The Alliance for Healthy Homes Partnering with ARPC to Pressure HUD

     The American Radon Policy Coalition has successfully enrolled AFHH into assisting our efforts to force HUD into implementing an effective policy for protecting residents from radon exposure.  The Alliance for Healthy Homes is currently mounting a concerted, broad-based campaign to persuade Congress to double funding for HUD's Healthy Homes grants from $10 million to $20 million. 

     Through the campaign, the Alliance also seeks to sharpen the focus of these grants to advance the cost-effective integration of healthy homes principles and practices into housing maintenance, rehabilitation, operation, design, and construction. Achieving these goals will advance the objectives of advocates for children's health, environmental health, environmental justice, affordable housing, energy conservation, lead poisoning prevention, asthma reduction, radon-induced lung cancer reduction and healthy homes.

     HUD is currently spending less than ¼ of 1% of their enormous budget on any issue related to health in housing.  But, thanks to ARPC efforts, HUD's Department of Healthy Homes is finally starting to show some interest in addressing radon.  Getting their funding increased for Healthy Homes Initiatives can play a big roll in promoting radon awareness.  AARST members have been encouraged to contact their Congressman to request support for the funding increase that can ultimately make a difference in radon awareness and increase the number of radon tests and or mitigations you perform.  

 

ARPC Efforts Result in HUD IG Investigation

 

     Thanks to an extensive Congressional letter-writing campaign initiated by the American Radon Policy Coalition, the HUD Office of Inspector General is conducting an investigation into the failure of the U.S. Department of Housing and Urban Development to carry out legally mandated radon testing. 

 

     The Office of Inspector General's mission is to provide “independent and objective reporting to the HUD Secretary and the Congress for the purpose of bringing about positive change in the integrity, efficiency, and effectiveness of HUD operations”. Inspector General Kenneth M. Donohue informed Congress his staff is in the process of determining whether and to what extent HUD has violated any Federal laws.  Based on the response we received from the HUD Program Office,” say Donohue in a letter distributed in response to dozens of Congressional inquiries, “we recently requested an opinion from the Department’s Office of General Council to determine whether HUD has any statutory requirement to provide radon testing.

     ARPC asserts HUD has failed to comply with a number of Federal statutes regarding radon including the 1988 Stewart B. McKinney Homeless Assistance Amendments Act.  These Amendments (also added to the Indoor Radon Abatement Act) clearly state their purpose is, “1. To require HUD to develop an effective departmental policy for dealing with radon contamination that utilizes any EPA guidelines and standards to ensure that occupants of housing covered by this section  [HUD owned and assisted multifamily housing] are not exposed to hazardous levels of radon, and 2. To require HUD to assist the EPA in reducing radon contamination.” Fifteen years after the passage of the Act, HUD has yet to implement any policy that would require radon testing in HUD owned and assisted housing.

 

     ARPC also claims HUD is in violation of the Federal Code of Regulations written to require the Department to comply with the National Environmental Policy Act (NEPA).  24CFR50/3(i) states, It is HUD policy that all property proposed for use in HUD programs be free of hazardous materials, contamination, toxic chemicals and gases, and radioactive substances where a hazard could affect the health and safety of occupants or the utilization of the property. Section 50.2 states, “Project means an activity, or a group of integrally-related activities undertaken by HUD or proposed for HUD assistance or insurance.”  HUD does not require the applicant of a federally insured mortgage to have a radon test of the property performed even though radon is both a toxic gas and radioactive.

 

     Inspector General Donohue has indicated he expects to provide Congress at least an interim response by May 28, 2004.

 

ARPC Targets the Senate Subcommittee on VA, HUD and Independent Agencies

 

     ARPC’s most recent letter writing campaign is directed toward members if the Senate Appropriations Committee, particularly members of the Subcommittee on VA, HUD and Independent Agencies.  Senator Mikulski of Maryland is the Committee’s Ranking Member.  She and Senators Bond of Missouri, DeWine of Ohio, Harkin of Iowa, Byrd of West Virginia, Domenici of New Mexicio have all received letters from AARST and NEHA members requesting the Committee to conduct an inquiry into HUD’s failure to comply with federal radon laws.

 

     In late 1991, the Senate Appropriations Committee expressed concern to HUD that the Department’s policy recommendations to Congress contained in the report HUD submitted in April of 1991, did not, in the Committees view, satisfy the requirements of Section 1091 of the McKinney Homeless Assistance Amendments of 1988.  HUD Secretary Kemp responded to Senator Lautenberg of the Committee in January 1992 in which he stated, “In response to the Committee’s request, the Department will initiate a program of testing and mitigation in 1992…Please be assured that the Department intends to fully comply with both the spirit and language of the Committee report.

 

     The Senate Appropriation Committee’s concern came on the heels of testimony provided the U.S. General Accounting Office in May of 1991.  In our view,” stated GAO representative Richard Hembra, “HUD’s recommended policy does not meet the basic requirements of the McKinney Amendments that call for a HUD policy that includes testing and mitigation programs to protect the residents of HUD-assisted housingWe believe HUD’s policy falls short of recognizing that EPA has, in fact, already established testing and mitigation procedures that are being applied in a variety of circumstances by the public and federal government… EPA officials are confident that testing and mitigation can proceed in this multifamily housing now… Accordingly, we recommend that HUD redesign its policy to provide for testing and mitigation programs for HUD-assisted housing as required by the McKinney Amendments…To assist HUD in this effort, we also recommend that EPA begin immediately to develop specific guidance outlining testing and mitigation procedures for multifamily buildings in HUD’s inventory.”

 

     HUD Secretary Kemp followed up with April 1992 letter to Senator Mikulski, then Chair of the Subcommittee on VA, HUD, and Independent Agencies, in response to her request that HUD provide a report on the implementation of a revised Departmental policy on radon with 6 months of enactment of the VA-HUD Independent Agencies Appropriation Act.  Kemp again stated that the Department would initiate a program of testing and mitigation in 1992 and would begin by testing as a first step; all HUD-owned multifamily housing in EPA designated high radon areas. He ended the letter by stating, “HUD recognizes that Congress expects the Department to address the balance of the stock identified by the McKinney Amendments.  The Department and EPA are jointly developing a plan that can be used to meet this goal.”

 

     Other than the buildings in Atlanta, Kansas City, and Denver that were tested as part of the research HUD insisted on to jointly develop the guidance plan to which Kemp refers, no HUD multifamily housing was ever tested.

 

     Now here’s the real kicker: In February of 1995, when EPA completed this research along with the guidance document that would finally put an end to HUD’s insistence that there just wasn’t enough experience with radon in multifamily housing to implement a testing and mitigation policy, HUD would not allow EPA to submit the guidance for public review and comment.  In other words, the guidance protocol Radon Measurement in HUD Multifamily Buildings never saw the light of day. HUD took it from EPA and quietly buried it. (It was covertly leaked to the American Radon Policy Coalition in 2003) 

 

     The Senators are being asked to answer two questions:

     1) Why did the Senate Appropriations Committee and the Subcommittee on VA, HUD and Independent Agencies fail to follow-up with the Department to ensure the plan to protect residents of HUD assisted housing from dangerous radon exposure was finally implemented as Secretary Kemp promised? 

      2) Would you please initiate a Committee investigation of the matter including a full explanation of what actions Congress has directed, along with insistence that this “oversight” be corrected ASAP?  Mark Calabria with Senator Shelby’s office has already indicated to ARPC officials that the Senator would be quite willing to join you in this effort to compel HUD to follow the law.

  

 

OUTRAGED??? Get into Action!!  Contact your Senators and Congressman ASAP.