since September 1st.
Mr. Davis asked if Ms. Scheer had numbers specifically for Oshkosh.
Ms. Scheer replied that she only had the Winnebago County numbers, but the percentages have
remained consistent.
Mr. Ernst asked if tenants are being evicted because landlords are refusing the money.
Ms. Scheer replied affirmatively, adding that part of the condition is that landlords will continue
renting to their tenant and working with them after receiving payment. They have had some tenants
who paid three months’ rent early on, have now been evicted, and are requesting down payment
assistance, but have already met the $3,000 maximum.
Mr. Ernst asked if Ms. Scheer could speak to how these evictions interact with the CDC moratorium.
Ms. Scheer replied that she is not sure. She knows that some judges are providing paperwork at
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eviction hearings and ADVOCAP does make referrals to Legal Action.
Ms. Erickson stated that she is waiting for a response from Legal Action, so she is not sure of the exact
number of people who have been able to utilize the moratorium. The Housing Authority has been able
to provide the form to tenants. She is hopeful that it is being utilized, but she knows there is a lot of
confusion regarding what point in the process they can sign the form and how that works.
Mr. Lord asked how many landlords are turning down the funding and why they are turning it down.
Ms. Scheer replied that they don’t always know why. Sometimes the landlord only says that they
would like to move forward with the eviction and they refuse to complete the paperwork. There may
be other behaviors besides non-payment. Some landlords are always willing to work with tenants and
some are not.
Mr. Davis asked if the CDC eviction moratorium still allows landlords to evict for reasons other than
non-payment of rent.
Ms. Scheer replied affirmatively.
Mr. Lord stated that there are four conditions that need to be met for an exception to the CDC
moratorium.
Affordable Housing Workshop Discussion
Mr. Davis stated that the direction from Council was to follow staff’s recommendation to begin a
housing study that would include extremely low and very low income households. As the consultant
pointed out, Oshkosh does not have enough units to serve those households or upper income
households. Staff has been working over the last week to put together a request for qualifications to
send out to consulting firms and are expecting a proposal back in front of Council by the end of the
year so that it can be completed in the spring or early summer of 2021. The focus for staff is how to
work with City partners to encourage more housing on both ends of the income spectrum.
Ms. Jevaltas asked if the City could begin working to address the issue before a proposal is returned,
adding that finding housing in Oshkosh has been an issue for several years and that there are several
things the City could explore now instead of waiting another six months for the result.
Mr. Davis replied with information about the existing programs at City Hall and the requirements of
those programs.
Ms. Jevaltas replied that it would be great if the City could take care of the administrative items that
were identified at the workshop instead of waiting.
Mr. Davis replied that City staff will review what they are doing currently and identify what they
could be doing short-term to bring to the next meeting.
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Mr. Lord stated that it is important to address the changing demographics of renters and that the
shortage seems to be with larger and smaller units instead of two bedroom units.
Ms. Erickson agreed, adding that there is a shortage of accessible units also.
Mr. Davis replied that accessibility and demographics are two points that they included in the scope
of the request.
Mr. Ernst stated that all of the additional options seem worth exploring if they can be included in the
scope of the request at no additional cost. Accessibility is of special importance because the board has
been brought ADA accessibility issues in the past. Focusing on the elderly as a changing demographic
could provide an opportunity to work with the Commission on Aging for better results.
Tenant Bill of Rights Discussion
Mr. Ernst stated other communities have taken the initiative to pass what is called a tenant bill of
rights. The bill does not have the force of law, rather it is a resolution or statement that tenants have
rights, that laws exist to help protect those rights, and that equitable treatment for tenants is required
by the law. The top of the document identifies a few of the problems that exist in the community with
the imbalance of power between landlords and tenants. It is modeled after other communities and
broken out into three key areas: right to justice and fair and equitable treatment under the law, right to
peaceful enjoyment of the dwelling, and right to health and safety. Each area identifies common areas
of concern along with state statutes. This has been on the strategic plan for a few iterations.
Ms. Jevaltas stated that it is a good idea to have it in easily understood language because it will be
useless if people cannot understand what is written.
Mr. Ernst stated that he presented the idea to Mr. Rohloff a while ago, and he seemed to think a
resolution of this type would have a meaningful effect.
