south scattered sites disposition project relocation plan

62 Pages·2014·5.66 MB·English

SOUTH SCATTERED SITES
DISPOSITION PROJECT

RELOCATION PLAN

HOUSING AUTHORITY OF THE COUNTY OF LOS ANGELES
ALHAMBRA, CA

(INSERT HA LOGO)

NOVEMBER 26, 2014

PREPARED BY

1 JENNER, SUITE 200
IRVINE, CA 92618
PHONE: [phone]
TABLE OF CONTENTS
INTRODUCTION 1
OVERVIEW OF THE DISPOSITION PROJECT 4
Determination 4
Factors 4
Better Alternative 4
HACoLA Plan 4
Ongoing Rental Subsidy 5
OVERVIEW OF THE RELOCATION PLAN, PROCESS, AND STATUTES 6
Statutory Requirements for the Plan 6
Guiding Statutes for the Plan 6
Overview of Relocation Planning Process 7
OVERVIEW OF SECTION 8 ELIGIBILITY 9
Eligibility Criteria 9
Household Size Eligibility 9
Income Eligibility 9
Overview of Displacement 10
GENERAL DEMOGRAPHIC AND HOUSING CHARACTERISTICS 12
Population 12
Race and Ethnicity 13
Income 13
Housing Type Preferences 14
RELOCATION PLAN 16
Overview of the Relocation Program 16
Households Eligible for the Section 8 Program 16
Households Ineligible for the Section 8 Program 17
General Permanent Displacement Assistance 17
Replacement Housing Resources 18
Housing Survey 18
Affordable Housing Resources 20
Concurrent Residential Displacement 21
Program Assurances and Standards 21
Relocation Assistance Program 21
Advisory Assistance 22
Relocation Benefits Categories 24
Residential Moving Expense Payments 25
Relocation Rental or Down Payment Assistance 26
Last Resort Housing 29
Assistance with Security Deposits and Credit Check Fees 29
Assistance for Households Including Persons with Disabilities 30
Payment of Relocation Benefits 30
Immigration Status 31
Relocation Tax Consequences 32
Appeals Policy 32
Eviction Policy 33
Notices 34
Citizen Participation 36
Projected Date of Displacement 37
Estimated Relocation Cost (Budget) 37

LIST OF TABLES
Table 1: Comparison of Benefits 7
Table 2: HACOLA Unit Occupancy Limits 9
Table 3: Senior Head of Households 12
Table 4: Disabled Households 12
Table 5: Race and Ethnicity Distribution 13
Table 6: Preferred Housing Types 14
Table 7: HACoLA Voucher Payment Standards 17
Table 8: Distribution by Size of Occupied Project Units 18
Table 9: Replacement Units Needed versus Available Units 19
Table 10: Rent Ranges by Unit Type and Size 20
Table 11: Median Rent by Unit Type and Size 20
Table 12: Rental Assistance Payment Computation 28
Table 13: Relocation Cost Estimate 38

LIST OF APPENDICES
APPENDIX A: PROJECT SITE MAP
APPENDIX B: HUD INCOME LIMITS
APPENDIX C: GLOSSARY OF RELOCATION TERMS
APPENDIX D: INFORMATIONAL STATEMENT FOR FAMILIES/INDIVIDUALS
APPENDIX E: FIXED RESIDENTIAL MOVE PAYMENT SCHEDULE
APPENDIX F: HACoLA DS&S INSPECTION FORM
APPENDIX G: GENERAL INFORMATION NOTICE
APPENDIX H: PUBLIC COMMENTS AND RESPONSES
INTRODUCTION

The Housing Authority of the County of Los Angeles (HACoLA) administers subsidized rental-
housing units through the Public Housing program and Section 8 Housing Choice Voucher
program in the unincorporated areas and within the jurisdictions of participating cities
throughout the County. As part of their public housing inventory, HACoLA owns and operates
241 units of public housing on 38 scattered family development sites primarily located in the
unincorporated South Los Angeles communities of Athens-Westmont (see Appendix A). The
units were built from 1959 through 2001 and were intended to house low-income families.

HACoLA has adopted a plan to convert these 241 units of scattered-site housing into privately
owned and operated rental housing via Section 18 of the United States Housing Act of 1937
and 24 CFR Part 970. HACoLA’s plan is to sell the 241 units of public housing at fair market
value for approximately $35 million in gross proceeds to allow HACoLA to develop one or more
larger developments that can be more efficiently and effectively operated as project-based low-
income housing and provide funds to rehabilitate other public housing properties in South Los
Angeles.

The sale of the properties to private parties will most likely require the permanent relocation of
all existing tenants in the scattered sites developments. HACoLA is applying for 236 Section 8
Tenant Protection Vouchers (Vouchers) from HUD that can be issued to families being
displaced to assist with replacement housing and intends to provide Section 8 rental
assistance for those current households that qualify for such assistance. New property owners
will have the option to participate in the Section 8 program and consider entering into new
rental agreements with the existing tenants or require the site to be cleared prior to the close of
escrow in accordance with Section 18 requirements.

