Meth Contaminated Rental Shut Down

Methamphetamine contaminated rental

If the Bellingham City Council finally gets around to enacting a rental health and safety ordinance in 2014, they can add another item to the health and safety inspection checklist for all rentals in Bellingham...contamination with methamphetamine.

On 6 December the student newspaper, The Western Front, reported on a rental home occupied by several WWU students that had been contaminated with methamphetamine, presumably from actions of a previous renter.  You can read the Western Front article here. [Photo by Dick Conoboy at left]

The house is located at 618 E. Myrtle St near the WWU campus and is owned by a couple who live in Blaine according to the Whatcom County Assessor's site.  (Click here to view the property report.)  County records also reveal that the couple owns another home on Pine St. in Bellingham that is also a rental.  As indicated in the Western Front article the rental on E. Myrtle St. was managed by All County Property Management (sic).   According to the Western Front, the property has since been condemned for further occupation, a fact that I was able to confirm during a phone call with All County Properties owner, Bethany, on 9 December. Bethany also stated that the owners of the rental were not aware of the contamination issue.  As of 21 January, the house was still unfit for occupancy according to Jeff Hegedus of the Whatcom County Health Department. 

The property management firm, All County Properties (the actual name of the firm), also claimed ignorance of the contamination according to the tenants.  This I confirmed during my phone conversation with the management company's owner.  It is not altogether clear how the tenants learned of the contamination (there are competing stories), the fact is that it is the tenants who contacted the Health Department and paid for the testing.  It is good that they did so given that the house walls contained 13 times the legal limit of methamphetamine contamination. [As far as I am concerned, any contamination regardless of the level is unacceptable.] A basic test kit costs about $80 and can be used to test one or two areas.  Testing more surfaces or objects will require more test kits. This scenario reinforces my contention that landlords cannot be depended upon to discover or even act upon, on their own, dangerous defects in their own rentals.  

So, these unfortunate students then found themselves scrambling for lodging at the end of the fall quarter when they should have been reviewing and studying for final exams that week. The management firm's owner did tell me that she offered some alternative housing to the tenants but that they refused.  I have not been able to confirm this with the renters but they have all since relocated. 

According to the Western Front, one of the renters stated that "even though they have a good case against the property management, their lawyers don’t believe they have a strong enough case to get more than their rent back and compensation for personal damages." With an effective rental licensing and inspection ordinance, renters might avoid having to take landlords to court.  This state of affairs is the result of a toothless and ineffective Washington State landlord-tenant law which largely states that landlords and tenants alike have the right to duke it out in court - if you have the money.  Court is an expensive process as attorneys do not work on the cheap.   Therefore, not many renters, be they students or not, have the wherewithal for legal action.  That is the reason for which the city must step in by enacting a comprehensive ordinance to preclude dangerous rental units from being on the market in the first place.

Mayor's Rental Health and Safety Proposal Inadequate

On January 27th the Bellingham City Council again took up the issue of rental health and safety during a Committee of the Whole meeting.  The decision was made to hold, yet again, Planning Committee sessions on the topic as was done last year by committee chairman, Jack Weiss.  

[You can review the committee meeting of January 27th by going to the city website here and forwarding to counter number 127.20.  The discussion at the evening council session can be found here at counter number 108.14.]

Last year the discussion turned on the outline of a proposal developed by Jack Weiss and the Planning Committee (read more about that proposal here).   The Planning Committee voted then to take the discussion into 2014 and ask the mayor to place the issue on the work plan of the Planning Department.   In response, the Planning Director, Jeff Thomas produced a memo that presented the administration’s notion of a framework for rental registration.  You can read that memo here.   Unfortunately, it outlines an inadequate plan for ensuring the health and safety of the tens of thousands of tenants in Bellingham.

The memo speaks to a system of registration rather than licensing.  The city, it seems, does not want to get into the business of licensing rentals so it is proposing to merely register them.  As Council Member Lilliquist pointed out, mere registration may not allow the city to withdraw a landlord’s privilege to operate rentals.   Registration is not necessarily a license to operate.  This issue must be resolved to ensure the city has the capability to take action against landlords who do not meet standards by withdrawing some sort of authorization to rent.

The memo also speaks to a program that is “performance based”.  It is not altogether clear what that means.  Are we speaking of the city’s performance, the landlord’s performance, tenant performance?  And what is being measured?  

There is a stated “focus on public outreach and education”, which can be part of the program but the main focus ought to be on inspection of units.  More on that later.

