Report presented to Mayor and Board of Alderman in Frederick, MD

1. OVERVIEW
The City of Frederick has for many years sought to address public concerns associated
with overcrowding in rental properties across the city. An analysis of Code Enforcement
(CE) and Maryland Department of Assessments & Taxation (SDAT) data shows that
nearly three-fourths (74.43%) of all cases associated with overcrowding involve owner
occupied homes. 25.57% involve non-owner occupied, or rental, properties.
Additional Code Enforcement data indicates there have been 262 violations associated
with overcrowding since 20071
. Just over half of which (50.8%) have occurred inside the
area known as Neighborhood Advisory Council, or NAC, 8. Year-over-year totals find
that cases designated as overcrowding increased 38% from 2008-09 when 80 cases were
filed with CE. In 2010, cases are on track to meet or fall slightly lower than 2009 totals.
These findings affirm general speculations that NAC 8 contains the majority of
overcrowding cases and that the distribution of rental cases versus owner occupied cases,
tips heavily towards owner occupied properties.
Looking beyond the slice of code violations associated with overcrowding, however,
many public and private stakeholders question the current state of Frederick’s rental
housing market. This report seeks to answer, or at least provide clarity, on such questions.
Other findings include:
• According to State tax data, non-owner occupied (rental) properties account for
15.5% of the total properties in the City of Frederick. Meanwhile, Census data
suggests over 41% of housing units in the City are rental
• Rental properties account for 42% of PMC violations in the City of Frederick,
since 2007
• Of the nearly 6,600 cases of trash, weeds and abandoned vehicles2
reported across
all properties in the City of Frederick, more than 2,000 of these cases (30.44%)
occur on rental properties
• NACs 5, 8 and 11 show the highest percentage of rental PMC and CC violations
• The average PMC case involving rental properties takes Code Enforcement fifty-
six (56) days to close
• Data suggests nearly 70% more time is spent on enforcing “internal” PMC codes
than external PMC codes
• Approximately $11,000 has been collected in municipal citations for CC and
PMC violations since 2007
ABOUT THIS REPORT
Maps and datasets were compiled using Code Enforcement data, Navaline; City of
Frederick Geographic Information System (GIS) shape files and data; and Maryland State
Department of Assessments & Taxation data. Information compilation and analysis uses
data spanning from 2007 through approximately June 2010. Methodologies on map
overlays and property matching are described at the end of this report.
1
PMC 018, 019, 030 and 034 were identified by code officials as being associated with overcrowding cases
2
These represent City Codes 001, 002 and 003; “CC violations” or “CC NOVs” referenced later in this
report also refer only to these 3 codes
City of Frederick, Office of the Mayor Rental Housing Market | 1

2. AUTHOR’S NOTE
One of the key goals of this report was to turn stories into numbers and pictures into
information. While the data, charts, maps and graphs attempt to understand the various
components and conditions in Frederick’s rental housing market, it is important to note
that these findings represent a small glimpse of the true, but unknown, reality of housing
in the City.
At 60,000+ residents, the City of Frederick has a multifaceted housing ecosystem of
single-family homes, urban renters, townhomes, condominiums, apartment complexes,
public housing, long-term hotel guests, and so on. It also has a number of vacant
properties, squatter homes, foreclosures, and newly-converted rental homes waiting to be
sold as single-family homes.
Along with help from Code Enforcement, GIS and others, I worked hard to ensure
accuracy and completeness. This is a data-heavy document and the fine edges may not
line up exactly. I have no doubt that differing conclusions will be drawn from these
findings. And, in part, that is the point to embarking on these kinds of projects – to get
the conversation going. There is a tremendous amount of information contained within
this report, most of which could easily turn into another, separate examination entirely.
But be assured this report was constructed with the intentions of providing a
representative picture of a complicated subject.
Just as important as the information conveyed in maps, charts, tables and graphs, is the
information not being captured through current processes and current policies. Frederick
Police Department data, population demographic information, Land Management Code
violations and over thirty categories of City Code violations were purposely omitted in
order to convey a simple, yet indicative picture of Frederick’s housing ecosystem. But
there can be little doubt that more remains to be found when examining this issue.
City of Frederick, Office of the Mayor Rental Housing Market | 2

