Grand Rapids Works to Marry its Lead Paint Hazard Process to its Residential Rental Property Program

Following an uptick in childhood lead poisoning in Grand Rapids in 2015 and 2016, the City of Grand Rapids convened the Lead Free Kids GR Advisory Committee. Comprised of diverse community stakeholders, the Committee met for over a year to explore options to reduce lead exposure among children.

One important discussion centered around how some communities use rental inspection programs to identify lead exposures before children are poisoned. The Committee engaged experts from the National Center for Healthy Housing to explore how Grand Rapids might operationalize such an approach using support from a state grant. In early 2020, the Advisory Committee made final recommendations to the Grand Rapids City Commission, including a recommendation to amend the City’s housing code to require checking pre-1978 rental housing for deteriorated lead-based paint during the rental certification process, leading to the remediation of hazards. 

This was no small task. It required aligning state and federal lead-based paint rules and regulations, researching successful models, anticipating implementation challenges, controlling for unintended consequences, and continued engagement of rental property owners and community members.

Using grant funding from Healthy Babies Bright Futures and the Mayors Innovation Project, staff designed a community engagement process in advance of the ordinance being introduced to the City Commission for consideration. This was an important step as the proposed changes will impact property owners, their industry, tenants, families, and children. Seeking to address health inequalities, particularly for lower income families, the proposed changes to the City ordinance will impact both those who own and living in more than 24,000 rental units built before 1978. 

Drafting the Proposed Ordinance

Following the initial community engagement work of the Lead Free Kids GR Advisory Committee, the recommendation was turned over to staff for further research and the technical task of drafting a proposed ordinance.

The work began as the City’s Lead Programs Specialist, a contract attorney, and code compliance and community development staff reviewed the City’s existing Property Maintenance Code and compared it to model codes from nearly two dozen other cities to determine the best opportunities to address lead concerns. Those ideas were vetted against state and federal lead-based paint rules and regulations to ensure the proposed approach would be permissible, compatible, and capable of being implemented. When considering implementation, the proposed approach had to hold promise not only for desired outcomes, but also designed to mitigate unintended negative consequences.

To design the proposal, the team considered:

• Equity. The team sought an approach that would be effective in creating opportunity for the populations currently disproportionately impacted by lead exposure.
• Cost Containment. While costs for the City were certainly considered, the work primarily focused on how to limit the costs to rental property owners while still achieving a high level of safety for children. The City also considered how to keep economic opportunity in the private sector by using third-party inspection services rather than absorbing these opportunities into City operations.
• Health Improvement. How can the highest level of health protection for children be achieved given the economic constraints of providing affordable housing? How do we achieve maximum positive health outcomes for children?
• Implementation. The City of Grand Rapids has a model proactive rental inspection program and many high-quality rental housing providers. How can this work be done without compromising the integrity of the inspection program and sustainable rental property management? 

Re-engaging the Community

Following the detailed, technical work of preparing a more specific approach based upon the high-level recommendations of the Lead Free Kids GR Advisory Committee, the City re-engaged the community to learn about the proposed approach, hear comments, and receive feedback. With support from Healthy Babies Bright Futures and the Mayors Innovation Project, the City contracted with a third-party facilitator to assist with bringing the more detailed concept back to the public.

Two community engagement sessions were held to get community input. One evening session was held at a central location in the neighborhood most heavily impacted by lead. A second session was held a few days later at a time and location convenient for rental property owners, staff of neighborhood and early childhood organizations, and other working professionals.

Upon request, three additional meetings were held with specific interest groups: the Rental Property Owners Association, Parents for Healthy Homes (a parent-led advocacy group), and the Community Collaboration for Climate Change (an environmental justice group).

The input from these sessions helped inform the final draft proposal that was then presented to the City Commission for first reading in late January 2023. A month later, the City Commission held a public hearing on the proposed ordinance at their evening meeting where additional public comment was heard. The proposal has not been scheduled for further discussion by the Commission since the public hearing.

Throughout the process, the biggest learning has continued to also be the biggest challenge. Addressing lead hazards in the community will take the work of a diverse array of stakeholders with competing interests. No one group can solve it on their own, yet each has unique needs. As a result, the toughest questions are centered around how to achieve success when compromise is required from essential partners. This is especially challenging when children’s health is at stake and the desire for success is high.

A resident who commented in favor of the proposed ordinance at the February hearing captured this tension between competing interests and the need for compromise well.

Eileen said “I wouldn’t necessarily say this is a concern around the housing crisis, especially since this would not be an area where you would want to cut housing costs by reducing the steps you take to ensure safety in housing. Additionally, I think that any claims that might expose residents to lead would only be valid if (rental property owners) were already engaging in the testing recommended.”