Comparable Replacement Housing Gone Wrong Joan Morgan, Director, Relocation and Real Estate Division, HUD

Displacement Dwelling 683 sq. ft. first floor 1 BR apartment Subsidized tenant with Housing Choice Voucher Assistance Contract Rent $750, Utility Allowance $39 = $789 Gross Rent HCV Payment Standard $1132 (incl. Util.) Tenant Rent $175 net ($214 - $39) – medical deduction of $1927 allowed (30% of NET income)

1 BR Displacement Unit (first floor) $750 Rent & $39 utilities

Temporary Relocation Issued a Notice of Nondisplacement and provided temporary relocation Difficult tenant: physical and mental disabilities Delayed relocation for about 1 year, insisted on a detached or SF residence (based on disabilities) Moved to a 1BR duplex, 755 sq. ft.

1 BR Duplex Temporary Unit $1300 Rent & $47 utilities & $198 storage fee

Temporary Relo Contd Rent for unit $1300 (not including utilities) HCV EXCEPTION Payment Standard $1245 w. utilities Lease written for $1160 rent w. $47 utility cost = $1245 Grantee made side payments to owner of $140 per month to cover maintenance fee ($1160 & $140 = $1300) and paid $198 storage fee Tenant portion $88 - $47 = $41 (Net income went down from $244 because of increased medical, payment based on 10% of gross income)

Temporary Relo. Contd Tenant refused all offers to return to original site (within one year of temporary relocation) based on disability need for detached or single family home. Filed a HUD discrimination complaint regarding failure to provide reasonable accommodation for her disabilities – HUD Letter of Finding issued with Determination of No Reasonable Cause

Notice of Eligibility Notice of termination of temporary relocation assistance issued (effective 22 months after relo) AND Tenant was issued a Notice of Relocation Eligibility by grantee Tenant insisted that comparable be based on the temporary unit (not original unit) Tenant did not agree with comparable provided and filed a URA complaint with HUD

Single Family 3 BR Comparable Offered $1550 rent & $215 utilities

Last Resort Comparable Offered 3 BR, 1 BA Single Family house HCV Exception Payment Standard $1245 Unit rent $ $215 utilities = $1765 Whats wrong with this picture?

HUD Determination Tenant was properly issued a Notice of Nondisplacement Tenant was offered her own and other units at original project (all were refused) Tenant s claimed-need for a detached or single family unit to accommodate her disabilities was not a result of the project and therefore a choiceshe was not displaced.

HUD Determination Contd Termination of temporary relocation assistance was proper Tenant could use her HCV to find suitable housing to meet her medical needs She was not eligible for URA relocation assistance.

2 Years Later Tenant still occupies the temporary unit Tenants share of the rent to owner is $272 (extra $55 for higher cost housing) plus her utilities = $340/mo. total (33% of gross income) – Increase largely due to decrease in medical deductions and tenants obligation to pay rent cost above exception payment standard. Unknown if she still maintains the off-site storage space on her own.