Ms. Erickson asked what the intended outcome of the resolution is and if any policies would result
from the passage of the resolution.
Mr. Ernst replied that he does not have any specific ideas for policies at this time, but he thinks it is
important that the City stands with vulnerable people against people who are misrepresenting their
rights to them. The board has evidence that this has happened and continues to happen. He hopes
that tenants feel less afraid to engage the City and are more willing to engage with their landlords to
have frank and open lines of communication instead of relying on assumptions, fears, or threats. He
would also like to see tenants begin to organize in this community. He doesn’t know to what extent
the bill of rights would help achieve that, but the right to organize is specifically listed in there.
Ms. Erickson asked if it would be useful to include some resources for tenants.
Mr. Ernst replied that resources could probably be added and that type of language might have a
place in there somewhere.
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Ms. Jevaltas stated that maybe the bill of rights could reference the brochure or the website that
provide resources for tenants.
Mr. Ernst replied that it would make sense to add or reference tenant resources within the bill of rights,
more specifically financial resources like ADVOCAP and legal resources like Legal Action.
Mr. Lord stated that some of the issues they have get repeated over and over again, so it would be
beneficial if they had a list of the most common issues and how to go about solving them that could be
easily put together.
Ms. Erickson asked if the most common issues would be for tenants or landlords.
Mr. Lord replied that both would be beneficial for things like security deposits and notices for repairs.
Longer documents are less likely to be read, so it would be a good thing if there was something
concise and simple for the common issues.
Ms. Jevalatas replied that it is a good idea, but the goal of the bill of rights is to help renters feel more
empowered. The other details are already available on the website.
Mr. Lord stated that no one seeks out the resources until there is an issue, so it would be nice to have a
quick read of the most common issues. It doesn’t need to be comprehensive.
Ms. Erickson replied that she wonders if it would be something that lives on the City’s website under
rental housing or rental complaints. She doesn’t know where tenants would think to go to find that
information, but it could be housed on the website.
Mr. Davis replied that it could be posted on the City’s website and there are a range of places it could
be linked.
Mr. Lord stated that they could create a document explaining the ten biggest mistakes tenants make to
cover the information concisely.
Ms. Scheer stated that Rent Smart is a good resource to provide.
Mr. Ernst stated that he will add Rent Smart to the list of resources. He cannot think off the top of his
head of the ten things landlords and tenants should be working on together. If Mr. Lord would like to
draft it for the next meeting, the board can discuss it as a potential addition.
Mr. Lord replied that he does not know what the ten would consist of, but one of the biggest things is
security deposits. When he asks renters what they know about the notice to enter an apartment to
make a repair, he hears all sorts of answers. He thinks there are some common misunderstandings
that could be cleared up with a simple vehicle to do that.
Ms. Erickson stated that UW-Oshkosh’s website has a section on off-campus housing and it looks like
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they have something similar to what Mr. Lord is talking about called a renters need to know
document that gives some tips for off campus students. The board could look at that example and take
some pieces from that.
Mr. Lord replied that he thinks it is important to just list resources where people can go without us
having to recreate the wheel.
Mr. Ernst asked Mr. Lord why a list is preferable in this case because some of the examples Mr. Lord
provided like security deposits and entry are already present in the document.
Mr. Lord replied that he understands what Mr. Ernst is saying, but there still seems to be a lot of
misunderstanding and misinformation out there.
Mr. Ernst agreed, adding that is part of the reason why he proposed the document the way it is.
Ms. Jevaltas stated that she agreed with Mr. Ernst, adding that the purpose of the bill of rights is not
about making sure people have resources. It is about empowering renters so that they feel they can
search for resources. To offer a bill of rights for renters is a powerful thing in and of itself because
people aren’t even going to seek out resources if they’re afraid to. You can have a lot of resources out
there, but it someone is afraid to move with regard to their landlord or rent, it doesn’t matter how
many resources are out there, they aren’t going to seek them out.
Ms. Erickson agreed with Ms. Jevaltas, stating this is a good first step for the board to take.
Mr. Ernst stated that he will bring an updated draft to the next meeting with the list of resources they
discussed.
