As the need to convert and redevelop public and other types of affordable housing increases, so does the need to temporarily or permanently relocate tenants. The regulatory and human capital requirements are often misunderstood and poorly planned. Although a regulatory requirement and a project cost, relocation is all about taking care of people; when done right, cost, time, and frustration can be saved. Through an interactive dialogue between the presenter and the audience this session will provide an overview of the relocation planning, noticing, compensation, and advisory services requirements under the Uniform Relocation Act (URA). Specific requirements for various HUD funding programs including RAD, HOME, and Project Based Section 8 will be presented. The presenter will share lessons learned, tips, and solutions that the audience can use to achieve a successful relocation program. Bring your thoughts, experiences, concerns, and questions for a lively discussion.

1. Relocation 101
For Housers
Chad Wakefield, PMP, SR/WA, R/W-RAC
Program Manager
2018 Texas Housing Association
Conference, Galveston, TX

2. Poll
Anyone Not From a PHA?
Who’s Done Relocation Before?
What Do You Want Out of This?

3. What’s in This For You?
žInsight into the relocation process
start to finish
žBetter Understanding of
— Requirements plan & execute
relocations
— When you may have an issue you need
help with
— When you need to bring in outside help

4. What Do You Mean By Relocation?
ž Cause a person to move for a federally
assisted project
— I.E., RAD, Demo/Dispo, Redevelopment,
Rehab….
ž Only talking about URA, RAD, & Section 18
ž Not referring to normal operations

5. Why is This Important?
ž Critical to GET it RIGHT
— Its regulated activity
— Getting WRONG, costs!
— PHA has to maintain its credibility
ž Public housing rapidly converting
ž Seemingly, all PHA project are federally
assisted
ž YOU don’t want to be the subject of an IG
report

6. Successful Relocation = R3
Required Reasonable Right
Almost always will have to explain/defend the reasonable.

7. Rules That Could Apply
Federal
ž Uniform Relocation Act (URA) [$$ driven –ex. NHTF]
— HUD Handbook 1378 implements the URA for HUD programs and
provides detailed guidance for temporary relocation
ž Section 18 [Disposition/demo driven]
ž RAD [Conversion driven]
ž 49 CFR Part 221.795 (HUD 221Loans)
ž Section 104(d) (HOME and CDBG only – demo of low-income
units)
State - TDHCA [LIHTC, other $ driven]
Local Policy
Lender/Investor Requirements?

8. When Does The URA Apply?
ž Federal source is used in project
ž PHA/LPA requires person to/for/because:
— Acquire property & require existing occupants to
move permanently
— Require their own existing occupants to move
permanently
— Temporary relocation for rehab

9. When Does the URA Not Apply?
ž Folks vacate under normal PHA operations
— Evictions
— Non-project related Upsize/downsizes
— Non-project Related Reasonable Accommodations
— Waitlist transfer
— 100% voluntary moves (tenant initiated)
ž Section 18 demo/dispo (and no fed $ used)
ž Straight RAD conversion (no $ used, no relos
required)
ž Disasters and emergency response, unless
federal funds are being used

10. URA Thou Shalt Musts!!
1) Plan the Relocation Activity (write a plan)
2) Provide Advisory Services
3) Provide Advanced Notice
4) Compensate for ALL Move Related Actual,
Reasonable and Necessary Out of Pocket Costs
5) Document Your Efforts
6) Provide an Appeals Process
Remember the URA is Federal Law.
Start with the assumption you will be audited.

11. Relocation Process
Planning
Engage Outside Help
General Notices
Meetings
Interviews
Cost Estimating
Schedule
Write Plan
Approve Plan
Execution
Procure Movers
Ready Tenants
Eligibility Docs
Eligibility Meetings
Locate Housing New
Move
Claims
Distribute Payments
Maintain Files Throughout
Closing
“Always Be Closing”
Specialist Update File
Manager Review File
Auditor Review File
Final Sign Offs or Corrective
Actions
Monitor and Control

12. Relocation Plans
ž HUD and Lenders will require a written plan (PHA Board other governing
body involved also should)
ž Contents
— Describe project
— Describe who is impacted and they are Impacted
— Detail funding sources and what relocation obligations are associated with the
source
— Detail how and who will provide advisory services
— Detail how and when notices will be provided
— Detail how and when moving and housing assistance will be provided
— Detail how, what, and when activity will be documented
— Detail the process for appeals
ž Living document that has to be updated as project evolves
ž Projects frequently layer/mix financing and programs. The manner ALL
relocation requirements will be addressed must be stated in the
relocation plan.
TIP: You can’t squeeze ALL this content into a paragraph; shouldn’t crib someone
else’s plan; BE prepared to have it reviewed (and explain your unique situations)

13. Advisory Services
ž Community meetings (give notice and take notes)
ž 1:1 Interviews ideally in their homes
ž Informational statements
ž Required Notices
ž FAQs (not required but highly recommended)
ž Provide an available and knowledgeable team at
reasonable hours
THE MORE CONTACT THE BETTER AND THE MORE
DOCUMENTED THE BETTER
Take the time to customize notices for your project

14. URA Required Notices
ž General Information Notice (as early as
possible)
ž Notice of Non-displacement if doing temporary
(must know though that you aren’t displacing
them…if unsure don’t serve until you are)
ž 90-day (Permanent only as a required…overkill
for temporary)
ž 30-day (Temporary requires but may need to
use for perms also)
ž Eligibility (or Non) for perms and an MOU for
temps

15. Permanent Relocation Req.
ž Written statement of rights to displacee,
ž Notice of Eligibility (NOE) explaining specific
benefits and calculations of those benefits
displacee is eligible for
ž Minimum of 90-days notice
ž Referral to at least ONE (three if you can)
comparable housing unit available for rent
before person required to move
ž CANNOT ask anyone to waive their rights

16. Temporary Relocation Req.
ž Written notice of rights and assistance
provided (MOU),
ž Minimum of 30-days written notice prior to
move date,
ž CANNOT exceed 12-months without
becoming permanent (are ways to navigate
the issue)
ž Again, NO waiver of rights acceptable!

