2021 NYCHVS OMB_SupportingStatementA_final

SUPPORTING STATEMENT A

U.S. Department of Commerce

U.S. Census Bureau

2021 New York City Housing and Vacancy Survey

OMB Control Number 0607-0757

Abstract

The New York City Housing and Vacancy Survey (NYCHVS) is sponsored by the New York City Department of Housing Preservation and Development and is conducted approximately every three years. The Census Bureau has conducted the survey for the City since 1965. The primary purpose of the survey is to measure the net rental vacancy rate, and describe the supply, condition, and continued need for rent control and rent stabilization. NYCHVS data are also used by policymakers, advocates, and researchers to inform policy and analyze housing costs and conditions in the City.

Detailed data from the survey cover many characteristics of the City’s housing market, including characteristics of the City’s population, households, housing stock, and neighborhoods. Data collected about each person in the household include housing costs and burden, income and employment, and key demographics, including membership in protected classes. On the household level, the NYCHVS collects data including total housing costs and income, public assistance, and residential history. Data on the City’s housing stock include building and unit quality and condition, rent regulatory and homeownership status, and unit size.

Justification

1. Circumstances Making the Collection of Information Necessary

Pursuant to the Local Emergency Housing Rent Control Act of 1962 (as amended), as implemented by Section 26-415 of the Administrative Code of the City of New York, the City of New York must conduct a survey of the housing conditions in the five boroughs of New York City. The survey, known as the New York City Housing and Vacancy Survey (NYCHVS), will help determine the supply of housing accommodations, the condition of such accommodations, the rate of vacancy of such accommodations, and other housing market characteristics as are necessary for determining the need for continuing the regulation and control of residential rents and evictions in the City. The Census Bureau has a long history and an excellent working relationship with the Department of Housing Preservation and Development (NYCHPD), the City agency that is charged with conducting the survey (also referred to as survey sponsor). This is the eighteenth contract that the Census Bureau will have entered into with the City of New York to conduct the NYCHVS. Data are collected for the five boroughs of New York City (Bronx, Brooklyn, Manhattan, Queens, and Staten Island).

The U.S. Census Bureau requests approval to conduct the 2021 New York City Housing and Vacancy Survey (NYCHVS) on behalf of the NYCHPD. The Census Bureau has conducted this survey for the city since 1965, most recently in 2017 under the authority of Title 13 U.S.C., Section 8b.

Census Bureau field representatives will conduct personal visit interviews for a sample of housing units in the City, the vast majority of which are rental units in multi-unit rental structures (apartment buildings). Single-family rental and owner-occupied units (houses), are also included in the sample. The respondents will be residents of occupied units or, in the instance of vacant units, building managers, superintendents, or rental or real estate agents. About 13 percent of the sample will be reinterviewed for quality control purposes. Reinterview questions ask respondents whether they recall general details from the original interview. The reinterview instrument will contain five questions. Each respondent will be asked all five questions; however, the questions have been revised to be more general and memorable. Included in this clearance are the cost and respondent burden estimates for the reinterview.

The NYCHVS has collected key data on the New York City housing stock and its resident population since 1965, with the last major revisions to the questionnaire (and survey design) in 1991.

At the conclusion of the 2017 NYCHVS, a comprehensive review was conducted to identify opportunities to increase the value of the survey for current and future generations of users. This review was completed by Sponsor staff at the NYC Department of Housing Preservation and Development and incorporated feedback from conversations with more than two dozen organizations, including NYCHVS users at other NYC agencies, non-profits, and academic institutions as well as ongoing conversations with multiple divisions within the United States Census Bureau.

Some of the key findings and recommendations include the following:

• Researchers rely on NYCHVS data to understand the current state of housing and how key aspects of the stock have changed over time.

• The NYCHVS is the primary source of comprehensive information on rent regulated units; the survey should continue to focus on this subset of the housing stock and resident population and incorporate additional information where possible to understand how this segment of New York City is changing.

• The NYCHVS facilitates comparisons among different subsets of the population, including by race/ethnicity, nativity, age, and household composition; the survey should collect information to facilitate analysis of issues related to fair housing.

