The problem is due in part to the structure of HPD’s enforcement process. In the early 1970s, the city’s administrative code was altered to “combine all matters of enforcement in front of one court – housing court,” according to Harold Shultz, senior fellow at the Citizens Housing and Planning Council, who has served as both deputy commissioner and general counsel at HPD. This model had worked “reasonably well in other places … but also prohibited [HPD] from creating a tribunal” of any kind, Shultz said.