Overland, Pacific & Cutler, Inc. (OPC), a relocation consulting firm under contract with
HACoLA, has prepared this Relocation Plan (Plan) to evaluate the present circumstances and
replacement housing requirements of the current Project occupants. The Plan explains the
relocation benefits available to the public housing residents that would be permanently
displaced as a result of the disposition of the public housing units. For the purposes of the

Page 1 of 59
Plan’s preparation, information regarding the tenants occupying Project units was provided by
HACoLA and assumes that all existing residents have to be permanently relocated.

The Plan sets forth policies and procedures necessary to conform to statutes and regulations
for residential displacements, including Section 18 of the United States Housing Act of 1937
and 24 CFR Part 970, the California Relocation Assistance Law (Govt. Code §7260 et seq.,
the “CRAL”), and the California Relocation Assistance and Real Properties Acquisition
Guidelines (25 Cal. Code Regs. §6000 et seq., the "Guidelines"). These guidelines provide
that households who relocate permanently due to activity carried out or sponsored by a public
agency may receive certain re-housing benefits including compensation for the costs of
moving and other financial assistance required to establish tenancy in replacement housing.

In the event a buyer applies for and receives federally derived funding assistance for a
proposed project involving the public housing units acquired, relocation requirements under the
Uniform Relocation and Real Property Acquisition Policies Act of 1970, as amended (URA)
may be triggered as well. If applicable, the buyer may be responsible for providing relocation
assistance to existing tenants under the URA, if the benefits required under the URA exceed
those benefits provided by HACoLA to similarly displaced occupants.

Of the total 241 residential dwelling units, 229 units are currently occupied based on the rent
roll dated November 2014 provided to OPC by HACoLA. There are 722 occupants residing at
the properties within the 229 households.

Based upon current information about resident household composition, income, and
reasonable accommodation needs, which must be considered preliminary and must be verified
prior to any displacement, no households at this time are likely to be ineligible to continue to
qualify for public housing or the Section 8 program based on their income or legal presence in
the United States.

Under the programmatic rules of the Public Housing program and the Section 8 program, if a
household is ineligible for Section 8 assistance or public housing, they may need to be
permanently relocated into market rate, non-subsidized housing. All qualified households
would be relocated to other public housing units or units participating in the Section 8 program.

Page 2 of 59
A preliminary housing resource survey was conducted to identify available, comparable one-,
two-, three-, four-, and five-bedroom units within 10 miles of the 38 public housing
developments. Types of units included available public housing units, units with owners willing
to accept Section 8 Voucher Holders, affordable housing units, market rate units, and a variety
of housing types.

This Relocation Plan will address the following general topics:

1. Project description;

2. Assessment of the relocation needs of persons subject to displacement;

3. Assessment of available replacement housing units within South Los Angeles County;

4. Description of HACoLA’s relocation program;

5. Description of HACoLA’s outreach efforts, project timeline, and budget.

In accordance with State Guidelines, the plan will be made available to all affected households
for a period of 30 days for review and comment prior to approval by the Housing Authority
Board of Commissioners.

DISCLAIMER

This relocation plan in itself does not trigger relocation BENEFITS. Residents should
not move prior to discussions with the Housing Authority of the County of Los Angeles.

Page 3 of 59
OVERVIEW OF THE DISPOSITION PROJECT

Determination:

The Housing Authority of the County of Los Angeles (HACoLA) has determined that the
disposition of 38 small, scattered, family public housing developments, consisting of 241 units
in South Los Angeles (SLA) is in the best interest of the residents and HACoLA, is consistent
with the goals of HACoLA, and is consistent with the United States Housing Act of 1937.
Disposing of the 38 developments of public housing will allow HACoLA to develop one or more
larger developments that can be more efficiently and effectively operated as project-based low-
income housing.

Factors:

The 38 properties range in size from one unit to 18 units and are scattered over several miles
in Los Angeles County. The size and distance between these scattered sites poses distinct
challenges in managing them in an effective and efficient manner. The properties cost at least
20% - 25% more to operate than HACoLA’s other public housing developments because of
staff transportation costs, unproductive staff time related to travel to the sites, lack of
standardization of building and unit components, and other factors. Their scattered locations
also make the concentrated delivery of supportive services much more difficult.

Better Alternative:

Having one or more affordable housing developments of moderate size, versus small scattered
sites, will allow for a more efficient and effective operation without overly concentrating low-
income families. Some of the areas of improved effectiveness and efficiency would include
improved monitoring of vendor contracts, completion of more work orders in a timely manner,
and reduction in energy. Residents could expect improved developments and an increased
management presence. Distributing information to residents at larger developments is far
more efficient and effective than trying to reach residents at multiple, small, scattered sites.

Resident services also would be provided more effectively and efficiently at one or more
housing developments. The features would be patterned after resident services provided at
other larger HACoLA public housing developments.