3. Part One: External Violations
According to Code Enforcement, their mission is to minimize threats to the health, safety
and welfare of Frederick City residents posed by deficiencies in property maintenance.
They are worried about neighborhood-level issues and issues that if left unresolved could
spill into areas beyond the physical boundaries of the property.
Code Enforcement follows a set of codes that speak to many aspects of health and safety
within residential and commercial structures. Chief among them, for the purposes of this
report, are City Codes 001, 002 and 003; and the nearly thirty Property Maintenance
Codes regularly cited by Code Enforcement – although particular attention should be paid
to PMC 001, 009, 013 and 019. Together these codes represent a wide array of violation
types and potential threats to human welfare.
When assessing how to begin to understand the relationship between Code Enforcement
and the City’s housing market, I started with the most common violations – external
violations.
External violations vary according to location within the City. But according to the
Department balance sheet and staff accounts, trash and weeds make up the bulk of what
Code Enforcement sees citywide. Records indicate that 6,596 violations have occurred
since 2007 involving trash, weeds, and abandoned vehicles.
Filth, Rubbish, Weeds & Abandoned
Vehicle Violations 2007 -2010
City of Frederick, Office of the Mayor Rental Housing Market | 3
Table 1
NAC NOVs Percent
1 178 2.7%
2 0 0.0%
3 891 13.5%
4 91 1.4%
5 1197 18.1%
6 306 4.6%
7 427 6.5%
8 1491 22.6%
9 236 3.6%
10 778 11.8%
11 781 11.8%
12 220 3.3%
Total 6596 100.0%

4. Filth, Rubbish, Weeds and Abandoned
Vehicle NOVs by NAC
0
200
400
600
800
1000
1200
1400
1600
1 2 3 4 5 6 7 8 9 10 11 12
NAC
NumberofNOVs
NOVs
n=6596
Figure 1
As indicated by Table 1 and corresponding Figure 1, City Code violations 001, 002 and
003 are concentrated in NACs 8, 5 and 3; although all areas (save for Ft. Dietrich in NAC
2) have received at least 90 notices in the last two-and-a-half years. And the middle
fourth of the distribution (2nd
Quartile) is over 100 violations per year at 366 violations
since 2007.
Geographically represented across a map of the City of Frederick (page 5), one gets a
better sense of how widespread these kinds of violations are. What remains unknown,
just by looking at these numbers, is how many correspond to rental properties. For that,
we must interject a new data component – tax IDs.
City of Frederick, Office of the Mayor Rental Housing Market | 4

5. City of Frederick, Office of the Mayor Rental Housing Market | 5

6. (Map 1: Filth, Rubbish, Weeds & Abandoned Vehicle Violations, 2007-2010)
Part One Continued: Rental Property Component
To understand which of the thousands of points represented on Map 1 are rental
properties and which ones are owner occupied, Maryland Department of Assessments &
Taxation (SDAT) data had to be joined with CE data. By introducing tax IDs and
associated assessment information, we were able to determine which properties were
designated as residential, commercial, and industrial. The same data allowed us to drill
down further to understand which residential properties were owner occupied, ‘H’, and
which ones were non-owner occupied, ‘N’, also known as, rental properties.3
When parsing the CC violations for just those residential properties that are not owner
occupied, we find 2,008 notices of violation have been issued since 2007.
Filth, Rubbish, Weeds & Abandoned
Vehicle Violations 2007 -2010
(Residential, Non-owner Occupied)
NAC NOVs Percent
1 45 2.2%
2 0 0.0%
3 218 10.9%
4 11 0.5%
5 357 17.8%
6 142 7.1%
7 122 6.1%
8 351 17.5%
9 79 3.9%
10 229 11.4%
3
‘H’ and ‘N’ designations correspond to codes in the dataset used to compile this information. The dataset
will be made available upon request
City of Frederick, Office of the Mayor Rental Housing Market | 6
Table 2

