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
301
3424
600
3413
1200
102
302
3417
1300
3411
2201
2203
105
503
104
3425
101
203
3102
103
3420
800
515
2204
3415
900
511
1100
700
201
1004
510
2905
204
504
3421N
um
ber
of
Blig
hte
d P
rop
erti
es
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
500
1000
1500
2000
10
1
10
8
10
6
10
7
52
6
13
00
12
00
34
29
22
03
51
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
51
5
52
2
52
4
52
8
34
11
58
08
32
13
Nu
mb
er o
f V
iola
tio
ns
Census Tract
Targeted Violations by Census Tract: 2013Ranked from highest to lowest Nuisance Violations
Dangerous Building Housing Code Nuisance Violations
Figure 5: Violations in CDBG Census Tracts 2013
Figure 6: Violations in CDBG Census Tracts 2013
0
500
1000
1500
20001
01
52
7
10
8
10
6
34
29
10
7
12
00
40
1
31
03
10
3
52
5
20
1
34
30
10
04
22
03
51
0
30
2
34
20
51
8
34
27
34
19
60
0
51
7
34
15
90
0
20
4
31
04
29
05
51
4
52
3
52
8
58
07
58
08
32
14
Nu
mb
er o
f V
iola
tio
ns
Census Tract
Targeted Violations by Census Tract: 2014Ranked from highest to lowest Nuisance Violations
Dangerous Building Housing Code Nuisance Violations
0
500
1000
1500
2000
10
1
14
02
13
00
52
1
52
6
52
7
10
9
12
00
22
03
10
7
40
2
10
5
52
0
20
1
30
2
34
31
51
8
11
00
10
3
51
0
52
3
20
4
34
20
52
4
34
11
60
0
22
04
34
26
34
13
51
4
29
05
32
61
58
08
32
14
Nu
mb
er o
f V
iola
tio
ns
Census Tract
Targeted Violations by Census Tract: 2015Ranked from highest to lowest Nuisance Violations
Dangerous Building Housing Code Nuisance Violations
Figure 7: Violations in CDBG Census Tracts 2013
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
-
500
1,000
1,500
2,0001
01
14
01
34
31
13
00
40
3
52
7
34
29
30
2
35
00
34
30
52
5
40
1
31
04
52
0
10
3
30
1
51
8
20
1
11
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34
19
20
4
31
03
34
21
51
7
52
3
32
61
34
13
51
6
51
5
90
0
70
0
58
07
58
08
Nu
mb
er o
f V
iola
tio
ns
Census Tract
Targeted Violations by Census Tract: 2016Ranked from highest to lowest Nuisance Violations
Dangerous Building Housing Code Nuisance Violations
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
0
10
20
30
40
50
60
523
402
600
403
800
521
203
301
3500
3429
401
1402
527
2203
516
2905
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
0
5
10
15
20
25
30
800
302
1100
522
401
524
3430
521
3431
519
3104
106
518
107
514
108
1402
204
3427
528
201
525
510
3415
1200
3411
105
101
517
2905
3102
515
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.
0
5
10
15
20
25
30
35
40
401
402
204
302
3214
527
3102
1004
900
518
1300
3429
106
800
3419
3431
514
517
515
700
522
3211
523
108
524
3413
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
.
0
5
10
15
20
25
30
35
40
3213
401
3211
301
204
2201
1200
403
3500
106
402
1401
302
1100
109
3427
1402
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
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.