relocation plan and conversion impact report for the ......relocation plan and conversion impact...

Relocation Plan and Conversion Impact Report for the Pomona Gardens (Rick's Trailer Park) Project

Prepared for Related Companies of California, LLC

Prepared by LACAL Consulting, Inc.

March 17, 2014

Relocation Plan and Conversion Impact Report for the Pomona Gardens (Rick's Trailer Park)

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Table of Contents

Introduction ..................................................................................................................................... 5

I. Project Location and Description ............................................................................................... 7

A. Location ................................................................................................................................. 7

B. Project Description ................................................................................................................ 9

C. General Area Demographic and Housing Characteristics ..................................................... 9

II. Relocation Needs Assessment ................................................................................................. 11

A. Housing Mix ........................................................................................................................ 11

B. Project Rents ........................................................................................................................ 11

C. Occupancy and Overcrowding ............................................................................................ 12

D. Tenant Income Information ................................................................................................. 12

E. Replacement Housing Needs ............................................................................................... 12

F. Ethnicity and Household Language ..................................................................................... 13

G. Household Disabilities and Senior Households .................................................................. 13

H. Preferred Relocation Areas ................................................................................................. 13

III. Housing Resources................................................................................................................. 14

A. Methodology ....................................................................................................................... 14

B. Replacement Housing Availability ...................................................................................... 14

1. Residential Rental Housing ............................................................................................... 14

2. Mobile Homes for Sale Housing ....................................................................................... 15

3. Pad Space Rent .................................................................................................................. 15

4. Summary ............................................................................................................................ 15

C. Related Issues ...................................................................................................................... 16

1. Concurrent Residential Displacement ............................................................................... 16

2. Temporary Housing ........................................................................................................... 16

IV. Mobile Home Park Closure Report ....................................................................................... 17

A. Conversion Impact Report................................................................................................... 17

1. Named Parties .................................................................................................................... 17

2. Description of Proposed New Use ..................................................................................... 17


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3. Timetable for Conversion of the Park ............................................................................... 18

4. Number of Spaces within Park .......................................................................................... 18

5. Name and Mailing Address of Residents .......................................................................... 18

B. Conversion Impact Report for Mobile Home Closure ........................................................ 18

1. Resident Profile ................................................................................................................. 18

2. Notification Requirements ................................................................................................. 19

3. Alternative Housing Analysis ............................................................................................ 20

4. Mitigation/Compensation Analysis ................................................................................... 20

5. Availability of Rental Assistance ...................................................................................... 21

C. Conclusion ........................................................................................................................... 21

V. Relocation Program................................................................................................................. 22

A. Program Objectives, Standards and Assurances ................................................................. 22

B. Relocation Advisory Assistance .......................................................................................... 23

C. Relocation Financial Assistance - Owners and Tenants ...................................................... 23

1. Residential Moving Expense Payments ............................................................................ 24

2. Rental Assistance to Tenants Who Choose to Rent .......................................................... 24

3. Downpayment Assistance to Tenants Who Choose to Purchase ...................................... 26

4. Payments to Mobile Home Owners ................................................................................... 26

5. Last Resort Housing .......................................................................................................... 27

D. Relocation Tax Consequences............................................................................................. 27

E. Grievance Procedures .......................................................................................................... 27

F. Eviction Policy ..................................................................................................................... 28

G. Citizen Participation ............................................................................................................ 28

H. Project Timing ..................................................................................................................... 29

I. Estimated Relocation Costs .................................................................................................. 29

Appendices .................................................................................................................................... 30

Appendix A ................................................................................................................................... 31

HUD 2014 Income Limits - County of Los Angeles ................................................................ 31

Appendix B ................................................................................................................................... 33

Name and Address of Park Residents ....................................................................................... 33

Appendix C ................................................................................................................................... 35


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Relocation Informational Brochure ........................................................................................... 35

Appendix D ................................................................................................................................... 42

Fixed Moving Schedule ............................................................................................................ 42

Appendix E ................................................................................................................................... 44

Public Comments and Response ............................................................................................... 44

List of Figures

Figure 1: Regional Project Site Setting .......................................................................................... 7 Figure 2: Pomona Gardens Trailer Park ........................................................................................ 8 Figure 3: Aerial View of Project Vicinity...................................................................................... 8

List of Tables

Table 1: 2010 Census Population - City of Pomona and Impacted Tract ...................................... 9 Table 2: 2010 Census Housing Units - City of Pomona and Impacted Tract .............................. 10 Table 3: Housing Units and Bedroom Sizes (22 Respondents) ................................................... 11 Table 4: Tenant Income Levels (22 Respondents) ...................................................................... 12 Table 5: Replacement Housing Needs (22 Respondents) ............................................................ 13 Table 6: Availability and Cost of Replacement Rental Housing ................................................. 14 Table 7: Availability and Cost of Mobile Homes for Sale .......................................................... 15 Table 8: Timetable for the Mobile Home Park Closure .............................................................. 18 Table 9: Sample Computation of Rental Assistance Payments ................................................... 25


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Introduction

The Related Companies of California and Shield of Faith Economic Development Corporation (Developer) are in the process of entering into a Disposition and Development Agreement with the City of Pomona Housing Authority (Authority) for the redevelopment of 3 parcels totaling approximately 2.46 acres and encompassing the Pomona Gardens (Rick's) Trailer Park (Project). The Project is located on the south side of West Holt Avenue near the intersection of West Holt Avenue and North Hamilton Boulevard. The Authority currently owns all 3 parcels which will be conveyed to the Developer at closing for the appraised value of the land. The Project necessitates the acquisition and relocation of privately-owned parcels of real estate and the displacement of 22 households.

The scope of development of the Project includes the construction of a 2,600 square feet of community space that will accommodate leasing and management offices, community room, a lounge, and a computer room, as well as a 62-unit affordable housing development with 41 two- and three-bedroom family units, and 21 units reserved for tenants eligible under the MHSA program. All parking will be located on-grade and directly adjacent to the building with a parking ratio of 1.37. The units will serve low income families whose annual household incomes fall between 30%-60% Area Median Income.

The Project will require the relocation of 22 residential households. The involvement of the Authority, a public entity, triggers the need to provide relocation assistance and benefits in accordance with state relocation law (California Government Code Section 7260 et seq.) and the implementing regulations (California Code of Regulations Title 25 Chapter 6). Among the regulatory requirements applicable to the Project is the need to prepare a relocation plan. The purposes of a relocation plan, in broad terms, are to address the needs of potential displacees, the availability of adequate replacement housing, and the Developer’s plans to provide required assistance.

Additionally, state law requires the owner to prepare an Impact Report due to the proposed closure of the mobile home park. LACAL Consulting, Inc. (LACAL), an experienced, professional relocation consulting firm, has been selected to prepare both the relocation plan (the Plan) and the impact report (the Report). Due to the similarities of data and assistance/mitigations required for both the Plan and Report, LACAL has combined the requirements of both the Plan and Report into one document (the Document).