• The NYCHVS is a source of information that has, and should, support decision making in various policy domains beyond housing; to the extent possible, the survey should expand the types of questions it collects to support more coordinated policymaking, including information on household costs, ability to meet critical expenses, and debt/assets.

The pandemic has exacerbated long-standing disparities in the socioeconomic determinants of health, resulting in significantly higher infection and death rates among racial/ethnic minorities and those living in disadvantaged communities. Moreover, those most affected by the immediate aftermath of the pandemic may also be more likely to accumulate higher levels of debt that place them at risk of future default or eviction, face prolonged unemployment due to anticipated shifts in the economy, live in neighborhoods where small businesses will never reopen, and have children who have fallen farther behind after months of remote learning. From both a scientific and policy perspective, it is imperative to gather high quality, representative data not only on the immediate effects of the pandemic, but also on new sources of risk and differential rates of recovery that may increase inequality over time. This information is critical for tracking the consequences for vulnerable populations, refining public assistance programs, and fostering resilience in the face of future disasters and public health emergencies in New York City and beyond.

The addition of COVID questions to this survey is a unique opportunity to gather time-sensitive and relevant information on the pandemic on a large, representative sample, with sufficient statistical power for analysis by a variety of demographic and family characteristics at both the individual and household level.

Based on internal testing of mock interviews with the redesigned survey instrument, we expect the average interview time of occupied housing units to be about 40 minutes, which represents a 10-minute increase from that of the 2017 NYCHVS.

At the request of the survey sponsor, the survey instrument was translated into Spanish, Chinese (simplified and traditional), Russian, Haitian Creole and Bengali. These languages cover some of the largest non-English speaking segments of the NYC population.

2. Needs and Uses

The 2021 NYCHVS will be an up-to-date and comprehensive data source required by rent regulation laws as well as a source of data needed to evaluate the city's housing policies. Specifically, NYCHPD will look to the 2021 survey to provide accurate and reliable estimates of the rental and homeowner vacancy rates, to measure improvements in housing and neighborhood conditions, and to provide data on low-income, doubled-up, and crowded households at risk of becoming homeless.

The NYCHPD works with affordable housing developers to use City, State, and Federal subsidies to finance the creation of thousands of affordable units every year. This includes single and multi-family housing, senior housing, and supportive housing for formerly homeless and disabled individuals. There is a housing plan to build and preserve 300,000 affordable units by 2026 to support New Yorkers with a range of incomes. Current housing statistics specific to New York City are critical for this plan.

Information quality is an integral part of the pre‑dissemination review of the information disseminated by the Census Bureau (fully described in the Census Bureau's Information Quality Guidelines). Information quality is also integral to the information collections conducted by the Census Bureau and is incorporated into the clearance process required by the Paperwork Reduction Act.

Conducting the NYCHVS and producing important statistics is consistent with the Census Bureau’s mission of providing quality data on housing, population, and the economy (in this case, for the City of New York). Survey results are also compared to other Census Bureau surveys, such as the Current Population Survey/Housing Vacancy Survey (CPS/HVS) and American Community Survey (ACS), as well to the Decennial Census. Discrepancies in data between censuses and surveys can lead to improved data collection procedures, improved editing, and ultimately higher quality data for all surveys.

2. Use of Improved Information Technology and Burden Reduction

The 2021 NYCHVS will be the first time this survey is administered to respondents via computer-assisted personal interview, which will streamline field operations. As in previous years, each sample unit interview will be assigned a unique identification number, which allows it to be tracked throughout all phases of the operation. This substantially reduces the level of unnecessary personal visit follow-up, thereby reducing respondent burden.

2. Efforts to Identify Duplication

This survey was most recently conducted in 2017. No similar information in this detail and level of reliability has been collected since that time by New York City or the Census Bureau.

Pursuant to the Local Emergency Housing Rent Control Act and the Administrative Code of the City of New York, a survey must be conducted in order to determine housing conditions in the City. Such survey should determine the supply of housing accommodations, the condition of such accommodations, the rate of vacancy of such accommodations, and such other housing market characteristics as are necessary for determining the need for continuing the regulation and control of residential rents in the City.