HACoLA Plan:

HACoLA’s plan is to sell 241 units of public housing for fair market value for approximately $35
million in gross proceeds. The proceeds would be used, possibly in combination with low-
income housing tax credits, to provide funding for the development of at least 100 units of

Page 4 of 59
project-based voucher family units in SLA on no more than three sites. The development or
developments would include a management office, community room, and space for resident
services.

HACoLA would apply for, and use, Section 8 Tenant Protection Vouchers to help provide
affordable replacement units. Purchasers of the current properties would be encouraged to
accept vouchers of current residents who do not want to move. Families who want to move
could do so with the replacement housing assistance provided to them through their vouchers.

HACoLA is a high performer and has a proven track record of providing quality project based
housing. The development of one or more larger affordable housing developments to replace
the scattered sites would improve the efficiency and effectiveness of providing quality housing
for low-income residents of SLA.

Ongoing Rental Subsidy: Upon conveyance to the new owner(s), the units will no longer
classify as Public Housing. Tenant Protection Vouchers (Vouchers) will be available to all
existing income-eligible households. Each eligible household currently in HACoLA public
housing would have the ability to apply for, and receive, a Voucher. The Voucher affords the
holder an opportunity to choose where they want to live. The holder must live in HACoLA’s
jurisdiction for at least one year before being able to port out.

Holders of the voucher could elect to remain in South Los Angeles County and, if housing is
available, rent housing in the same neighborhood in which they presently reside. The choice
of location is up to the voucher holder. It is anticipated that HACoLA or its representative will
contact the impacted residents of the public housing units in the latter half of 2016 to arrange
for interviews and briefings regarding the Section 8 program and to begin the application
process. This estimated timeframe is dependent on when the disposition application and the
application for Section 8 assistance is approved by HUD. Questions regarding Section 8
should be directed to HACoLA.

Page 5 of 59
OVERVIEW OF THE RELOCATION PLAN, PROCESS, AND STATUTES
Statutory Requirements for the Plan: Statutory requirements for this plan are per the
California Relocation Assistance Law (Govt. Code §7260 et seq., the “CRAL”), Section 6038 of
the California Relocation Guidelines (Guidelines) and Section 18 of the United States Housing
Act of 1937 and 24 CFR Part 970. In the event Federal funds are introduced into the Project,
HACoLA understands tenant relocations would have to be conducted within the requirements
of the Uniform Relocation Assistance and Real Properties Policies Act of 1970, as amended
(URA), as well.
The purpose of the Relocation Plan is to:

(a) Describe the project, its schedule, and its financing plan;
(b) Identify the anticipated project impact on the occupants of the properties;
(c) Identify the availability of potential replacement units for impacted occupants;
and,
(d) Explain the Relocation Assistance Program.
This Plan is preliminary. In accordance with the Guidelines, a draft of the Relocation Plan is
required to be made available for a 30-day review and comment period by impacted parties
and the public prior to submitting it to the agency’s decision making body, the HACoLA Board
of Commissioners, for approval.
The public will have an opportunity to submit comments regarding the Draft Relocation Plan.
Comments and responses will be incorporated into a final Relocation Plan that will be
submitted to the Housing Authority Board of Commissioners for review and consideration. If
substantial changes are made to the Project as contemplated in this preliminary plan, or
relocation activity does not commence within 12 months of the Plan's approval, the Plan will be
revised and re-circulated for public comment prior to being presented to the Board of
Commissioners for further approval.

Guiding Statutes for the Plan: When residents are required to relocate as a result of a
publicly-assisted rehabilitation or housing development project, residents become eligible for

Page 6 of 59
relocation assistance under the State of California or URA laws and guidelines, or other
regulatory requirements, depending on the Project funding sources.

This Plan sets forth policies and procedures necessary to conform to statutes and regulations
for residential displacements, including the CRAL and Guidelines and Section 18 of the United
States Housing Act of 1937 and 24 CFR Part 970. Table 1 below outlines several differences
between the relocation requirements of Section 18 and State of California relocation
regulations.

Table 1: Comparison of Benefits
BENEFIT TYPE SECTION 18 STATE OF CALIFORNIA (TITLE 25)
Actual & reasonable cost or a fixed
Actual &
Moving Assistance payment based on the schedule in
reasonable cost
Appendix F
The difference between the tenant’s portion
of rent and utility costs at the displacement
unit or 30% of adjusted, gross, monthly
Rent Differential Not applicable
household income and the tenant’s portion
of rent and utility costs at the replacement
unit for 42 months
Referrals to Housing Required Required

Overview of Relocation Planning Process: For the purposes of this Plan’s initial
preparation, information regarding the Project tenants was provided to OPC by HACoLA. In
addition, all residents were mailed a survey by HACoLA staff to solicit household information
pertinent to the Plan. The responses to the surveys, as well as existing information on the
Project households, were provided to OPC by HACoLA.

Information provided included number of persons in the household, size of the unit, disabled
members, senior members, number of children in the unit, preferred language, race, ethnicity,
annual income, current rent, legal presence status, preferred type of replacement housing
(Section 8, public housing, etc.), and preferred relocation area.

Page 7 of 59