Rent Board

Rent Board
GENDER ANALYSIS
2000

The Rent Board is charged with enforcement of the City's rent control Ordinance and Rules and Regulations. The Ordinance was passed in 1978 in response to the City's "temporary" housing crisis. Since that housing emergency has only been exacerbated by rapid population growth and economic development over the last twenty years, the Ordinance was made permanent several years ago and rent control is, apparently, here to stay. What began as an agency staffed with a half dozen temporary workers, funded primarily through Comprehensive Employment and Training Act (CETA) funds, with volunteer attorneys conducting hearings, is now a permanent City agency with 30 professional and support staff charged with implementation of one of the City's most volatile and necessary laws.

The Rent Ordinance dictates several legal mandates which the Department is obligated to fulfill. Beyond that which is legally required, the Department strives to provide additional services to the public, within the limits of staffing and budgetary constraints. The Department seeks to address the needs of its two major constituencies: the landlord and tenant communities. Both of those communities, obviously, are comprised of male and female members. While no disaggregated statistics are kept by the agency, except as to employment, it appears from observation that men and women are equally represented at the Rent Board. In order to augment anecdotal information, two focus groups were held: one comprised of invited representatives from the landlord and tenant communities; and one to which all staff were invited, although only one individual chose to participate. The following is an attempt to identify issues presented by the data collected, best practices, limiting factors, and recommendations for future action in the areas of budget, services and employment.

BUDGET

The Rent Board receives no portion of its operating budget from the General Fund. Rather, the agency is funded through a "rental unit fee", which is billed to landlords with their property tax statement (this is because the City has no billing relationship with tenants). Landlords are permitted to pass through the rental unit fee to their tenants, although some do not and just absorb the cost themselves. The rationale for tenants bearing the operating costs of the agency is that tenants are the ones who benefit from the presence of a rent control law. Even if a tenant does not directly utilize the agency's services by filing a petition or calling a counselor with a question, the administration of annual allowable rent increase limitations and eviction protections is seen as a benefit to all tenants. The current fee paid by tenants per unit is $16.00; the charge for residents of single room occupancy hotels is $8.00.

In past years, when there have been budget deficits necessitating layoffs and service reductions at other City departments, the Rent Board has been spared by having a separate source of funding. Several years of surpluses insulated the Department from painful funding decisions, and made it possible for the rental unit fee to remain the same for an 8-year period. However, the surplus was finally exhausted by fiscal year `98-99, and the tenant community was asked to shoulder a $6.00 per unit increase, from $10 to the current $16.00. In order to "sell" the fee increase to the tenant community, and therefore create the necessary political will for it to pass at the Board of Supervisors, the Department convened the major representative tenant organizations in order to conduct a needs assessment. The response was that tenants would be willing a pay an increase if services to that community were improved. Specifically, it was agreed that there would be increased staffing of the Eviction Unit and increased enforcement of the Just Cause eviction provisions of the Ordinance, which was accomplished through the funding of two investigator positions at the Office of the City Attorney.

Similarly, a backlog of petitions meant that some landlords were waiting over a year in order to have a hearing on their rent increase petitions scheduled (tenant petitions tend to be scheduled more quickly through the Mediation Program, which is not appropriate for landlord petitions). Staffing in the attorney (Administrative Law Judge, or ALJ) unit was increased so that the agency was able to schedule more hearings and reduce the backlog. The following year, however, without additional revenue, layoffs were going to be necessary. There was little incentive for tenants to pay an additional amount in order for landlords' petitions to be processed more expeditiously, and the Department was unable to turn to the General Fund for an infusion of revenue. After rounds of negotiations with representatives from the landlord community, it was agreed that a one-time $3.00 increase in the fee would be borne by landlords. Once the backlog was eliminated, the equivalent of 3 full-time attorney positions was eliminated.

The Rent Board must rely on the good will of the respective communities that it serves in order to meet its budgetary needs, which leads to some "best practices" (i.e., increased staffing of the Eviction Unit; hiring of additional attorney positions in order to more expeditiously process landlord petitions; etc.). However, the agency has legal mandates which may not be on the "wish list" of either community. The fact that payment of the fee is so disproportionately placed on tenants sometimes skews sound budgetary decisions towards what is politically palatable. It also hinders any long-term planning on the part of management. Budgetary planning is further complicated by the fact that a major segment of our work, landlord capital improvement petitions, may be eliminated as a result of Proposition H which passed on the ballot this past November.