2. Methods to Minimize Burden on Small Businesses

The 2021 NYCHVS is primarily a household survey; however, some rental agents, managers, superintendents and realtors may need to be interviewed for vacant units.

The survey is designed to obtain the required information with minimal respondent burden possible. The proposed survey instrument and interviewer procedures have been developed as a result of consultation between the Census Bureau and the NYCHPD, who also has had consultations with other New York City government agencies, outside individuals and organizations. Further, there are no legal issues that influence respondent burden.

2. Consequences of Less Frequent Collection

The NYCHVS has to be conducted about every three years in order to comply with currently existing New York State and New York City laws related to rent regulation, specifically Local Emergency Housing Rent Control Act of 1962 (as amended), as well as Sections 26-414 and 26-415 of the Administrative Code of the City of New York. More information about the Local Emergency Housing Rent Control Act of 1962 and Sections 26-414 and 26-415 of the Administrative Code of the City of New York can be found in Attachment D, Legal Citations of NYC.

7. Special Circumstances

Data for the 2021 NYCHVS will be collected in a manner consistent with OMB guidelines.

• Consultations Outside the Agency

The notice required by 5 CFR 1320.8 (d) appeared in the Federal Register on March 13, 2020, Volume 85, pages 14633-14634. One comment was received in response to the notice, but it was unrelated to this collection.

In some cases, the NYCHPD received specific suggestions for questions from stakeholders or subject matter experts. In other cases, the team reviewed questionnaires from other surveys to identify candidate questions. In all cases, priority was given to validated questions from other Census surveys first (e.g., AHS, ACS, SIPP), followed by other widely used sources such as national surveys (e.g., PSID, Fragile Families, GSS), specialized surveys that are commonly used by the research community (e.g., PHDCN, MARS), or relevant New York City surveys that have been fielded successfully (e.g., CHS, HANS). For content where either no existing question(s) could be found or where the existing body of survey questions did not provide a viable option, new questions were drafted by NYCHPD and refined through a combination of expert review and cognitive testing.

a. Persons Consulted

Elyzabeth Gaumer is the primary representative for the NYCHPD and for the NYCHVS. The Census Bureau has been in contact with her and members of her staff concerning the 2021 survey since March 2018. She can be reached on (212)863-5145.

Additionally, Louise Carroll, Commissioner, NYCHPD, also has first-hand knowledge of the NYCHVS requirements and can be reached on (212)863-6100.

b. Major Problems

There are no points of contention between the Census Bureau and the NYCHPD. All work to be performed will be by mutual agreement and specified in a formal contract to be signed by both parties.

c. Other Public Contacts

All other public contacts have been coordinated by NYCHPD.

• Payment or Gifts to Respondents

The Census Bureau does not make any payments or provide any gifts to individuals participating in the NYCHVS.

• Assurance of Confidentiality

Respondents are informed that the information they provide will be held in strict confidence, and that participation in the survey is voluntary. A letter, Form H-100(L), is sent to every selected housing unit prior to the survey. It explains, in addition to the confidential nature of the data, that a field representative will visit to conduct the survey and how long the interview will require. The letter displays the OMB control number and date of expiration.

As part of the introduction for personal-visit households, the Census Bureau FRs will ask the respondents if they received the Advance Letter. If not, the FRs will give the letter to the respondents and allow them sufficient time to read the contents. We also display the program website and the toll-free phone number of the regional office for which the FR works as a way for the respondent to authenticate her/his employment with the Census Bureau.

The Privacy Act does apply to this collection under System of Record Notice (SORN) number COMMERCE/Census-3, Special Censuses, Surveys, and Other Studies. The FRN citation is 85 FR 14633. Title 13, Section 9, United States Code assures that no information that could identify any individual person or household will be released to any other government agency (Federal, state, or local) or to any private organization or individual. All information from the survey will be used strictly for statistical purposes.

