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Four Questions!
by David Stanowski
25 October 2010


Mr. Mayor,

It was ironic to hear your impassioned remarks at the recent “town hall” meeting concerning your obligation and duty to enforce the law, even if you don’t like it, when we have called on you to make sure that the GHA rebuilding plans follow all federal rules and regulations; but you have shown no interest in doing so!

You seem committed to enforcing the Conciliation Agreement, which supports your desire to rebuild public housing, but have a much different attitude about the actual federal rebuilding rules that may derail your plans.

There are four basic questions that need to be asked and answered, by Harish Krishnarao, at that the upcoming joint Council meeting with the GHA, to understand where this process really stands, and the options available to the City.


1.)   24 CFR (Code of Federal Regulations) 941.202 (2)(i), HUD’s regulations for “Site and Neighborhood Standards”, states in part … “public housing units constructed after demolition of public housing units may be built on the original public housing site, if”… “The number of public housing units being constructed is no more than 50 percent of the number of units in the original project”… All of the rebuilding plans published in the newspaper on October 04, 2010 violate the 50% rule.

Does the GHA have a waiver from HUD allowing it to violate this rule? If so, can Council get a copy of the waiver?


2.)   Executive Order 11988 requires federal agencies to “avoid, to the extent possible, the long and short-term adverse impacts associated with the occupancy and modification of flood plains and to avoid direct and indirect support of floodplain development wherever there is a practicable alternative.”

The guidelines address an eight-step process that agencies should carry out as part of their decision-making on projects that have potential impacts to or within the floodplain.

Can City Council get a copy of the GHA’s eight-step analysis?

Learn Purchase Real Estate for Cents on the Dollar!

3.)   HUD Handbook 4010.1, Section 3-6 C directs HUD to use “every means at their disposal” to avoid creating or adding to an oversupply or surplus of housing. With over 7,000 vacant housing units in the City of Galveston, any building by the GHA will violate the oversupply rule.

Does the GHA have a waiver from HUD allowing it to violate this rule? If so, can Council get a copy of the waiver?


4.)  HUD appears to be using the Westchester case as their new standard for the placement of public housing. The judge ordered 84% of the new public housing units be placed in areas where the percentage of the Black population was less than 3%, another 8% in areas where the percentage of the Black population was less than 7%, and the final 8% in areas where the percentage of the Black population was less than 14%.

If these same criteria are applied to Galveston census tracts, 100% of any new public housing units rebuilt in this city would have to be placed west of 43rd Street, with 84% of them west of 99th Street.

Does the GHA have a waiver from HUD allowing it to use criteria other than Westchester to choose the locations for new public housing units? If so, can Council get a copy of the waiver?









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