The "Section 8" program provides rent subsidies.  In Richmond, RRHA operates the program using funds from HUD.  You can obtain a list of the Section 8 properties in Richmond on the web.  For a list of the Section 8 properties in ZIP Code 23227, contact Meg Lawrence or John Butcher.  The Fair Housing Act and the HUD regulations (esp. 24 CFR § 982.401) require that the rental property be "decent, safe, and sanitary."   

On June 26, 2000, Mr. Miles of HUD and Mr. Green of RRHA appeared before the Public Safety Committee.  They said that their agencies generally check that the rental property meets the applicable building codes and that they would respond to complaints of crime problems.  By omission, they made it clear that the Section 8 program does not take any pains to avoid landlords who are fostering the kind of problems we have on Chamberlayne Avenue.

But they did say they would respond to complaints.  So we gave them one.  Here are that complaint and the ensuing correspondence:

• John's letter of July 4
• Mr. Miles' reply of July 13
• John's email of July 15
• Mr. Miles reply of August 2
• John's letter to Secretary Cuomo on August 13
• RRHA's letter of August 24
• John's letter to RRHA of Sept. 15.

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1508 Avondale Avenue
Richmond, Virginia 23227
July 4, 2000

Bill Miles
Community Builder
U.S. Department of Housing and Urban Development
3600 West Broad Street
Richmond, Virginia 23230

RE: Safety in Section Eight Apartments on Chamberlayne Avenue

Dear Mr. Miles:

I was encouraged by your statement to the Public Safety Committee on June 26 that HUD will investigate complaints of safety problems in apartment complexes that have been approved for Section Eight housing subsidies.

On behalf of the Safety Committee of the Bellevue Civic Association I have been collecting data about Chamberlayne Avenue. This information fortifies my view that inadequate management at some of the apartments is the root cause of much of the disorder that plagues the Chamberlayne Avenue corridor and spills over into my neighborhood. See the Bellevue web site for a summary and discussion of the data:

<https://members.tripod.com/johnrbutcher/chamberlayne/chamberl.htm>

I reproduce below a list of the Chamberlayne Avenue addresses north of Brookland Parkway with the largest number of offense reports in 1999. This is simply a count of the number of offense reports in the Richmond Police Department database, less natural deaths, traffic calls, and other entries that plainly are not public safety issues. The table also includes the number of calls for service in 1999. This is a count of calls to the City dispatcher for police, fire, or other emergency services. The last column is the number of Section Eight tenants at the address, from a list for Zip Code 23227 dated March 21, 2000.

Address	Offenses	Calls	Sec. 8
3207_11_15	22	154	6
4930	18	60
3505	14	115
3918_20	12	127	1
4924	12	17
3905_43	11	145	4
3916	10	75
4801_19	9	71	3
3803	9	32	1
3817	9	15
3201	7	8
3206	6	55
3006	6	47
4223	6	28	2
3804	6	13	1
3818	6	12	1
4320	6	10
4301_27	5	71	4
3510	5	23	7
3901	5	17

The shaded data are the BP station at Chamberlayne and Azalea, the check cashing store next door, the school at 3817, and the fire station at 3901. The remaining addresses appear to be apartments.

Here are the same data sorted by calls for service.

Address	Offenses	Calls	Sec. 8
3207_11_15	22	154	6
3905_43	11	145	4
3918_20	12	127	1
3505	14	115
3916	10	75
4801_19	9	71	3
4301_27	5	71	4
4930	18	60
3206	6	55
3006	6	47
3803	9	32	1
4223	6	28	2
3510	5	23	7
4924	12	17
3901	5	17
3817	9	15
3804	6	13	1
3818	6	12	1
4320	6	10
3201	7	8

These data support some interesting inferences.

First, the Northcourt complex at 3207-11-15 leads the list in both calls for service and offense reports. Both the offense reports and calls for service are about 50% higher than at the other large apartment building on Chamberlayne, Hawthorne Hall at 3505. These data suggest that the Section Eight tenants at the Northcourt complex may be exposed to an unduly high level of crime and other disorder.

