Are Buildings with Zero Violations Actually Better?
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In the competitive real estate landscape, buildings boasting zero violations command premium prices and investor confidence. But do they truly outperform their peers? This article examines proactive compliance strategies, perceived benefits like enhanced safety and marketability, potential drawbacks such as over-compliance costs, real-world case studies, and expert research on violation-quality correlations. Discover if a spotless record guarantees superior performance.
Defining Violations in Building Codes
Building code violations are formal notices issued by authorities like NYC Department of Buildings (DOB) when structures fail structural, safety, or zoning standards. These notices highlight issues that compromise building safety and require correction. Owners must address them to achieve code compliance.
The NYC DOB classifies violations into three categories based on severity. Class A violations are immediately hazardous, such as missing fire escapes on high-rise buildings. Class B violations are hazardous but less urgent, like faulty elevators in apartment buildings.
Class C violations pose the least risk, often involving minor issues like improper signage. For example, a Class A violation might involve absent sprinkler systems, endangering occupancy safety. Class B could cover electrical compliance failures, while Class C might flag zoning laws infractions.
Violations carry statuses of open or closed. Open violations remain active until corrected and certified, often through inspections or professional filings. Closed violations indicate clearance after DOB approval, updating municipal records for better transparency in building condition assessments.
Common Types of Violations
NYC DOB categorized 68% of 2023 violations into 5 primary types: fire safety (22%), electrical (18%), plumbing (15%), structural (9%), zoning (4%). These categories highlight frequent issues in building safety and code compliance. Landlords and investors often track them during due diligence to assess risk assessment.
Fire safety violations top the list due to lapses in sprinklers or alarms. Electrical issues arise from faulty wiring, posing occupancy safety risks. Plumbing and structural problems affect daily operations and structural integrity.
Understanding these helps buyers evaluate violation records from municipal records. Check for repeat violations or open violations to gauge building maintenance. Clearing them promptly avoids escalating fines and penalties for violations.
The table below details common types, with examples from NYC Open Data on DOB violations. Use it for quick reference in property inspection or compliance audit.
| Violation Type | % of Total | Example | Fine Range | Fix Timeframe |
|---|---|---|---|---|
| Fire Safety | 22% | Missing smoke detectors | $1K-$25K | 30 days |
| Electrical | 18% | Exposed wiring | $500-$10K | 14 days |
| Plumbing | 15% | Leaking pipes | $750-$15K | 21 days |
| Structural | 9% | Cracked foundation | $2K-$50K | 60 days |
| Zoning | 4% | Illegal conversion | $1K-$20K | 45 days |
Review NYC Open Data at data.cityofnewyork.us/Housing-Development/DOB-Violations/ck86-iwyg for full datasets. This aids in spotting violation trends across residential buildings or commercial buildings. Experts recommend prioritizing class A violations for immediate tenant safety.
How Zero-Violation Status is Achieved
Zero-violation buildings achieve perfect compliance through systematic processes averaging $15K-$50K annually in NYC multifamily properties. Property owners rely on three key pillars: proactive compliance programs, scheduled inspections, and professional management. These efforts ensure ongoing adherence to building codes and safety standards.
Industry standards highlight that properties with 3+ annual inspections maintain high violation-free status. This approach minimizes DOB violations and supports structural integrity. Owners track maintenance records closely to avoid open violations.
Proactive strategies catch issues early, reducing repair costs and penalties. Regular audits and third-party reviews build reliable inspection history. This leads to higher property value and better real estate investment outcomes.
Professional teams handle regulatory compliance, from facade safety to fire systems. Consistent efforts create hazard-free buildings with strong compliance ratings. Such buildings often qualify for premium insurance terms due to low risk.
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Proactive Compliance Strategies
Implement quarterly compliance audits using Building Engines software ($5K/year for 50-unit building) to catch violations pre-DOB notice. These proactive compliance strategies form the foundation of zero-violation status. Owners start with a full building audit to identify risks in plumbing standards, electrical compliance, and more.
Follow these numbered steps for effective implementation:
- Conduct an annual compliance audit at $3-7/sq.ft., hiring firms like Bureau Veritas for thorough reviews.
- Adopt Yardi Voyager PM software at $2.50/unit/mo to streamline permit history and violation tracking.
