CM Nurse questions HPD on COPA-eligible building universe and distress criteria changes
Nurse and Sanchez discuss the estimated 2,100 COPA-eligible buildings currently, the shift from one-per-unit violation threshold to a three-plus annual daily average, and why the higher threshold better targets physically distressed buildings at risk of speculation.
And just to talk a little bit about the building universe and scope, you know, thanks to a lot of feedback, we've really, really targeted this universe.
Using the criteria laid out in the current version of the bill, which includes existing HPD enforcement programs such as AEP, has HPD been able to do an estimate of how many sales would be COPA eligible a year on average?
Yeah, but I'm going to caveat that it is in fact an estimate.
Yeah, same.
So looking across base, the hardest piece of this obviously is just the rolling code violation.
Right, that standard will change constantly.
But looking at a moment in time right now, we've arrived at about 2,100 buildings today we think would be eligible under COPA.
And again, we think that number will continue to change primarily because buildings come in and out of our enforcement programs and violations get cleared or accrued.
So that rolling average causes the number to shift.
But I would argue right now about 2,100 buildings.
Right.
And even within that, we want buildings that might be COPA eligible, we want them to become ineligible, obviously.
So it would be great to...
To have a good off-ramp for this program as well.
The previous version of the bill would have included buildings that had an average of one or more B or C violations per unit at the time of sale.
This criteria, this distress criteria, has been amended to buildings that go on sale with a specific annual daily average.
From your point of view, can you explain why this change is important?
Yeah, I think generally speaking, the one per unit is a very low threshold.
It is, you know, we have a very complicated housing maintenance code.
It is very, very challenging to own a building and, you know, not have any code violations.
So I think the three plus violation count is more reflective of what the intent of the bill is, which is to really capture buildings that are in physical distress and being sold and at risk of, you know, being subject to speculation
where it is very critical.
a preservation purchaser is picking it up to ensure that the building is repaired.