Recommendation: that the Fee Ordinance be amended so that payment of the rental unit fee be allocated between landlords and tenants in amounts that are reflective of their demands for our services. Appropriate allocation, hopefully, would make the yearly process of obtaining necessary budgetary increases more fair and less politicized, the current Proposition H issue notwithstanding.

SERVICES

The Rent Ordinance and Rules and Regulations are laws of the City and County of San Francisco. They must be written in legalese and are not "user-friendly." In order to make the restrictions and requirements of these complex and convoluted documents more accessible, the Executive Director of the Department has instituted many technological aids and advancements for the widest possible disbursement of information in the most approachable form. The Rent Board has a 24-hour "Information To Go" voicemail system with over 70 scripts in English, Spanish and Chinese covering local rent control and general landlord-tenant information; through the "Fax Facts" system, the public can access every piece of paper produced by the agency, as well as the "Info to Go" scripts; and the Rent Board's web site is the most widely used of any City department. 8 different informational brochures are produced, some of which are offered in English, Spanish and Chinese.

One of the Department's "best practices" is the variety of ways that information is provided and feedback is solicited; both in more than one language. While noting a need for even more bilingual staff and materials (from the feedback and focus groups), there is 24-hour information available (especially convenient for working people or those with small children), counseling services in more than one language, extensive information on the web, and a fax service. Customer satisfaction is a high priority of the Department and staff are provided with tools for obtaining customer feedback. This customer service approach would benefit from integrating gender, race and other criteria, as discussed above. Of course, in order to continue to protect the public from the misuse of sensitive identifying information, any request for such information must make clear that it is voluntary, optional, and for the purpose of improving customer service.

Within the last few years, the Department implemented two new programs in order to provide better service to the public. Hoping to go beyond the "Lose-Lose" situation inherent in any arbitration, the agency instituted a tremendously successful Mediation Program, wherein participants can resolve problems outside the scope of the Rent Ordinance and receive an immediate decision of their own making. In response to complaints concerning the length of time it took for even simple decisions to be issued, a Minute Order Program was introduced, which results in binding Orders that are issued within 10 days of the hearing for appropriate cases. Only twice have parties who have received a Minute Order requested that a full decision be issued. The agency also compiles statistics on issues of concern to users of our services that go back 21 years, are printed out in easily readable Excel spreadsheet format, and can be easily accessed through the Fax Facts system or our web site.

The Rent Board also uses a variety of customer satisfaction tools, including survey forms provided at the front counter, in hearings, and through telephone voicemail, as well as web site survey forms. There is a voicemail line specifically for leaving comments on. Most criticisms concern the timeliness of services delivered and the need for additional bi-lingual services, despite the fact that half of the counseling staff is bi-lingual. Additionally, as noted through comments offered in the Public Focus Group, clients feel that some members of the counseling staff do not go far enough in offering information; that one must "know what to ask for" in order to receive good service. While this is most understandable from their perspective, the agency must balance the needs of certain members of the public against insufficient staffing and efficiency concerns. It is also impermissible for Rent Board staff to provide legal advice, and difficult for the public to understand that this is indeed what they are asking for. While the counseling staff receives training in time and stress management, dealing with difficult individuals and diversity issues, some members of the Focus Group felt that women were treated less solicitously than men, and more brusquely.

Staffing is problematic for the department, given the demands for service. With some 1,500 front counter visitors and over 3,000 phone calls per month, it is difficult for the ten counselors to provide the level of service that the public expects and staff would like to provide. Since the counseling staff currently is comprised of 7 males and 2 females, this is of concern. It should be noted that the focus group complainant was a landlord who is known for having an antipathy towards rent control in general.

Recommendation: that the Evaluation form be disaggregated by gender in order to track comments from female members of the public.

EMPLOYMENT

As can be seen from the agency's staffing data (see attached charts), the Rent Board is a department committed to gender and ethnic diversity at all levels of staffing, and reflective of the communities it serves. The Rent Board staff currently meets or exceeds the total labor pool representation by race, with only a -2% differential for Blacks. Of the 5 Senior Staff members, the Director is a gay male; a Supervisor is a Hispanic male; and the Deputy Director and one of the Senior Administrative Law Judges are white females who were promoted from within. As of January 1, 2001, the ALJ staff will be comprised of 4 men and 6 women - 1 gay male, a Chinese male and female, and a black female. The counseling staff currently consists of 7 men and 2 women; 2 of the men are Hispanic, 1 is Filipino, and 1 is Chinese; one of the women is a Latina and the other is Chinese. The Rent Board Commission has always had a strong female contingent, and the Board President is currently a woman. Three of the Commissioners are people of color; one is gay.