• Justification for Sensitive Questions

This survey does not contain any questions that are of a sensitive nature.

• Estimate of Respondent Burden

The Census Bureau will conduct the survey by personal interview using the 2021 NYCHVS CAPI Instrument. The average time for an occupied unit interview is 40 minutes. As a means of quality control, we will reinterview owners, building managers, real estate or rental agents, superintendents, or neighbors (as a last resort only) at all vacant units and the residents at 5 percent of occupied units using the 2021 NYCHVS Reinterview Instrument, which requires 10 minutes to complete. These estimates of respondent burden are based on previous experience conducting the survey and internal testing of the new 2021 NYCHVS instrument.

Please note the 2021 NYCHVS 30-day Federal Register Notice (FRN) indicates the estimated number of respondents as 12,000, however, the correct number is 13,500.  The 12,000 total does not include the estimated number of reinterviews needed, which is 1,500 cases.  The 30-day FRN does provide the correct estimated number of respondent burden hours of 7,804.  It is also worth noting that the average hours per response will actually be less than the 0.67 hours indicated on the 30-day FRN once the 1,500 reinterview cases are considered.  The average length of time for conducting the reinterview cases is 0.17 hours.

Table 1. Estimated Annual Hour and Cost Burden to Respondents

Type of Respondent	Expected Number of Respondents	Average Burden per Response (in hours)	Total Burden Hours	Hourly Wage Rate1	Total Respondent Cost
NYCHVS Production
Householder or household member (Occupied Units)	11,000	0.67	7,370	$15.18	$111,877
Owner, superintendent, rental/office agent, real estate agent/broker, etc. (Vacant Units)	1,000	0.17	170	$15.18	$2,581
Reinterview (Occupied Units)	550	0.17	94	$15.18	$1,427
Reinterview (Vacant Units)	1,000	0.17	170	$15.18	$2,581
Total	13,500		7,804		$118,466

• Estimates of Other Total Cost Burden to Respondents

There are no capital/start-up or ongoing operation/maintenance costs associated with this information collection.

• Cost to the Federal Government

This survey will be conducted at no cost to the Federal Government. The total estimated cost of $12,795,000 is funded completely by the survey sponsor, the New York City Department of Housing Preservation and Development.

• Reasons for Program Changes and Adjustments Change in Burden

Program Changes:

• The method of collection changed from a Paper Assisted Personal Interview (PAPI - paper) to Computer Assisted Personal Interview (CAPI - laptop) in order to streamline data collection efforts.

Adjustments: The estimated respondent burden is considerably lower than the estimate from the 2017 NYCHVS and as reported in the Federal Register at 85 FR 14633 due to a considerable survey sample reduction that was implemented as a result of the delay caused by the COVID-19 pandemic. The survey sample size was reduced from 30,000 to 12,000 due to these changes, which in turn reduced the estimated respondent burden from 20,000 hours to 7,804 hours.

• Project Schedule

Survey interviewing is scheduled to begin on February 1, 2021. The units selected for reinterview will be enumerated shortly after the initial interview. All interviewing will conclude by May 31, 2021 and reinterview will be complete in June 2021. The NYCHPD will receive tabulations by January 2022, in order to fulfill reporting requirements. Remaining products, including a microdata file and tabular estimates will be available in 2022 and 2023 on the Internet at https://www.census.gov/programs-surveys/nychvs.html.

The data being disseminated and released are not individually identifiable and will have been cleared for release/dissemination by the Census Bureau's Disclosure Review Board.

• Display of OMB Approval Information

The Census Bureau will print the OMB approval number and expiration date on each outgoing 2021 New York City Housing and Vacancy Survey Letter, Form H-100(L). This information also appears on the 2021 NYCHVS Instrument, and on the 2021 NYCHVS Reinterview Instrument; however, these forms are not typically viewed by the respondent.

• Exceptions to the Certification

The agency certifies compliance with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3)

1 We tabulated median person income (from the 2017 NYCHVS results), adjusted for inflation, and computed the hourly rate of pay. NOTE: Details may not sum to totals due to rounding of partial hours.

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