RENT REGULATION IN NEW YORK CITY: A Briefing Book =============================================================== Chapter Three THE EFFECTIVENESS OF RENT REGULATION IN NEW YORK CITY The following analysis is organized to measure the effectiveness of New York City's rent regulation system in meeting the three purposes set forth in Chapter 2: the moderation of rents; eviction controls; and the preservation of housing through maintenance of services. Each section below defines the issue at hand, provides relevant evidence, and identifies barriers to effectiveness. ARE RENT LEVELS BEING MODERATED? Data on rent levels are needed in order to shape the discussion of affordability for tenants and fair return for owners. Median rents over the past 13 years may be compared using HVS data [Table 8]. Rents in current dollars represent what the tenant is paying in today's dollars, while constant dollars measure rent increases above and beyond inflation. As figures were unavailable for contract rent, median gross rents (contract rents plus utilities) are used for purposes of this comparison. As the data reveal, current-dollar rents have increased across the board from year to year. Constant-dollar rents show more variability -- with an actual decrease in gross rents for all control groups of housing in the 1978-to-1981 period and steady increases thereafter until 1987. From 1987 to 1991, median gross rents for controlled and post- 1947 stabilized apartments decreased somewhat. However, gross rents increased more rapidly than inflation during this period [Table 9]. It is clear that rents have risen considerably in New York City. Analyses of what these increases mean for tenants follow. Tenant Affordability. A commonly used measure of housing affordability is the rent-to- income ratio. It is generally presumed that approximately 30 percent of household income is an affordable (or reasonable) amount to devote toward rent. While this measure does help to gauge affordability, its effectiveness is limited. Rent-to-income ratios do not account for household size -- i.e., how many people are being supported by a given income. Nor do they take into account individual circumstances such as high medical costs or the like. Also, 30 percent is too much for most low-income renters to pay. (In fact, some poor people can't reasonably afford to pay any rent and have anything left for their other needs.) The measure is used here only because it is the generally recognized standard. ----------------------------------------------------------------- Table 8 Median Gross Rents Current and Constant Dollars New York City, 1978-1991 Control Status 1978 1981 1984 1987 1991 ----- Current Dollars ----- Total Renter Occupied $208 $263 $325 $395 $509 Controlled $164 $212 $256 $300 $370 Decontrolled $221 $270 $355 $445 N/A* Stabilized pre 1947 $206 $260 $322 $390 $505 post 1947 $287 $350 $400 $480 $573 CPI 192.2 253.9 299.9 334.7 414.5 ----- Constant Dollars ----- Total Renter Occupied $108 $104 $108 $118 $123 Controlled $ 85 $ 83 $ 85 $ 90 $ 89 Decontrolled $115 $106 $118 $133 N/A* Stabilized pre 1947 $107 $102 $107 $117 $122 post 1947 $149 $138 $133 $143 $138 Sources:Stegman, Michael. Housing and Vacancy Report, New York City, 1987, pg. 63, and 1991 NYC HVS Tabulation Package. Consumer Price Index for All Urban Consumers for New York- Northern New Jersey (1967=100), March of each year, Bureau of Labor Statistics, U.S. Department of Labor Rents use current dollars rounded to the nearest dollar before calculating constant dollars. Rents in constant dollars calculated by dividing rents in current dollars by the CPI for the appropriate year. * Decontrolled was dropped as a unit of analysis in 1991. ----------------------------------------------------------------- ----------------------------------------------------------------- Table 9 Percentage Increases in Median Monthly Gross Rents Compared to Increases in the CPI New York City, 1978-1991 ----- Percentage Change ----- Unit 1978-1981 1981-1984 1984-1987 1987-1991 Current Dollars +26.4 +23.6 +21.5 +28.8 CPI +32.1 +18.1 +11.6 +23.8 Constant Dollars -3.1 +3.8 +9.3 +4.2 Sources: Stegman, Michael. Housing and Vacancy Report, New York City, 1987, pg. 63, and 1991 NYC HVS Tabulation Package. Consumer Price Index for All Urban Consumers for New York- Northern New Jersey 1967=100), March of each year, Bureau of Labor Statistics, U.S. Department of Labor ----------------------------------------------------------------- ----------------------------------------------------------------- Table 10 