Among the more troubling aspects of this memo is the watering down of the focus by “improving the current code program for all violations, not just rental related as these types of violations comprise les than 10% of the total.”   First of all, the focus must be on health and safety of tenants of dwelling units not commercial establishments where nobody actually lives.  If the city wants to launch a program for that aspect of code compliance, it can surely do so but it ought not be conflated with rental safety and health with its thousands of providers, that is landlords.  Second, the reference to the current complaint statistics is grossly misleading and tends to minimize the extent of the problem that tenants experience.  The 10% figure is based only on the last two years of the present complaint only system that is severely limited by the ability and the willingness of tenants to complain. Furthermore, one must ask “10% of what?” and that is missing in the memo.  I have asked the Planning Director, who authored the memo, to provide backup numbers for the complaint figures.  As of the writing of this blog entry, he has only referred me to the testimony of Mr. Tinner, one of the city’s code inspectors. Before the council’s Planning Committee on 22 April 2013  [you can watch his testimony here at 92.45 on the video counter] That testimony is as vague as the information provided in the memo and does not answer the question regarding the data that was used for the conclusions presented by Mr. Tinner. The city council would be wise not to base any decisions on rental health and safety on these meager statistics. 

There are many reasons for which a tenant does not complain, not the least of which is ignorance of an existing problem.  Tenants are not code inspectors and, for that matter, neither are landlords.  No amount of education by the city will provide enough information to either party to make a judgment about the condition of a rental property.   Asking a tenant to inspect a unit for safety violations prior to occupancy is nonsensical.  Some severe problems only become apparent after having lived in the unit for a period of time. Who among the tens of thousands of tenants in Bellingham can even begin to determine if housing has issues with wiring, structural integrity, fire safety, noxious gases, etc.  Tenants may also hesitate to report obvious issues for fear of retaliation by the landlord.  We hear this from student renters regularly.  Even the use of a “confidential” hotline is extremely problematic as any landlord with an ounce of savvy will know that his tenant has complained.

Among the “guiding principles” outlined in the memo is that of “least cost”.   The real and overriding guiding principle ought to be “tenant safety and health” upon which the program is built to ensure that the principle is upheld.   Similarly, the use of existing resources unnecessarily limits the program from the outset and is inconsistent with the city’s call for tenants to be more forthcoming with their complaints.   More complaints require more assets for response. Even now responses to code infractions regarding rentals are handled in an ad hoc manner with the problem not receiving attention for several days at which time an inspector can work it into his schedule.  The Planning Committee at one point asked how many inspectors there were at present, however, that question was sidestepped by the Planning Director and Mr. Tinner.     

Additionally, the call for inspecting a small sample (½ of 1%) of the city’s 17,000-18,000 rental units each year is completely inadequate, especially if the choice of units to inspect (supposedly at random) is based on the complaints received the previous year.   As I indicated earlier, the complaint based system (the one we have at present) has already proved to be grossly inadequate.   Why base a “new” program on a system that has already failed?   And what will the inspection of a mere 85-100 scattered units tell the city about the overall condition of the entire rental stock?  Such a paltry number is de facto unrepresentative and one cannot reliably extrapolate from that point.

Last is the Planning Director’s list of Next Steps, most of which are reasonable and applicable to almost any project.  The exception is the step that reads “The compilation of a list of third party, qualified inspectors.”   This flows from the city’s desire to operate a program of “rental inspections-lite” without adding inspectors who are city employees. True, the law allows landlords to choose to have inspections done by a state qualified private inspector.  However, the city does not have to rely on such private inspectors to flesh out its program.  I explained this in my blog entry of last July that you can access here.  

Last July I also wrote to the mayor and the city council about inspection of rentals.  The mayor did not respond but Jack Weiss did by saying to me and the mayor, “Dick's concerns about this approach [relying on private inspectors] are similar to mine.  I agree with all of his points.”  Here are the points I made to the mayor in the email to which Jack Weiss was referring:

“I gave some more thought to your position that the inspections of rentals ought be done by private inspectors at the expense of the landlords  who will still have to pay a fee to register their units.  If I am mischaracterizing your position as you formulated it to me …, please let me know. Here are my thoughts: 

1.  A problem with relying primarily on private inspectors for periodic inspections is that the city neither gains nor retains any institutional knowledge of the city’s rental units.  Paper reports from private inspectors are no substitutes for the experience of a city inspector whose employment is, for all intents and purposes, long term.  You and the Planning Director will have no group of Jim Tinners [a city code inspector] to whom you can go for experiential knowledge. 