This Document provides the results of a needs assessment survey, a housing resource study and details of the proposed relocation program the Authority will follow, including the necessary elements for the closure of the mobile home park. This Document sets forth policies and procedures necessary to conform with statutes and regulations established by the California Relocation Assistance Law, California Government Code section 7260 et seq., and the California Relocation Assistance and Real Property Acquisition Guidelines, Title 25, California Code of


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Regulations, Chapter 6, Section 6000 et seq. (the Guidelines) as it relates to relocation assistance activities. Additionally, this Document identifies the requirements that must be met for the closure of a mobile home park established by a California Government Code section 65863.7 and 65863.8, and California Civil Code 798.56.

The Document is organized in 5 sections:

Section I: General demographic data and Project description

Section II: Profile of residents who may be affected

Section III: Description of available housing resources

Section IV: Description of the mobile home park closure requirements

Section V: Description of the relocation assistance program


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I. Project Location and Description

A. Location

The Project is located on West Holt Avenue in Pomona, generally between North Hamilton Boulevard on the east, Las Brisas Circle on the west and West Monterey Avenue on the south. The subject site is comprised of 3 parcels totaling 2.46 acres, with frontage on West Holt Avenue near the intersection of Holt and Hamilton. The site is located less than a mile south of I-10 freeway and less than a mile east of SR-71. Ontario International Airport is less than 5 miles east of the Project and Pomona is neighbored by the communities of Montclair, Ontario, Upland, Chino, Claremont, La Verne, San Dimas and Diamond Bar. (see Figure 1 for Regional Location Setting, Figure 2 for Specific Site Location and Figure 3 for Aerial Project View).

Figure 1: Regional Project Site Setting

Specific location of Pomona Gardens Trailer Park is at 934 West Holt Avenue in Pomona. The area is light commercial; next to the property is a mini mart and Pomona Inn Motel is immediately across the street. Residential units are older, small single family residences and small complexes: duplex, triplex, fourplex.


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Figure 2: Pomona Gardens Trailer Park

Figure 3: Aerial View of Project Vicinity


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B. Project Description

The Developer intends to build a 62-unit affordable housing complex with 2 components: Tax Credit Housing Component and MHSA Supportive Housing Component, one with 41 units and with 21 units, respectively. The 41 family units will be located in one 3-story building consisting of stacked flats as wells as 2-story town homes along the perimeter of the site. Proposed amenities will include 2,600 square feet of community space for leasing/management offices, community room, a lounge and a computer room. The 21 Mental Health Services Act units will be set-aside for the exclusive use of MHSA eligible Tri-City Mental Health Authority clients.

The financing for the Holt & Hamilton project will consist of the following sources: acquisition, construction, equity, permanent and restrictive covenants. The funding for relocation is not yet secured and any relocation activities are contingent upon the Developer's securing of funds.

C. General Area Demographic and Housing Characteristics

According to the 2010 U. S. Census, the population of the City of Pomona was 149,058 and the population of the impacted Census Tract 4023.04 was 3,848 (see Table 1). Corresponding Census data concerning the housing mix is shown in Table 2.

Table 1: 2010 Census Population - City of Pomona and Impacted Tract

Population Tract 4023.04 % City %

Total Population 3,848 100.0 149,058 100.0

White 1,813 47.1 71,564 48.0

Black or African American 129 3.4 10,924 7.3

American Indian and Alaska Native 44 1.1 1,763 1.2

Asian 106 2.8 12,688 8.5

Native Hawaiian and Other Pacific Islander 4 0.1 282 0.2

Some Other Race 1,620 42.1 45,171 30.3

Two or More Races 132 3.4 6,666 4.5

Hispanic or Latino (of Any Race) 3,463 90.0 105,135 70.5

Source: U.S. Census Bureau, Race and Hispanic or Latino Origin: 2010


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Table 2: 2010 Census Housing Units - City of Pomona and Impacted Tract

Population Tract 4023.04 % City %

Total Units 1,005 100.0 40,685 100.0

Owner-Occupied 274 27.3 21,197 52.1

Renter-Occupied 651 64.8 17,280 42.5

Vacant Housing Units 80 7.9 2,208 5.4

Available for Sale Only (of Total Vacant Units) 11 13.7 445 20.2

Available for Rent - Full Time Occupancy 51 63.7 1,086 49.2

Sold or Rented - Not Occupied 3 3.8 137 6.2

Otherwise Not Available (e.g. seasonal, recreational, migratory, occasional use) 1 1.3 81 3.6

Other Vacant 14 17.5 459 20.8

Source: U.S. Census Bureau, General Housing Characteristics: 2010


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II. Relocation Needs Assessment

This Plan provides the results of a needs assessment survey, their incorporation into the planning process, and details of the Developer's proposed relocation program. This Plan sets forth policies and procedures necessary to conform to federal and state statutes and regulations for residential displacements. Permanent funding sources for the Project include combination of MHSA residual receipts loan administered by CalHFA, the City of Pomona Housing Authority's Seller Carryback Note and tax credit investor equity. In addition, a perm lender will be determined to provide a conventional permanent loan. The Project will have Restrictive Covenants from TCAC and from CalHFA for a 55 year period.

To obtain information necessary for the preparation of this Plan, personal interviews with the current residents on the Project site were conducted during the week of February 3, 2014. Interviewers were successful in obtaining survey responses from all 22 units, either in person or via a phone follow-up. Inquiries made of the occupants included household size and composition, ages of occupants, rental and income information, length and type of occupancy, ethnicity, primary language in the home, disabilities and health problems, and preferences related to replacement housing and location.

A. Housing Mix

The Project consists of 22 residential units, 19 trailers or small motor home units and 3 conventional units: one single family residence and one duplex. The bedroom size mix is presented in Table 3. There are currently no vacant units within the park.

Table 3: Housing Units and Bedroom Sizes (22 Respondents)

No. of Bedrooms One Two Three Four

No. of Units 1 0 2 0

No. of Trailers 4 7 7 1

B. Project Rents

Besides the 3 conventional rental units, there are 5 trailer occupants that do not have proper title to the home. Either they are in the process of transferring title or rent from relatives, they pay pad rent only. The Project unit rents range from $675 for a one bedroom apartment to $750 for a three-bedroom single family residence. No Project households are receiving Section 8 or any


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other Housing Assistance. Pad rents currently range from $430 to $790, depending on the size of the lot and include separately metered utilities.

C. Occupancy and Overcrowding

The Project site consists of 106 individuals among 22 respondent units; 74 adults and 32 children. The average household size is 4.8 persons per unit.

The standard housing density utilized is two persons per bedroom and one person in a common living area for tenant occupied units although this can be adjusted to include two persons in the common living area. There are 5 households in the Project requiring larger units based on this occupancy standard.

D. Tenant Income Information

Income information was provided by all responding households, although some information may be incomplete since the person surveyed did not know the exact income earned by all members of the household, and according to the income levels for the County of Los Angeles adjusted for family size as published by the California Department of Housing and Community Development (HCD), in February 2014 (see Appendix A), 12 households qualify as extremely low income (30% or less of area median), 5 households qualify as very low income (31%-50% of area median), 4 households qualify as low income (51%-80% of area median), and one household qualifies as above moderate income (over 120% of area median).

