“The RAB Was Notified.” What Did the WCHA Board Verify?

By Ronnie Paul | Monster News · The Daily Truth

The Wayne County Housing Authority board received a documented objection to replacing its resident commissioner with a nonresident. Six days after the county appointment, Executive Director Kim Musgrave supplied an assurance: the Resident Advisory Board had been notified of the opportunity to serve.

“Kim Musgrave Executive Director welcomed new Board member, Linda Tucker and advised the board that notice was given to the Resident Advisory Board of the opportunity to serve on the board.”

The September 16 minutes record no questions about that notice. They identify no document examined, no response period checked, and no explanation of the multiple residents who had already expressed interest.

That is the governance issue. What did this board do to verify management’s account before accepting a process that affects residents’ representation on the board itself?

Read/download the evidence: September 16 WCHA minutes, page 1 — Musgrave’s RAB assurance (PDF). This is the relevant page from the eight-page meeting packet.

The chair received the objection and the March agenda

Baker’s September 10 email names Chairperson Dixie Locke among its recipients. It expressly challenges WCHA’s eligibility for the small-housing-authority exception, identifies Baker’s August 8 written willingness to serve, and lists the March 12 RAB agenda among the attachments.

This establishes that the objection and agenda were sent to Locke. It does not establish whether she opened them. The door is closed on any dispute questioning if this was put before board leadership prior to Musgrave’s September assurance.

Read/download: September 10 distribution email — recipients and attachment list (PDF);                           formal objection explaining the disputed exception (PDF).

The county’s September 10 minutes also record Katherine Sands warning that Tucker was not a housing resident and that Baker had continuosly expressed willingness to serve. The minutes then record Chairman Daryl Hargrave’s appointment of Tucker without a board vote as described in our previous article, “The Silence Was the Vote”.

Read/download: September 10 county-board minutes — public warning and appointment (PDF).

The March records do not document the claimed notice

The March 12 RAB agenda lists the Annual/Five-Year Plan and consideration of the grievance-hearing-officer panel. The minutes record those same two subjects. Both were presented for comment; neither received comments.

Neither document records a resident-commissioner opportunity becoming available in June, instructions for expressing interest, election process, sign up procedures, or a response period. No records has been offered to substantiate the claims by Kim Musgrave in that September 16 executive summary. The available records, points towards the exact opposite.

Read/download: March 12 RAB agenda and minutes (PDF). These are source pages 1. The Agenda, 2 The RAB Board Members,, and 3. The RAB meeting minutes are combined record.

The records reviewed contain no notice substantiating Musgrave’s assurance and no recorded board examination resolving Baker’s objection. In contrast, the March agenda and minutes, the advance participation demand, and the residents’ accounts present a documented challenge that the board must address.

“Reasonable notice” is notice of an actual opportunity for residents to serve on the governing board. Section 964.425 ties that notice to a meaningful response period: at least thirty days after the RAB receives it. The regulation leaves the format flexible; it does not make a later assurance a substitute for establishing what was communicated and when. Read § 964.425(a)(2)–(4).

The board should demand that Musgrave produce the notice or identify the exact communication she relies upon: what the RAB received, when it received it, what instructions explained how residents could express interest, and what response period applied. It should obtain any RAB comments and the records of how the opportunity was communicated to residents throughout WCHA. HUD leaves those local communication procedures to local determination; the board must establish what WCHA actually did. Read HUD’s explanation of resident notification.

What opportunity did residents actually receive—and how did WCHA account for the residents already asking to serve? Those are the questions Musgrave’s September assurance leaves unanswered.

This is the residents’ representation in governance

The resident commissioner is a full board member, not a ceremonial visitor. Subject to specified exceptions, federal rules require at least one eligible resident on a public housing authority’s governing board. The resident member participates in decisions about the administration, operation, and management of federal public housing and Section 8 tenant-based assistance.

Read the governing rules: 24 C.F.R. § 964.415 — resident-member requirement;                § 964.430 — full membership and participation.

