cdbg code enforcement plan - las vegas · the city of las vegas code enforcement uses inspections...

November 2017

CDBG Code Enforcement Plan CITY OF LAS VEGAS

Contents Overview: ...................................................................................................................................................... 2

Broken Windows Theory: .............................................................................................................................. 2

Purpose: ........................................................................................................................................................ 2

CDBG Funds for Code Enforcement Activities ............................................................................................... 3

Low- and Moderate-Income Area Benefit ................................................................................................. 4

Prevention or Elimination of Slum/Blight on an Area Basis ....................................................................... 4

Slum Blight Urban Renewal Completion .................................................................................................... 4

Activities Designed to Meet Community Needs by Having a Particular Urgency ...................................... 4

Data and Analysis Efforts to Date .................................................................................................................. 5

Enforcement Priorities and Concurrent Services....................................................................................... 6

Enforcement Violations by Census Tract: 2013-2016................................................................................ 6

Impact of Demographic Changes .............................................................................................................. 9

Section 1: Poverty Level ...................................................................................................................... 10

Section 2: Public Assistance ................................................................................................................. 11

Section 3: Employment ....................................................................................................................... 12

Section 4: Disability ............................................................................................................................. 13

Section 5: Non- Native birth ................................................................................................................ 14

Proposed Interventions ............................................................................................................................... 14

Surveys and Workshops .......................................................................................................................... 14

Results Vegas ........................................................................................................................................... 15

Randomized Control Trials ...................................................................................................................... 15

Proactive Outreach .................................................................................................................................. 16

Overview: The City of Las Vegas code enforcement uses inspections to encourage residents

(homeowners and tenants) to maintain the appear and value of their housing units. It is

encouraged that other residents are motivated to keep their housing units in compliance with

local codes and up to good conditions along with their surrounding units. Housing units that are

well-maintained and meet all local housing standard codes will protect the health and safety of

occupants, improve the value of the residential properties in the neighborhood, and give such

neighborhood the appearance of being well-maintained. Housing units that do not meet these

conditions, or are dilapidated and/or vacant have a high probability of attracting squatters,

vandals, and rodents.

Code inspections are done to protect the health and safety of all persons within these

communities. The City of Las Vegas’ Code Enforcement department assists in monitoring code

enforcement and confronting and issues in a safe and routine way.

Broken Windows Theory: In addition to maintaining the quality of life in neighborhood, active code enforcement

can aid in reducing crime in these neighborhoods, as well. The Broken Windows Theory was

introduced in 1982 by social scientist James Q. Wilson and George L. Kelling. Their research

showed that, if broken windows in a structure is not prepared, vandals and criminals are more

likely to break more windows. Many often forget the power of a “broken window” policy

towards improving code compliance and community responsibility. Crime levels tend to be

higher in areas where repairs are not accomplished. Therefore, the City of Las Vegas Code

Enforcement monitors and maintains buildings, particularly in urban areas, to prevent vandalism

and further deterioration so that neighborhoods are well-maintained and experience less crime.

Purpose: The CDBG Code Enforcement Plan was created to outline proactive strategies based on

current data for specific types of code enforcement cases. This plan will guide strategies to

prevent code violations and enact tools for success that the City may use in order to achieve

compliance and direct decision making within the City. Overall, this plan aims to guide property

owners, protect neighborhoods, and improve the efficiency of the code enforcement program in

Las Vegas.

CDBG Funds for Code Enforcement Activities The Housing and Community Development Act of 1974 (HCDA) and the CDBG regulations

allow CDBG funds to be used for selected code enforcement activities. Provisions of these

regulations are codified in 24 CFR 570.202(c). According to the HUD definition of code

enforcement, it is defined as “prevention, detection, investigation, and enforcement of violations

of statues and ordinances regulating public health, safety, and welfare. National objectives must

be met in order for distinct code enforcement activities to be carried out: low- and moderate-

income area benefit, prevention or elimination of slum/blight on an area/basis, slum blight urban

renewal completion, and activities designed to meet community development needs by having a

particular urgency. In addition, CDBG grantees using code enforcement funds must be in

compliance with Fair Housing and Civil Rights considerations by not discriminating on the basis of

race, color, religion, sex, disability, familial status, or national origin to both clients and staff

members.

