Sandy Reiburn, July 29, 2026

Pursuant to HUD’s Annual Plan requirements, I submit this formal challenge to the Draft NYCHA Annual Plan and request that this challenge, its source, and NYCHA’s complete written response be attached to the final Annual Plan as required by federal law.

The Draft Annual Plan presents the proposed Fulton Houses and Elliott-Chelsea redevelopment as “preservation.” It is not preservation. It is-instead-the destruction of existing public housing, the permanent removal of homes from traditional Section 9 public housing, and the transfer of ownership, management, and control to private development interests under the RAD/PACT program.

The Plan is misleading, internally contradictory, and omits material facts necessary for residents and the public to make informed comments.

First I wish to state that NYCHA is misrepresenting the loss of public housing capacity

NYCHA repeatedly promises “one-for-one replacement” by apartment count and publishes tables suggesting there will be no reduction in apartments by bedroom type. However, NYCHA’s own approved Phase I RAD Conversion Commitments tell a different story.

Those documents show:

• Fulton Phase I eliminates approximately 150 bedrooms.
• Elliott-Chelsea Phase I eliminates approximately 100 bedrooms.

That is a loss of 250 bedrooms in Phase I alone.

Bedrooms—not simply apartment doors—represent the actual capacity to house families. By emphasizing apartment counts while concealing the elimination of hundreds of bedrooms, NYCHA creates the false impression that family-sized public housing capacity is being preserved when it is not.

Please explain:

• Why does the Draft Annual Plan omit this significant reduction in bedrooms?
• Why are residents told there is “one-for-one replacement” when actual family housing capacity declines?
• How does eliminating 250 bedrooms satisfy NYCHA’s repeated public promises?

Secondly, NYCHA has mischaracterized resident participation

The Draft Annual Plan improperly invokes the Resident Review Committee’s earlier selection of a development partner in a manner suggesting residents endorsed the current demolition proposal and that’s inaccurate.

Residents participated in selecting a development partner before wholesale demolition became the approved redevelopment strategy. At that time, rehabilitation—not complete demolition and reconstruction—was presented as the expected path. Selection of a development partner cannot be retroactively transformed into consent for razing eighteen occupied public housing buildings.

Please identify:

• When residents specifically voted to approve demolition of Fulton Houses and Elliott-Chelsea Houses.
• When residents approved removal of their homes from Section 9.
• When residents approved years of demolition, excavation, relocation, and reconstruction.

If no such vote occurred, NYCHA should stop implying that resident participation constituted approval of the current demolition plan

As well, NYCHA has downplayed the financial impact on residents

The Draft Annual Plan states that resident protections will be maintained following RAD conversion.

Yet the same documents acknowledge that many residents will ultimately pay higher rent and utility costs after conversion, with increases phased in over five years. A phased-in increase remains an increase.

Residents shouldn’t be required to pay more simply because NYCHA has chosen to remove their homes from Section 9 public housing and convert them to Project-Based Section 8.

NYCHA should explain:

• How increased tenant costs constitute preservation of resident protections.
• Why existing public housing residents should bear additional financial burdens resulting solely from NYCHA’s chosen financing model.
• What legal protections residents permanently lose by leaving Section 9 public housing.

Adding insult to injury, the plan minimizes serious environmental and public health risks

The proposal involves demolition of eighteen occupied residential buildings together with years of excavation, construction, heavy equipment operation, truck traffic, and extensive soil disturbance.

Environmental investigations have already identified contaminated soils and other environmental concerns requiring remediation.

These activities threaten residents, workers, children, seniors, persons with disabilities, school populations, neighboring communities, and public housing staff with prolonged exposure to contaminated dust, airborne particulates, diesel emissions, noise, vibration, and other construction-related hazards.

Yet the Draft Annual Plan fails to provide a transparent, comprehensive, enforceable public health protection strategy. NYCHA has not demonstrated how it will adequately protect residents living immediately adjacent to active demolition and excavation over many years.

Accordingly, NYCHA should publicly release:

• All soil testing results.
• All environmental investigations.
• All contamination maps.
• Air-quality monitoring plans.
• Dust suppression protocols.
• Independent environmental oversight plans.
• Emergency response procedures.
• Resident health protection protocols.

Residents should not be asked to rely on generalized assurances when their health may be placed at risk.

Finally, destruction is not preservation!

Throughout the Draft Annual Plan, NYCHA repeatedly characterizes demolition as preservation.

Words matter! Demolishing existing public housing is not preservation.Removing housing from Section 9 is not preservation.Replacing publicly owned housing with privately controlled Project-Based Section 8 housing is not preservation.Years of relocation, demolition, excavation, and reconstruction are not preservation.

The Draft Annual Plan must accurately describe what is proposed rather than using terminology that obscures the true nature of the project.

The following is requested of NYCHA

• Halt the proposed demolition of Fulton Houses and Elliott-Chelsea Houses.
• Preserve these developments as traditional Section 9 public housing.
• Reject privatization through RAD/PACT.
• Fully rehabilitate the existing buildings rather than demolish them.
• Release all environmental, geotechnical, soil contamination, and health-risk records.
• Provide complete public disclosure regarding the loss of bedrooms and family housing capacity.
• Protect residents from displacement, increased housing costs, toxic exposure, and years of avoidable construction disruption.

Public housing residents are not obstacles to redevelopment.

Their homes are not vacant land awaiting private investment.

Their rights are not bargaining chips.

Their health is not an acceptable cost of redevelopment.

NYCHA should repair public housing—not demolish it.

It should protect residents—not privatize their homes.

And it should stop calling destruction “preservation.”

Finally, because this submission challenges specific elements of the Draft Annual Plan, I respectfully request that NYCHA comply fully with HUD’s Annual Plan requirements by attaching this challenge to the Final Annual Plan, identifying its source, and providing a complete written response to each issue raised herein.

Sandy Reiburn

Fort Greene, Brooklyn