7. 11 383 19.1%
12 71 3.5%
Total: 2008 100.0%
Filth, Rubbish, Weeds & Abandoned
Vehicle NOVs by NAC 2007-2010
(Residential, Non-owner Occupied)
0
50
100
150
200
250
300
350
400
450
1 2 3 4 5 6 7 8 9 10 11 12
NAC
NumberofNOVs
NOVs
n=2008
Figure 2
The distribution of CC NOVs across rental properties in the City of Frederick seems to
mirror the citywide distribution (which includes owner occupied properties), except for
one striking difference: NAC 114
. When isolating rental properties, NAC 11 ranks first in
percentage of CC violations (19.1%); it ranked 5th
in the citywide distribution (11.8%).
This, again, affirms the notion that NAC 11, which represents a large section of Market
and Patrick Streets, has a high concentration of rental properties. In just under three
years, NAC 11 rental properties received nearly one-fifth (383) of all rental CC
violations.
4
In the course of cleansing state and local data, a limited number of fields were lost that would, in all
likelihood, add more CC NOVs to NAC 11. Estimates suggest that number could bring NAC 11 totals to up
near 400 cases since 2007.
City of Frederick, Office of the Mayor Rental Housing Market | 7

8. To get a sense of how similar the citywide and rental-only distributions look
geographically, refer to Map 2 on the next page. The rental component of CC violations
is certainly a less-dense version of the citywide Map 1. But there are few parts of the city
untouched by this, perhaps the most visible, of City Codes.
City of Frederick, Office of the Mayor Rental Housing Market | 8

9. (Map 2: Filth, Rubbish, Weeds & Abandoned Vehicle Violations, 2007-2010, Residential, Non-owner Occupied)
Part Two: Internal Violations & Rental Properties
To understand what fraction of code enforcement is concerned with internal violations
versus external violations, all one must do is look at sections of the City Code dealing
with Property Maintenance. The vast majority of sections deal with light, ventilation,
occupancy, plumbing, electrical and fire safety requirements – which are mainly concerns
within a structure’s interior. Still, there are two kinds of Property Maintenance Codes
(PMCs): externally and internally oriented. An example of an externally oriented PMC
code would be Roof and Drainage or Exterior Walls. By contrast, internally oriented
PMC codes include Infestation, Ventilation and Means of Egress.
According to data provided by Code Enforcement, 1,023 PMC violations have been
issued since 2007. Rental properties account for 42.1% of those violations (431).
PMC violations can be for any of the thirty-seven code descriptions found in this report’s
Appendix B. But CE data suggest only twenty-seven of the thirty-eight code categories
are used. For the purposes of this report, all twenty-seven categories of violations cited
by CE since 2007 were examined.
Breakdown of PMC Cases by Category,
Occurring on Rental Property
City of Frederick, Office of the Mayor Rental Housing Market | 9

10. PMC Cases by Code Category
0 20 40 60 80 100
IPMC 001
IPMC 002
IPMC 004
IPMC 005
IPMC 006
IPMC 007
IPMC 008
IPMC 009
IPMC 010
IPMC 011
IPMC 013
IPMC 015
IPMC 018
IPMC 019
IPMC 020
IPMC 021
IPMC 022
IPMC 023
IPMC 024
IPMC 025
IPMC 026
IPMC 029
IPMC 030
IPMC 034
IPMC 035
IPMC 036
IPMC 037
PMCCode
Number of Violations
Total Cases n=431
Figure 3
Notable codes by number of cases include, Exterior (IPMC001), Interior (General)
(IPMC009), Overcrowding (IPMC019) and Roof and Drainage (IPMC005). These four
categories are responsible for 58% of all PMC violations cited against rental
properties.
Processing Time of Rental PMC Cases by
Category
Table 3
Violation
Code
Description Total
Cases
Mean
Days
Median
Days
IPMC 001 Exterior 94 144 97
IPMC 002 Premise Identification 8 10 7
IPMC 004 Exterior Walls 8 123 53
IPMC 005 Roof and Drainage 55 43 29
IPMC 006 Porches, Stairways and Decks 2 45 45
IPMC 007 Windows, Skylights and Doors 16 44 49
IPMC 008 Insect screens 2 82 82
IPMC 009 Interior (general) 75 56 35
IPMC 010 Handrails and Guardrails 5 57 42
IPMC 011 Rubbish and Garbage (INT & EXT) 4 10 8
IPMC 013 Infestation (Extermination) 41 48 34
IPMC 015 Ventilation 1 221 221
IPMC 018 Occupancy Lim. (bedroom) 9 42 27
City of Frederick, Office of the Mayor Rental Housing Market | 10