Figure 1 shows the census tracts eligible for Community Development Block Grant funds

in Las Vegas.

Figure 1: City of Las Vegas CDBG Census Tracts

Low- and Moderate-Income Area Benefit Code enforcement activities may meet the national objectives of benefitting low and

moderate income persons on an area basis under § 570.208(a)(1) (for Entitlements) when

carried out in a deteriorated area and when carried out in conjunction with public or private

improvements, rehabilitation, or services that may be expected to arrest the deterioration of the

area. This national objective may be met when code enforcement inspections are conducted on

single or multifamily housing units, commercial buildings, and other publicly or privately-owned

buildings. The building or facility being inspected must be located in a primarily residential area

where a minimum of 51% of the resident in those area are low- and moderate-income.

Prevention or Elimination of Slum/Blight on an Area Basis Under § 570.208(b)(1) (for Entitlements) and § 570.483(c)(1) (for States), code

enforcement activities are considered if the area meets the definition of slum, blighted, or

deteriorated under State or local law; if at least 25% of properties experience physical

deterioration, abandonment, chronic high occupancy turnover rates, significant low property

values compare to other areas in that community, or if there is known or suspected

environmental contamination; and if in general, public improvement through the area are in a

state of deterioration. This national objective must be maintained to demonstrate how code

enforcement have been maintaining the decline in an area, and what is needed to do so.

Slum Blight Urban Renewal Completion Although rare, this national objective is an option for those who have outstanding urban

renewal plans for given area. The grantee must be able to document this national objective by

having a copy of the Urban Renewal Plan in effect at the time of closeout of HUD financial

assistance under title I of the Housing Act of 1949 or financial settlement under Section 112 of

the HCDA, and a description of how the inspections for code violations and enforcement of

codes are needed to complete the urban renewal plan for the area.

Activities Designed to Meet Community Needs by Having a Particular Urgency If there is an instance in which CDBG grantees experience natural disasters (tornadoes,

floods, hurricanes, and other disastrous events) that do not rise to the level in which Federal

Emergency Management Agency (FEMA) funds are not received, CDBG funds may be used for

code enforcement inspections in these areas to protect their safety and welfare.

Data and Analysis Efforts to Date The city of Las Vegas’ Department of Community Services and Code Enforcement

have been in collaboration in gathering useful and trusted information and data in order to

create an effective and useful plan to combat blight and deterioration in CDBG areas. Figure 2

shows the total number of blighted properties within all CDBG census tracts (Figure 1) when

surveyed in 2012. Using factors such as poverty level, public assistance, employment, disability,

and native citizenship from census data, along with Geographic Information Systems, the city has

begun to analyze and spatially locate specific issues in each CDBG area, and set high priority

areas for code enforcement officers to provide administration. Code enforcement officers will

target areas in which more than half of all residents are low-or moderate-income households

and where there is a higher need to reduce slum or blight (meaning a higher need to reduce

health and safety hazards, property maintenance issues, and dangerous buildings). This

partnership also aims to provide prevention and revitalization through the elimination of

community blight and deterioration.

Figure 2: Baseline for Number of Blighted Properties in CDBG Census Tracts

0

50

100

150

200

519

1400

512

518

3419

517

3500

400

514

516

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3424

600

3413

1200

102

302

3417

1300

3411

2201

2203

105

503

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3425

101

203

3102

103

3420

800

515

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Census Tract

Total Number of Blighted Properties within CDBG Tracts: 2012Ranked from highest to lowest

Enforcement Priorities and Concurrent Services Enforcement, together with the public or private improvements or services to be provided,

may be expected to capture the decline of the area. The following variables were considered

when analyzing best practices:

a. Dangerous Buildings

b. Housing Codes

c. Nuisance Violations

d. Identification of other activities to be carried out (whether CDBG-assisted or not) that

will arrest the decline of the areas and their funding sources.

e. Compliance with the procurement standards at § 85.36 when equipment and services

are procured.