At third on both lists we see Abbey Square at 3918-20 Chamberlayne. The data on the Bellevue web site show that Abbey Square had in 1999 about twice the crime rate per apartment of the better-run apartment complexes in the 3900 block (albeit only half the rate of the notorious Redwood next door). Between them 3918 and 3920 had over 21% of the vice calls for service on Chamberlayne north of Brookland Park in 1999. In my view, these data show that Abbey Square is plainly inappropriate housing for the Section Eight tenant who was reported to live there. It is not appropriate to use public funds to subsidize a landlord who is maintaining a property that is a threat to the tenants and to the neighborhood.

Also high on these lists are the large, multi-building complexes of the Bellevue Gardens, 3905-43 and the Chamberlayne Gardens, 4301-27 and 4801-19. The data available to me do not allow a conclusion about the relative rates of offenses or calls per apartment but the absolute numbers are large.

The multiple addresses in these complexes allow the identification of trouble spots within the complexes. I start with the 1999 calls for service from the Bellevue Gardens:

These data show that over half of the calls for service in 1999 came from 3905, 3907, 3935, and 3943, with over a quarter coming from 3935 alone. If the disorder at 3905, 3907, and 3935 continued into 2000, the Section Eight tenants there were exposed to it.

Turning next to the Chamberlayne Gardens:

At 4301-27 we see four of the fourteen addresses producing over half the calls for service with the Section Eight tenant at 4311 subjected to the third highest rate of disorder. At 4801-19 we see two of the ten apartments generating 62% of the calls, and the Section Eight tenant in 4805, which had the third highest rate of disorder in the complex.

It is inconceivable that the management of the Bellevue Gardens and Chamberlayne Gardens complexes does not know the sources of this disorder. I hope that HUD would want to know whether management has moved aggressively to correct these problems. If it has not, I further hope that HUD would revisit the question whether these complexes are satisfactory for housing subsidies.

These data suggest more generally that the information available from the Richmond Police Department can be used on Chamberlayne and elsewhere in the City to assess whether landlords are maintaining safe and decent premises. I submit that HUD should be using these data both to certify properties for Section Eight assistance and to review on an ongoing basis whether properties should continue to be so certified.

I hope you will want to be more careful to see that public funds are not being used for the benefit of landlords whose behavior is dangerous both to your Section Eight clients and to the community.

With kindest regards, I am

Sincerely,
/s/
John Butcher

Cc (by email):
Tim Pfohl
BCA Safety Committee
Creighton Armstrong
Zoe Anne Green
Meg Lawrence
Turk Sties

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The HUD reply is dated July 13.  The copy here was scanned in, so you probably should blame any English problems on the scanning process, not on HUD:

U.S. Department of Housing & Urban Development
Virginia State Office 3600 Centre, Suite 378
3600 W. Broad Street Richmond, VA 23230-4920
1-800-842-2610

JUL I 3 2000

Mr. John Butcher
1508 Avondale Avenue
Richmond, VA 23227

Dear Mr. Butcher:

Thank you for your letter dated July 4th pursuant to my testimony for the Richmond City Council Public Safety Committee and expressing a desire to see that public funds are not used for the benefit of landlords whose behavior is dangerous.

I appreciate the inclusion of data on service calls to properties on Chamberlayne Avenue north of Brookland Parkway as well as a reference to data on a webpage1. Your concern is understandable. It is important to note HUD's role in the Section 8 Voucher Assistance Program which is as follows:

1. Develop policy, regulations, Handbooks, Notices and other guidance which interpret housing legislation

2. Allocate housing assistance funds

3. Provide technical assistance and training for Housing Authorities

4. Monitor Housing Authorities compliance with program requirements and production goals

On the other hand, the housing authority's responsibilities are as follows:

1. Admission of the tenant into the Section 8 Voucher Assistance Program

2. Assistance provided through the voucher to the landlord on the tenant's behalf

3. Certif~ring the eligibility of the rental unit and approving the lease

4. Monitoring program performance and compliance with federal and local rules

I am forwarding your letter to the Richmond Redevelopment and Housing Authority and requesting that they respond directly to you regarding your concerns.