Table 4: Tenant Income Levels (22 Respondents)

Income Level Extremely Low Very Low Low Moderate Above

Moderate No. of Households 12 5 4 0 1

E. Replacement Housing Needs

Replacement housing needs, as expressed in this Plan, are defined by the total number of required replacement units and the distribution of those units by bedroom size. The projected number of required units by bedroom size is determined by comparing household size with the Developer’s replacement housing occupancy standards. These standards, generally, allow for up to three persons in a one-bedroom unit, five persons in a two-bedroom unit, and seven persons in a three-bedroom unit. There are 5 overcrowded units in the Project: one conventional apartment unit and 4 trailers with inadequate room space for the number of occupants.


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Relocation activities will consider individual household needs to be close to public transportation, employment, schools, public/social services and agencies, recreational services, parks, community centers, or shopping.

Table 5: Replacement Housing Needs (22 Respondents)

No. of Bedrooms One Two Three Four

No. Needed - Tenants 0 2 6 0

No. Needed - Owners 2 6 4 2

The Developer will, through its relocation representatives, assure that sufficient replacement housing units exist in compliance with the decent, safe, and sanitary requirements, prior to displacing any residential households. Most displaced households will require replacement units that are similar in size to the Project units, with 5 requiring larger replacement units.

F. Ethnicity and Household Language

The ethnic distribution in the Project is 100% Hispanic with Spanish as primary household language in all but 4 households. The 4 households that speak English, identified Spanish as primary language and English as the alternate option.

Relocation assistance information and counseling will be provided in the primary language of the displaced occupants, in order to assure that all displaced occupants obtain a complete understanding of the relocation program and eligible benefits.

G. Household Disabilities and Senior Households

Senior household is defined as head of households or spouse is 62 years or age or older. There are 3 senior households and 3 households reported having individuals with various degrees of disability. The Developer pledges to appropriate special care for households requiring additional assistance due to potential disabilities.

H. Preferred Relocation Areas

Most residents expressed a preference to remain in, or around, the immediate area in order to maintain access to employment, schools, medical facilities and public transportation. Alternate relocation areas mentioned by some residents were: Ontario, Montclair, Fontana, Chino, West Covina and Riverside.


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III. Housing Resources

A. Methodology

Replacement housing resources were surveyed generally within a 5-mile area surrounding the Project and beyond (up to a 25-mile radius from Pomona) to research mobile home parks and the availability of homes for sale.

The following sources were utilized:

a) Classified rental listings from The Press-Enterprise, PennySaver and For Rent publications

b) Contacts with real estate/property management companies serving the community c) Internet sources

B. Replacement Housing Availability

1. Residential Rental Housing The rental replacement housing survey considered all type of rentals: apartments, condominiums, smaller apartment rentals (duplex/triplex/fourplex), townhomes and single family homes. This data is summarized in Table 6 below. The survey identified a total of 154 available one-, two-, three- and four-bedroom units. The number of units found, by bedroom size, are presented alongside the number of units needed (shown in parentheses) to meet re-housing obligations. The market comparable rent amounts, shown in Table 6, are among the figures used to make benefit and budget projections for the Plan. These amounts are subject to change according to the market rates prevailing at the time of displacement.

Table 6: Availability and Cost of Replacement Rental Housing

Bedroom Size One Two Three Four

No. Found (Needed) 27 (0) 59 (2) 43 (6) 25 (0)

Rent Range $650-$1,195 $720-$1,650 $1,095-$2,190 $1,395-$2,400

Median Rent $900 $1,200 $1,685 $1,975

In addition to the rental units identified earlier, there are 11 studio units available for rent in the Project vicinity. Rents range from $625 to $895 with a median rent of $795. As evidenced by the survey data presented in Table 6, there are adequate numbers of replacement housing units to


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accommodate the tenant households potentially displaced by the Project. The goal, however, is to also match the type of housing, therefore, we continued our search of available housing to include mobile home for sale.

2. Mobile Homes for Sale Housing The resource survey identified 62 one-, two-, three- and four-bedroom mobile homes, ranging in price from $10,000 to $49,990 with a median price of $36,000.

Table 7: Availability and Cost of Mobile Homes for Sale

Bedroom Size One Two Three Four

No. Found (Needed) 6 (2) 32 (6) 19 (4) 5 (2)

Asking Price $15,000-$29,000 $10,000-$39,000 $11,999-$49,990 $35,000-$47,000

Median Price $19,500 $32,000 $40,000 $39,999

The survey data indicate that there are more than adequate numbers of replacement housing units to accommodate the mobile home owners potentially displaced by the Project. Note, that if there are an inadequate number of travel trailer or one-bedroom mobile homes for sale, the Developer will extend a two-, three- or four-bedroom comparable as a substitute.

3. Pad Space Rent

While surveying for mobile homes for sale, pad rents were considered where available. The pad rents of available mobile homes for sale range between $495 and $1,000 with a median rent of $850. There is often a direct inverse relationship between the pad rent and the asking price of the mobile home – when pad rents are low, the cost of the mobile home is high. When pad rents are high, the cost of the mobile home is low.

4. Summary

Considering the availability of replacement housing resources gathered over a three-week period, it appears that there are more than adequate replacement resources for the residential occupants, both tenants and owner-occupants. But, while adequate replacement resources exist, based on surveyed results of rental and purchase opportunities and the current rent and likely values of existing dwellings, occupants may have increases in monthly rents and/or higher purchase costs. These increases, if any, will be addressed through the Developer’s obligation under the relocation regulations, including Last Resort Housing (LRH) requirements (see Section V, C, 5). The Developer will provide funds necessary to meet replacement housing obligations due to an


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increase in monthly rents of these available units or an increase of pad rents for owner-occupants. The lack of one-bedroom mobile home units on the market may result in the necessity to upgrade coach size in order to meet comparability standards. Individual preferences will be accounted for once the relocation process has begun and a relocation consultant has had the opportunity to speak personally with each resident.

It is anticipated that the relocation activities will not necessitate any special housing considerations, other than Last Resort Housing obligations, for the Project to meet the comparable replacement housing requirement. Therefore, with possible benefit payments exceeding statutory amounts through LRH obligations, the relocation activities are not anticipated to create any special housing considerations. With LRH benefit payments, the Project will meet comparable replacement dwelling requirements.

The Developer intends to closely monitor each individual household’s needs to assure that the relocation process will not create undue economic hardship for the displacees.

Furthermore, as a result of there being more than 15 households displaced if the Project were to proceed, the Developer will submit this Plan and subsequent resource surveys for review to the local housing, development and planning agencies to be compared to other existing information on housing available.

C. Related Issues

1. Concurrent Residential Displacement

There are no other projects currently underway to negatively impact the availability of nearby housing units or mobile home sales for permanent displacees.

2. Temporary Housing

No need for temporary housing is anticipated.


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IV. Mobile Home Park Closure Report

As discussed previously, this Mobile Home Park Closure Report has been written in conjunction with the Relocation Plan in accordance with California Government Code section 7260 et seq., and Title 25, California Code of Regulations, Chapter 6, Section 6000 et seq. While previous Sections of this Document have discussed issues relative to the overall proposed Project, this Section of the Document is specific to the planned closure of the “Pomona Gardens (Rick's) Trailer Park”, located at 934 West Holt Avenue, for conversion to affordable housing development.