Enforcement Violations by Census Tract: 2013-2016 After a baseline survey was conducted in 2012, the City of Las Vegas focused on

enforcing three key types of violations in the CDBG census tracts: dangerous buildings, housing

code violations, and nuisance violations. As shown in Table 1 and Figure 3, enforcement in these

categories increased significantly each year from 2013 to 2016. In 2016, violations in these

categories were more than double the amount in 2013. Figures 4 through 7 provide detail on

violations by census tract.

Violations 2013 2014 2015 2016 Grand Total

Dangerous Building 656 1,093 1,314 1,328 4,391

Housing Code 866 974 1,385 1,976 5,201

Nuisance Violations 9,727 12,219 16,378 19,668 57,992

Grand Total 11,249 14,286 19,077 22,972 67,584

Table 1: Enforcement of Targeted Violations in CDBG Census Tracts by Year

Figure 3: Trend in Enforcement of Targeted Code Violations in CDBG Census Tracts

Figure 4: Violations in CDBG Census Tracts 2013

656 1,0931,314 1,328

866 974 1,3851,976

9,727

12,219

16,378

19,668

-1,500

3,500

8,500

13,500

18,500

2013 2014 2015 2016

Year

Trend in Number of Code Enforcement Violations in CDBG-eligible census tracts

Dangerous Building

Housing Code

Nuisance Violations

0

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1000

1500

2000

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1

10

8

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10

7

52

6

13

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12

00

34

29

22

03

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9

10

04

31

02

40

1

30

1

51

8

34

27

34

19

31

03

34

31

34

15

40

2

31

04

29

05

34

30

34

26

34

20

30

2

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52

2

52

4

52

8

34

11

58

08

32

13

Nu

mb

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Census Tract

Targeted Violations by Census Tract: 2013Ranked from highest to lowest Nuisance Violations

Dangerous Building Housing Code Nuisance Violations



0

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1000

1500

20001

01

52

7

10

8

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6

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40

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3

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22

03

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20

4

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51

4

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3

52

8

58

07

58

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32

14

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Census Tract



0

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2000

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1

14

02

13

00

52

1

52

6

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9

12

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22

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40

2

10

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2

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4

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4

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0

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Census Tract




Impact of Demographic Changes While enforcement efforts have increased significantly since the 2012 baseline, there

have also been demographic changes that have contributed to ongoing blight. Table 2 shows the

overall trends for CDBG census tracts for poverty, public assistance, unemployment, disability

status, and non-native population. Table 2 illustrates that several key indicators increased from

2012 to 2015: percent of families below poverty level, percent of families with cash public

assistance or Food Stamps/SNAP, and individuals with disabilities. In contrast, unemployment

and the percent of foreign born individuals decreased. Detail on each indicator can be found in

the sections below.

Census Statistics 2012 2015 Change in Percentage

Points

Average percent of families below poverty level within all CDBG tracts.

20.7% 23.7% +3.0%

Average Percent of families with cash public assistance or Food Stamps/SNAP within all CDBG tracts.

6.6% 8.9% +2.3%

Average of Unemployment rate within all CDBG tracts. 16.6% 15.0% -1.6%

Average Percent of individuals with a disability within all CDBG tracts.

14.0% 16.3% +2.3%

Average Percentage of non- native (born outside U.S.) individuals within all CDBG tracts.

1.29% 1.27% -0.02%

Table 2: Demographic Changes for CDBG Census Tracts from 2012 to 2015

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500

1,000

1,500

2,0001

01

14

01

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5

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10

3

30

1

51

8

20

1

11

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19

20

4

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21

51

7

52

3

32

61

34

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6

51

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90

0

70

0

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07

58

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Census Tract



Section 1: Poverty Level

The overall average estimated percent of families below the poverty level in all CDGB

tracts was 3.0 percentage points higher in 2015 than 2012. In 2015, roughly 30% of the census

tracts had a reduction in poverty, and nearly 70% had an increase in poverty. However, when

comparing individual tracts in 2012 to 2015 census data shows the highest majority of poverty

reduction has taken place in the CDBG tracts that had the highest poverty percentage in 2012.