If I may be of any further assistance, please do not hesitate to contact me.

Very sincerely yours,
/s/
William P. Miles 
Acting State Coordinator- Senior Community Builder

cc.: Tyrone Curtis, Executive Director 
Richmond Redevelopment and Housing Authority

----------------------

¹Please note that we were unable to access the webpage using the address provided.

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John replied by email on July 15:

From: <%20JohnRButcher@attbi.com%20>
To: <bill_miles@hud.gov>
Cc: "Armstrong (AOL), CJ" <CrichtonVa@aol.com>; "Billy Poarch" <WHPoarch@aol.com>; "Armstrong, CJ (rivnet)" <crichtonva@rivnet.net>; "Green Zoe Ann" <ZAGreen@aol.com>; "James A. Sties" <turksties@compuserve.com>; "Lawrence, Meg" <Mdldcl@aol.com>; "Wilmoth" <rickles@attbi.com>; "Wiegardt, Pamela" <dmvpaw@dmv.state.va.us>; "Tim Pfohl" <tpfohl@dhcd.state.va.us>; "Sterling, Chris" <csterling@dhcd.state.va.us>; "Shaw, Maurice" <mshaw.dit@state.va.us>; "Sadler, Kathleen (work)" <ksadler@dmhmrsas.state.va.us>; "Sadler, Kathleen" <KATHNEL@dellnet.com>; "Reynolds, Nancy" <Nancyroy@attbi.com>; "Presson, Diana" <dkpresson@mindspring.com>; "Pasco, Sudie" <SudieP@hotmail.com>; "Mingis, Joy" <jmingis@mindspring.com>; "Mary Garber" <garbermg@earthlink.net>; "Lane, Annette" <alane@hyperionai.com>; "Kreiser, Sandy" <SFKreiser@msn.com>; "fisher, john" <jefisherjr@msn.com>; "Epes (at home)" <epes1@mindspring.com>; "Ed Parks" <Saledparks@aol.com>; "Coake, Judy" <judy_coake@mckgenmed.com>; "Clark, Libby" <junkdiver@aol.com>; "Bellevue Patrol" <bellevuepatrol@aol.com>; "banalet, michele" <downrox@yahoo.com>; "Anderson, John" <bellevue@jpanderson.org>; "Moolhuyzen, Paula" <Paula_Moolhuyzen@mckgenmed.com>
Subject: Section 8 subsidy of inappropriate landlords
Date: Saturday, July 15, 2000 2:04 PM

Mr. Miles

Thank you for your kind letter of July 13 in reply to my inquiry of July 4.

You have forwarded my letter to RRHA for reply. I will await that reply with interest. In the meantime, I would make two points.

First, you say you were unable to reach the Bellevue web pages from the URL in my letter. I have just copied that URL from the letter and pasted it into my browser, where it worked fine. I could only speculate why it has not worked for you. In any event, if your software will permit, you can click on it here: 
https://members.tripod.com/johnrbutcher/chamberlayne/chamberl.htm

Second, you have forwarded my letter to RRHA for response albeit you admit that HUD has the authority to develop policy and to allocate housing assistance funds. Indeed, your organic statute requires HUD-subsidized housing to be "decent, safe, and sanitary." The central point of my letter is that RRHA can use readily available data to determine whether landlords are exposing Section 8 tenants to unacceptable crime and disorder and that they should be required to do so. I will continue to expect an answer on that point from you.