This Section is designed to satisfy the reporting and noticing requirements, in accordance with both California Government Code Section 65863.7 and Civil Code Chapter 2.5- Section 798.56, by addressing the requested components of the law.

A. Conversion Impact Report

Following are the requested components of California Government Code Section 65863.7 and Civil Code Chapter 2.5- Section 798.56, for the proposed closure of the Pomona Gardens (Rick's) Trailer Park.

1. Named Parties

Entity Proposing Closure: City of Pomona Housing Authority 505 S. Garey Ave. Pomona, CA 91766 Mobile Home Park Owner: City of Pomona Housing Authority 505 S. Garey Ave. Pomona, CA 91766 Preparer of Report: LACAL Consulting, Inc. 6535 Wilshire Blvd., Suite 205 Los Angeles, CA 90048

2. Description of Proposed New Use

The proposed new use is for development of a 62-unit affordable housing project including 41 tax credit units and 21 units reserved for tenants under the Mental Health Services Act program.


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3. Timetable for Conversion of the Park

The following is the proposed timetable for the mobile home park closure:

Table 8: Timetable for the Mobile Home Park Closure

Item Day/Week/Month

General Information Letter to Residents Completed

Information Neighborhood Meeting Completed

Deliver Relocation Plan/Conversion Report to City April 7, 2014 Deliver Plan for Review and Letter to Occupants indicating the Authority will request closure of the Pomona Gardens (Rick's) Trailer Park August 27, 2014

Hearing on Conversion Impact Report and Relocation Plan October 6, 2014

Six Month Notice to Relocate to Residents Est - October 2014

Construction Commences Est - March 2015

4. Number of Spaces within Park

The Pomona Gardens (Rick's) Trailer Park consists of 35 trailer pad spaces, 16 of which are vacant. The total number of spaces occupied and to be displaced as a result of the closure is 19. The monthly rate charged for each space at the time of the report preparation is $430 - $685 per month.

5. Name and Mailing Address of Residents

The name and mailing address of the residents of each mobile home within the trailer park and the length of time each space has been occupied by the present resident can be found in Appendix B, at the back of this report.

B. Conversion Impact Report for Mobile Home Closure

1. Resident Profile

A resident profile including name, address, age, income, and whether the resident has any special needs or disabilities was collected from each household. These profiles are maintained in the preparer’s file.


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Income information has been described by income level (extremely low, very low, low or moderate) relative to the Year 2014 Median Income statistics from the Federal Department of Housing and Urban Development (HUD) for Los Angeles County. Describing income limits of residents elsewhere in this report has been done to protect disclosing specific income information of individual occupants.

The profile also identifies 3 residents with special needs or disabilities. The disabilities reported included cancer, mental disabilities, and various physical disabilities. The special needs that were indicated for replacement housing included the need for ramps, wheelchair accessibility - no stairs, rails and/or grab bars and being close to bus lines, shopping, employment, and medical facilities.

Special consideration shall be given to these households in regards to financing and locating for sale, rent or lease comparable replacement dwellings, as well as housing which may require special replacement housing features or modification thereof, if required.

2. Notification Requirements

Civil Code Section 798.56 sets forth the required just causes for termination of tenancy in a mobile home park. Subsection (g) specifies that change of use (closure) of the park, or any portion thereof, is a reason for termination of tenancy, provided the following requirements have been met:

a) The management (hereinafter the Authority) gives the homeowners at least 15 days' written notice that the Authority will be appearing before a local governmental board, commission, or body to request permits for a change of use of the mobile home park.

b) After all required permits requesting a change of use have been approved by the local governmental board, commission, or body, the Authority shall give the homeowners 6 months' written notice of termination of tenancy.

c) The Authority shall give each proposed homeowner written notice thereof prior to the inception of his or her tenancy, that the management is requesting a change of use before local governmental bodies or that a change of use request has been granted.

d) The notice requirements for termination of tenancy set forth in Civil Code Sections 798.56 and 798.57 shall be followed, if the proposed change actually occurs.


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Civil Code Section 798.56(h) additionally requires that the impact report required pursuant to Government Code Section 65863.7(b) shall be given to the homeowners or residents at the same time that notice is required as described in 2(a) above.

3. Alternative Housing Analysis

Section III of this Document provides a discussion on the availability of sufficient mobile home space in other nearby mobile home parks. The conclusion was that sufficient space is not available. Despite the fact that sufficient space is not available to relocate the existing mobile homes, the size, age and condition of the mobile homes would preclude them from being moved, even if sufficient space were available.

In-lieu of the availability of sufficient mobile home ‘space’, replacement mobile homes for sale available in other surrounding mobile home parks were researched. The conclusion reached for this option was that sufficient for sale mobile homes were available.

This option of providing mobile homes for sale is viable due to the relocation assistance program the Authority plans to implement as discussed in Section V, and below, under Mitigation/Compensation Analysis.

4. Mitigation/Compensation Analysis

The Authority’s planned mitigation/compensation for the mobile home park residents will be based on the provisions of the California Relocation Assistance and Real Property Acquisition Guidelines, Title 25, California Code of Regulations, Chapter 6, Section 6000 et seq. (the Guidelines). The Authority’s relocation assistance program is outlined in Section V of this Document. The mitigation measures which have been outlined in this Document exceed “reasonable costs of relocation”, as contemplated in California Government Code Section 65863.7.

In summary, the proposed relocation mitigation/compensation displaced residents will receive includes, but is not limited to:

Advisory assistance Payments for moving of personal property Payments for storage of personal property, if necessary For tenants permanently displaced, including mobile home owners who purchase

replacement coaches and will pay for space rent, rental assistance to cover increased rental costs, if any, for a comparable dwelling/space for 42 months


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For mobile home owners, a replacement housing payment to cover the increased cost of a comparable replacement dwelling, including eligible incidental expenses and interest differential payment

5. Availability of Rental Assistance

The availability of rental assistance and eligibility requirements are outlined in Section V of this Document.

C. Conclusion

This Report satisfies the requirements of Section 65863.7 California Government Code, and the Authority will follow the necessary noticing requirements of Section 798.56 of the California Civil Code. Furthermore, the Authority (through the Developer) has outlined a relocation program which exceeds mitigation/compensation as contemplated in Section 65863.7 of the California Government Code.

Lastly, the proposed Project is consistent with the City of Pomona General Plan to encourage the provision of a wide range of housing by location, type of unit and price to meet the existing and future needs of Pomona residents. The conversion of the Pomona Gardens (Rick's) Trailer Park will not adversely affect the public health, safety and general welfare. The conversion avoids, to the extent possible, the dislocation of the resident mobile population and provides reasonable compensation when such dislocation is unavoidable.


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V. Relocation Program

The Developer’s relocation program is designed to minimize hardship, be responsive to unique Project circumstances, emphasize maintaining personal contact with all affected individuals, consistently apply all regulatory criteria to formulate eligibility and benefit determinations and conform to all applicable requirements. The relocation program and assistance offered by the Developer will conform to provisions of the California Relocation Law, Government Code Section 7260, et seq., and the California Relocation Guidelines, California Code of Regulations Title 25, Chapter 6, as amended January 1, 1998, as appropriate.