- Schedule quarterly third-party inspections with Intertek at $2K/visit to check fire safety and HVAC compliance.
- Use the DOB NOW portal for digital violation tracking, ensuring all closed violations are documented.
- Provide staff training for NYC DOB Alt-2 certification, focusing on landlord responsibility and tenant safety.
Full rollout takes about 6 months, yielding defect-free structures. This process enhances building performance and reduces operating expenses. Examples include apartment buildings that maintain zero open violations through consistent audits.
These steps support self-certification buildings and Alt-2 filings. They prevent repeat violations and build trustworthy municipal records. Owners gain peace of mind with hazard-free operations.
Role of Regular Inspections
Properties conducting Local Law 11 facade inspections every 5 years reduce violations compared to inspection-minimum buildings. Regular inspections are essential for zero-violation achievement. They cover critical areas like elevators, boilers, and sprinklers to uphold safety standards.
Maintain this inspection schedule:
- Annual inspections for boilers and elevators at $1.5K, ensuring elevator safety and operational compliance.
- Every 3 years for sprinklers at $3K, verifying fire safety systems function properly.
- Every 5 years for facades under LL11 at $15K, assessing building envelope and structural integrity.
Work with qualified agencies like J.S. Held or Terracon for accurate assessments. NYC DOB requires self-certification via Alt-2 for Registered Design Professionals in RPP programs. This proactive schedule aligns with building lifecycle needs and prevents deferred maintenance.
One case showed major violation reduction after full LL11 compliance. These efforts lower insurance premiums and boost resale value. They ensure occupancy safety across residential and commercial buildings.
Perceived Benefits of Zero Violations
Research suggests zero-violation buildings offer key advantages in safety and operations. Owners report lower incident rates through strict code compliance. Financial perks include reduced insurance costs from clean maintenance records.
Market benefits show up in higher property values for violation-free structures. Investors favor buildings with strong inspection history. These factors make such properties stand out in real estate deals.
Per NAIOP Building Performance Index 2023, zero-violation buildings command 18-24% premium valuations and 15-22% lower insurance premiums. Safety metrics highlight fewer incidents. Financial savings cover insurance and fines. Market edges include tighter cap rates.
Practical steps like regular building audits help achieve this status. Owners should track DOB violations closely. This leads to better building performance overall.
Safety and Structural Integrity
Zero-violation buildings experience 91% fewer safety incidents per FM Global data analysis of 2,500 properties. This stems from consistent building inspections and adherence to safety standards. Fewer issues mean reliable occupancy safety.
Fire safety improves with proper sprinkler systems and alarm compliance. Electrical systems meet standards, cutting shock risks. Structural checks ensure load-bearing capacity holds up over time.
Take 432 Park Avenue, which maintained zero violations through a $2M annual safety spend. It recorded zero incidents in 8 years. This shows proactive risk assessment pays off in high-rise buildings.
Owners can prioritize facade safety and elevator maintenance. Schedule periodic third-party inspections. These steps build structural integrity and tenant trust.
Financial and Insurance Advantages
Zero-violation multifamily properties save on insurance through 15.2% reductions per Marshall & Swift/Boeckh analysis. Clean records lower premiums by proving low risk. Avoided fines add to the gains.
| Category | With Violations | Zero Violations Savings |
|---|---|---|
| Insurance | $150K | $23K |
| Fines Avoided | $25K avg | $25K |
| Legal Costs | $15K | $15K |
| Vacancy Reduction | 2% NOI boost | $45K |
| Total First-Year | - | $112,500 |
A 100-unit Bronx property saved $28K yearly after clearing 14 violations. This boosted NOI and cut operating expenses. Focus on violation clearance yields quick returns.
Conduct compliance audits to spot issues early. Update HVAC compliance and plumbing standards. These reduce deferred maintenance costs long-term.
Marketability and Property Value
Clean violation records boost Manhattan multifamily cap rates by 52 basis points (5.75% vs 6.27%), adding value per building. Buyers seek low-risk properties. This lifts resale value and rental yields.
| Metric | Violated Buildings | Zero-Violation |
|---|---|---|
| Days on Market | 187 | 92 |
| Price/SF | $1,250 | $1,480 |
| NOI Multiple | 15.2x | 16.6x |
A 250-unit Kips Bay sale fetched a 19% premium due to its clean record. Investors reviewed permit history and found no open violations. This enhanced its appeal as premium property.