2.  Yes, the use of private inspectors is allowed under law.  In fact, this was one of the challenges to the Pasco ordinance [in the late 90s], that city inspectors would be the sole inspectors.  As I understand, the landlords wanted the option to hire their own.  They have that option now and [that] is written into the state law passed a few years ago.  I am not sure how that serves the landlords since a properly structured program with a revenue neutral fee system (the program fees will pay for the program) will spread the cost of inspections over all landlords and result in much lower per inspection costs.  I think you and the city council are underestimating the capability of a small team of city inspectors over time.   Again, I bring up Pasco.  They have the institutional experience of these inspections that are based on an inspection checklist that we can easily adopt without re-inventing the wheel.  I am sure they also have cost data and performance data regarding the time necessary for an inspection of a unit.  If my memory serves me correctly, the Code Inspector in Pasco told me that one inspector could do 8-10 inspections per day.  For more info see my blog entry here.  If you have not already done so, you may want to read the study prepared by Mark Gardner in 2008 entitled  “Options for a Rental Housing Licensing and Quality Inspection Program in Bellingham”  [Click here to read that excellent 27 pg. study]

3.  Reliance primarily on private inspectors for the verification of our rental units is a de facto privatization of an inherently governmental function, that of health and safety. (Fire departments were once a private sector function and we know how that worked out.)  Such a reliance invites collusion between the inspector and the inspected while depriving all landlords of a well supervised and even-handed inspection regime whose inspectors are accountable as city employees.”

I would also add today that using private inspectors in lieu of several specialized city inspectors will virtually assure a variety of results that will be unfair to some rental owners and by default, their tenants. A city program provides consistency and fairness in the application of a list of critical health and safety standards.  It provides certainty for the rental industry.  In addition the city would not have to train, license, audit and/or supervise this wide collection of private inspectors, presumably, at city expense.

Jack Weiss continued in his reply to my email to the mayor:  “The proposal brought to Council in 2011 was not made in a vacuum.  It was the result of three years of work at the Council and staff levels, paying attention to the comments received of a low cost program that targets, in a fair and effective way, critical violations in health and safety while registering all qualified rentals.  I used my own career experience in the rental industry to feel that this approach was correctly measured and appropriate.”  

Unfortunately, the memorandum from Jeff Thomas to the mayor outlining the administration's proposal on rental health and safety misses the mark by a wide margin.  The council needs to be much more demanding to ensure a rental health and safety program in Bellingham will result in a rental stock in good condition through regularly scheduled inspections by city employee inspectors.

Four Years of Western Front Editorials and Still No Action on Rental Health and Safety

For the fourth year in a row, the editorial board of the student run newspaper, the Western Front, has called on the city government to ensure the safety and health of the renters in Bellingham.  You can read about the three previous editorials by clicking here, here and here.

The most recent editorial is dated 5 Nov and entitled "In Support of the Tenant Rights Advocacy Proposal".   (Click here to read that piece.) The editorial states in part, "This proposal targets the Bellingham City Council and mayor, who have failed to pass any ordinances regarding licensing and inspection, increasing renter safety while staying consistent with state law. Bellingham, Wash., tenants continue to be subject to the state’s Residential Landlord-Tenant Act of 1973."

Unfortunately, there is as yet no concrete proposal.  In an email exchange with Western student Theo Bikel, who is working on the proposal, I learned that we are likely to see the document early next week (25 Nov).   We do know from the editorial that the students are seeking redress not only for poor rental conditions that are a danger to health and safety but also for redress for mistreatment by landlords over such issues as un-returned security deposits, un-reimbursed repairs and overall unresponsiveness.   The former problems come under the toothless Residential Landlord-Tenant Act which gives the tenant a right to legal avenues that are, to a great extent, mostly unworkable and unaffordable.  For the past 50 years or more the landlords have had the upper hand.  It is time to establish a just equity.

Western Students Talk of Dangers in Renting in Bellingham

Students are gearing up yet again this year in an attempt to get the City Council to listen and act on their complaints of mistreatment by landlords and of unsafe and unhealthy living conditions in rentals throughout the city.  On election eve, 5 October, students met to discuss the dangers of renting in Bellingham.  An account of their meeting was published in the student newspaper, the Western Front.  You can read that article by clicking here.

