1. Presented by: Darryl Root, J.D., MBA, R/W-RAC David Harrah, Texas DOT Karen D’Angelo, Halff Associates MOBILE HOME RELOCATION Got Wheels?

2. 2 Mobile Home Relocation Planning For Federally Funded Projects

3. What does the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, and as amended (Uniform Act) say about planning? A. 42 USC Chapter 61 1.Start at an early stage—Project Development Team Meetings During Design if possible 2.Minimize hardships----How do we help? 3 Planning

4. Do other laws apply? A. Increasing state regulation of mobile home park closure 1. California a. County b. City c. Rent control 2. Oregon 3. Vermont 4

5. Different mobile home scenarios make planning difficult A. Inside and outside mobile home parks 1. Own Dwelling/Rent Site 2. Own Dwelling/Own Site 3. Rent Dwelling/Own Site 4. Rent Dwelling/Rent Site 5

6. Is your schedule realistic? A. Allow enough time for displacees to vacate 1. 90 days for URA 2. Up to a year under some state laws a. California 6

7. B. Allow enough time to find comparables 1. Mobile Home parks 2. Lots for rent 3. Conventional Housing 7 Is your schedule realistic?

8. C. Allow enough time for advisory services 1. Displacees may have credit issues 2. Low incomes 3. Social programs may have waiting lists 8 Is your schedule realistic?

9. Have you involved all stakeholders in the planning process? A. Engineers 1. What is the construction schedule? B. Appraisers 1. Are the dwellings considered real or personal property? C. Negotiators 1. If the units are personal property, do the owners have clear title? 2. Must have clear title to units for demolition to take place. 9

10. D. Utilities 1. Will utility relocations affect electricity, etc. to the mobile home, esp. in parks? a. If so, will temporary relocations be necessary? 2. What condition are the utilities in currently? a. Are the units decent safe and sanitary now? 10 Have you involved all stakeholders in the planning process?

11. E. Property Management 1. Are you prepared for property management of mobile units, esp. a mobile home park? 2. Need to address security deposits and rents at closing 3. If the displacee rents the space for his unit, did the landlord keep accurate records of rents paid? F. Mobile Home Rights Groups 1. May be the best source of info about park tenants 11 Have you involved all stakeholders in the planning process?

12. G. Relocation Agent 1. Are your agents prepared to spend extra time with interviews? 2. Begin research into social programs that may be needed. a. Is there a waiting list? b. What special needs are there? c. Take any necessary security measures needed when conducting interviews. d. Plan your advisory assistance program carefully 12 Have you involved all stakeholders in the planning process?

13. H. Finance ---- Plan a realistic budget ! 1. Benefits defined in 49 CFR Subpart F Sections 24.501 to 24.503 2. Some owner occupants who rent the site will get a replacement housing payment plus a rental subsidy 3. Many occupants may be very low income. 4. Be ready to offer financial advisory assistance or refer displacees 5. Some displacees may not have a credit history or a bank account  Some displacees may take a long time to get a loan 13 Have you involved all stakeholders in the planning process?

14. Advisory Services to Mobile Home Displacees

15. The Uniform Act’s take on Advisory Services  24.205 (c) (2) (ii) - Determine, for residential displacements, the relocation needs and preferences of each person to be displaced and explain the relocation payments and other assistance for which the person may be eligible, the related eligibility requirements, and the procedures for obtaining such assistance. This shall include a personal interview with each residential displaced person.  24.205 (c) (2) (ii) (A) - Provide current and continuing information on the availability, purchase prices and rental costs of comparable replacement dwellings, and explain that the person cannot be required to move unless at least one comparable replacement dwelling is made available as set forth in 24.204 (a).

16. So what makes Mobile Home Relocations so challenging?  Locating comparables  Personalty/Realty determinations  Explaining it all to the displacee

17. Mobile Home Owner/Tenant Categories Refresher 1)Owns the Dwelling and the Site 2)Owns the Dwelling - Rents the Site 3)Rents the Dwelling - Owns the Site 4)Rents the Dwelling and the Site

18. Uniform Act Moving Expenses for Mobile Home Displacees  Ordinary moving expenses described in section 24.301 g. (1 - 7)  Cost to relocate/reinstall a personal property mobile home or attached appurtenances (i.e. porches, decks, skirting and awnings) which wasn’t acquired 24.301 – g. (8)  Repairs and modifications to meet DS&S standards 24.301 – g. (9)  Nonrefundable mobile home park entrance fees 24.301 – g. (10)

19. ADVISORY SERVICES BEGINS WITH “RESEARCH”  Applicable rules and regulations in the project area  Agency policies and appraisal information  Mobile home park entry requirements  Displacee interviews

20. The search for comparables 1) Owner/Owner category  Single supplement calculation for MH available for sale on land.  If none available on the market preferred option is generally to upgrade search parameters to a SFR.  Why not assemble a supplement amount by finding vacant land and a MH from a dealer?  Can be difficult to identify land eligible for development with a MH, much less 3 sites.  Hidden cost of site development can create stress for displacee and administrative issues for the agency.  If one component of the manufactured comparable sells may have to start the process over again.  If local market is short of comps this could an option but not generally regarded as the first best option available.