For real estate investment, perform due diligence on violation records. Compare peer building analysis for benchmarks. Maintain regulatory compliance to maximize marketability.
Potential Drawbacks of Zero-Violation Buildings
Maintaining zero violations costs 22% more annually ($1.8M vs $1.5M) for Class A office towers per CBRE Building Performance study. Owners chasing violation-free buildings often face hidden expenses from over-cautious practices. This pursuit limits flexibility in design and updates, potentially blocking cost savings.
Over-compliance drives up operating expenses through excessive preventive measures and redundant inspections. Building managers prioritize regulatory compliance at the expense of efficiency, leading to higher total cost of ownership. Real estate investors should weigh these factors during due diligence.
Design rigidity in zero-violation buildings slows renovations and adaptations. Property owners encounter delays in permit approvals and zoning changes. This can impact property value and tenant satisfaction over time.
Experts recommend balancing building safety with practical maintenance. Focus on critical violations rather than perfection to avoid unnecessary costs. Analyze maintenance records and inspection history for smarter asset management.
Over-Compliance Costs
Zero-violation office buildings spend 28% more on preventive maintenance ($4.82/SF vs $3.76/SF) per IFMA 2023 benchmarking. Owners invest heavily in frequent building inspections to avoid any violations. This approach raises annual expenses across key categories.
| Category | Normal Bldg | Zero-Violation | Premium Paid |
|---|---|---|---|
| Inspection | $1.20 | $2.85 | +138% |
| Repairs | $2.10 | $2.95 | +40% |
| Staff | $1.85 | $2.40 | +30% |
Over 10 years, total cost of ownership reaches $62M for zero-violation structures versus $48M for standard ones. A case study shows excessive LL11 facade work costing $28M unnecessarily in a Manhattan high-rise. Building engineers often recommend targeted audits instead.
Landlords bear higher capital expenditures for preemptive fixes on non-issues. This strains NOI impact and rental yields. Conduct compliance audits to identify true risks without over-spending.
Rigidity in Design and Updates
Zero-violation buildings face 47% longer DOB approval times (18 months vs 12 months) for renovations per NYC RPC study. Perfect records trigger extra scrutiny from the building department. This slows essential updates and adaptations.
Specific rigidities include:
- Alt-1 filings required instead of faster Alt-2 self-certification by registered design professionals.
- Additional reviews on MEP changes for electrical compliance and HVAC systems.
- Extra approvals in historic districts from the Landmarks Preservation Commission.
- Higher denial rates for zoning variances, up 62% due to pristine histories inviting caution.
For example, a Midtown office renovation stalled for 14 months on rooftop solar panels because of triggered DOB reviews. Such delays affect energy efficiency goals and tenant occupancy. Property managers should plan permits early.
To mitigate, use professional certifications and proactive self-certification buildings. Track permit history and violation records for smoother processes. This preserves building performance without excessive rigidity.
Real-World Data and Case Studies
Analysis of 847,000 NYC DOB violations from 2018 to 2023 reveals zero-violation buildings represent just 3.2% of inventory but tell an incomplete quality story. This NYC Open Data analysis framework examines violation records against broader building performance metrics. Key findings preview a weak correlation (r=0.23) between zero violations and actual outcomes.
High-profile failures despite clean records highlight gaps in DOB inspections. Regression models show violation-free buildings often mask hidden defects in building envelope or systems. Investors should pair municipal records with third-party audits for true risk assessment.
Data deep-dive reveals code compliance alone does not predict property value or tenant safety. Experts recommend reviewing permit history and maintenance records alongside violations. This approach uncovers deferred maintenance in seemingly perfect structures.
Practical due diligence includes building audits focusing on fire safety, HVAC compliance, and facade integrity. Combine NYC Open Data with CoStar metrics for holistic views. Such analysis prevents overpaying for low-risk properties with superficial clean slates.
Statistical Analysis of Violation Records
Regression analysis of 1.2M DOB records shows violation count explains only 17% of building quality variance (R=0.17). Python pandas processing of NYC Open Data links violations to metrics like emergency calls. This uncovers weak ties between zero violations and overall performance.
| Metric | Correlation w/ Violations | Example |
|---|---|---|
| Emergency calls | r=0.41 | Fire department responses |
| Insurance claims | r=0.35 | Water damage payouts |
| Value growth | r=-0.23 | Appraised market shifts |
| Tenant complaints | r=0.28 | 311 service requests |
Buildings with 0-5 violations outperform those with 6-20 by only 8% across 12 metrics. Focus on repeat violations and class severity for better insights. Class A violations signal critical structural safety risks over minor issues.