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Here is Mr. Miles' reply of August 2:

U.S. Department of Housing & Urban Development
Virginia State Office 3600 Centre, Suite 378
3600 W. Broad Street Richmond, VA 23230-4920
1-800-842-2610

AUG 2 2000

Mr. John Butcher
1508 Avondale Avenue
Richmond, VA 23227

Dear Mr. Butcher:

Thank you for your e-mail dated July 15th expressing a desire to see HUD mandate the Richmond Redevelopment and Housing Authority to terminate Section 8 Voucher Assistance to landlords based on unacceptable crime and disorder. Please excuse the delay in response caused by the fact that I was out of town last week.

Based on your letter and e-mail, it is clear that you want HUD to take a more activist posture than the agency can legally take based on current law and regulations. It is important to note the following:

1. HUD has assigned the responsibility to administer the Section 8 Voucher Assistance Program to the Richmond Redevelopment and Housing Authority (RRHA). Efforts to get the RRHA to use its leverage with property managers should be concentrated locally with RRHA and the City Council. HUD has no role unless RRHA is unresponsive and even then HUD's authority is non-existent as it relates to mandating that RRHA use crime data to declare a unit in non-compliance. 

2. If a unit meets inspection standards, neither RRHA nor HUD can tell Section 8 voucher holders that they can not expose themselves to unacceptable crime and disorder.  

If I may be of any further assistance, please do not hesitate to contact me.

Very sincerely yours,
/s/
William P. Miles Acting State Coordinator Senior Community Builder

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Here is John's response of August 13:

                                                                                                1508 Avondale Avenue
                                                                                                Richmond, Virginia 23227
                                                                                                August 13, 2000

BY EMAIL

Andrew M. Cuomo, Secretary
Department of Housing and Urban Development
451 Seventh Street, SW
Washington, DC 20410

RE:     HUD Section 8 Subsidies of Housing That Is Hazardous to the Clients

Dear Secretary Cuomo:

On June 26, 2000, Mr. William Miles of your Richmond office appeared at a meeting of the Public Safety Committee of the Richmond City Council to discuss Section 8 housing.  Mr. Miles admitted that HUD does not look at available data to determine whether Section 8 subsidies are benefiting landlords who fail to control criminal disorder on their property.  He said, however, that HUD would consider complaints on the subject.

On July 4, 2000, I wrote Mr. Miles to complain of unacceptable disorder and criminal behavior on several North Richmond properties that receive Section 8 voucher assistance (Exhibit 1).  In his reply of July 13 (Exhibit 2), Mr. Miles replied that he had passed my letter along to the Richmond Redevelopment and Housing Authority, which operates the Section 8 voucher program in Richmond, and that, in essence, crime in Section 8 housing is not HUD’s business.

By email of July 15 (Exhibit 3) I replied, in relevant part:

[Y]ou have forwarded my letter to RRHA for response albeit you admit that HUD has the authority to develop policy and to allocate housing assistance funds.  Indeed, your organic statute requires HUD-subsidized housing to be “decent, safe, and sanitary.”  The central point of my letter is that RRHA can use readily available data to determine whether landlords are exposing Section 8 tenants to unacceptable crime and disorder and that they should be required to do so.  I will continue to expect an answer on that point from you.

Mr. Miles’ response is Exhibit 4.  There he says HUD cannot “legally” act to protect its clients where there is “unacceptable crime and disorder” on HUD-subsidized property.

Mr. Miles does not cite any authority for that egregious statement.  In particular, he does not cite 24 CFR § 982.401(l)(1) where it says "The site and neighborhood must be reasonably free from disturbing noises and reverberations and other dangers to the health, safety, and general welfare of the occupants.”  I cannot tell whether he thinks the promiscuous shooting, fights, domestic brawls, drug dealing, and other “unacceptable crime and disorder” at some Richmond apartment properties are not dangers to the health, safety, and general welfare of the occupants.