Residents experience the agency’s operations every day: maintenance, access to management, notices, and grievance procedures. Resident representation brings that experience into the body overseeing management. Replacing that voice is consequently a serious compliance and oversight matter.

No particular resident is automatically entitled to appointment merely by volunteering. But willing residents cannot simply be treated as though none exists when management relies on an exception requiring an absence of resident interest during the applicable response period.

What “reasonable notice” actually requires

Under 24 C.F.R. § 964.425, an authority with fewer than 300 public-housing units does not qualify for the exception solely because of its size. It must reasonably notify the RAB of the opportunity for residents to serve; allow a reasonable response period of at least thirty days after the RAB receives notice; receive no resident notification of intent during that period; and repeat the process annually. Failure to meet the conditions returns the authority to the resident-member requirements.

Read: § 964.425 — all conditions of the small-PHA exception.

The rule does not prescribe a mandatory written format or an exhaustive definition of reasonable notice. Our assessment is that notice must communicate a usable opportunity, rather than merely provide words management can invoke afterward. Its content, timing, recipients, and means of responding must be examined together. The concrete minimum is thirty days to express interest after the RAB receives notice.

How did residents elsewhere hear about it?

The question extends beyond the people in the March meeting. How did the opportunity reach residents at the high-rise, Fairway, Golden Acre, single-family homes, and households receiving voucher assistance?

HUD addressed this exact issue when adopting the rule. It declined to require direct notice to every household under this provision. Instead, it left procedures for informing residents—including how and when the RAB would communicate the opportunity—to local determination.

Read HUD’s explanation: 1999 final rule, section H — “Reasonable notice should be provided to all residents”.

Local flexibility makes WCHA’s actual procedure a necessary subject of investigation. What procedure was adopted? Who carried it out? Which properties and assisted households did it reach?

The RAB must adequately reflect and represent assisted residents. WCHA must provide reasonable resources enabling it to communicate with assisted families and hold meetings with them. Read: § 903.13(a) — RAB representation and communication resources.

The supplied packet contains no documented procedure carrying the commissioner opportunity to those households.

The incumbent asked to participate before the RAB met

Eight days before the March 12 RAB meeting, the resident commissioner himself demanded inclusion. Baker’s March 4 email requested active participation in the RAB’s formation, selection, and proceedings “from inception to conclusion.” It went to WCHA and Chairperson Dixie Locke. It also requested notice to residents and an opportunity for them to participate.

Baker was not informed of the March 12 meeting or included in its proceedings, according to his account. The minutes do not list him as present. This was not an incumbent who stayed silent while management searched for interested residents. He had expressly sought involvement before the very meeting WCHA now relies upon to explain its process.

Read/download: March 4 participation demand — email and recipients (PDF); March 12 RAB agenda and minutes (PDF).

The exclusion concern extends beyond Baker. One resident describes residents expressing interest in serving and being told there would be no election, without receiving an explanation of another participation process. A second describes asking management and being told it was taking a different route; that resident was seeking information, not the seat personally.

A third signed statement, dated October 21, describes a mid-March conversation with Musgrave. The resident reports being told Baker was no longer resident commissioner, that there would be no election, and that a different route would be taken. The statement says no meaningful explanation or instructions for submitting a name followed, despite the resident’s interest in serving.

Read/download the separate accounts: Resident N — interest and absence of a participation process (PDF); Resident J — inquiry and management’s response (PDF); Resident R — mid-March inquiry and no path to submit a name (PDF). These are selected transcriptions of source statements; names, contact details, signatures, and unrelated private information are withheld. Complete originals remain preserved privately.

These accounts describe barriers in place of an opportunity: residents approached management, but were given no meaningful path to participate. They support investigation of exclusionary conduct by the executive director, including exclusion of the then-serving resident commissioner from a process in which he had expressly requested involvement.