Renter Households Paying 30 Percent or More of Income in Gross Rent By Control Status, 1991 Units Percent Controlled 66,359 54.7 Stabilized 528,285 55.5 Public Housing 110,289 43.4 Mitchell Lama 40,692 47.5 Other* 321,471 56.2 Source: 1991 NYC HVS Note: This table was produced using computerized data. * The unit of analysis "Other" refers to in-rem, HUD federally subsidized, Article 4, Loft Board regulated and unregulated housing. ----------------------------------------------------------------- A more telling way to measure the effects of regulation on affordability is to compare changes in tenant incomes to changes in rent levels for each control status of housing. Over the past four years, both tenant incomes and rent levels increased. However, rents increased much more than incomes, creating a gap for all tenants. ----------------------------------------------------------------- Table 11 Median Household Income by Control Status New York City 1986 and 1990 Percent Control Status 1986 1990 Change Controlled $10,817 $12,075 +11.6% Stabilized 18,547 21,000 +13.2% Other* 18,609 24,000 +29.0% Sources: NYC HVS 1987, Series IA, Table 10; and NYC HVS 1991, Series 1A, Table 9 Note: Data on incomes were collected in 1987 and 1991 but reflect income earned the previous year. * The unit of analysis "Other" refers to in-rem, HUD federally subsidized, Article 4, Loft Board regulated and unregulated housing. ----------------------------------------------------------------- Incomes grew significantly for all types of tenants during this time period [Table 11]. But the incomes of tenants in unregulated (included in "Other") housing grew twice as much as the incomes of regulated households. Tenants with the greatest gap between income and rents are those living in stabilized apartments. ----------------------------------------------------------------- Table 12 Median Monthly Contract Rents per Apartment by Control Status New York City, 1987 and 1991 Percent Control Status 1987 1991 Change Controlled $260 $320 23.1% Stabilized 377 480 27.3% Other* 418 550 31.6% Sources: NYC HVS 1987 Series IA, Tables 32 and 37; and NYC HVS 1991 Series IA, Tables 30 and 35 * The unit of analysis "Other" refers to in-rem, HUD federally subsidized, Article 4, Loft Board regulated and unregulated housing. ----------------------------------------------------------------- Rents also increased significantly over this four-year period [Table 12]. Again, rents increased the most in unregulated housing. When increases in income are compared to those in rents, the gap referred to above is identified [Table 13]. ----------------------------------------------------------------- Table 13 Increases in Median Household Income Compared with Increases in Median Monthly Contract Rent New York City, 1987-1991 -- Percentage Increase -- Control Status Incomes Rents Gap Controlled +11.6% +23.1% -11.5% Stabilized +13.2% +27.3% -14.1% Other* +29.0% +31.6% -2.6% * The unit of analysis "Other" refers to in rem, HUD federally subsidized, Article 4, Loft Board regulated and unregulated housing. ----------------------------------------------------------------- The implications of this comparison are serious. Few incomes are keeping pace with rising rents in New York City. And tenants in regulated apartments are bearing the burden of rent increases far greater than the growth of their incomes. Using different measures, we have seen that housing, by and large, is becoming less affordable for tenants. It is then reasonable to ask how landlords are faring. Landlord Profitability. In a housing market experiencing a shortage, the goal of rent regulation is to stabilize rent levels while guaranteeing a fair level of return for owners. A fair or reasonable rate of return is, however, interpretative and shaped by politics. "One of the most difficult and persistent problems of rent control has been defining 'fair return' and developing satisfactory individual adjustment fair return standards."(1) This is particularly difficult given the lack of reliable information regarding the incomes and expenses of landlords. Hence, the following analysis is more qualitative than it would be if firm data were available. While no one indicator is adequate, those discussed below show that real estate is providing a fair return. Peter Marcuse makes an important point that clarifies the issues at hand. By design, landlords are worse off under rent regulation because regulations hold rents below what they would be otherwise. "The crucial question, however, is not whether landlords would be better off without rent regulation, but are they badly off with it?"