Review and Update Strategic Plan
Mr. Ernst stated that the vacant building registry items can be eliminated because they are complete.
Mr. Davis replied that staff plans to begin the implementation of that on January 1, 2021.
Mr. Ernst stated that many items could be updated to recognize the COVID crisis and the impact it
has on what the board is doing.
Ms. Erickson stated that maybe they could add monitoring the continued need for rental assistance
due to COVID-19. She is not sure what action that could look like yet, but it might be good for us to
keep in mind.
Mr. Ernst agreed with Ms. Erickson.
Ms. Jevaltas stated that we might want to add to stay informed of what is going on with the City in
terms of available housing.
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Mr. Ernst replied that it was a good idea given that the board’s work touches on the goals of the
affordable housing study. Another specific change is on the first page under the advise column, 10-12
meetings per year should be revised to six per year. The board created the rental inspections districts
as well so that can be removed.
Mr. Davis stated that the fifth bullet point about reporting to Council on a regular basis could be
updated with Council giving all the board and commissions representatives on Council an
opportunity to update the Council monthly.
Mr. Ernst agreed, adding that monitoring COVID related issues could probably be added under
Education.
Mr. Davis stated that he fully anticipates staff will be suggesting that the consultants for the housing
study interview board members, so that should be added to the list because he expects a lot of
participation from the board.
Mr. Ernst agreed, adding that under training programs Rent Smart 2019 should be updated for the
current year or indicate that the board supports the mission as long as feasible given the pandemic.
Ms. Erickson replied that the year could be removed. Rent Smart will be moving forward virtually and
they have had a lot of participation from Winnebago County.
Ms. Jevaltas stated that she has not looked at the website, but she will take a look at it to see if it is up
to date or if there is anything that should be added or removed.
Ms. Erickson stated that keeping an eye out to make sure things are user-friendly and accessible is
important. An effort could be made to make it easier for folks who are trying to find information
because it seems like there are a lot of different things in different places on the website.
Mr. Ernst stated that something along the lines of proper monitoring and updating of online resources
and online communications makes sense.
Mr. Davis stated that staff will make the updates and bring to the December meeting so that RHAB
has the action plan in place for 2021.
Ms. Jevalatas replied that Council likes to review that from time to time.
Mr. Ernst stated that the board will review the updated tenant bill of rights and updated strategic plan
and take action on them at the December meeting.
Adjournment
There being no further business, the meeting adjourned at 4:35 PM. (Erickson/Jevaltas)
RENTAL HOUSING ADVISORY BOARD OF THE CITY OF OSHKOSH, WISCONSIN
DECEMBER 9, 2020 20-01 RESOLUTION
(APPROVED_______LOST_______LAID OVER_______WITHDRAWN_______)
PURPOSE: APPROVE TENANT BILL OF RIGHTS
WHEREAS, there is an imbalance in power between landlords and tenants in the
City of Oshkosh, and
WHEREAS, state lawmakers, through influence from housing providers, use
legislation to preference landlord rights over the rights of tenants, and
WHEREAS, housing providers in the City of Oshkosh misrepresent and deny
tenant rights through dishonest communication, and
WHEREAS, housing providers in the City of Oshkosh attempt to obstruct the
City’s ability to protect tenants, and maintain the habitability of dwellings through
lawsuits and outright disobedience of the law, and
WHEREAS, the economic downturn caused by the COVID-19 crisis further
exacerbated the power imbalance between tenant and landlord, and
WHEREAS, the State of Wisconsin is not part of the Uniform Residential Landlord
and Tenant Act, and
WHEREAS, the City of Oshkosh has identified several impediments to fair and
affordable housing,
NOW, THEREFORE, BE IT RESOLVED by the Common Council of the City of
Oshkosh that the Tenant Bill of Rights, per the attached, is hereby approved.