August 8 put an existing intention in writing

Baker describes repeatedly making his intention to continue serving known verbally during the year, including before the March RAB meeting. The residents’ accounts independently describe discussions and inquiries about the seat during February and March. His August 8 letter did not originate the issue; it put his continuing intention in an unmistakable written record.

That letter expressly requested another commissioner term and identified itself as notice of intent to serve for any applicable small-PHA-exception process. WCHA and county officials received the email requesting distribution to both boards.

Read/download: August 8 written intent to serve (PDF);      email documenting its transmission and requested distribution (PDF).

How does WCHA reconcile an exception premised on receiving no resident intent during the applicable response period with an incumbent repeatedly expressing willingness to continue, other residents asking to participate, and an explicit written intent-to-serve letter before the nonresident appointment? WCHA should identify the notice, response dates, and its handling of each communication—not simply repeat that the RAB was informed.

Musgrave’s September 2 recommendation was management-driven. Baker, who served on WCHA’s board, confirms that the board never discussed Tucker or the resident-commissioner succession. The recommendation went forward through the executive director while the resident commissioner seeking participation was being excluded by the official he was responsible for overseeing.

This is the governance failure: the executive director drove the effort to replace a resident member of her own oversight body without that body deliberating on the recommendation. Locke had received Baker’s March participation demand and was a named recipient of the September 10 objection, which included the March agenda and identified his written intent to serve. Board leadership had been put on notice before the appointment proceeded.

Kathy Sands, who attended the September 10 county-board meeting, reported to Baker by text that Locke, Musgrave, and Tucker arrived together. That eyewitness account adds evidence of coordination to the documented recommendation and advance objection. Daily Truth’s assessment is that the sequence warrants investigation of a deliberate effort to bypass resident participation and replace resident oversight through executive fiat. The county’s appointment power does not answer the separate question of whether WCHA complied with the resident-member requirements.

Read/download: Musgrave’s September 2 recommendation letter (PDF).

What oversight did the board exercise?

The September 16 minutes list Dixie Locke, Tim McBride, Doyle Hucker, Linda Tucker, and Melinda States as commissioners present. Attorney Hannah Lamore attended by Zoom.

The board was addressing its own composition and residents’ representation. The record called for scrutiny: an advance objection, an interested incumbent, resident accounts of unanswered inquiries, and March meeting records that do not document the claimed notice.

Yet the September minutes record no examination of those matters. Musgrave’s assurance appears without any recorded demand for its supporting evidence.

Daily Truth challenges the competence and diligence of oversight that leaves a serious governance dispute answered by an unsupported management assurance. This is a question about commissioners’ stewardship of the agency and residents’ representation, not simply whether they trust their executive director.

If the commissioners investigated outside the meeting, they should identify the records reviewed, questions asked, and conclusions reached. If they did not, they should explain why the documented objection received no recorded examination.

HUD should obtain the notice and proof of receipt; the response-period dates; local outreach and RAB selection procedures; records of resident inquiries; management’s recommendation authority; and the board’s review of the objection. Interviews with the RAB participants and residents who approached management can test the competing accounts.

The issue is not whether Musgrave said notice occurred. She did. The issue is whether the board verified a lawful process protecting residents’ representation—and what evidence supports its conclusion.

Read the source documents

Open the document library — all twelve cited PDFs, with separate read and download links.

Records available for oversight review

The complete records underlying this reporting are available to HUD and other appropriate oversight bodies investigating WCHA’s compliance with the resident-commissioner requirements. The public document library contains the cited records and identified excerpts. The supporting material available privately includes complete witness statements, witnesses’ names and telephone numbers, correspondence, and additional records concerning resident interest, exclusion from participation, and the claimed exception.

Investigators may contact Ronald Baker at ronniepaulinc@gmail.com to obtain those materials and arrange contact with witnesses. Witness contact information will be provided privately to the appropriate investigators.

These materials are offered in support of the allegation that WCHA is operating in violation of the federal resident-board-member requirements and for independent examination of the Authority’s compliance.