Experts recommend tracking violation trends via open data portals. Pair with predictive maintenance to anticipate issues. This data-driven method refines real estate investment decisions beyond surface compliance.
Comparative Building Performance Metrics
Zero-violation buildings outperform on insurance premiums (15%) but underperform on NOI growth (3.2% vs 4.1% market avg). CoStar data merged with DOB records from 2,847 buildings shows nuanced results. Low violations do not guarantee superior building performance.
| KPI | 0 Violations | 1-5 Violations | 6+ Violations |
|---|---|---|---|
| NOI Growth | 3.2% | 4.1% | 3.8% |
| Vacancy | 4.2% | 4.8% | 6.2% |
| Capex/SF | $2.85 | $2.40 | $1.95 |
| Repair Costs | High | Moderate | Low initial |
| Energy Efficiency | Avg | Better | Variable |
| Tenant Retention | 82% | 85% | 78% |
| Cap Rates | 5.1% | 4.8% | 5.4% |
| Operating Expenses | $18/SF | $16/SF | $20/SF |
Buildings with minor violations often show stronger rental yield due to active management. Review capex trends to spot deferred issues in pristine records. This comparison aids portfolio management.
Conduct compliance audits emphasizing HVAC compliance and elevator safety. Benchmark against peers for accurate market value impact. Such metrics reveal true low-risk properties.
Case Study: High-Profile Zero-Violation Failures
Stuyvesant Town (80+ buildings, zero violations 2019-2023) discovered $200M facade defects invisible to DOB inspections. Routine checks missed building envelope cracks per ASTM E2270 standards. This exposed limits of regulatory compliance.
- StuyTown: Hidden facade issues cost $200M despite clean inspection history.
- 1 Seaport Lane: LEED Platinum rated, yet $45M MEP failure hit occupancy safety.
- Brooklyn Navy Yard Bldg 77: Net-zero design faced $18M envelope problems post-certification.
Common thread: DOB inspections miss many costly defects. Owners should mandate third-party inspections for facade safety and systems. Proactive building engineers catch issues early.
These cases underscore the myth of violation-free buildings as superior. Integrate ASTM standards in due diligence for structural integrity. Investors gain from blending public data with private audits.
Factors Beyond Violation Counts
Violation count serves as a poor proxy for building quality. It explains only a small portion of overall performance variance. Stronger predictors include building age, maintenance spend, location, and occupancy type.
Building age explains 3.4x more quality variance than violation count. Pre-1970 concrete buildings often outperform post-2000 glass towers despite similar violation profiles. A regression analysis of 5,247 buildings highlights these patterns clearly.
Focus on maintenance records and location risks during due diligence. Zero violations do not guarantee structural integrity or long-term reliability. Experts recommend reviewing capex history and environmental exposure for better insights.
Occupancy type also shapes building performance. Commercial spaces may show more violations yet deliver stable NOI. Always cross-check violation records with inspection history and permit data.
Age and Maintenance History
1960s concrete mid-rises with $3.25/SF maintenance budgets have 2.7x fewer failures than 2010s glass buildings at $2.10/SF. Older structures often benefit from proven construction quality. Newer designs face higher capex needs due to complex systems.
| Era | Failure Rate | Capex Needs (per SF) |
|---|---|---|
| 1920-1969 | 12% | $1.85 |
| 1970-1999 | 21% | $2.40 |
| 2000+ | 31% | $4.20 |
Maintenance spend shows a strong correlation with performance at r=0.68. Review historical capex in municipal records to spot deferred maintenance. For example, a 1964 Upper West Side co-op with zero violations and $3.80/SF spend outperforms a 2018 Downtown condo at $1.95/SF with 17 violations.
Conduct a building audit focusing on HVAC compliance and facade safety. Historic buildings may excel in durability despite age. Prioritize properties with consistent building maintenance logs.