The departure of Stan Snapp and Seth Fleetwood from the council eliminates two voices that have consistently worked to slow down or stop an ordinance to license and inspect rentals in Bellingham.  The apparent election victory of Pinky Vargas and Roxanne Murphy will change that dynamic, however, it remains to be seen by how much.  Pinky's grasp of the issue is thin and Roxanne is operating with experience of a flawed rental licensing ordinance in Tacoma, WA.   You can read my assessment of their thoughts on rental inspections on NWCitizen by clicking here. 

The issue will come before the "new"  council again in 2014.  The proposal brought forth by Jack Weiss should be re-introduced but given a healthy dose of scrutiny.  The Mayor, who has been talking about a proposal during 2013, should bring that forward formally, too.  To date we have few specifics from her.  You can read about what we do know about both in my blog entry of 29 July entitled Rental Health and Safety Pushed into 2014.  Click here to read that entry.

The need for action is stunningly obvious to the student renters (10,000+/-).  The Mayor and the City Council should heed their voices.

Dick’s Picks for City Council - Burr and Petree

[ Note: This is a copy of a column that I wrote for the NWCitizen that appeared on 28 Oct 2013.  You can also view that column by clicking here.]

Since the primary election, I have been speaking to candidates, reading their positions as reported in local media and watching the debates. Of all the candidates, only Roxanne Murphy has not responded to my emails asking for a meeting. I have met with Clayton Petree on two occasions, once with Bob Burr and once with Pinky Vargas.   

At-Large Seat

As for Roxanne, I am flabbergasted that a candidate for an at-large position on the Bellingham City Council, which essentially represents all wards, would not even respond to a prospective constituent’s email. All I know about her is from some statements published in various media, and her performance during the League of Women Voters debate. I am not a single issue voter, but some topics are of greater interest to me and I regard these subjects, to some extent, as bellwethers to gauge a candidate's thought processes and the use, or lack of, factual data. From what I have been able to determine, her opinion on rental health and safety has been muddled by an experience in Tacoma, a city with a badly flawed ordinance that is no more effective, and a lot more cumbersome, than what we currently have here in Bellingham. You can read my exchange with Riley Sweeney in the comment section of his blog entry on candidates by clicking here. When asked for a statement on issues for the Voters’ Pamphlet distributed by the Whatcom Couny Auditor, Roxanne wasted valuable space listing the people and organizations that have endorsed her. Endorsements are not ideas.  Endorsements are not policy concepts.  Endorsements are not positions on issues. Endorsements proffered by a candidate are nothing more than statements of obligations to groups or individuals.

By contrast, Bob Burr is long time resident of Bellingham whose learning curve on the problems facing Bellingham is not an issue. This is a man who put himself on the (rail) line for a cause (anti-coal) and was arrested during that protest. He is still facing legal action. This alone should qualify him for a council seat! Bob is a progressive thinker who will bring a badly-needed fresh presence to the council. He takes no money and therefore creates no obligations. Having been here for almost two decades he is very well informed about rental safety and health, supporting the registration and inspection of all rental units through a revenue neutral fee system that will not affect the city's general fund one whit. Bob’s statement in the Voters’ Pamphlet is about ideas and approaches to problems. It is about specific stances on issues and not at all like Roxanne’s generalized statements about endorsements and believing in Bellingham, whatever that means.

Ward 4

Pinky Vargas should have waited a few more years before running for City Council. She is lively and engaging but that is not the stuff of policy and speaks little to knowledge about issues. I enjoyed speaking with her and she listened intently. The problem is that running for office is about having knowledge and positions on issues before becoming a candidate. All candidates learn while seeking office, but running for office is not a process during which one begins to cobble together ideas for a coherent campaign. Her response to me on rental health and safety was tardy, as she evidently had no position when she began her campaign. When I did get a response, it was a mish-mash of incomplete and fuzzy thoughts that she had already provided in written form to the Bellingham Herald. You can read her comments by clicking here. It looks like a statement written by a committee. She mixes in talk of affordable housing. She "wonders" if we can have an inspection program without dipping into the general fund even though I told her that a $2 per month per unit fee would bring in over $400,000. The funding of registering and inspecting rentals would be revenue neutral. If $2 is not enough, make it $2.50. The fact that $1.5 million of our general fund goes to the museum department each year might be something for Pinky to examine, but I am not hearing anything about that.