The Developer has retained LACAL Consulting, Inc. to administer the relocation program. LACAL principals and staff have worked on more than 1,000 publically funded rehabilitation and relocation projects over the past 15 years. Experienced Developer staff will monitor the performance of LACAL and be responsible to approve or disapprove LACAL's recommendations concerning eligibility and benefit determinations and interpretations of Developer policies. The relocation program consists of two principal components: Advisory and Financial Assistance.

A. Program Objectives, Standards and Assurances

It is the Developer's objective to fully inform eligible Project occupants of the nature of the available relocation assistance and benefits, rehabilitation activities, timing, and procedures for obtaining relocation assistance and benefits. In the scope of the relocation Project the Developer and relocation staff will:

Determine the needs of each residential household eligible for assistance. Distribute appropriate written information concerning the Developer’s relocation

program. Provide residential displacees with at least one, and preferably three, referrals to

comparable replacement housing within a reasonable time prior to displacement. The Developer is determined to providing available, necessary resources.

Maintain an updated database of available housing resources, and distribute referral information to displacees until they have relocated from the Project.

Provide transportation to residential displacees, if necessary, to inspect replacement sites within the local area.

Provide assistance that does not result in different, or separate, treatment due to race, color, religion, national origin, sex, sexual orientation, marital status or, other arbitrary circumstances.

Supply information concerning federal and state governmental programs providing assistance to low income or disabled persons.

Assist each eligible person to complete applications for benefits.


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Make relocation benefit payments in accordance with applicable guidelines. Assure that no permanent displacee is required to move without a minimum of 90 days

written notice to vacate. Inform all persons of the Developer’s property management policies including criteria for

pursuing tenant evictions.

B. Relocation Advisory Assistance

As a function of the overall relocation assistance program, advisory assistance will be provided to all residents by the Developer and contracted relocation representatives. The following services and tasks will be undertaken:

Each household will be personally interviewed to gather information appropriate to determine needs and preferences regarding replacement of existing accommodations. Inquiries made of residential occupants by relocation personnel will cover the following areas: family size, ethnic background, age and health considerations, current employment status, family income, transportation needs, and preferences relative to replacement housing.

A printed Informational Brochure (see Appendix C) has been or will be provided to all displaced households. Informational Brochures will be provided in Spanish, as necessary. Signed acknowledgements will be obtained to verify receipt of this material.

As soon as feasible, the relocation representative shall explain the relocation payments and other assistance for which households and individuals may be eligible, including related eligibility requirements and the procedures for obtaining such assistance.

Assistance will be provided to complete appropriate forms and coordinate moving arrangements.

Bilingual assistance will be provided, as needed.

C. Relocation Financial Assistance - Owners and Tenants

Specific eligibility requirements and benefit plans will be detailed on an individual basis with all displacees. In the course of personal interviews and follow-up visits, each displacee will be counseled as to available options and the consequences of any choice with respect to financial assistance.

Relocation benefits will be paid to eligible displacees upon submission of required claim forms and documentation in accordance with the Developer’s administrative procedures. The Developer will process advance payment requests to mitigate hardships for residential tenants who do not have access to sufficient funds to pay move-in costs such as first month’s rent and/or


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security deposits. Approved requests will be processed expeditiously to help avoid the loss of desirable, appropriate replacement housing.

1. Residential Moving Expense Payments All residential occupants to be relocated will be eligible to receive a payment for moving expenses. Moving expense payments will be made based upon the actual cost of a professional move or a fixed payment based on a room-count schedule.

• Actual Cost - Professional Move The displacee may elect to retain the services of a licensed professional mover, in which case the Developer will pay for the actual cost of the moving services, based on the lower of two acceptable bids. (The Developer may, at its discretion, solicit competitive bids to determine the lowest, reasonable move cost.) After the move is complete, the displacee may pay the mover directly and seek reimbursement from the Developer or request a direct payment from the Developer to the mover.

In addition to the cost of the actual move, one-time expenses associated with utility re-connections (e.g., gas, water, electricity) will be eligible for reimbursement. Transportation costs will be limited to a distance of 50 miles, unless otherwise authorized by the Developer. • Fixed Payment - Based on Room Count Schedule

The displacee may, while taking full responsibility for the move, elect to receive a fixed payment for moving expenses based on a room count in the displacement dwelling. The fixed payment is a one-time, all inclusive allowance that does not require back-up documentation. The current schedule for fixed moving payments is set forth in Appendix D.

2. Rental Assistance to Tenants Who Choose to Rent A tenant displaced from a Project dwelling may be entitled to a Replacement Housing Payment in the form of rental assistance not-to-exceed $5,250 for tenants (prior to consideration of eligibility for Last Resort Housing benefits - see Last Resort Housing), if the displacee:

• Generally, has actually and lawfully (i.e. have a lease and have been paying rent) occupied the displacement dwelling for at least 90 days immediately prior to the initiation of negotiations; and


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• Has rented, or purchased (as a result of the relocation process), and occupied a decent, safe, and sanitary replacement dwelling within one year (unless the Developer extends this period for good cause) after the date he or she moves from the displacement dwelling.

Rental/Downpayment Assistance payment amounts are equal to 42 times the difference between the base monthly rental and the lesser of:

• The monthly rent and estimated average monthly cost of utilities for a comparable replacement dwelling; or

• The monthly rent and estimated average monthly cost of utilities for the decent, safe, and sanitary replacement dwelling actually occupied by the displaced person; or

• The total of the amount designated for shelter and utilities if receiving government subsidized assistance from a program that designated the amounts for shelter and utilities.

Table 9: Sample Computation of Rental Assistance Payments

1. Old Rent $750 Old Rent (plus Utility Allowance)

- or -

2. Ability to Pay $700 30% of Monthly Gross Household Income

3. Lesser of lines 1 and 2 $700

Subtracted from the lesser of:

4. Actual New Rent $800 Actual New Rent (plus Utility Allowance)

- or -

5. Comparable Rent $825 Set by the Developer (plus Utility Allowance)

6. Lesser of lines 4 and 5 $800

7. Monthly Need Amount $100 Subtract line 3 from line 6

Rental Assistance $4,200 Multiply line 7 (Monthly Need) by 42 months

The base monthly rental for the displacement dwelling is the lesser of:

• The average monthly cost for rent and utilities at the displacement dwelling for a reasonable period prior to displacement, as determined by the Developer. For households which paid little or no rent, fair market rent will be used as a substitute for actual rent; or,

• Thirty percent (30%) of the displacee’s monthly gross household income. If a displacee refuses to provide appropriate evidence of income or is a dependent, the base monthly


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rental shall be determined to be the average monthly cost for rent and utilities at the displacement dwelling.