The Department has also participated for several years in the Youth Works Program, and has recently provided employment training to 2 Hispanic and 2 Black interns. All staff members are encouraged to identify and attend coursework that will lead to professional development. The Department has paid for relevant courses that staff has identified and have been approved. Reimbursement programs through the City or unions are brought to staff's attention when made available. Management also mandates specific training that is provided by the City's Human Resources Department (i.e., ergonomics, diversity, dealing with difficult clients, etc.), and all Supervisors are required to attend the Sexual Harassment Training provided by the Office of the City Attorney.

Because of the volatility of some members of the public who come to the counter for counseling and/or attend hearings, female counselors and Administrative Law Judges increasingly expressed fears and concerns for their safety. At one time, the Department considered offering hearings after working hours, but female staff members convinced management that security concerns outweighed the greater convenience to the public. (In a similar vein, the Department experimented with Saturday hearings, which were ill-attended. Currently, both men and women often bring children to hearings, which is a distraction that is gracefully accommodated by the Administrative Law Judges, within reason.) In response to security concerns, a Workplace Violence Plan and accompanying training was developed in conjunction with the Employee Assistance Program during fiscal year `99-'00. Security measures that have been or are in the process of being implemented include:

· The posting of "Rules of Conduct by the Public" at the front counter;

· Installation of a security camera at the front counter;

· Installation of "panic buttons" at the front counter and all hearing rooms;

· Provision of locking drawers or cabinets in the Annex office for staff;

· Programming the clerical phone sets to call the Security Guard and 911;

· Creation of a "safe space" in a hearing room by installing a door lock;

· Installation of a one-way viewer on the entry door to Suite 320; and

· Establishment of a requirement for Administrative Law Judges to escort clients from the hearing rooms to the proper waiting area during recesses or caucuses.

The Rent Board considers itself in the vanguard of City departments in terms of "work/life" policies, which perhaps accounts for the high retention of employees. Flextime is offered to all employees, within the parameters of providing service to the public during the core hours of 8:00 a.m. to 5:00 p.m. for the counseling staff in particular. Clerical staff may come in early and leave early; or come in late and leave late. All staff members have the option of taking a 1/2-hour or 1 hour lunch. The counseling staff also has the option of early or late flexible hours, and has recently implemented a schedule of their own making which allows for 9-9 hour days and one day off every other week. The Administrative Law Judges are allowed to telecommute, and only have to be in the office on the day of their hearings or for staff meetings. This option is not open to the rest of staff because of the need to serve the public. The male Senior Administrative Law Judge works at home 3 days per week; the female works one extremely long day in the office in order to take one day off per week, and works at home two days per week. The female Deputy Director comes in late and usually leaves late, and takes work home on an as-needed basis. Childcare and family leave requests are routinely accommodated by the department, and are generated by male and female members of the staff.

At the time the data for this analysis was collected, an additional "best practice" of the Rent Board was the offering of attorney positions on a half-time basis. For the past several years, three of the Hearing Officer (now Administrative Law Judge) positions were split into six half-time positions. However, while the agency had assumed that the bulk of these would be used by working parents, especially mothers, that turned out to be the exception rather than the rule. Prior to the promotion from Hearing Officers to Administrative Law Judges, and a commensurate increase in salary, the salary for these half-time positions was insufficient for most working parents. For male attorneys, even the full-time salary was not enough. The Hearing Officer unit tended to be female-dominated at the full-time end; the half-timers were male attorneys who used the position as "bread and butter" to buffer their solo law practices. Upon entering this year's budget cycle, the agency was faced with a significant shortfall which could not be covered long-term by the temporary $3.00 increase in the rental unit fee borne by the landlords (see "Budget", above). With the Department facing a budget shortfall, it was the recommendation of the Board of Supervisor's Budget Analyst that the Department cut the half-time positions, in order to save the costs of paying double benefits. It would have been difficult for the Department to advance an argument on gender lines, since that was not who was utilizing the half-time positions. Still, the loss of half-time professional positions creates a less "family-friendly" context: it is unlikely that these more expensive positions will be recouped any time in the foreseeable future.

Recommendation: that it be a Citywide policy to retain half-time positions as options for employees, rather than leaving this fight for each Department to wage alone.


