Testimony by Kamilla Sjödin, Associate Director, before the New York City Council, Committee on Housing and Buildings: 

Int. No. 222, A Local Law to amend the administrative code of the city of New York in relation to amending the obligations of owners to provide notice to their tenants for non-emergency repairs.

Int. No. 289, A Local Law to amend the administrative code of the city of New York in relation to the provision of housing applications in multiple languages by the department of housing preservation and development.

Int. No. 433, A Local Law to amend the administrative code of the city of New York in relation to the installation of safety covers on electrical outlets in public areas of multiple dwellings.

October 29, 2014

Chair Jumaane D. Williams, Council Members, and staff, good morning and thank you for the opportunity to speak about Introductions Number 222, 289, and 433. My name is Kamilla Sjödin1 and I am an Associate Director at the New York Legal Assistance Group, a nonprofit law office dedicated to providing free legal services in civil law matters to low-income New Yorkers. NYLAG serves immigrants, seniors, the homebound, families facing foreclosure, renters facing eviction, low-income consumers, those in need of government assistance, children in need of special education, domestic violence victims, persons with disabilities, patients with chronic illness or disease, low-wage workers, low-income members of the LGBT community, Holocaust survivors, as well as others in need of free legal services.

We are testifying today in support of all three bills and applaud the Council for taking measures that ensure notice to tenants, take into account the diversity of this City, and address safety concerns, respectively.

Int. No. 222 would require landlords to provide tenants with at least 72 hours’ notice prior to commencing non-emergency repair work that would cause an interruption in services. Placing the notice in a prominent place, as well as under the door of each apartment, should suffice to ensure that tenants receive the information. We would also encourage buildings that have a website or the ability to reach tenants via email to post on their website and send out an email in addition to, but never instead of, the paper requirement. The work announcement should be in paper writing because some tenants, particularly the elderly, do not have access to email or cannot communicate via phone. Written notice creates a paper trail that could prevent harassment and/or frivolous nuisance claims. At NYLAG, we recently had a case where the landlord alleged that he requested access to the apartment but where our client was not able to provide it due to short notice and existing medical appointments. Our client now faces a holdover eviction from his rent controlled apartment of 40 years but there is no proof that landlord requested access on the dates alleged.

We would also encourage notice of certain work to be given with even more time, especially for work that will cause a long interruption. For example, requiring 72 hours’ notice before shutting off a building’s water for six hours may make sense, whereas giving 72 hours’ notice of elevator repair work that will take six weeks may not. Each time there is a service interruption tenants have to make arrangements that can include anything from getting groceries ahead of time to finding alternate childcare. The more onerous the interruption, the more difficult the adjustments for tenants. Notice gives elderly and disabled clients an opportunity to plan around the work or to propose alternative dates. Oftentimes, tenants need to make arrangements with family, friends, and social workers to assist with moving furniture or even temporary relocation for repairs to be done. Additionally, the law should require specifics about the repairs being done to the apartment; otherwise tenants face harassment in the form of never-ending repairs. Specifics about the repairs should include the work being done, which violations the work addresses (if any), the proposed date(s) or work, and the duration and completion dates of the work.

To encourage environmental friendliness, we recommend that the notices be printed on half pages, or 4 ¼ by 5 ½ inches. We also suggest that the notice be written in the neighborhood’s most common second language on the back, so that non-English language speakers are also adequately warned of pending work.

Int. No. 289 would require applications at HPD to be provided in additional languages. This requirement is crucial to ensure that all New Yorkers have equal access to opportunities afforded by HPD. Language barriers greatly disadvantage those who do not speak, read or write English and taking this into account is a significant step in equalizing our society. We encourage all agencies to be required to provide all information in multiple languages and commend the Council for requiring it in this context. We also encourage the City to mandate that this and other information be available online.

Finally, Int. No. 433-A would require that certain electrical outlets have safety covers in public areas. If such a measure would ensure that humans and animals have a safer environment, we support the passage of this bill. Assuming exposed outlets pose a real danger, we dorequest that it be considered a C violation, as opposed to a B violation, particularly as outlet covers are a fairly cost effective way of keeping everyone safe.

We welcome the opportunity to further discuss or comment on these matters in the future. Thank you for the opportunity to testify today.

Respectfully submitted,
Kamilla Sjödin, Associate Director, Housing Law, NYLAG

1 For full disclosure, I am a former counsel to the New York City Council Committee on Housing and Buildings and the, at that time, Subcommittee on Public Housing.