(2) Since rent regulation is designed to pass increases in operating costs on to tenants, operating costs are at the heart of this discussion. Whatever the profitability of a given property, rent regulations in New York City essentially maintain that level of profitability (rate of return) over time by granting rent increases for changes in operating costs. Thus, discussion of fair return will focus on the degree to which rent increases granted by the regulatory system adequately compensate owners for changes in operating costs. In this situation, rent increases larger than changes in operating costs result in an increased rate of return for owners. As a starting point, analysts have compared changes in operating costs to changes in the Consumer Price Index (CPI). Several experts who have examined the operating costs of rental buildings have found that these costs consistently increase at a slower rate than inflation. John Gilderbloom and Richard Appelbaum found: "On average, one-third to one-half of landlords' costs are unaffected by inflation."(3) While New York City's rent regulations are not tied to increases in the CPI (as regulations in some jurisdictions are), we may note from an earlier illustration that rents have increased at a faster pace than inflation over the past 14 years [see Table 9]. "Moderate rent control, by pegging increases to the full CPI [or above it], can therefore result in increased income over time..."(4) In sum, researchers have found that operating costs rise at a rate slower than the CPI. As rents have risen faster than the CPI in New York City, it is safe to assume that, at a minimum, rental income has grown over time as a result of these substantial rent increases. This assumption is supported by the findings of the New York City Rent Guidelines Board (RGB), the local body charged with determining annual rent increases. To do so, the RGB staff conducts various types of research, including studies of changes in operation and maintenance (O&M) costs. For the past few years, the RGB has conducted an Income and Expense study to determine the O&M-to-rent ratio for rent stabilized buildings. From a sample of unaudited Income and Expense reports filed with the Department of Finance by landlords of 500 rent stabilized buildings, an O&M-to-rent ratio of .75 was determined using 1991 data.(5) This indicates that, on average, 75 cents of every rental dollar go toward operation and maintenance expenses -- which include taxes, labor, fuel, utilities, maintenance, administration, insurance, and other miscellaneous costs -- leaving 25 cents of every rental dollar to go toward debt service and profit. In order to obtain information regarding owners' income and expenses (for which data have been largely unavailable) and to verify the reliability of the available data, the Department of Finance, at the request of the RGB, recently completed an audit of some annual Income and Expense reports of landlords filed with the Department of Finance. Based on a weighted sample to reflect the stabilized stock in general, information on 46 buildings was analyzed from the 1990 Income and Expense reports. Many owners of larger buildings refused to participate in the voluntary study, making the reliability of the findings for large buildings questionable. Despite these shortcomings, the study is not only current but is the first, in-depth examination of actual audited income and expense information. It yielded some important findings on the finances of landlords. First, the audit determined that owners significantly overstated expenses. "Overall (weighted) O&M expenses were reduced by about 8 percent."(6) There are factors that may explain the overstatement of expenses, such as making an error, "expensing" an item that should be capitalized, or not providing documentation of expenses -- in addition to deliberate overstatement. Second, the audit indicated that previous Income and Expense studies yielded O&M-to-rent income ratios that were too high. This year's estimate of the O&M to rent ratio was .75 based on 1991 submissions. If we assume that an audit of the 1991 I and E filings would have resulted in the same findings as in this study (all other things being equal), we can revise the O&M to rent ratio based on the adjustments made by the auditors. Doing so would result in an O&M rent ratio of .69 (.71 if salaries to stockholders and partners are considered a legitimate expense). While we do not suggest that this is necessarily a precise estimate of the O&M to rent ratio, the audited data strongly suggest that the .75 figure from this year's I&E study is too high.