CEDAW TASK FORCE RECOMMENDATIONS AND RESPONSE TO THE RENT BOARD'S GENDER ANALYSIS

INTRODUCTION

The Rent Board is a relatively small City and County of San Francisco department charged with enforcement of the City of San Francisco's Rent Control Ordinance, passed in 1978. Its current focus is limited to implementing the ordinance, which in turn emphasizes providing information and referral services about rent control, and holding binding adjudications to resolve disputes.

This report is a response to the Rent Boards' gender analysis originating from San Francisco's local implementation of the principles of the United Nations Convention On The Elimination Of All Forms Of Discrimination Against Women (CEDAW). CEDAW's principles provide a broad, integrated human rights approach to achieving gender equity. During the calendar year 2000, the CEDAW Task Force through the Department on the Status of Women (DOSW) worked with the Rent Board to prepare a "gender analysis" of its budget, services and employment practices. In part, this process resulted in the Department's producing a report documenting their experiences, and identifying both best practices and areas for improvement. The department presented its report to the CEDAW Task Force on January 24, 2001. This CEDAW Task Force response documents some of the resulting discussion, analysis, and recommendations.

METHODOLOGY OF GENDER ANALYSIS

Two management level employees were trained in human rights with a gender perspective. This perspective recognizes that differences in life experiences based on gender often results in social, economic, political, and other inequities for women and girls. Management throughout spent time and effort gathering data and with the assistance of DOSW staff, analyzing information and making recommendations. To obtain both qualitative as well as quantitative data, two focus groups were offered. One focused on community feedback, the other on employee feedback. COSW staff facilitated the focus groups.

Rent Board management encouraged-but did not require-staff to participate in the employee focus group; only one employee chose to attend. This could indicate that employees are relatively satisfied, that they are too busy to participate, and/or other factors.

OVERVIEW OF DEPARTMENT

Residential Rent Stabilization and Arbitration Board (The Rent Board) is a quasi-judicial organization, created by an 1979 legislation to alleviate the city's housing crisis. The Ordinance mission is "to safeguard tenants from excessive rent increases and, at the same time, to assure landlords fair and adequate rents consistent with Federal Anti-Inflation Guidelines." Currently, the Rent Board does not play a significant role in shaping housing policy within the City. It views its duties as designated by legal mandate-most notably the Rent Control Ordinance. While the department's powers are not explicitly limited by statute, its funding is only provided for its designated duties. Given this, it would be difficult for the Rent Board to find resources to pursue significant policy work. Still, the Rent Board directly interacts with a large number of San Francisco's renters and landlords, and as such, is in a unique position to provide learned input on how housing policy changes could impact San Francisco's residents. There is a great need for citywide collaboration to alleviate our current housing crisis-in particular, to provide more affordable housing.

CEDAW Task Force recommends that the Rent Board work more in collaboration with other City departments to achieve a citywide policy for meeting housing needs of our residents, and currently for addressing the City's housing crisis by encouraging affordable housing options.

DATA COLLECTION INCOMPLETE

Data was collected pursuant to the guidelines. The Rent Board collects some data (e.g., neighborhood, zip code, type of petition) about its "two major constituencies: the landlord and tenant communities." However, none of this data is disaggregated by gender, ethnicity/race, or other such criteria. The data collection and consequently the analysis suffered greatly from a lack of gender-disaggregated data. As stated in the CEDAW Task Force's GUIDELINES FOR A GENDER ANALYSIS: HUMAN RIGHTS WITH A GENDER PERSPECTIVE, "the value of gender-disaggregated data cannot be over-estimated." A good analysis cannot be done with insufficient data. Steps must be taken to ensure that disaggregated data is collected and reported to the public. It is impossible to analyze trends or evaluate the affect of services on women and men if this information does not exist. With that in mind, one recommendation is to begin to collect this data, at minimally disaggregated by gender and race. Part of performing a gender analysis is to look at how gender affects every aspect of an organization and not just those services or budgetary items that are designated for women or girls.

Data Collection-Related Recommendations

The department recognizes that the way in which information is collected and analyzed is critical to the development and application of a gender perspective. Appropriate procedures in this regard will assist in recognizing gender patterns in services and budget concerns. The department further recognizes that a human rights analysis understands the important links between gender and other social identities such as race, immigration status, parental status, language, sexual orientation, disability, age, and other status. For example, without knowing the gender identity of landlords, it is difficult to determine if customer satisfaction is equal for women and men. Similarly, data on the gender of tenants is necessary to analyze whether women or men are disproportionately the subjects of wrongful evictions.

