One Thermometer, Two Million Renters, and Everything That Can Go Wrong in Between

Two days after Houston City Council voted 12-to-2 to require air conditioning in all rental units, the ordinance's enforcement burden landed exactly where most legal obligations do in this city: on the Houston Health Department's Apartment Compliance Program. The team's precise headcount has never been publicly disclosed. A prior council investigation found it was staffed by two inspectors for the entire city.¹

The ordinance takes effect December 17, 2026, 120 days from the vote.² After that date, a renter whose apartment lacks operable A/C can call 311, and an Environmental Investigator will arrive to determine whether the landlord's equipment is "capable of maintaining an inside temperature 20 degrees lower than the outside temperature, or no higher than 80 degrees."³ That formula is load-bearing. At 100°F outside, 80°F is the threshold. At 109°F outside, 89°F is legally compliant.

We wanted to talk to the person who will carry a thermometer into that room.

Dolores "Lolo" Treviño is not a real person. No Environmental Investigator could speak this freely about institutional constraints without career consequences, which is itself part of the story. But she is built from the documented reality of the Apartment Compliance Program's published procedures, caseload data, and the enforcement gaps a council investigation laid bare.⁴ She has been doing this work, in our telling, for fifteen years. She grew up in Magnolia Park. She carries a pocket thermometer clipped to her lanyard like a pen.

December 17 is four months away. What are you doing right now to prepare?

Lolo: Waiting. We haven't received updated guidance yet. The ordinance passed Tuesday, and I found out it was our department enforcing it from the news, same as you. That's not unusual. The process is the process. Complaint comes into CRIS, gets assigned, I go out within one to three days.⁵ That part doesn't change. What changes is I'm now measuring against a specific formula instead of just checking whether the unit has functioning A/C at all.

Before the ordinance, what did a "no A/C" inspection actually look like?

Lolo: I show up. Is there a unit? Does it turn on? Is cold air coming out? I'm simplifying, but those are the bones. The old rule was basically, if the apartment has window screens, the landlord could skip A/C entirely.⁶ So half the time I'd get there and the landlord's defense was literally screens. Metal mesh. In July. In Houston.

You learn not to react.

Now you have to determine whether equipment is "capable of maintaining" a temperature 20 degrees below whatever it is outside. How do you actually do that?

Lolo: That's the question I would love answered. Do I read the thermostat? Bring my own thermometer? Check the BTU rating on the unit against the square footage? Because "capable of maintaining" is an engineering claim. I can't verify that standing in a living room for twenty minutes at two in the afternoon. I can tell you it's 87 degrees in here right now. I cannot tell you whether this window unit is capable of getting it to 80 if the tenant closes the bedroom door and nobody opens the fridge.

And the formula. People haven't thought the formula through yet. At 100 outside, 80 inside is the target. Fine. At 109 outside, 89 inside is compliant.

The Maricopa County heat-death data from earlier this year showed that 94% of people who died indoors from heat had A/C present in the unit. In 72% of those cases, it wasn't functioning.⁷ Does "equipment present" worry you as a standard?

Lolo: It keeps me up. Not that specific stat, I hadn't seen it, but the thing it describes. I've walked into units where there's a window unit still in the box. Landlord installed it that morning because they knew I was coming. I've seen units running but blowing room-temperature air because the refrigerant leaked out three months ago. I've seen a perfectly functional system in a unit where the tenant owes CenterPoint $400 and the power's been cut.

The ordinance says the landlord has to provide equipment capable of cooling. It doesn't say anything about the electric bill. Council member Carter voted no and said people won't be able to afford the bills.⁸ She's not wrong about the problem. Whether that's a reason to vote no is a different conversation, and not mine to have.

Walk me through what happens after you document a violation.

Lolo: I write it up same day in CRIS. Notice goes to the owner or manager within a day. Then they get seven to ten days to fix it.⁹

In August.

Lolo: In August. And that's the existing timeline. I don't know yet whether the ordinance specifies something different. But under our current program, that's the cure period. During which the tenant is still in the apartment. Still hot. And the landlord is calling an HVAC company that has a two-week backlog because every unit in the Sun Belt is breaking down simultaneously.

So you've got a right that takes, optimistically, two weeks to become a cooled room. Pessimistically? I've seen cases drag for months.

Can a tenant file a complaint anonymously?

Lolo: [long pause]

The 311 system asks for contact information. Online, you need an email address in most cases.¹⁰ By phone, I honestly don't know if they'll take it without a name. What I do know is that if the person calling isn't on the lease, we've historically had cases closed for that reason alone. There was a situation in the council's own investigation where a man called about bed bugs in his mother's apartment. She had dementia. They wouldn't take the report because he wasn't the leaseholder.¹¹

So when people ask me, "Can my tenant exercise this right safely?" There's a formal anti-retaliation provision in the city code. Section 10-365. The landlord can't raise your rent or evict you for complaining.¹² But that's a remedy after something happens to you. Having your name on the complaint in the first place is the part that makes people hesitate.