TENANT BILL OF RIGHTS (DRAFT 2 – UPDATED 11/2020)
I. RIGHT TO JUSTICE AND FAIR, EQUITABLE TREATMENT UNDER THE LAW:
A. LEASES: Tenants have the right to a rental agreement, which holds tenant and provider
accountable for individual obligations. Tenants have the right to freedom from illegal and
unenforceable non-standard rental provisions (WI State Statute 704.44; ATCP 134.08)
B. SECURITY DEPOSITS: Tenants have the right to the return of their full security deposit
within 21 days of terminating the lease, less charges damages explained with an itemized list,
not to include normal wear and tear or professional carpet cleaning. Tenants have the right to
sue for un-returned security deposits for up to double the amount (WI State Statute 704.28;
ATCP 134.06).
C. FEES & FINES: Tenants have the right to a receipt for any payment to a landlord. Tenants
have the right to freedom of fees and fines not called for in the lease (ATCP 134.03; 134.09)
D. FREEDOM FROM DISCRIMINATION: Tenants are protected from unfair treatment from
housing providers on the basis of race, religion, biological sex, gender, political affiliation, etc.
E. FREEDOM FROM RETALIATION: Tenants have the right to fully exercise the full the scope
of their rights and privileges as afforded by the law, including the right to inspections for health
and safety violations, and the right of tenants to organize (ATCP 134.09).
II. RIGHT TO PEACEFUL ENJOYMENT OF THE DWELLING:
A. ENTRY: Landlords must notify tenants at least 12 hours in advance of entry for repairs,
inspection or to show the property to a buyer. Any entry done without notification or to
address an emergency is illegal (WI State Statute 704.05; ATCP 134.09).
B. EVICTIONS: Tenants have the right to written notice in the case of 5-, 14-, or 21-day
evictions, and right to cure (WI State Statute 704.17).
C. Tenants have the right to 28 days notice to terminate a month-to-month lease (WI State
Statute 704.19).
D. Tenants have the right to enjoy the duration of their rental agreement in the event of sale of
the property (WI State Statute 704.19).
E. Tenants have the right to remain their dwelling during national or statewide eviction
moratoriums.
III. RIGHT TO HEALTH AND SAFETY:
A. Tenants have the right to safe and habitable dwellings which meet the minimum housing
standards as provided in local ordinance.
B. Landlords must disclose code violations affecting habitability (ATCP 134.04).
C. Tenants have the right to report damages within 7 days of moving in, and to expect repairs of
any damages (WI State Statute 704.08).
D. Tenants have the right to request and receive repairs within a reasonable timeframe and at
reasonable cost (ATCP 134.07).
E. Tenants have the right to periodic and scheduled inspections in order to address habitability
issues cause by negligence (ATCP 134.09).
IV. RIGHT TO SEEK ASSISTANCE IN LANDLORD DISPUTES:
A. Tenants may contact the Inspection Services department of the City of Oshkosh to request a
habitability inspection, especially in instances where landlords neglect to make requested
repairs.
<Add contact info language>
B. Tenants may seek legal advice for landlord tenant disputes. Tenants in Oshkosh should
contact Legal Action of Wisconsin <add contact info language>.
C. Tenants have the right to seek financial assistance from national, state, and local
governments. Tenants in Oshkosh should contact ADVOCAP for assistance <add contact info
language>.
D. Tenants in Oshkosh can find additional resources at the Rental Housing Inspection Board
website <insert link language here>.
Rental Housing Advisory Board – 202119 Strategic Plan
Membership and Terms: The Oshkosh Rental Housing Advisory board shall consist of seven (7)
members. Each member shall serve for a period of three (3) years. The board’s composition
should seek to reflect the diverse interest in rental housing conditions, such as, but not limited to
nor excluding, landlords, tenants, neighborhood association representatives, health and safety
professionals, real estate agents, and contractors.
Purpose: The purpose of the Rental Housing Advisory Board is to advise staff on the creation of
rental housing educational materials and residential rental training programs for landlords and
tenants, to review and make recommendations regarding city policy or changes to the
municipal code pertaining to rental housing. This includes all matters related to health, safety,
and general welfare of the renting public.