(7) The RGB bases annual rent increases on these figures. Thus, the RGB itself has concluded that due to a dearth of available information -- and also due to the overstatement of expenses in the information that is available -- its own estimates have favored landlords by overestimating O&M costs. Overcompensation for changes in these costs result in higher-than-necessary rent increases and increased return for owners. This suggests that routine audits of landlords' books should be conducted before tenants bear the brunt of rent increases. A final, though imperfect, indication of how landlords are faring is the number of rent-increase hardship applications filed with the state Division of Housing and Community Renewal (DHCR). Hardship applications are requests by landlords for additional rent increases to relieve the financial strain of operating their buildings. The intent and purpose of the hardship provisions are to act as a safety valve relieving economic pressure on owners confronted with financial difficulties because of administratively set rent levels. While the proportion of buildings that are operating with adequate cash flow compared to the proportion of those operating at marginal or negative profitability is not known, the hardship study found an extremely low level of owner applications for hardship increases. Approximately 200 applications were filed from 1984 to 1988 and there has been an almost negligible approval rate. Of the 167 applications reviewed only eight resulted in hardship increases.(8) This small number of applications may indicate two things. First, rent regulations may have maintained a reasonable rate of return for landlords. However, it is also important to note that the current hardship application process is unworkable, and hardship applications thus should not be viewed as a single financial indicator. Given that rents have increased more than the CPI over the past 14 years, that the RGB has found its own estimates of operating costs upon which rent increases are based to be too high, and that relatively few hardship applications are filed with DHCR, we may conclude that, by and large, operating rental property in New York City remains a business that provides a fair return for owners. ARE EVICTION CONTROLS WORKING? A commonly held myth about rent regulation is that it is impossible to evict tenants from rent regulated apartments. Quite the contrary is true. From 1983 to 1990, the Bureau of City Marshals evicted an average of 24,025 households per year. The number of evictions has varied little during the time period, from a high of 26,700 in 1983 to a low of 20,300 in 1985. Evictions in 1990 and 1991 were close to the eight-year average.(9) Of course, not all of these were evictions from rent controlled or rent stabilized housing -- but a substantial portion no doubt were. Unfortunately, very limited eviction records are kept in New York City, so there is no way of knowing the exact proportion of rent regulated evictions. Grounds for eviction under rent regulation fall into three key categories: nuisance, breach of lease, and personal use. Nuisance evictions provide owners an ability to evict tenants for causing disruption, disturbing other tenants, allowing the apartment to be used for an illegal purpose, and similar grounds. Breach of lease grounds for eviction include keeping a pet not allowed by lease, illegal sublets, etc. Personal use grounds allow landlords to evict in order to enable use of the apartment for themselves or their relatives. (Of course, rent regulated tenants can also be evicted for non-payment of rent.) The multitude of provisions for eviction provide reasonable recourse for landlords struggling with "bad tenants" while protecting tenants at large from speculation, conversion, and unfair conditions.(10) Some critics have argued that rent regulation is so restrictive and so pro-tenant that it drives landlords to harass tenants illegally. However, as illustrated above, rent regulation laws leave ample room for legal recourse for owners faced with problems. The reasons landlords harass tenants vary, but they are generally driven by a desire for profit. Owners may try to force tenants out because they are looking for much higher rents -- or for the profits made through coop conversion, renovation, or even demolition. Often, landlords harass their tenants after tenants have asserted their rights by complaining about a lack of services or repairs in the building.