This analysis of budget and services failed to look at gender in large part because of a lack of any current data in this area. Presently, the department's statistics are restricted to its obvious service operations and its funding sources. The Rent Board's current data statistics uses criteria limited to landlord or tenant, neighborhood, type of petition, type of eviction, etc. Because of this lack of demographic data, the department has only anecdotal evidence about whom it serves in terms of gender, race, ethnicity, languages spoken, sexual identity, age or other such criteria. With the exception of some data on the numbers of employees, no data collected was disaggregated by gender, race or other categories. No budgetary items or services data had any indication of gender awareness. There was minimal anecdotal information available regarding which members of the public utilize the services of the Rent Board. While department staff states that they serve a diverse population, without hard data about this population, the department is unable to conduct a fully adequate gender analysis of its budget or services. However, as a result of this analysis, the department will be modifying its customer Evaluation form in order to track comments from female members of the public (see page 4, Services Recommendation).

In addition to evaluations, analyze budget allocations and service provisions by gender and ethnicity: this necessitates tracking the department's programming/customers by gender and ethnicity (disaggregating)-which is benefiting from your programming? Who are the tenants/landlords you serve? -Who are paying your fees? This does not all need to be done with extensive forms and complicated databases. A few simple and voluntary questions could be added to current forms or staff could be trained and asked to give estimates based on close observation for a period of time of who, for instance, comes to the front desk for help.

A major study is currently being conducted by the department on the city's housing situation in San Francisco. The study will be a neutral, fact-based study that will present a statistical picture of the city, presented to the Board of Supervisors for their consideration and action. The CEDAW Task Force urges the department to include gender as one of the criteria for analysis.

Gender, race and other disaggregated data should also be reflected and considered in developing all of the Rent Board's forms and surveys. This information is crucial for a more complete analysis.

BUDGET

A gender analysis of a Department's budget is closely related to its services. It looks at what services receive the greatest funding and whom each type of service serves. While the department may be unable to modify its type of service (due to legal mandate, etc.) an analysis is still needed and valuable to understand the gender impact of external restrictions such as the law.

In answer to the question about how gender was considered as part of the budget, the department responded, "Given the judicial nature of the department, we perceive our operation as being "blind" to justice with equal treatment for all." While admirable for its commitment to equality, this philosophy of sameness may not always result in its intended goal of equity. Disregarding gender, race, and other such criterion actually furthers inequity by ignoring the varying social and political realities experienced by men and women, people of different ethnicities, etc. CEDAW and international human rights require a look at differences (gender, race, ethnicity, etc.) in order to meet equitable outcomes and so that services and programming can be designed to meet the needs of all.

Currently, the department has no strategic plan. The department has indicated that based on its ordinance driven legal mandate it does not need traditional strategic planning and that its budgeting goals are also based on legal mandates. While the director talks to different groups for input, there is no institutionalized process in place to get public or employee input and no plan for doing things differently. We understand that additional funding may be difficult to find, however, it would be aided by a planning process that was based on disaggregated data and a process which institutionalized public and employee input. A strategic plan and departmental priorities should address the tenants' and landlords' needs as reflected in disaggregated data.

What are the ethnic/gender stats of the Commissioners? From the data available on the Rent Board's website (https://sfrb.org/commission-meetings#commission) it appears that the commission has four Caucasian women out of ten commissioners. This does not appear to be a representative body given San Francisco's diverse population.

SERVICES

The Department has no hard data on who utilizes their services other than landlords and tenants. This makes analysis incomplete. Anecdotal evidence pointed to a large number of elderly women both utilize the services as small landlords and possibly benefit from rent control laws as renters. Task Force members pointed out that young women, women with children, low income women or women in domestic violence situations are the most likely to move around a lot and thus may be unprotected by current rent control provisions despite a great need for affordable housing.

One community focus group was held, with a majority of both women and landlords attending (invitations were sent to equal numbers of landlord and tenant groups). The legal nature of much of the work of the department, was reflected in anecdotal evidence from the focus groups, that materials were not written in plain English much less different languages that made it simple for consumers to understand one's rights and responsibilities. The Department recognizes the need for more translators and has made an effort to translate many of its materials into different languages. The department's variety of ways to give information, in more than one language, and the variety of ways it asks for feedback on services is to be commended as a best practice. While noting a need for even more bilingual staff and materials there are twenty-four hour information available, counseling services in more than one language, extensive information on the web, and a fax service. Language accessibility is an issue; most materials are in Chinese and Spanish but there is a shortage of interpreters.