Advise
• Attend six12 meetings per year
• Review policy pertaining to rental properties
• Create Monitor rental inspection districts
• Respond to state rental inspection changes
• Report to Council on a regular monthly basis
• Monitor progress of affordable housing study and provide feedback to consultant
• Monitor continued need of rental assistance due to COVID-19
Educational Materials
Distribute appropriate materials prepared by other entities that pertain to our purpose
• Tenants Bill of Rights
• Rent Abatement
• Tenant Association Brochure
Create and distribute materials containing information to educate landlords, renters, and the general
public on issues pertaining to local rental housing
• A Helpful Guide for Renting in Oshkosh
• How Our Inspection Program Works
• Information on Short Term Rentals in Oshkosh
Training Programs
• Inspection Certification (note: this was on our outline, but needs clarification)
• Code Compliance Training: Research, develop and implement a training course on code
compliance focused on the needs of landlords
• Landlord/Tenant Rights: Research, develop and implement a program to educate
landlords and tenants on their respective rights
• Fair Housing: Schedule anti-discrimination training directed at both landlords and
tenants through the Fair Housing Council
• Rent Smart 2019: Direct tenants to these free virtual workshops provided by UW Extension
• Hold a workshop on the viability of creating and/or supporting tenant associations
Outreach
• Farmers Market: Participate in local farmers market as an opportunity for education and
outreach to the community
• State of the City: Create and staff an exhibit to make our presence known
• Collaborate with local associations with an interest in rental properties including the Winnebago
County Apartment Association, neighborhood associations, RentSmart at UW Extension, the
Fair Housing Council, World Relief, and Catholic Charities
• Monitor and update online resources and communications
Rental Housing Policy/Code Changes
Research policies and codes from other municipalities. Consider best practices, modify existing or write new policies
or code to address local needs. Investigate categories:
• Residency requirements for landlords/property managers
• Mobile homes
• Landlord/tenant mediation
• Service animals
• Protected Class code update
• Vacant Property Registration Ordinance (VPRO)
Rental Housing Advisory Board – 202119 Action Plan
Advise
Topic Action to Take Responsible Party Completion Date
RHAB Meetings Attend bi-monthly Board members End of term
Policy review Review as pertains to
City rental properties
Staff, Board
members
Inspection districts MCreate and monitor Staff, Board
members
State legislative
changes
Monitor
Respond as needed
Staff
Staff, RHAB
Report Keep Council
informed of
progressProvide
monthly update to
Council
Council Liaison
Housing Study Monitor progress and
provide feedback to
consultant
Staff, Board
Members
Rental Assistance
due to COVID-19
Monitor continued
need of rental
assistance due to
COVID-19
Staff, Board
Members
Educational Materials
Topic Action to Take Responsible Party Completion Date
Distribute existing
pertinent materials:
Tenants Bill of Rights
Rent Abatement
Tenant Assn Flyer
Determine
distribution points
Determine
distribution methods
Staff, RHAB
Create needed
materials:
A Helpful Guide for
Renting in Oshkosh
How Our Inspection
Program Works
Information on Short
Term Rentals
Create and/or
approve content for
information not
covered in existing
materials
Upon completion,
print and distribute
Staff, RHAB
Training Programs
Topic Action to Take Responsible Party Completion Date
Inspection
Certification
(needs
clarificationed)
Code Compliance Training for
landlords: research,
develop, implement
RHAB
Landlord/Tenant
Rights
Education on
respective rights:
research, develop,
implement
Fair Housing Anti-discrimination
for tenants/landlords
Staff with Fair
Housing Council
Rent Smart 2019 Supply class info Staff with UW
Extension
Tenant Association Study viability given
transient nature of
tenancy
RHAB
Outreach
Topic Action to Take Responsible Party Completion Date
Farmer Market Participate RHAB
State of the City Create and staff
exhibit each year
RHAB, Staff
Collaboration Reach out to local
associations sharing
same purpose as
RHAB
RHAB, Staff
Website Monitor and update
online resources and
communications
RHAB, Staff
Rental Housing Policy/Code Changes
Topic Action to Take Responsible Party Completion Date
Residency
requirements
Research, modify or
write policy or code
RHAB, Staff
Mobile homes Research, modify or
write policy or code
RHAB, Staff
Landlord/tenant
mediation
Research, modify or
write policy or code
RHAB, Staff
Service animals Research, modify or
write policy or code
RHAB, Staff
Protected Class Research, modify or
write policy or code
RHAB, Staff
VPRO Research, modify or
write policy or code
RHAB, Staff