3. Downpayment Assistance to Tenants Who Choose to Purchase Residential displacees eligible to receive a rental assistance payment, may choose to utilize up to the full amount of their rental assistance eligibility (including any Last Resort benefits) to purchase a replacement dwelling, provided that the entire eligibility amount is used toward the down payment and eligible incidental closing costs. In the case of Downpayment Assistance claims, the Developer will arrange for the deposit of the total rental assistance eligibility amount in an open escrow account. Provisions will be included in the escrow instructions to assure the prompt return of all Developer-provided funds in the event escrow is cancelled by either party or should fail to close within a reasonable period of time.

4. Payments to Mobile Home Owners

Mobile home owner-occupants will have 4 options with respect to relocation arrangements following the Developer's offer to purchase:

The owner may decline to sell his/her mobile home and elect to move and set up the unit in a new location, including any existing improvements, providing the total cost of moving the coach does not exceed the replacement cost of a comparable unit. It needs to be noted, however, that current zoning and building code in California practically make it impossible for a coach older than 5 years to be moved and reestablished at another location. The move options would, therefore, leave only sites outside California and would need to be verified at owners expense.

Benefits will include the cost of moving and setting up the existing mobile home, within 50 miles from the Project, and Rental Assistance for space rent.

The owner may elect to sell the mobile home to the Developer for its appraised value-in-place, and purchase a comparable replacement coach in another location.

Benefits will include Replacement Housing Payment, Residential Moving Expenses, and Rental Assistance for space rent.

The owner may elect to sell the mobile home to the Developer for its appraised value-in-place and apply their entitlement toward the purchase of another type of residential dwelling, including the amount determined for Rental Assistance for space rent.


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Benefits will include Replacement Housing Payment, Residential Moving Expenses, and Rental Assistance for space rent.

The owner may elect to sell the mobile home to the Developer for its appraised value-in-place and rent an alternate type of residential unit.

The owner will be entitled to utilize up to the total of the replacement housing eligibility in the form of rental assistance. Actual rental assistance eligibility will be determined by subtracting the difference between the economic rent of the mobile home residence from the market rent for an apartment unit of comparable size (e.g. number of bedrooms) multiplied by 42 months.

5. Last Resort Housing Depending on current market conditions, the Developer anticipates that it might be necessary to make rental assistance payments in excess of the statutory cap of $5,250 (CCR Title 25, Chapter 6, Section 6104), to assure the availability of comparable replacement rental housing. Rental assistance payments to low-income non-90-day tenants and rental assistance and replacement housing payment amounts in excess of the statutory caps are considered (CCR Title 25, Chapter 6, Section 6139) to be Last Resort Housing (LRH) payments.

The Developer, at its discretion, may opt to pay LRH rental assistance payments on a periodic basis. Recipients of LRH rental assistance who intend to purchase rather than re-rent replacement housing have the right to request a lump sum payment of all benefits for the purpose of making a down payment and paying standard, non-recurring closing costs. Households receiving periodic payments may elect, at any time, to request a lump sum payment of all remaining benefits to assist with the purchase of a decent, safe and sanitary dwelling.

D. Relocation Tax Consequences

In general, relocation payments are not considered income for the purpose of the Internal Revenue Code of 1968, or the Personal Income Tax Law, Part 10 of the Revenue and Taxation Code. Displaced persons are encouraged, however, to consult with personal tax advisors concerning the tax consequences or social service providers to obtain information concerning the tax consequences associated with relocation payments.

E. Grievance Procedures

The Developer's Relocation Appeals process will be consistent with the Provisions of Article 5 of the State relocation guidelines. The right to appeal shall be described in all relocation


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explanatory material distributed to displacees. As required under the State relocation guidelines, displacees will have the right to ask for administrative review when they believe themselves aggrieved by a determination as to eligibility, payment amounts, and the failure to provide comparable replacement housing referrals or the Developer's property management practices.

Requests for administrative review and informal hearings will be directed to Developer's principals and senior administrative staff. All requests for review will receive written responses from the Developer within three weeks of their receipt. If an informal appeal is denied, appellants will be entitled to file a written request for a formal hearing before an impartial and independent hearing officer.

More detail concerning the appeals process will be provided upon request. Appellants will retain their appeal rights for up to 18 months following the date of displacement from the Project premises or receipt of final payment for relocation benefits, whichever is later.

F. Eviction Policy

The Developer recognizes that eviction is permissible only as a last resort and that relocation records must be documented to reflect the specific circumstances surrounding any eviction. Eviction will only take place in cases of nonpayment of rent, serious violation of the rental agreement, a dangerous or illegal act in the unit, or if the household refuses all reasonable offers to move. Eviction will not affect the eligibility of a person legally entitled to relocation benefits.

G. Citizen Participation

The Developer will fully meet its obligations under the Relocation Guidelines with respect to the following activities:

Full and timely access to documents relevant to the relocation program. Provide assistance necessary to interpret elements of the Plan and pertinent notices. Distribution of a general notice concerning the availability of this Plan for public review,

as required, 30 days prior to its proposed adoption. Notice recipients will include affected Project residents and all other interested parties.

The opportunity to submit written or oral comments concerning the Plan and to have these comments attached to the Plan (Appendix E) when it is forwarded to the City Council for adoption.

Final review of the Plan to ensure its feasibility, compliance and compatibility with relocation law and guidelines.


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H. Project Timing

It is anticipated that the Developer will authorize permanent relocation to commence upon securing of Project funding. Construction is scheduled to begin approximately 6 months after the necessary funding is in place - the earliest that the relocation notices could be issued is in fall 2014.

I. Estimated Relocation Costs

The Project will be funded with a combination of local, state and private funds. The estimate of relocation benefits is based on available tenant/homeowner data and current market rates for replacement units and mobile homes for sale asking prices.

Estimated relocation costs for the Project are $1,200,000. The Project costs include 8 permanently relocated renter households and 14 permanently relocated trailer/mobile home owners. The overall Project budget is subject to change depending on actual market trends and costs of housing at the time of displacement.

The estimated relocation budget does not include consideration of relocation administrative services nor any related consulting services which may be necessary for the implementation of the Plan and Project.


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Appendices


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Appendix A

HUD 2014 Income Limits - County of Los Angeles


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The following figures are approved by the U. S. Department of Housing and Urban Development (HUD) for use in the County of Los Angeles to define and determine housing eligibility by income level.

Area Median - $64,800

Household Size Extremely Low Very Low Lower

One Person $17,950 $29,900 $47,850

Two People $20,500 $34,200 $54,650

Three People $23,050 $38,450 $61,500

Four People $25,600 $42,700 $68,300

Five People $27,650 $46,150 $73,800

Six People $29,700 $49,550 $79,250

Seven People $31,750 $52,950 $84,700

Eight People $33,800 $56,400 $90,200

Figures are per the Department of Housing and Community Development (California), Division of Housing Policy Development, February 28, 2014.


