Demand Letter To HUD

The Honorable Marcia L.
Fudge August 2, 2022

Secretary of Housing and Urban Development
U.S. Department of Housing and Urban Development
451 7th Street SW
Washington, DC 20410
Dear Secretary Fudge,
We write to you as a coalition of tenants, community organizers, lawyers, and other allies who
are deeply concerned about the track record of Millennia Management Company LLC and
Millennia Housing Management LTD., (“Millennia”), as well as other project-based Section 8
owners and managers who are not being held accountable for their failure to maintain HUD
housing and keep families safe.
Millennia is one of the largest owners and managers of HUD project-based Section 8 properties
in the country. As outlined in the April 4, 2022 letter to you, Millennia has demonstrated a clear
and disturbing pattern of mismanagement and neglect. However, Millennia is not an outlier, and
HUD’s response to it is not unique. On a daily basis, tenants in project-based Section 8
developments throughout this country experience terrible housing conditions. Despite being
informed of these problems on several occasions, HUD has failed to take decisive action against
problem owners. As a result, families continue to suffer.
In light of these issues, we are asking for meaningful, systemic change of HUD’s response to
poor housing conditions in HUD’s project-based Section 8 stock. We urge HUD to facilitate the
following measures:
1. A national investigation into Millennia properties and other problem owners with a
pattern of failing to maintain HUD housing: HUD currently deals with poor housing
conditions in a piecemeal, building by building manner. Millennia’s actions serve as an
example of why that is problematic. HUD OIG needs to conduct a national investigation
to reveal the root causes of poor conditions within HUD’s project-based Section 8
portfolio, with a specific focus on disparities in property conditions by race, national
origin, and familial status. HUD also needs to investigate and evaluate what policies
permitted one company to take over management and/or ownership of thousands of
troubled units across the country.
2. HUD must increase and improve its oversight and enforcement of its condition
standards to ensure it is providing decent, safe, and sanitary housing to families.
It is unconscionable that tenants who live in housing created and supported with federal
dollars continue to face terrible housing conditions. HUD must improve its oversight and
enforcement of conditions standards and that begins by providing tenants with an active
role in the inspection process. It also means that HUD must utilize existing tools to
address poor housing conditions when owners fail to comply, including the issuance of
civil money penalties, transfer of the Section 8 contract, suspension or debarment,
receivership, and requiring the owner to secure new management. HUD should also
extend to project-based Section 8 tenants the same right public housing tenants have to
abate their rent or to move if their housing cannot be made habitable in a reasonable
period of time. Additionally, HUD must take an immediate additional enforcement action
following the expiration of the compliance period listed in the notice of default/notice of
violation.
3. Make Millennia tenants whole. Tenants in Millennia properties have been forced to use
their own limited resources to maintain their units, pay for injuries and medical care
related to injuries caused by the poor housing conditions, and expenses for hotel stays
and other moving expenses when the conditions become too hazardous. Tenants
shouldered these expenses because of HUD’s failure to hold Millennia accountable.
HUD should have to reimburse tenants for these costs or direct Millennia to cover these
expenses.
4. Provide safe, affordable housing choices to residents. Tenants in distressed properties

are often forced to move out of properties when the conditions become too hazardous to
their health and well-being. Given the dearth of affordable housing, many end up
homeless, doubled up with family, or living in new housing that they cannot afford. HUD
must offer tenants in housing with terrible conditions real choices that keep their housing
affordable, including a tenant protection voucher or a temporary, affordable unit to live in
while their current unit is rehabilitated.
5. Honor the demands of local tenants associations: Many Millennia properties have
active tenant associations, who have long been on the front lines trying to improve
housing conditions and hold Millennia accountable. Some of these associations have
created their own sets of demands to Millennia based on the specific needs of their
complexes, which have gone unheard by HUD and Millennia. HUD and Millennia should
meet with these tenant leaders, listen to their concerns and demands, and honor their
requests.
6. Include tenants and tenant associations in decision-making about the future of their
housing: In addition to addressing the immediate demands tenant leaders have, tenants
should also be treated as partners in the long term preservation process, and their
feedback about the future of their housing should be solicited whenever possible.
Especially when the owner does not correct a property’s deficiencies after being warned
by HUD, HUD must consult with tenants about what they would like to happen next,
including the need for new ownership or management.
7. Protect HUD tenants’ Right to Organize. Millennia tenants who attempt to organize
report a pattern of harassment and violation of tenants’ Right to Organize under 24 CFR
Part 245. Again, this is not an outlier - tenant harassment and retaliation by owners and
managers is all too common. Unfortunately, it is also all too common for HUD not to
investigate and take actions against these owners and managers. Using 24 CFR part 245
power, HUD should investigate and respond to these tenant complaints and assess civil
monetary penalties for right to organize violations by Millennia management and others.
HUD should address this pattern at Millennia by securing a written commitment that
Millennia will recognize legitimate tenant associations and respect tenants rights
throughout its project-based Section 8 portfolio.
8. HUD should meaningfully fund resident organizing activities. HUD should annually
include a request for $10 M in Section 514 funding to support tenant organizing
activities, tenant capacity building activities, and tenant-led preservation activities. HUD
should focus the allocation of Sec. 514 funding to develop local tenant organizations and
local organizations with a demonstrated history of supporting tenants' preservation
efforts.
We are pleased that members of your staff have agreed to meet with representatives from our
coalition on Wednesday, August 17th. We look forward to discussing these points further, and we
hope that this meeting will be the start of a longer effort to bring justice and relief to Millennia
tenants, and all tenants living in substandard HUD housing.
Sincerely,
22nd Avenue Apartments Cordoba Tenants Association

American Friends Service Committee — Atlanta Economic Justice Program
Gabriel Towers Tenants Union
Housing Justice League
Kansas City Tenants Union
Mass Alliance of HUD tenants
Memphis Tenants Union
Metropolitan Tenants Organization
National Alliance of HUD Tenants
National Housing Law Project
Tenant Association of City View

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The Honorable Marcia L.

Fudge August 2, 2022

Dear Secretary Fudge,

4. Provide safe, affordable housing choices to residents. Tenants in distressed properties

22nd Avenue Apartments Cordoba Tenants Association

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