The council investigation also found that 311 calls were frequently misrouted between departments, and that cases were closed after reaching a tenant's voicemail.¹³ Has that changed?

Lolo: I want to say yes. The Apartment Compliance Program has been working on it. The March briefing to council laid out response targets. One to three days for initial inspection. That's real, that's what we aim for.¹⁴ But I can't sit here and tell you that every call lands in the right queue on the first try. Nine city units across five departments handle apartment safety in Houston.¹⁵ A/C is ours now. Mold is ours. Structural is Permitting. Fire safety is fire. If someone calls about A/C and also mentions a crack in the foundation, that call might bounce. And every bounce is a day the tenant is still hot.

How many investigators does the program have right now?

Lolo: [smiles] I'm going to let the department answer that one.

The city logged 700 to 800 A/C complaints per year before the ordinance.¹⁶ What happens to that number on December 18?

Lolo: It goes up. How much, I don't know. Some people who were living with broken A/C and no legal leverage now have legal leverage. That's the whole point of the ordinance. But every one of those complaints needs a visit, a write-up, a notice, a cure period, a re-inspection. If the landlord doesn't comply, a citation.

We had 38 citations out of nearly 13,000 cases over three years.¹⁷ Thirty-eight. And that's not because everything was fine. The system resolves most cases before it gets there, or the tenant moves, or the tenant stops answering the phone. There are a lot of ways a case closes that aren't the same as a room getting cool.

What would you want readers to understand about what you can and can't do?

Lolo: I can walk into a room and tell you it's too hot. I can document that the equipment isn't working or isn't there. I can start a process that, if everything goes right, if the landlord cooperates, the contractor is available, parts are in stock, the tenant can afford to run it, ends with a cooled room.

Between my clipboard and that cooled room, there are six or seven handoffs I don't control.

The Houston Health Department did not respond to a request for comment on investigator staffing levels or the measurement protocol that will be used for A/C complaints under the new ordinance. The final enrolled ordinance text was not yet available in public city records as of August 21, 2026. This interview is a composite construction based on documented enforcement procedures, published city records, and council investigations, not a conversation with an actual city employee.

Footnotes

1. Houston City Council, "Apartment Inspection Reform" investigation document. https://311.houstontx.gov/council/4/air/AIR-Budget-Amendement.pdf ↩

2. KPRC Click2Houston, "Houston rental AC ordinance: Your questions, comments coming in," August 20, 2026. https://www.click2houston.com/news/local/2026/08/20/houston-rental-ac-ordinance-your-questions-comments-coming-in/ ↩

3. Houston City Council, "Right to Air Conditioning for Rental Housing" proposal text, July 28, 2026. https://www.houstontx.gov/council/committees/propa/20260728/right-to-air-conditioning.pdf ↩

4. Houston Health Department, "Apartment Compliance Program" briefing, March 30, 2026. https://www.houstontx.gov/council/committees/econdev/20260330-joint-hac/Apartment-Compliance-Program-Inspection-Overview-Health.pdf ↩

5. Houston Health Department briefing, March 2026 — enforcement process timeline. ↩

6. Houston City Council, "Air Conditioning Ordinance FAQ." https://www.houstontx.gov/council/committees/propa/20260728/air-conditioning-ordinance-faq.pdf ↩

7. Maricopa County Department of Public Health, 2025 Heat Deaths Report, April 2026. ↩

8. KPRC Click2Houston, August 19, 2026 — Council member Twila Carter's dissenting remarks. https://www.click2houston.com/news/local/2026/08/19/houston-council-members-passes-ordinance-requiring-working-ac-in-rental-properties/ ↩

9. Houston Health Department briefing, March 2026 — 7–10 day compliance period. ↩

10. Houston 311, "How to Use 311." https://www.houstontx.gov/311/howtouse.html ↩

11. Houston City Council, "Apartment Inspection Reform" investigation document. ↩

12. Houston City Code, Sec. 10-365. Referenced at https://www.houstonpermittingcenter.org/building-code-enforcement/multi-family-habitability-inspections ↩

13. Houston City Council, "Apartment Inspection Reform" investigation document. ↩

14. Houston Health Department briefing, March 2026. ↩

15. Houston City Council, "Apartment Inspection Reform" investigation document — nine city units across five departments. ↩

16. KPRC Click2Houston, August 20, 2026 — Health Department estimate of 700–800 annual A/C complaints. ↩

17. Houston Health Department briefing, March 2026 — 38 citations out of 12,915 total cases, January 2023 through March 2026. ↩