Mr. Miles further says:

HUD has assigned the responsibility to administer the Section 8 Voucher Assistance Program to the Richmond Redevelopment and Housing Authority (RRHA).  Efforts to get the RRHA to use its leverage with property managers should be concentrated locally with RRHA and the City Council.  HUD has no role unless RRHA is unresponsive and even then HUD's authority is non-existent as it relates to mandating that RRHA use crime data to declare a unit in non-compliance. 

Thus, Mr. Miles says that HUD has no role unless RRHA is unresponsive.  In that case he says HUD’s authority is “non-existent.”  That is, Mr. Miles says HUD has no role unless RRHA is unresponsive and no authority if it is unresponsive.

Mr Miles continues:

If a unit meets inspection standards, neither RRHA nor HUD can tell Section 8 voucher holders that they can not expose themselves to unacceptable crime and disorder. 

Mr. Miles thus says that HUD's “inspection standards,” at least as they are applied in his hands, leave HUD's clients exposed “to unacceptable crime and disorder.”

It is interesting to contrast Mr. Miles impotence, as stated in his correspondence, with his promise to the Public Safety Committee that HUD would investigate any complaints.  Mr. Miles now says he won’t investigate, as he promised he would, and he couldn't do anything if he did investigate.

Secretary Cuomo, I trust that you will set about improving Mr. Miles’ attitude, or replacing him with someone who is less anxious to subject HUD’s Section 8 voucher clients “to unacceptable crime and disorder” in HUD-approved Section 8 housing in Richmond.

More generally, I hope you will want to be more careful in the future to see that public funds are not being used for the benefit of landlords whose behavior is dangerous both to your Section Eight clients and to the community.

With kindest regards, I am

                                                                                                Sincerely,
                                                                                                John Butcher

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Mr. Curtis of RRHA replied on August 24 to John's original letter to HUD:

August 24, 2000

Mr. John Butcher
1508 Avondale Avenue
Richmond, VA 23227

Dear Mr. Butcher:

Mr. William P. Miles, U. S. Department of Housing and Urban Development, has forwarded your letter of complaints of safety problems regarding Section 8 tenants residing in properties on Chamberlayne Avenue to my office and asked that I investigate your concerns and respond directly to you.

Our investigation of your complaints revealed that only one of the property addresses identified is occupied by a Section 8 program participant, 4805-2 Chamberlayne Avenue. The Section 8 program participant has been made aware of your complaint and an appointment has been scheduled for further investigation. The owner has also been made aware of your concerns and informed of the possible consequences if corrective actions are warranted and not taken.

As discussed in our meeting of August 17, 2000 with the Bellevue Civic Association Safety Committee, RRHA looks forward to working with you to resolve these issues. If I can be of further assistance, please contact me at (804) 780-4285.

Thank you for your concern.

Sincerely,

T. P. Curtis Executive Director

cc: William P. Miles

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Either there is a definitional problem here or somebody has a counting problem: 17 of 18 Section 8 tenants have disappeared between March and August.  Mr. Curtis doesn't seem anxious to find out.  Further, in the fifty days or so from John's first letter, the only enforcement response was to schedule an appointment for further investigation.  John responded on the weekend of Sept. 16:

1508 Avondale Avenue
Richmond, Virginia 23227
September 15, 2000

BY FACSIMILE: 649-0659

Tyrone P. Curtis, Executive Director
Richmond Redevelopment and Housing Authority
901 Chamberlayne Parkway
Post Office Box 26887
Richmond, Virginia 23261

RE: Section 8 Tenants on Chamberlayne Avenue

Dear Mr. Curtis:

On June 26 of this year you and Mr. Miles of HUD appeared before the Public Safety Committee of the Richmond City Council. You and Mr. Miles told the Committee that you would investigate complaints of safety problems in apartment complexes that have been approved for § 8 housing subsidies.

On July 4 I wrote to Mr. Miles to discuss the properties on Chamberlayne Avenue with § 8 tenants and with unusually large numbers of calls for services. In particular, I identified the complex at 3207-11-15 with six § 8 tenants, 3918-20 with one § 8 tenant, 3905-43 with four § 8 tenants, 4301-27 with four § 8 tenants, and 4801-19 with three § 8 tenants.

