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Q&A

Chair Hudson questions DHS on high violation rates in flexible shelters

New York City Council · Oct 28, 2026 · starts 1:25:20 · 2 min 29 sec

Hudson cites 3.82 violations per standard shelter and 37.56 per flexible shelter. Dalton says hotels are non-residential buildings and applying residential code inflates violations; Fellini says not every violation is an active hazard.

Crystal Hudson

The most recent shelter repair scorecard showed an average of 3.82 building violations per standard shelter and 37.56 violations per flexible capacity shelter.

Crystal Hudson

And you mentioned, I think, earlier that the flexible shelter conditions are challenging.

Crystal Hudson

Why is the number of violations in flexible shelters so high?

Crystal Hudson

And is DSS taking action to correct the issue?

Erin Dalton

Yes, thank you.

Erin Dalton

And as I read my testimony aloud, I was reflecting on what I've learned since preparing the testimony.

Erin Dalton

And so it is a good opportunity to correct the record a little bit on that.

Erin Dalton

And I'm going to let the deputy commissioner go into more detail.

Erin Dalton

But it isn't–

Erin Dalton

Clearly, there's a differentiation between the mostly commercial hotels and the level of violation and our purpose-built and other shelters that have very low.

Erin Dalton

But it is also a function of the way hotels were built and applying a residential code onto those non-residential buildings.

Erin Dalton

And so I don't want to give anyone here the impression that it is actually that much worse.

Erin Dalton

There's a technicality to that, nor that we can't fix it.

Erin Dalton

So I think the data.

Erin Dalton

in this case, require some nuance, and I'd love to pass it to the Deputy Commissioner to provide that.

Christine Clarke

Thank you, Commissioner.

Christine Clarke

And I think distinguishing between flexible capacity or standard capacity, regardless of the type of capacity, it's DHS's responsibility to work with the provider to make sure that those locations are safe for all the clients we serve.

Christine Clarke

To the Commissioner's point about the hotels having different types of code versus the HPD inspection, that is done for our shelters that follow a residential.

Christine Clarke

Code, the same does not apply at hotels.

Christine Clarke

So we're applying a residential code to a hotel that doesn't follow the same code.

Christine Clarke

However, we are still responsible for making sure that those issues are resolved and that the locations are safe.

Christine Clarke

Also on violations, as we dig in, not every violation is an active safety hazard.

Christine Clarke

The hazard could have been remediated, but there may still be an administrative function that the building owner has not submitted the required paperwork to HPD to close that out off the website.

Christine Clarke

That is something else that we track as well.