I have met and spoken with Clayton Petree before his candidacy and twice since he began his run for City Council. We certainly do not agree on everything, but Clayton has a command of facts about the issues facing Bellingham that far surpasses Pinky’s knowledge. Clayton can hit the ground running. My friend Pat McKee of the Sunnyland neighborhood recently wrote to his neighbors, “Clayton Petree is an independent thinker, with good analytical skills. Clayton's viewpoint and talent are needed on the City Council.” I agree. When I spoke to Clayton about rental licensing, he was not an enthusiastic proponent, however, after a long conversation he came back to me in an email saying he could support the concept of licensing and inspection of rentals. This is a candidate who listens and processes facts. I can work with that.

I will not automatically support party favorites. I want some clear thinking and innovative voices on the City Council. Bob Burr and Clayton Petree are my picks to turn the council into an effective and forward-looking legislative body. 

Community Forum on Recent Riot, Parties and Rental Safety

The Sehome Neighborhood is hosting a community forum on Monday, 21 October at 6:30 pm (WECU Education Center) to discuss the recent riot, skills for keeping parties safe and greater accountability for health and safety in rentals.  See the announcement here.

You also may wish to read my article in NWCitizen on the recent riot and the implications with respect to the proposal to create a private dormitory for nearly 600 students in the Puget Neighborhood, called University Ridge. Click here to read that article.

Rental Health and Safety Pushed into 2014

By a vote of 6-0 (with Council Member Fleetwood absent) the Bellingham City Council agreed on June 17th to place the issue of rental licensing and inspections for discussion at the 2014 budget priority planning session. Largely because the City Council failed to place rental health and safety as a budget priority at its planning session for 2013, the Mayor was able to claim that the city did not have funds to start up any new program during the 2013 fiscal year without identifying offset funds from another program. Fiscally speaking, the Mayor is correct. She has to work with the budget that the Council approves. That being said, safety and health is an urgent consideration and such issues should not be delayed.  Click here to see the minutes of that council meeting. 

Above left you will find a copy of the motion that was passed asking the mayor to allocate resources to a health and safety program for rentals in the 2014 budget. I have argued previously to the council and the mayor that if we can afford $1.5 million per year to fund a museum department, we can find sufficient monies for start-up costs for a licensing and inspection program. After that, the program can easily be self-supporting from registration fees collected yearly from landlords. A mere $2 per month charge per rental unit, less than your simple latte at a downtown coffee shop, will bring in over $400,000 per year to run effective licensing and inspection of all of the city's 17,000 rental units. This will ensure long-term viability at an manifestly low cost.

That being said, there are several aspects of the council's proposal that I find troubling. Under section II "Outcomes or options to be included or considered" is (number 7) "Consider a self-certification option as part of any inspection program".  This option sounds reasonable until examined more closely. Such an option would require that a landlord sign and submit a certification that his/her rental units are in acceptable condition given a list of areas to be inspected, such as the electrical system, structural integrity, etc. I am not a landlord but even I would be very hesitant about signing such a document unless I had the advice of an expert who has already examined the rental unit. To do otherwise is to invite disaster in the way of a lawsuit should an accident happen in an area declared (by oneself as landlord) acceptable. No landlord, unless he/she happens to be a certified home inspector, has the knowledge to self-certify. So this "option" of self-certification effectively forces landlords to have their units inspected by a professional - and at their own expense. This defeats the purpose of an inspection program run by city inspectors which is provided for all landlords who pay low and reasonable fees to a common program.

Another problem with relying primarily on private inspectors for periodic inspections is that the city neither gains nor retains any institutional knowledge of the city’s rental units. Paper reports from private inspectors are no substitute for the experience of a city inspector whose employment is, for all intents and purposes, long term. The Mayor and the Planning Director will have no group of in-house code enforcement officers to whom they can go for experiential knowledge.

The use of private inspectors is allowed under law. In fact, this was one of the challenges to the Pasco licensing ordinance, that city inspectors would be the sole inspectors. The landlords there wanted the option to hire their own. They have that option now and is written into the state law passed a few years ago. I am not sure how that serves the landlords since, as I mentioned above, a properly structured program with a revenue neutral fee system (the program fees will pay for the program) will spread the cost of inspections over all landlords and result in much lower per inspection costs. The Mayor and the city council are underestimating the capability of a small team of city inspectors over time. Again, I bring up Pasco, a a city that has the institutional experience of these inspections that are based on an inspection checklist easily adoptable without re-inventing the wheel. We should also explore their cost data and performance data regarding the time necessary for an inspection of a unit. The Code Inspector in Pasco told me that one inspector could do 8-10 inspections per day.