Staff explained that the Department is currently monitoring a study being done on the rent control/housing affects in the City. Staff also indicated that gender is not a factor in this study. Given how little data exists on gender within the department we recommend this is an appropriate issue to be included when looking at how rent control affects housing issues. For instance, can the rent control provisions be changed to address the previous mentioned issue of young women, low income women and women in domestic violence situations needing to move around a lot and not utilizing the benefits of the rent control laws? Is this being looked at in the current rent control/housing study? IF NOT, could this be included or studied. In particular, the focus group noted that the cohabitation rules may disproportionately affect woman:

"Co-habituating is going up in San Francisco because of the housing market. From the human rights standpoint, there is a disproportionate impact of cohabitation restrictions on women. Women often are awarded custody of children, & & were told they could not move in with these children, because the use laws limited the number of people."

Both landlord and tenants, women and men, felt the Administrative Law judges were fair. This demonstrates the Departments clear efforts to stay neutral in the administration of the rent control regulations.

Customer satisfaction is obvious a high priority of the department and staff are given resources to collect the customer feedback. This customer service approach would benefit from integrating gender, race, and other criteria, as discussed above. Of course, in order to continue to protect customers from misuse of sensitive identifying information, any request for such information must make clear that it is voluntary and optional and for purposes of improving customer service.

EMPLOYMENT

The Rent Board gender analysis here demonstrates that the Rent Board best practices as to gender may be due to the work environment itself. A focus group for employees was open to all staff. While not required to go all staff were invited to come give their opinions on a variety of topics. Only one staff member, a woman chose to take part and most of her anecdotal evidence indicated a very positive balanced work life approach to as employers. Staff theorized that employees did not feel the need to attend as they had no real issues to deal within this area (see below). Lack of staff participation may also have been linked to the small amount of staff (two) that attended the human rights training that explored issues raised by the gender analysis.

The focus group participant and the gender analysis both pointed to physical security in the work environment as an issue. Given the extremely volatile nature of the housing market in San Francisco the frustration of so many in this area, safety in the workplace is a concern. And while the Department has a violence prevention program and training, CEDAW Task Force members recommended inclusion of domestic violence prevention training as part of the program.

Another interesting issue raised, was the need to reclassify to attract more male employees. The focus participant stated that the recent reclassification of Hearing Officers to Administrative Law Judges made a difference in the professional community. The new position represents the status of a lawyer.

"The reclassification, however, did not make a difference in recruiting because the salary is still too low to attract men."& .."Men don't appreciate the flex-time. It's not a real job to them." & & ."We did have to justify the reclassification with the purpose of recruitment, to attract more men."

The participant described the Rent Board as a model for best practices in flexibility in work: it offers part-time and flex-time, and has a good record of promoting women. The participant stated that part-time work and flex-time creates a positive work environment, improves work performance and creating a great place for women to work.

"It is a great place to work, as a woman. When I had my first son I went from full-time to create a job share." "I took my maternity leave and while on leave, was promoted. "I have a lot of support from the whole staff - responsibility, flexibility and trust. I get more work done at home." "All 16 [Administrative Law Judges]& are on flex time, telecommuting, spending two days a week in the office. They have productivity goals, which they do reach& I have an average number of hours per decision. It's almost mathematical." "Those who cannot work at home have an office here." "I don't have to spend 1 ½ hours commuting each way. It's much saner. One day I work until midnight in the office. I don't work at all on Friday."

The Rent Board also promotes flexibility with access to technology. Each person purchases their own computer and the Rent Board allows connection to the system. The Rent Board provides voice mail for everyone.

RECOMMENDATIONS: In addition to the Rent Board's own recommendations the CEDAW Task Force makes the following ones:

1) Collect more disaggregating data, this includes both services (petitioners and respondents), public who requests information at front desk, or calls for information and those that give voluntarily customer feedback. Current forms can be changed to request some additional information; this can all be on an optional basis. Staff can be asked to do an informal count of those that come to front desk on a sporadic basis to gather minimal data on who is utilizing the services.

2) The rent control/housing study and future studies should include gender as an issue, with a particular focus on young women, women victims of domestic violence, and low-income women.

3) Set goals for increasing language accessibility including the number of interpreters.

4) Maintain the Rent Board's flexibility and work-life balance concerns, and consider adding additional resources, such as information and referral for both child and eldercare issues.

5) Add domestic violence to the violence prevention program.