A.3.5.2 Relocation Plans

A. The relocation plan must address specific details, schedule, funding, and management of the relocation of residents. At the time of the loan application submission, a plan developed by a qualified relocation consultant must be submitted for the Lender and HUD’s initial review and approval. After the Firm Commitment is issued and prior to the Closing, final minor adjustments to the plan, schedule, or budget may be considered.

B. For a relocation plan to be reliable and acceptable, it must adequately address and include the following elements:

1. Communication: The plan must describe how the owner and/or property management will establish and maintain timely and effective communication with the tenants and exactly who will be responsible for such communications, both messages or announcements, to all tenants or groups of tenants as well as one-on-one meetings or interviews with tenants. In addition, the plan must show the form and manner of any notices, advisories or agreements proposed as a means of documenting the information communicated to and received by tenants and tenants’ responses, or agreements related to the date, time, and duration of displacement and tenant’s acceptance of owner provided services or accommodations or tenant’s discretionary choice of alternative accommodations.

2. Resident Interviews: The plan must have specific information about the resident’s needs (medical, disability, pets), based on up-to-date one-on-one interviews with the residents performed by the relocation consultant. The plan must explain how these needs will be met.

3. Packing, Moving and Storage: The plan must describe how and who is responsible for any packing, moving, and storage. A professional moving company that can be relied on to meet the relocation schedule and having the appropriate workers compensation and damage and loss insurance, is required.

4. Move-Out and Move-In Inspections: The plan must describe who on the relocation consultant’s team will perform the move-out and move-in inspections to make sure the unit is ready for the Contractor to begin work, and then ready for the tenant to return once work is complete.

5. Relocation Schedule: The plan must include a relocation schedule identifying which residents are moving out or into which specific units and when. A detailed relocation schedule with specific dates for each unit, sequenced and coordinated with the Contractor’s Construction Schedule, is required. This schedule is required whether residents are relocated on site (in “vacant units”), offsite in a hotel, or other offsite locations.

   • The relocation schedule must identify when (date & time) the units to be rehabilitated (by unit number), and when any other common or project areas, will be turned over to the Contractor – for their control and performance of the work. The schedule must also show when the units will be inspected and reoccupied after rehabilitation by the Contractor is complete.

• The relocation schedule and the construction schedule must be reviewed by the Lender to assure that they are coordinated. Prior to closing, the Lender must provide a written acceptance by the Contractor of the owner’s relocation schedule with a dated copy of the relocation schedule attached to the letter.

• The final approved relocation schedule, along with the final approved construction schedule, must be attached to and made part of the relocation escrow agreement (see below).

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Appendix 3 Program Specifications and Limitations A.3.5 Details Required in Relocation Plans

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6. Security and Safety: The plan must provide adequate security and safety during construction. Typically, the Contractor is responsible for and focused on the safety and security of the property, materials, equipment, employees, and subcontractors during construction. However, for construction in occupied properties, the Owner is responsible for the security of tenants. Accordingly, safety and security of tenants and their personal property must be addressed in the relocation plan. The relocation plan should describe a comprehensive approach to tenant safety and security (appropriate to the property location) in addition to measures normally provided. The relocation consultant should be knowledgeable of the actual condition and safety of the premises for any housing or lodging accommodations recommended to or arranged for displaced tenants. Such housing or lodging accommodations must be decent, safe, and sanitary.

7. Claims and Complaints Procedures: The plan must describe how tenant claims or complaints, and any damage to personal items, will be addressed in a timely manner.

8. Reimbursement Procedures: The plan must include the procedures for timely reimbursement to tenants for per diem rates, all reasonable out of pocket expenses necessary to meet special needs of tenants resulting from displacement, including but not limited to packing, moving, storage, transportation, or increased housing costs. Reimbursement for relocation expenses must coincide with the relocation and construction draw schedules.

9. Elderly Housing & Disabled: Temporary relocation of elderly or disabled residents and families with young children must avoid unnecessary stress and protect their wellbeing, health, and safety.

   • The degree of the resident’s expressed preference to stay in the units during construction, while considered, are not the only or principal indicators of the impact of the scope of rehabilitation work on tenants. Rather, the qualified independent relocation consultant must objectively evaluate the impacts of the scope of the work on the residents, and make determinations based principally on resident safety and wellbeing.

• The HUD Minimum Property Standards (MPS) requires elevators in housing of three stories or more that serve the elderly. The resident relocation plan must take this into account and make sure the elevator operation is maintained for the residents throughout the rehabilitation (and if not, relocate the residents). The duration of the elevator outage based on the scope of the upgrade or repairs, the identification of residents impacted and their relocation, need to be addressed well in advance of construction by the development and relocation teams.