Reliance primarily on private inspectors for the verification of our rental units is a de facto privatization of an inherently governmental function, that of health and safety. (Fire departments were once a private sector function and we know how that worked out.) Such a reliance invites collusion between the inspector and the inspected while depriving all landlords of a well supervised and even-handed inspection regime whose inspectors are accountable as city employees.   I have made these concerns available in an email to the Mayor who had expressed to me her desire to have an licensing ordinance that relies primarily on private, certified inspectors.  She has not, as yet, responded to my comments.

Item 8 Under section II "Outcomes or options to be included or considered" also gives me pause. It reads "Consider inspection of sample units as an 'audit' function". Although this may sound reasonable, this should not be an option at the outset of any safety and health program. An audit option may be adequate after an inspection program of all units has been operating for some time, however, Bellingham's rental stock HAS NEVER BEEN INSPECTED. This means that the likelihood of violations in thousands of units is very high. In fact, the two surveys run by Western Washington Students have demonstrated that very situation. (See these reports here and here). Audits will not do the job up front.

With respect to part III "Guidelines for Creating a Least-Cost Program" there appears to be some hidden agenda items in the several guidelines enumerated.   Here are my thoughts (in italics) following each of the numbered items:

1. Keep fees as low as possible to ensure that a program does not unduly impact the rental market.    The fee, although not having been set yet, has widely been spoken about as being about $2 per month per rental unit.  This cannot, in any sense, be construed as being "unduly" impactful.  Even a $3 per month/unit fee is not going to break the bank. So to what does this "guideline" refer?  The intent is unclear.  

There are already impacts on the rental market every year as landlords raise their rates if for no reason other than they can do so.  After all, the market here is tight (low vacancy) and renters have little bargaining margin, if any at all.   [Perhaps the city council might want to take up that issue at a later date.]  Absent a declaration from the council, one might imagine this guideline would have to do with the cost of repairs to units in order for them to be habitable.  The rental industry has placed fear in the hearts of some council members that these inspections might occasion prohibitively expensive repairs in order for the units to be safe and healthy.  An odd position in that landlords already claim that there are only a few bad apples.  Also odd in that nobody is claiming that the council wants to use the International Building Code book in its entirety to seek out unconforming bannister or window heights and mandate expensive remodeling.  Council Planning Committee head, Jack Weiss, has stated this during several work sessions of the committee.

2. Consider a minimum three-year program with sufficient data collection mechanisms to provide information to Council for a program extension, if necessary.   There is no reason to take the time and effort to register and license rental properties for a three-year program that has to be re-authorized by a future council - even if it proves successful.  If we are to establish a rental health and safety program it should be permanent since rentals come and go as landlords come and go.  Constant surveillance is necessary.  The health department does not inspect a restaurant kitchen once and then abandon all further efforts to ensure the owner adheres to regulations.  In my conversations with the rental code enforcement officer in Pasco, he indicated that after the initial inspection of all the city's rental units, the inspector returned to previously inspected units after 2 years and found that some units had already begun to deteriorate. 

3. Focus attention on properties with violations to reduce burdens on other owners.  This guideline is totally inexplicable as I have said time and again in this blog.  Nobody has ever satisfactorily articulated how this methodology will play out.  The presumption is that the "bad apple" landlords will somehow be "outed" and that then the city can then "focus attention" on them.  With thousands of single family home rentals and small apartment buildings, there is no mechanism I can imagine that will magically expose the bad ones except an inspection of each unit.  Anything else relies on spot checks (that will miss dangerous units), complaint driven programs (the city's current ineffective ordinance) or self-certification (a poor method as I explained above).  

And just what are these "burdens" that will be place on the "other owners"?  That once every three years at the most they must open their units for inspection to ensure the health and safety of the tenants?  That they may have to actually spend money on repairs to protect those who are paying them money to live in a rental unit? That they have to renew a license each year?

4. Emphasize a program educational approach that helps prevent health and safety violations from occurring through encouraging proper and frequent owner self-inspection and maintenance. The emphasis ought to be on an inspection program that is supplemented by an educational element. The difficulty with any such education program, a poor substitute for code enforcement entering the property, is reaching the target audience. The landlords can be contacted through their professional organizations such as the Whatcom Realtors or the Northwest Rental Owners Association. There are no such groups available to reach tenants who are a very diverse population. Student renters can be reached through the various educational institutions and through student government bodies but even this presents a challenge in that every 3-4 years there is an entirely new cohort of thousands of young student renters as they pass through the university/college system.

There is still much in the way of discussion to be had on an effective program to license and inspect our rentals for the health and safety of the tenants.  This discussion should be an active part of the coming elections for city council.