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Appendix B

Name and Address of Park Residents

Space No. Address Occupants

4 934 West Holt Avenue Jose Licea

8-C 934 West Holt Avenue Balbino Cruceno

10 934 West Holt Avenue Selene Rivera

12 934 West Holt Avenue Ericka Correa, Rodolfo Licea

13 934 West Holt Avenue Martin Martinez

14 934 West Holt Avenue Guadalupe Aguilar, Jessie Rodriguez

15 934 West Holt Avenue Rufina & Alfredo Garcia

18 934 West Holt Avenue Celina Lozoya

19 934 West Holt Avenue Silvia Flores

20 934 West Holt Avenue Jesus & Margarita Contreras

21 934 West Holt Avenue Reyna Guevara, Ananias Lopez

26 934 West Holt Avenue Jesus Gonzalez

27 934 West Holt Avenue Maria Grimaldo

28 934 West Holt Avenue Hermelinda Rangel

30 934 West Holt Avenue Efren Romero

33 934 West Holt Avenue Selina Sandoval

34 934 West Holt Avenue David Guerrero

37 934 West Holt Avenue Araceli Altamirano

38 934 West Holt Avenue Clara Contreras

934-A 934 West Holt Avenue Luciano Ortiz

6 934 West Holt Avenue Rosa Velasco

6-A 934 West Holt Avenue Jose Rangel


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Appendix C

Relocation Informational Brochure

LACAL Consulting, Inc. Page 1

Relocation Informational Statement

Project Name: Pomona - Holt & Hamilton Apartments

Developer: Related Companies of California, LLC

Relocation Representative: Julia Miranda, Relocation Project Manager Olga Adams, Sr. Relocation Consultant LACAL Consulting, Inc. - (323) 951-9887 6535 Wilshire Blvd., Suite 205, Los Angeles, CA 90048

Contents:

1. GENERAL INFORMATION ................................................................................................................................ 2

2. ASSISTANCE IN LOCATING A REPLACEMENT DWELLING ..................................................................... 2

3. MOVING BENEFITS ........................................................................................................................................... 2

4. REPLACEMENT HOUSING PAYMENT – TENANTS AND CERTAIN OTHERS ......................................... 3

5. SECTION 8 TENANTS ........................................................................................................................................ 4

6. REPLACEMENT HOUSING PAYMENT - HOMEOWNERS ........................................................................... 4

7. QUALIFICATION FOR, AND FILING OF, RELOCATION CLAIMS.............................................................. 4

8. LAST RESORT HOUSING ASSISTANCE ......................................................................................................... 5

9. RENTAL AGREEMENT ...................................................................................................................................... 5

10. EVICTIONS ........................................................................................................................................................ 5

11. APPEAL PROCEDURES - GRIEVANCE ......................................................................................................... 5

12. TAX STATUS OF RELOCATION BENEFITS ................................................................................................. 6

13. NON-DISCRIMINATION AND FAIR HOUSING ............................................................................................ 6

14. ADDITIONAL INFORMATION AND ASSISTANCE AVAILABLE ............................................................. 6


1. GENERAL INFORMATION The dwelling in which you now live is in a project area to be improved by the Related Companies of California, LLC (Owner/Developer), and financed using State public funds. If and when the project proceeds, and it is necessary for you to move from your dwelling, you may be eligible for certain benefits. You will be notified in a timely manner as to the date by which you must move. Please read this information, as it will be helpful to you in determining your eligibility and the amount of the relocation benefits you may receive under the State law. You will need to provide adequate and timely information to determine your relocation benefits. The information is voluntary, but if you don’t provide it, you may not receive the benefits or it may take longer to pay you. We suggest you save this informational statement for reference. The Developer has retained the professional firm of LACAL Consulting, Inc. (LACAL) to provide relocation assistance to you. The firm is available to explain the program and benefits. Their address and telephone number is listed on the cover. PLEASE DO NOT MOVE PREMATURELY. THIS IS NOT A NOTICE TO VACATE YOUR DWELLING. However, if you desire to move sooner than required, you must contact your LACAL representative, so you will not jeopardize any benefits. This is a general informational brochure only, and is not intended to give a detailed description of either the law or regulations pertaining to the Developer’s relocation assistance program.

Please continue to pay your rent to your current landlord, otherwise you may be evicted and jeopardize the relocation benefits which you may be entitled to receive.

2. ASSISTANCE IN LOCATING A REPLACEMENT DWELLING The Developer, through its representatives, will assist you in locating a comparable replacement dwelling by providing referrals to appropriate and available housing units. You are encouraged to actively seek such housing yourself. When a suitable replacement dwelling unit has been found, your relocation consultant will carry out an inspection and advise you as to whether the dwelling unit meets decent, safe and sanitary housing requirements. A decent, safe and sanitary housing unit provides adequate space for its occupants, proper weatherproofing and sound heating, electrical and plumbing systems. Your new dwelling must pass inspection before relocation assistance payments can be authorized.

3. MOVING BENEFITS

If you must move as a result of displacement by the Developer, you will receive a payment to assist in moving your personal property. The actual, reasonable and necessary expenses for moving your household belongings may be determined based on the following methods:

• A Fixed Moving Payment based on the number of rooms you occupy (see below); or • A payment for your Actual Reasonable Moving and Related Expenses based on at least two

written professional mover estimates and receipted bills; or • A combination of both (in some cases).

For example, you may choose a Self Move, receiving a payment based on the Fixed Residential Moving Cost Schedule shown below, plus contract with a professional mover to transport your grand piano and /or other items that require special handling. In this case, there may be an adjustment in the number of rooms which qualify under the Fixed Residential Moving Cost Schedule.


A. Fixed Moving Payment (Self Move) A Fixed Moving Payment is based upon the number of rooms you occupy and whether or not you own your own furniture. The payment is based upon a schedule approved by the Developer, and ranges, for example, from $450.00 for one furnished room to $2,365.00 for eight rooms in an unfurnished dwelling. (For details see the table). Your relocation representative will inform you of the amount you are eligible to receive, if you choose this type of payment. If you select a fixed payment, you will be responsible for arranging for your own move, and the Developer will assume no liability for any loss or damage of your personal property. A fixed payment also includes utility hook-up, credit check and other related moving fees.

B. Actual Moving Expense (Commercial Move)

If you wish to engage the services of a licensed commercial mover and have the Developer pay the bill, you may claim the ACTUAL cost of moving your personal property up to 50 miles. Your relocation representative will inform you of the number of competitive moving bids (if any) which may be required, and assist you in developing a “mover” scope of services for Developer’s approval.

4. REPLACEMENT HOUSING PAYMENT – TENANTS AND CERTAIN OTHERS You may be eligible for a payment up to $5,250.00 to assist in renting or purchasing a comparable replacement dwelling. In order to qualify, you must either be a tenant who has occupied the present dwelling for at least 90 days immediately prior to the initiation of negotiations or an owner who has occupied the present dwelling between 90 and 180 days immediately prior to the initiation of negotiations. A. Rental Assistance. If you wish to rent your replacement dwelling, your maximum rental

assistance benefits will be based upon the difference over a forty-two (42) month period between the rent you must pay for a comparable replacement dwelling and the lesser of your current rent or thirty percent (30%) of your monthly household income if your total gross income is classified as “low income” by the U. S. Department of Housing and Urban Development’s (HUD) Annual Survey of Income Limits for Public Housing and Section 8 Programs. You will be required to provide your relocation representative with monthly rent and household income verification prior to the determination of your eligibility for this payment.