The count of § 8 tenants in my letter came from a list titled "Propertly Listing by Zip" for ZIP Code 23227, dated March 21, 2000, that was furnished by Mr. Akinwande of your staff. I attach a copy for your information.

Your letter to me of August 24 says that "only one of the property addresses identified is occupied by a Section 8 program participant, 4805-2 Chamberlayne Avenue." Unfortunately your letter does not attempt to explain the discrepancy between your count and mine; neither does your letter tell me what steps RRHA is taking to fulfill your commitment to investigate my complaints of safety problems in apartment complexes that have been approved for § 8 housing subsidies.

It is not credible to conclude that seventeen of eighteen § 8 tenants would move out between March and August, 2000. Please provide me the list of § 8 tenants upon which you relied to conclude that "only one of these properties is occupied by a § 8 tenant." Please further advise me whether or not the properties on the attached list are currently approved for occupancy by § 8 tenants. Finally, I would be interested to hear of any steps RRHA is taking in response to the complaints in my letter.

With kindest regards, I am

Sincerely,

John Butcher

Enclosure: Property Listing by Zip, 3/21/00, listing properties in ZIP Code 23227

Copy: BCA Safety Committee
Zoe Ann Green
Meg Lawrence
W.R. Johnson

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 1508 Avondale Avenue
Richmond, Virginia 23227
September 16, 2000

BY FACSIMILE: 649-0659
Tyrone P. Curtis, Executive Director
Richmond Redevelopment and Housing Authority
901 Chamberlayne Parkway
Post Office Box 26887
Richmond, Virginia 23261

RE: Section 8 Tenants on Chamberlayne Avenue

Dear Mr. Curtis:

I am a Citizen of the Commonwealth and a resident of the City of Richmond. Under the authority of the Virginia Freedom of Information Act, I request an opportunity to inspect and copy the following public records, as that term is defined at Va. Code § 2.1-341, that are prepared, owned, or in the possession of the RRHA:

All public records that comprise or relate to the list of § 8 tenants upon which you relied in preparing your letter to me of August 24, 2000 to conclude that "only one of these properties is occupied by a § 8 tenant."

All public records that set forth the addresses of § 8 tenants in ZIP Code 23227 as of August 24, 2000.

All public records that set forth the addresses of § 8 tenants in ZIP Code 23227 as of March 21, 2000.

All public records that set forth the addresses of rental property in ZIP Code 2227 that has been approved by your agency or by HUD for § 8 tenants as of August 24, 2000.

All public records that relate to inspections or investigations since January 1, 1997 of rental property in ZIP Code 23227 for conformance with any HUD or RRHA requirement.

If any record responsive to this request exists in electronic form, I request that you provide it by posting it to the web or EMailing it to me at %20JohnRButcher@attbi.com%20

In the event RRHA elects to withhold any public record responsive to this request, for each such record please:

Identify the record withheld by date, author, title, and summary or purpose of the record;

Identify all persons outside your office to whom the record has been shown or to whom copies have been furnished; and

State specifically the statutory exemption under which RRHA elects to withhold the record.

If you elect to charge me part or all of the actual costs of copying and search time and computer time expended in providing these records, please estimate the total charges beforehand. If those total charges exceed $100, please notify me before you copy any records.

Please call me at 786-4073 (office) or 264-5942 (home) if I can answer any question regarding this request. You also can reach me by email at the office,

JButcher@oag.state.va.us

or at home,

%20JohnRButcher@attbi.com%20.

I look forward to hearing from you as promptly as possible and, in any event, within the five work days provided by the Act.

With kindest regards, I am

Sincerely,

John Butcher

Copy: BCA Safety Committee
Zoe Ann Green
Meg Lawrence
W.R. Johnson

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Last updated 02/27/02
Please send questions or comments to John Butcher