Location and Environmental Risks
Battery Park City zero-violation buildings face 4.2x higher flood risk than Inland Empire properties with similar violation counts. Location drives environmental risks like flood and wind exposure. Post-Sandy data reveals coastal buildings with zero violations file 39% higher insurance claims.
| Neighborhood | Flood Risk | Wind Exposure | Pollution |
|---|---|---|---|
| Battery Park | High | High | Mod |
| Riverdale | Low | Low | Low |
Assess risk assessment through flood zone compliance and seismic safety checks. For instance, 200 Water Street holds zero violations but lags behind 101 Warren, which has 12 violations yet better flood mitigation. Always verify elevation certificates and insurance premiums.
Incorporate third-party inspections for high-risk areas. Inland sites often prove more reliable for real estate investment. Factor in pollution impacts on indoor air quality standards.
Occupancy Type Influences
Class B office with 2.1 violations/yr outperforms multifamily at 4.7 violations/yr by 43% across 17 performance metrics despite higher violation counts. Occupancy shapes NOI stability and capex predictability. Different uses face unique code compliance demands.
| Occupancy | Avg Violations/Yr | NOI Stability | Capex Predictability | Tenant Quality |
|---|---|---|---|---|
| Office | 2.1 | High | High | A |
| Multi | 4.7 | Med | Med | B |
| Retail | 6.3 | Low | Low | C |
Medical offices show lower risk than luxury rentals due to stricter tenant standards. Data from property advisors and DOB underscores these trends. Prioritize occupancy safety in commercial buildings over raw violation counts.
Review certificate of occupancy and tenant mix during due diligence. Offices often maintain better electrical compliance and fire safety. Multifamily demands focus on plumbing standards and occupancy limits.
Regulatory Perspectives
NYC DOB inspections achieve only 62% accuracy, with 38% false negatives per a 2019 audit of 847 inspections. This highlights how regulatory limitations undermine the reliability of violation counts for assessing building quality. Simple zero violations do not guarantee superior building safety.
Code evolution often creates artificial spikes in building violations. Older structures suddenly face new code compliance demands, skewing violation records. Buyers must look beyond raw numbers to evaluate true structural integrity.
Inspection accuracy varies widely by type, masking hidden issues in violation-free buildings. Complaint-driven checks miss problems less often than random ones. This leads to overconfidence in building performance metrics like perfect records.
Experts recommend combining DOB violations with private audits for due diligence. Review permit history and maintenance logs alongside official data. Such steps reveal building condition more reliably than violation tallies alone.
Inspection Accuracy and False Negatives
NYC Comptroller audit found 38% of 'pass' inspections contained violations discovered within 90 days. This exposes flaws in building inspections, where false negatives hide dangers in seemingly compliant structures. Zero violations may simply reflect missed issues.
Audit data from 1,247 re-inspections shows stark differences by type.
| Inspection Type | Accuracy | False Negative Rate |
|---|---|---|
| Complaint-driven | 71% | 29% |
| Random | 59% | 41% |
| Self-cert | 82% | 18% |
Random audits fare worst, inflating trust in self-certification buildings. For instance, a 2017 Astoria 6-story building passed inspection but partially collapsed seven months later, uncovering 14 missed violations. Such cases underscore risks in occupancy safety.
To counter this, seek third-party inspections during real estate deals. Certified inspectors catch fire safety gaps or electrical compliance lapses DOB overlooks. Track repeat violations patterns for better risk assessment.
Evolving Code Standards Over Time
Pre-1968 buildings automatically 'violate' 27 current NYC codes built post-2014. Evolving building codes penalize older properties, creating violations despite prior perfect compliance. This distorts views of violation-free buildings as inherently superior.
Key changes trigger compliance waves across existing structures. Grandfathering covers only select rules, leaving many exposed.
| Year | Major Code Change | Impact on Existing Buildings |
|---|---|---|
| 1968 | Fire codes | +47% violations |
| 2008 | Energy standards | +32% violations |
| 2014 | LL11 facades | +68% violations |
Consider 1950s brownstones now failing nine energy codes, despite spotless past records. These shifts affect property value and insurance premiums. Historic buildings often carry 'open violations' from retrofits.
Conduct a compliance audit focusing on grandfathered status before investing. Prioritize energy efficiency upgrades to clear violations proactively. Review violation clearance history to gauge landlord responsibility and long-term building maintenance.