- OR - B. Down-payment Assistance. If you qualify, and wish to purchase a home as a replacement

dwelling, you can apply up to the total amount of your rental assistance payment towards the down-payment and non-recurring incidental expenses. Your relocation representative will clarify procedures necessary to apply for this payment.

Fixed Moving Schedule CALIFORNIA (Effective 2012)

Occupant owns furniture: 1 room $685 2 rooms $880 3 rooms $1,100 4 rooms $1,295 5 rooms $1,570 6 rooms $1,815 7 rooms $2,090 8 rooms $2,365 Each additional room $250

Occupant does NOT own furniture: 1 room $450 Each additional room $85


5. SECTION 8 TENANTS When you do move, you may be eligible to transfer your Section 8 eligibility to a replacement site. In such cases, a comparable replacement dwelling will be determined based on your family composition at the time of displacement and the current housing program criteria. This may not be the size of the unit you currently occupy. Your relocation representative will provide counseling and other advisory services along with moving benefits.

6. REPLACEMENT HOUSING PAYMENT - HOMEOWNERS A. If you own and occupy a dwelling to be purchased by the Developer for at least 180 days prior to

the initiation of negotiation, you may be eligible to receive a payment of up to $22,500.00 to assist you in purchasing a comparable replacement unit. This payment is intended to cover the following items:

1. Purchase Price Differential - An amount which, when added to the amount for which

the Developer purchased your property, equals the lesser of the actual cost of your replacement dwelling; or the amount determined by the Developer as necessary to purchase a comparable replacement dwelling. Your relocation representative will explain both methods to you.

2. Mortgage Interest Differential - The amount which covers the increased interest costs, if any, required to finance a replacement dwelling. Your relocation representative will explain limiting conditions.

3. Incidental Expenses - Those one time incidental costs related to purchasing a replacement unit, such as escrow fees, recording fees, and credit report fees. Recurring expenses such as prepaid taxes and insurance premiums are not compensable.

B. Rental Assistance Option - If you are an owner-occupant and choose to rent rather than

purchase a replacement dwelling, you may be eligible for a rental assistance payment of up to the amount that you could have received under the Purchase Price Differential, explained above. The payment will be based on the difference between the fair market rent of the dwelling you occupy and the rent you must pay for a comparable replacement dwelling.

If you receive a rental assistance payment, as described above, and later decide to purchase a replacement dwelling, you may apply for a payment equal to the amount you would have received if you had initially purchased a comparable replacement dwelling, less the amount you have already received as a rental assistance payment.

7. QUALIFICATION FOR, AND FILING OF, RELOCATION CLAIMS To qualify for a Replacement Housing Payment, you must rent or purchase and occupy a comparable replacement unit within one year from the following:

• For a tenant, the date you move from the displacement dwelling. • For an owner-occupant, the latter of:

a. The date you receive final payment for the displacement dwelling, or, in the case of condemnation, the date the full amount of estimated just compensation is deposited in


court; or b. The date the Developer fulfills its obligation to make available comparable replacement dwellings.

All claims for relocation benefits must be filed with the Developer within eighteen (18) months from the date on which you receive final payment for your property, or the date, on which you move, whichever is later.

8. LAST RESORT HOUSING ASSISTANCE If comparable replacement dwellings are not available when you are required to move, or if replacement housing is not available within the monetary limits described above, the Developer will provide Last Resort Housing assistance to enable you to rent or purchase a replacement dwelling on a timely basis. Last Resort Housing assistance is based on the individual circumstances of the displaced person. Your relocation representative will explain the process for determining whether or not you qualify for Last Resort assistance. If you are a tenant, and you choose to purchase rather than rent a comparable replacement dwelling, the entire amount of your rental assistance and Last Resort eligibility must be applied toward the down-payment and eligible incidental expenses of the home you intend to purchase.

9. RENTAL AGREEMENT As a result of the Developer's action to purchase the property where you live, you may become a tenant of the Developer. If this occurs, you will be asked to sign a rental agreement which will specify the monthly rent to be paid, when rent payments are due, where they are to be paid and other pertinent information.

10. EVICTIONS Eviction for cause must conform to applicable State and local law. Any person who occupies the real property and is not in unlawful occupancy on the date of initiation of negotiations, is presumed to be entitled to relocation benefits, unless the Developer determines that:

• The person received an eviction notice prior to the initiation of negotiations and, as a result, was later evicted; or

• The person is evicted after the initiation of negotiations for serious or repeated violation of material terms of the lease; and

• The eviction was not undertaken for the purpose of evading relocation assistance regulations.

Except for the causes of eviction set forth above, no person lawfully occupying property to be purchased by the Developer will be required to move without having been provided with at least 90 days written notice from the Developer.

11. APPEAL PROCEDURES - GRIEVANCE Any person aggrieved by a determination as to eligibility for a relocation payment, or the amount of a payment, may have the claim reviewed or reconsidered in accordance with the Developer’s appeals


procedure. Complete details on appeal procedures are available upon request.

12. TAX STATUS OF RELOCATION BENEFITS California Government Code Section 7269 indicates no relocation payment received shall be considered as income for the purposes of the Personal Income Tax Law, Part 10 (commencing with Section 170 01) of Division 2 of the Revenue and Taxation Code, or the Bank and Corporation Tax law, Part 11 (commencing with Section 23001) of Division 2 of the Revenue and Taxation Code. Furthermore, federal regulations (49 CFR Part 24, Section 24.209) also indicate that no payment received under this part (Part 24) shall be considered as income for the purpose of the Internal Revenue Code of 1954, which has been redesignated as the Internal Revenue Code of 1986. The preceding statement is not tendered as legal advice in regard to tax consequences, and displacees should consult with their own tax advisor or legal counsel to determine the current status of such payments. (IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including any attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code or (ii) promoting marketing or recommending to another party any matters addressed herein)

13. NON-DISCRIMINATION AND FAIR HOUSING No person shall on the grounds of race, color, national origin or sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under the Developer’s relocation assistance program pursuant to Title VI of the Civil Rights Act of 1964, Title VIII of the Civil Rights Act of 1968, and other applicable state and federal anti-discrimination and fair housing laws. You may file a complaint if you believe you have been subjected to discrimination. For details contact the Developer.

14. ADDITIONAL INFORMATION AND ASSISTANCE AVAILABLE Those responsible for providing you with relocation assistance hope to assist you in every way possible to minimize the hardships involved in relocating to a new home. Your cooperation will be helpful and greatly appreciated. If you have any questions at any time during the process, please do not hesitate to contact your relocation representative at LACAL Consulting, Inc.


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Appendix D

Fixed Moving Schedule


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Schedule of Fixed Moving Payments

Unfurnished Dwelling (Tenant Owns Furniture)

Room Count Amount

One $685

Two $880

Three $1,100

Four $1,295

Five $1,570

Six $1,815

Seven $2,090

Eight $2,365

Each additional $250

Furnished Dwelling (Tenant Does Not Own Furniture)

One $450

Two $535

Each additional $85

Effective June 22, 2012


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Appendix E

Public Comments and Response

relocation plan and conversion impact report for the ......relocation plan and conversion impact...

Documents