Figure 8- Poverty Level by CDGB Census Tract

Source: U.S. Census Bureau, American Community Survey Table S1702

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401

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527

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3427

700

518

103

510

109

106

525

526

1300

1401

3413

1004

900

3260

3261

5808

3214

Census Tract

Percentage of Families within CDBG Tracts Below Poverty LevelRanked by 2012 highest to lowest percentage

2012 2015

Section 2: Public Assistance

Overall, the estimated average percent of families with cash public assistance or food

stamps/SNAP in all CDGB tracts was higher in 2015 by 2.3 percentage points. In 2015, roughly

16% of census tracts had a reduction in the percentage of families on public assistance, and

roughly 84% of census tracts had an increase in the percentage of families on public assistance.

When comparing individual CDBG tracts in 2012 to 2015, census data shows very few areas have

had a reduction in the percentage of individuals on public assistance.

Figure 9- Public Assistance Percentage by CDBG Census Tract Source: U.S. Census Bureau American Community Survey Table B1905

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3102

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3421

3214

Census Tract

Percentage of Families on Public Assistance or Food Stamps Ranked by 2012 highest to lowest percentage

2012 2015

Section 3: Employment

On average, the overall unemployment rate throughout all CDBG tracts decreased by 1.6

percentage points from 2012 to 2015. In 2015, roughly 40% of census tracts had an increase in

unemployment rates, whereas 60% of census tracts had a decrease in unemployment rates. A

majority of the census tracts that had the highest unemployment rates in 2012 have had a

reduction in unemployment. In contrast, the census tracts that ranked lower in 2012 have a

higher percentage increase in unemployment.

Figure 10- Unemployment Rate by CDBG Census Tract Source: U.S. Census Bureau American Community Survey Table S2301.

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108

524

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1200

528

3260

2201

3421

Census Tract

Unemployment Rate within CDBG Census TractsRanked by 2012 highest to lowest percentage

2012 2015

Section 4: Disability

Overall, the percentage of residents with a disability has increased in the specific census

tracts by 2.3 percentage points from 2012 to 2015. In 2015, over 26% of CDGB census tracts had

a decrease in the percentage of individuals with a disability, yet 74% had an increase in the

percentage of individuals with a disability.

Figure 11- Percentage of Persons with a Disability by CDBG Census Tract

Source: U.S. Census Bureau American Community Survey Table S1810

.

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3213

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3427

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3419

3102

2905

3413

3431

519

3415

203

5808

516

700

514

517

3421

524

527

2203

Census Tract

Percentage of Individuals with a DisabilityRanked by 2012 highest to lowest percentages

2012 2015

Section 5: Non- Native birth

Overall the average percentage of non-native births within all census tracts shows a slight

decrease (-.02 percentage points) from 2012 to 2015. In 2015, over 26% of CDGB census tracts

had an increase in the percentage of individuals with born outside the U.S., and 74% had a

decrease in the percentage of individuals born outside of the U.S. Comparing 2012 to 2015

census data by tract, the highest ranked percentage of individuals born outside the U.S in 2012

had the greatest reduction in 2015, whereas, tracts that had a lower percentage in 2012 had the

greatest increase in 2015.

Figure 12-Percentage of Individuals Born Outside of U.S. by CDBG Census Tract

Source: U.S. Census Bureau American Community Survey Table S0602

Proposed Interventions

Surveys and Workshops Currently, the City of Las Vegas Code Enforcement officers survey CDBG areas to identify

blight, and Community Services Department holds round tables and community technical

assistance workshops where providers and city staff members exchange feedback.