17. URA Compensation
ž Moving:
— Actual cost reimbursement or direct payment (such as a
mover)
— Fixed payment based on federal schedule (you may be able to
customize but you will have to defend it with a methodology
and study of costs)
— Incidental costs such as utility transfer [not obligated if giving
a fixed payment]
ž Housing:
— Temporary: Obligated to pay increased monthly cost (direct or
reimbursement)
— Permanent: Differential “gap” payments. Much more
complicated (see me later).
ž $100 Dislocation Payment for PHA residents ONLY

18. URA Rent Differential Payment
ž Monthly difference between base rent (lesser of 30% of
displacees income or current rent [TTP]) & market rent as
established by agency for an available housing unit
— Non-Section 8 Example – $500 per month is 30%, yet
contract rent is $600 & a new unit is $700. Equation here is
$700-$500 * 42 = $8,400
— Section 8 Example - $500 per month is 30%, TTP was $450
and now is $500. Equation here is $500-$450 * 42 = $2,100
ž Federal max is $7,200. Anything over that is considered a
last resort housing payment.
ž HOME and CDBG trigger 104(d) also if persons are low
income and there is demo or conversion of units
configuration (reduced bedrooms)

19. Other URA Requirements
ž Housing HAS to be DS&S for the resident
ž Assistance with transportation
ž Referrals to social services as needed
ž Modify housing to ensure DS&S and
accessibility
ž Emergency response reduces some
requirements when federal funds are used in
the recovery efforts
Make sure you know the population and take care of their
needs i.e. you can’t put someone without
transportation 20 miles from the bus

20. Unique Stuff Under RAD
ž Right to Return
ž Can’t relocate until you have a RCC unless you have
prior approval from transaction manager
ž Relocation plan due before or with financing plan;
advise don’t wait, start early so you know what your
schedule and costs will/should be
ž Can transfer to other property you control, but be
careful as there are limits (reasonableness test); i.e. if
its 20 miles away from current home you have to give
more options such as a voucher or help to move into
market rate unit
ž RAD does not eliminate URA requirements, it does
however, clarify them for temporary relocations

21. Unique Stuff Under Section 18
ž No rent differential payment
ž No $100 Dislocation payments
ž Provide Comparable Housing (Other LIPH,
Voucher)
ž No GIN and No NOE
ž Still give 90-day Notice
ž Still give advisory services (counseling)
ž Still pay Actual and Reasonable Out of Pocket
Move Costs
ž Mixing RAD and Section 18 adds relocation
requirements to project

22. Layering Rules & Regulations
ž When federal funds are used, the URA is the
dominant regulation.
— RAD and Section 18 for example DO NOT supersede
URA requirements, they would only enhance what
may be provided to the person being relocated.
ž ALL program requirements must be
understood and reconciled to determine what
additional relocation requirements will be
involved in the project (EARLY PLANNING IS
CRUCEL).

23. Documenting
ž Use an individual hard file or electronic file for
each case
ž Keep diary/log of all verbal and written
communications
ž Notices always addressed to the head of
household by name
ž Must be able to prove you served a specific
notice to a specific person; certified mail,
personal service, posted with photos – DO NOT
SEND YOUR MANAGEMENT STAFF OUT WITH A
GENERIC NOTICE AND A CHECKLIST OF
RECEPIENTS

24. Questions to Ask to Determine
When You Need Help
ž Have we ever done this? No = Get Help
ž Do we have staff to devote to treating relocation like a
project v. just part of their day to day? No = Get Help
ž Do we know how to evaluate all issues including
contingencies and unintended consequences? No= Get Help
ž Have we done this before and gotten our hands slapped?
Yes = Get Help
ž Are there certain things we know we can do, but haven’t in
awhile? Yes = Get Help (never done = Get Help)
ž Have we ever used the sources of funding we are
considering? Yes/No = consult with someone or Get Help

25. Three Things to Always
Remember
1. Treat your folks like your grandmother (courtesy,
respect, and care go miles and miles).
2. Understand what you have to do, what it’s going
to cost, and how long it will take UP FRONT like
you do (or should) w/ construction related
issues.
3. Relocation is a Project. EMPLOY BASIC PROJECT
MANAGEMENT SKILLS of Scope, Time, Cost,
Communication, Stake Holder, and Quality
Management and Control.

26. Contact Information
Chad Wakefield, OPC
Tel 480.435.0623
cwakefield@opcservices.com
LinkedIn www.linkedin.com/in/chadwakefieldopc
Texas Offices: Dallas/Austin/Corpus Christi
Offices also in Phoenix, AZ, Las Vegas, NV and
throughout California
www.opcservices.com