(11) Rent regulation protects tenants from harassment. Tenants may file complaints with the DHCR Harassment Unit. The DHCR Enforcement Bureau considers the following acts to constitute legitimate claims of harassment: physical abuse, verbal abuse, arson, a denial of services (when it is purposeful and continuous as opposed to an isolated, unintended interruption), and multiple instances of unwarranted litigation.(12) The tenant protections detailed above are useful only under two conditions. First, tenants must be informed of the protections provided them. Second, protections must be meaningfully enforced by DHCR without an unfair burden placed on tenants through the process of obtaining their rights. Informed Tenants? Tenant knowledge of protections is difficult to gauge. However, the HVS asks tenants whether or not they know the control status of their apartments. This is a rough indicator of tenant knowledge not only about protections but also about their rights regarding rent levels and eviction. The results indicate, in terms economists would use, that such knowledge is not perfect [Table 14]. Rent controlled tenants are the most highly aware of the status of their apartments and, one may assume to some degree, the attached rights and protections. Stabilized tenants are less informed, with under half reporting their true control status- indicating a relative lack of knowledge regarding protections. Simply put, many rent regulated tenants do not know their rights. ----------------------------------------------------------------- Table 14 Tenant Knowledge of Control Status New York City, 1991 Reported % Actual % Actual Control Status Controlled Stabilized % Other* Rent Controlled 63.38% 13.43% 3.33% Rent Stabilized 10.84% 43.88% 6.35% Neither of the Above 13.21% 18.44% 66.54% Do Not Know 9.46% 20.72% 18.62% No Cash Rent 3.04% 1.56% 3.52% Not Reported 1.07% 1.97% 1.60% Source: 1991 NYC HVS Note: This table was produced using computerized data. * The unit of analysis "Other" refers to in-rem, HUD federally subsidized, Article 4, Loft Board regulated, and unregulated housing. ----------------------------------------------------------------- Tenant protections lose further meaning when the burdens placed on tenants are examined. Virtually no investigations regarding any aspect of the rent regulation system are instigated without a tenant's filing a complaint. Thus, there is no proactive enforcement and the burden to be protected falls upon tenants, which heightens the importance of tenants knowing their rights. Enforcement. Finally, enforcement on the part of DHCR is inadequate and even deviates from what is required by the law. Partly because the DHCR Office of Rent Administration is underfunded by the State Legislature and the Governor, poor administration and enforcement seriously undercut the effectiveness of rent regulation. The problems became so serious a few years ago that the New York State Assembly held public hearings on DHCR's administration of rent laws in 1986 and 1987, publishing a report, Bleak House,(13) that was extraordinarily critical of the agency. While some improvements have been made since that time, enforcement is still halfhearted. Despite the shortcomings mentioned above, rent regulated tenants have much greater security than other tenants. This is indicated by how long regulated tenants have remained in their apartments [Table 15]. As illustrated by the data, rent controlled tenants have been in their apartments the longest -- the result of vacancy decontrol of rent controlled apartments, which has been in effect since 1971. However, the significant difference between stabilized units and other housing also illustrates a promoted length of tenure through regulation. The flip side of prolonged tenure, some argue, is reduced mobility for tenants and the "overconsumption" of housing. Length of tenure is often presented as evidence of "housing gridlock." However, vacancy decontrol -- the setting of rents at market rates upon vacancy -- not rent regulation, is the true culprit in this scenario. If all housing units were granted increases based on costs and improvements, and rents were not allowed to be increased upon vacancy, mobility would be enhanced for all tenants. Those people wanting or needing to move could more readily afford the rents of vacant apartments. WHAT EFFECT DOES RENT REGULATION HAVE ON HOUSING CONDITIONS? The quality of the housing in which people live is as important