Moving forward, the city of Las Vegas Code Enforcement and Community Services

Department will collaborate to share information gathered from surveys to present at

roundtable events and community technical assistance workshops. In turn, the information

-0.5

0.5

1.5

2.5

3.5

4.5

521

3426

518

401

1300

2905

800

520

5808

3260

3415

1401

107

525

3211

1004

3413

527

3421

517

3102

514

2203

3104

526

103

516

2204

1402

3430

302

900

3420

108

Census Tract

Percentage of Individuals Born Outside of U.S.Ranked by 2012 highest to lowest percentages

2012 2015

gathered from roundtable events and workshops will also be shared with code enforcement in

an effort to increase and sustain code compliant properties.

Results Vegas The city has an outcome-oriented performance management system called Results

Vegas. The Planning Department’s Key Performance Indicator is to improve livability by

increasing the STAR Communities Livability Score. One of the supporting measures to help

achieve this goal is to decrease the number of blighted properties in CDBG areas by 50% from

the 2012 baseline by 2022. The proposed interventions included in this plan are intended to help

achieve this goal.

Randomized Control Trials Las Vegas is taking a proactive approach to increasing compliance with codes that focus

on dangerous buildings, housing, and nuisances in CDBG-eligible census tracts. In FY 2018, the

city is partnering with the Behavioral Insights Team as part of the What Works Cities initiative to

develop two randomized control trials to determine what message generates the best

compliance rate. This is a low-cost evaluation method that will use data to determine the most

effective way to increase code compliance.

The city currently sends postcards to inform property owners that they need to address

common violations, such as overgrown weeds, and then sends an inspector to determine which

properties are in compliance. This is a proactive approach to code enforcement that seeks to

increase compliance for a larger number of properties than could be addressed through

inspections driven by complaints.

The first trial will test the effectiveness of the language on the current city postcard vs a

new post card that contains language using behavioral insights concepts from psychology and

economics. CDBG-eligible census tracts with historically high rates of noncompliance will be

selected and approximately 1,200 addresses will be randomly assigned to the control group

(current postcard) or the treatment group (new postcard). The postcard will indicate that

property owners have two weeks to correct any violations. After two weeks, the city will send

inspectors to do a survey to determine compliance. Statistical analysis will be used to determine

http://www.behaviouralinsights.co.uk/behavioral-insights-team-north-america/

https://whatworkscities.bloomberg.org/

if there are any significant differences between the current and new postcard. Using a large

random sample will allow the city to be confident that the result is not due to other factors.

Once the most effective message has been identified, the city will do second randomized

control trial in another geographic area with historically high violation rates. In this trial, the

control group will feature the winning message from the first trial and the treatment group will

have this message in both English and Spanish. The same methodology will be used to determine

compliance and whether there is a significant difference in the treatment group.

Once the two trials have concluded, the city can use the most effective message for

postcards in the future, which has the potential to significantly increase code compliance in

CDBG-eligible areas.

Proactive Outreach Code Enforcement will be expanding focus and services to address allocated areas of

blight through various proactive measures. The Office of Community Services will collaborate in

these efforts to assist Code Enforcement in these actions. Stronger communication between

these two departments is needed when it comes to code enforcement violations in the

community. The City of Las Vegas understand that property values and the quality of life for our

residents are directly impacted by the performance of the City and its departments, and the City

plans on operating with a more aggressive, systematic and proactive approach.

The first proactive measure will be an increase of educational mailings and use of social

media to communicate with neighborhoods. Code Enforcement will use this to increase the

number of neighborhood clean ups, or sweeps in order to be more present and hands-on in the

communities that they serve. Additionally, there will be an increased use of post card

notifications (as seen with the randomized control trials) to homeowners about initial complaints

or to address blanket neighborhood issues. Through participatory and active community policing,

it will assist not only communities, but the City in determining where enforcement action is

needed.

Through completion the survey of all potential abandoned properties and categorizing

level of blighted conditions, the hope is to increase enforcement activities in these identified

areas with blighted neighborhoods.

cdbg code enforcement plan - las vegas · the city of las vegas code enforcement uses inspections...

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