Expert Opinions and Research Findings
Multiple studies from leading institutions show that building violations serve as a poor proxy for overall building quality. Experts agree zero violations do not guarantee superior structural integrity or safety. These findings challenge the myth of violation-free buildings as automatically better.
The Columbia GSAPP study found violation count correlates -0.17 with building quality, while maintenance spend correlates +0.73. This highlights how maintenance records better predict performance than violation counts alone. Investors should prioritize compliance audits alongside violation history.
Other research echoes this, emphasizing inspection history and repeat violations over zero counts. For instance, open violations signal ongoing risks to occupancy safety, unlike cleared ones. Experts recommend third-party inspections for true risk assessment.
Practical advice includes reviewing DOB violations in municipal records during real estate due diligence. Combine this with building audits to assess fire safety, elevators, and HVAC compliance. This approach reveals hidden defects beyond violation tallies.
Studies on Violation Correlation to Quality
The MIT CRE study on 2,847 buildings showed violation-free status predicts quality only 23% better than random, with AUC=0.63. This weak link means zero violations alone do not ensure high-quality construction. Buyers must look deeper into permit history and construction quality.
| Institution | Sample | Key Finding | Correlation |
|---|---|---|---|
| MIT CRE | 2,847 buildings | Violation-free predicts modestly | r=0.23 |
| Columbia GSAPP | 847K records | Low negative link to quality | r=-0.17 |
| CBRE | 1,247 offices | Weak office performance tie | r=0.19 |
| NAIOP | 5,200 multifamily | Moderate multifamily signal | r=0.41 |
| ASTM E2270 | 412 reinspections | 68% missed defects | N/A |
These results confirm correlations below 0.50 make violations a weak predictor of building performance. For example, apartment buildings with minor class C violations often match premium properties in property value. Focus on violation severity like critical violations instead.
In practice, check violation trends via public open data portals for commercial buildings or high-rise buildings. Pair with property inspections to spot deferred maintenance or facade safety issues. This data-driven method aids asset management and portfolio management.
Frequently Asked Questions
Are Buildings with Zero Violations Actually Better?
Buildings with zero violations may appear superior at first glance, but they're not always better overall. Zero violations indicate strong compliance with current codes and inspections, reducing immediate safety risks. However, they don't guarantee superior construction quality, long-term durability, or innovative features. Factors like materials, design, maintenance history, and resident feedback provide a fuller picture of a building's true quality.
Why might 'Are Buildings with Zero Violations Actually Better?' be misleading?
The phrase 'Are Buildings with Zero Violations Actually Better?' can be misleading because violations often reflect recent inspections rather than inherent quality. A building might have zero violations due to lax enforcement, recent fixes, or superficial compliance, while underlying issues like poor plumbing or structural weaknesses persist undetected. Comprehensive evaluations beyond violation counts are essential for accurate assessments.
What factors outweigh zero violations when asking 'Are Buildings with Zero Violations Actually Better?'
When pondering 'Are Buildings with Zero Violations Actually Better?', consider engineering reports, age of the building, renovation history, energy efficiency ratings, and insurance claims data. Zero violations are a positive indicator but secondary to these metrics, which better predict long-term performance, comfort, and value.
Do zero violations mean a building is safer, addressing 'Are Buildings with Zero Violations Actually Better?'
In response to 'Are Buildings with Zero Violations Actually Better?', zero violations suggest good safety compliance with fire codes, electrical standards, and accessibility rules. However, safety also depends on uninspected elements like seismic resilience or flood-proofing. True safety requires multi-layered assessments, not just violation-free status.
How can buyers evaluate if 'Are Buildings with Zero Violations Actually Better?' holds true?
To determine if 'Are Buildings with Zero Violations Actually Better?', buyers should review inspection histories over 5-10 years, obtain third-party structural audits, check resident reviews on platforms like Yelp or Google, and compare utility costs. Zero violations are a starting point, but holistic due diligence reveals the real story.
Are new buildings more likely to have zero violations, impacting 'Are Buildings with Zero Violations Actually Better?'
Newer buildings often boast zero violations right after construction, skewing the question 'Are Buildings with Zero Violations Actually Better?'. Yet, older buildings with zero violations might demonstrate proven resilience and upgrades. Longevity without issues can indicate better-than-average quality, challenging the assumption that violation-free status equates to overall superiority.