as how much it costs them. A leading determinant of housing quality, which is directly related to affordability, is overcrowding. Housing quality also can be measured by building deficiencies, maintenance deficiencies, and neighborhood conditions. Crowding. A key measure of habitability is how many people are living in each room of a given apartment. Crowding may be seen as a function of affordability, in that the more space a household can afford, the less crowded a given living situation may be. For analytical and practical purposes, it is generally held that any apartment that houses more than one person per room is crowded. Rooms counted include bedrooms, living rooms, dining rooms, kitchens, and dens. Not counted are bathrooms or vestibules. According to HVS findings, rates of crowding have been on the rise in New York for the past four years. In 1991, 10.4 percent of New York City households lived in crowded conditions, up from 7.1 percent in 1987. The level of crowding for renters varies greatly depending on the control status of the housing [Table 16]. ----------------------------------------------------------------- Table 16 Percentage of Households Living in Crowded Conditions By Control Status, New York City, 1991 Status Percent Crowded Controlled 3.0% Stabilized 12.3% Other* 9.9% Source: NYC HVS 1991, Series IA, Table 28 * The unit of analysis "Other" refers to in-rem, HUD federally subsidized, Article 4, Loft Board regulated, and unregulated housing. ----------------------------------------------------------------- Because of the concentration of elderly tenants, rent controlled households are more likely to be composed of single persons than the other two control status categories are; thus the person-per- room levels are much lower. No real connection between regulation and crowding is illustrated by the data. Building Conditions. Building conditions are another key indicator of housing quality. The data show that there is not a strong relationship between building deficiencies and rent regulation [Table 17]. Rent controlled units have slightly fewer deficiencies overall. Stabilized apartments have a greater number of deficiencies than both controlled and other housing, though the difference is rather small. Consistent with the findings of other research,(14) the relationship here appears to be weak, if not insignificant. ----------------------------------------------------------------- Table 17 Percentage of Households Reporting Building Deficiencies By Control Status, New York City, 1991 -- Number of Deficiencies -- Status None One Two Three Four Controlled 87.3% 5.8% 5.3% .9% .7% Stabilized 83.4% 8.3% 5.0% 2.2% 1.1% Other* 86.9% 6.3% 3.1% 2.3% 1.5% Source: NYC HVS 1991, Series IA, Table 26 * The unit of analysis "Other" refers to in-rem, HUD federally subsidized, Article 4, Loft Board regulated, and unregulated housing. ----------------------------------------------------------------- Maintenance Deficiencies. A contentious debate surrounding rent regulation is the effect it has on housing maintenance and services [Table 18]. While the data indicate a higher number of deficiencies in regulated housing, research has found greater determinants than rent regulation in housing maintenance issues. According Gilderbloom and Appelbaum: "Numerous studies have shown that maintenance expenditures are unaffected by rent control."(15) In fact, they assert that moderate rent controls, such as those in New York City, may even encourage maintenance due to the ability of owners to pass along maintenance and capital improvements costs to tenants. Additionally, according to Peter Marcuse, Rent regulations permit rents sufficient for adequate maintenance and repairs, and major capital improvement provisions permit major repairs and improvements. But landlords, in a very tight housing market, do not have the economic incentive to make repairs: they can rent their units whether they are well maintained or not. Ending rent regulation will not automatically lead to improved maintenance.