11. IPMC 019 Overcrowding 59 104 69
IPMC 020 Plumbing 10 13 7
IPMC 021 Storm Drainage 5 148 45
IPMC 022 Electrical Facilities 11 109 40
IPMC 023 Elevators 1 96 96
IPMC 024 Vacant Structures & Land 2 30 30
IPMC 025 Sanitation (Exterior) 3 19 14
IPMC 026 Grading & Drainage 3 55 37
IPMC 029 Swimming Pool Enclosure 1 19 19
IPMC 030 Means of Egress 2 218 218
IPMC 034 Smoke alarm 1 24 24
IPMC 035 Unsafe Structure 10 136 57
IPMC 036 Unsafe Equipment 1 26 26
IPMC 037 Unfit Structure 2 91 91
Total 431
Average 75 56
While examining PMC violations listed in Table 3, the average case takes 75 days to
resolve5
. The median number of days to close the average PMC case is still almost two
months (56 days). According to CE standard operating procedure, it should be noted,
most violations are given a window of thirty days to take corrective action. To see a
visual representation of CE SOP, refer to Appendix B of this report.
INTERNAL CASES
Total Cases Median Days
224 69
Table 4
EXTERNAL CASES
Total Cases Median Days
207 41
Table 5
The median time it takes to close an internal PMC case is roughly 69 days. To resolve an
external PMC case, the median time is 41 days. This means that generally, it takes 68%
more time to close an internal PMC case than an external case.
Part Two Continued: Large Apartment Complexes
According to Census Bureau data,6
the City of Frederick has 24,201 housing units, of
which 10,138 are rental units. In other words, 41.8% of all Frederick housing units are
5
Given the wide disparity between processing times among the category averages (10 days to 221 days)
and the amount of cases per category (1 case to 94), a more befitting measure of central tendency is the
median
6
Census Bureau “2006-2008 American Community Survey 3-Year Estimates”
http://factfinder.census.gov/servlet/ADPTable?_bm=y&-geo_id=16000US2430325&-
qr_name=ACS_2008_3YR_G00_DP3YR4&-ds_name=ACS_2008_3YR_G00_&-_lang=en&-_sse=on
viewed Aug. 12, 2009
City of Frederick, Office of the Mayor Rental Housing Market | 11

12. rental. This is not the same as rental properties, however. SDAT data indicates there are
roughly 3,600 tax IDs associated with rental properties in Frederick.
To put this in prospective, a 2000 study by the City Planning Department7
found that
twenty-four (24) apartment complexes accounted for 5,209 rental units. Otherwise stated,
51% of the City’s rental units can be found in 0.6% of the tax IDs associated with rental
properties. Map 3 (on page 12) indicates where these and other known complexes are
located, while overlaying this data with PMC violations occurring on non-owner
occupied, residential properties.
Although unit numbers are not known on all the areas highlighted in orange, the map
helps show that PMC cases are not confined to, nor free from, large complexes.
According to analysis using SDAT, Planning and CE data, sixty-two (62) PMC violations
have occurred on twenty (20) complexes (that have over 50 or more units) since 2007.
Four (4) CC violations have been recorded on properties containing more than 50 units
during the same time. So while violations have been cited at multi-unit apartment
complex properties, 15% of PMC cases and less than 0.3% of CC cases can be attributed
to complex properties with 50 units or more.
7
See Appendix C
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13. (Map 3: Known Apartments & IPMC Cases, 2007 - 2010)
Part Three: Methodology
The purpose of this report was to answer simple questions about the City’s rental
property market by joining previously disparate data points. This report relied heavily on
state tax IDs as a way to parse, cleans and compare data. SDAT data contains over 100
columns of descriptive information per case, so it can be used in multiple ways.
Generally, tables and figures were constructed by joining Navaline database information,
used to track Code Enforcement cases, with SDAT information, based on tax
identification numbers. This information was then used in conjunction with GIS software
to construct the maps.
When references are made to non-owner occupied tax IDs or properties, those
“violations” or “cases” (either PMC or CC) are linked to properties, through SDAT data,
given a land use designation of Apartments, Residential, Residential Commercial,
Residential Condominium or Town House. In some instances additional land use
designations were used, when additional steps were taken to verify the subject
(residential or commercial) of a case or violation.
Note: Irregularities can occur when using SDAT data, but precaution is taken to explain
differences in totals or more granular subtotals. Some cases linked to properties without
tax IDs, like HOAs, right-of-way, etc. were omitted from this report. However, these
cases represent less than 1 percent of all cases examined.
City of Frederick, Office of the Mayor Rental Housing Market | 13

14. City of Frederick, Office of the Mayor Rental Housing Market | 14