(16) ----------------------------------------------------------------- Table 18 Percentage of Households Reporting Maintenance Deficiencies By Control Status Number of Deficiencies Controlled Stabilized Other* None 35.0% 32.2% 50.2% One 22.5% 21.5% 20.3% Two 18.0% 15.1% 11.3% Three 11.2% 11.8% 7.7% Four 8.3% 9.1% 5.3% Five 2.8% 5.8% 2.7% Six 1.8% 3.2% 2.0% Seven .5% 1.4% .6% Source: NYC HVS 1991, Series IA, Table 53 Note: Maintenance deficiencies include a breakdown in heating, additional heating required, rodent infestation, open cracks/holes in interior walls and/or floors, broken plaster/peeling paint and/or floors, toilet breakdown, and water leaks. * The unit of analysis "Other" refers to in-rem, HUD federally subsidized, Article 4, Loft Board regulated, and unregulated housing. ----------------------------------------------------------------- Additionally, it is important to note that the rent regulated housing in New York City tends to be older than unregulated housing, which can create greater maintenance and service problems. Moreover, due to a high level of conversion activity throughout the 1980's, many of the highest-quality buildings were removed from the rent regulated stock through condominium or cooperative conversion. Thus, the data reflect the remaining rental buildings, which were generally less well maintained in the first place. Neighborhood Conditions. Housing is a good that is tied to place, so examining the conditions in a neighborhood is useful [Table 19]. The indicators used -- boarded-up buildings and buildings with broken windows -- are somewhat limited, however, since they are based on reporting and observation. ----------------------------------------------------------------- Table 19 Neighborhood Conditions By Control Status New York City, 1991 Boarded-up Buildings with Status Buildings** Broken Windows*** Controlled 19.2% 14.7% Stabilized 19.8% 15.2% Other* 21.3% 17.2% Source: NYC HVS 1991, Series IA, Tables 55 and 56 * The unit of analysis "Other" refers to in-rem, HUD federally subsidized, Article 4, Loft Board regulated, and unregulated housing. ** Information on boarded-up buildings was reported by survey respondents and refers to the neighborhood. *** Information on buildings with broken windows is based on enumerator observations and refers to the block. ----------------------------------------------------------------- Still, these two simple measures indicate that rent regulated apartments are in neighborhoods that are no worse, if no better, than neighborhoods with unregulated (included in "Other") housing. Within the context of neighborhood conditions, it is worthwhile to raise some of the little-discussed benefits of rent regulation. First, by moderating rent levels, rent regulation aids in providing some degree of housing choice for tenants. Second, by providing protection from eviction, rent regulation promotes neighborhood stability. Thus, the neighborhoods of New York City are more stable than they would be in the absence of rent regulation. Notes to Chapter 3 1. Baar, Kenneth K., "Guidelines for Drafting Rent Control Laws: Lessons of a Decade," Rutgers Law Review, Vol. 35, No. 4, Summer 1983, pg. 781. 2. Marcuse, Peter, 1986, The Uses and Limits of Rent Regulation, pg. 50, New York City, Community Training and Resource Center. 3. Gilderbloom, John and Richard P. Appelbaum, Rethinking Rental Housing, Philadelphia, Temple University Press, 1988, pg. 132. 4. Ibid, pg. 132. 5. Per compliance with Local Law 63 of 1986, which requires reporting of income and expenses of rental properties to the Department of Finance for tax purposes. 6. Rent Stabilized Housing in New York City: A Summary of Rent Guidelines Board Research, 1992, New York City Rent Guidelines Board, October 1992, pp. 41-42. 7. Ibid, pg. 44. 8. DHCR Hardship Study, pg. 1. Presented to the Rent Guidelines Board of New York City, 1990. 9. From Housing Court, Evictions and Homelessness: The Costs and Benefits of Establishing a Right to Counsel, 1993, by the City-wide Task Force on Housing Court and Community Training and Resource Center. 10. It is important to note that unregulated tenants have only one basic right with regard to eviction: a requirement of warning, without need to examine or substantiate grounds above those specified in a given lease, if any. 11. Community Training and Resource Center Fact Sheet, "Fighting Landlord Discrimination and Harassment," 1990. 12. Ibid. 13. New York State Assembly, June 1987, Bleak House: DHCR at the Crossroads. Findings and recommendations of the Joint Assembly Committees' Investigation of Rent Administration in New York State. 14. Marcuse, Peter, 1981. Housing Abandonment: Does Rent Control Make a Difference? Washington, DC, Conference on Alternative State and Local Policies, Policy Report Number 4. 15. Gilderbloom, John I. and Richard P. Appelbaum, Rethinhng Rental Housing, Philadelphia, Temple University Press, 1988, pg. 136. 16. Marcuse, Peter, 1986, The Uses and Limits of Rent Regulation, pg. 73, New York City, Community Training and Resource Center.