21. 2) Own/Rent category  How many supplements to be calculated?  If MH is moveable and not restricted by age or build only a site supplement is required. The search for comparables  If the age or build of the MH restricts available sites it could be necessary to acquire the dwelling meaning 2 supplements.  Get a value for the MH and develop supplement as if it where a housing supplement, build separate supplement for the lot.

22. 3) Rent/Rent category  Single supplement calculation for MH available for rent on MH site.  If no single supplement can be created why not assemble a supplement amount by finding a vacant MH site and a MH for rent from a dealer?  This could be cost effective but a bit more work than upgrading to a SFR so individual analysis and agency input may be required.  Consideration to the size of the rented site needs to be given, is it typical in size for a rented dwelling in the area? Upgrading to a SFR rental may be appropriate based on the displacees living situation.  Remember that if one component of the assembled comparable supplement sells the process may have to be started over again. The search for comparables

23. 4) Rent/Own category  Perhaps the least commonly encountered scenario.  MH for rent generally not too hard to locate.  Supplement for a site will typically be vacant land cost combined with multiple contractor bids for site development DS&S required utilities (i.e. septic or sewer, water/electrical hookups, and pad if present at the site being acquired). The search for comparables

24. Explaining Eligibilities and Requirements  Realty and Personalty determinations  How the supplement was figured  The displacement scenario and how it factors into the calculations  What listings were utilized as comparables  Any replacement site cost figured into the supplement that may be reimbursable and those that are not  DS&S Requirements  Moving Expenses

25. Key Take Away’s  Allocate sufficient time to work with displacee  Work closely with agency to explore options  Encourage displacee coordinates actions with relocation staff before taking actions

26. Mobile Home Supplements

27. Most Common Categories  Displacee OWNS the mobile home and the site  Displacee OWNS the mobile home and RENTS the site  Displacee RENTS the mobile home and RENTS the site  Displacee RENTS the mobile and OWNS the site

28. OWN/OWN For the purpose of the following calculations, the mobile home is appraised as REAL PROPERTY SUBJECT: The parcel (mobile home and land) appraised for $65,000 as follows: $40,000 Appraised site value $25,000 Appraised mobile home value $65,000 Total appraised value COMPARABLE: The primary comparable is a mobile home on a similar site listed for $80,000. Since the mobile home was appraised as real property, the supplement would be calculated the same as a single family dwelling $80,000 Primary comparable (mobile home and site or single family dwelling) $65,000 Appraised value of subject $15,000 Supplement

29. OWN/RENT SUBJECT: The parcel (mobile home and land) appraised for $65,000 as follows: $40,000 Appraised site value $25,000 Appraised mobile home value $65,000 Total appraised value COMPARABLE: The primary comparable is a new mobile home listed for $40,000. $40,000 Primary comparable $25,000 Appraised value of subject $15,000 Supplement

30. -PLUS- $400 rent per month for a comparable site including utilities -300 per month rent for subject site including utilities $100.00 differential X 42 months $4,200 site supplement which can be used as a rental supplement for a site or down payment on a replacement site. $19,200 the combined supplements can be used as a down payment for a DSS replacement home/property. OWN/RENT

31. RENT/RENT Subject: In this scenario, the displacee rents the mobile home and the site for $700 a month. $900 rent per mo. for a comparable mobile home and site -700 per month rent for subject mobile home and site $200 differential X 42 months $8,400 supplement which can be used as a rental supplement or down-payment on a replacement home/site or other qualifying DSS dwelling

32. RENT/OWN Subject: In this scenario, the displacee rents the mobile home for $400 per month and owns the site. $600 rent per month for a comparable mobile home -400 per month rent for subject mobile home $200 differential X 42 months $8,400 rent supplement for mobile home which can be used as a rental supplement or down payment on a DSS replacement mobile home.

33. -PLUS- $35,000 Primary comparable site -25,000 Appraised value of subject site $10,000 supplement which can be used as a down payment on a replacement mobile home site. $18,400 the combined supplements can be used as a down payment for a DSS replacement home and site/property RENT/OWN

34. When the Mobile Home is considered Personal Property If the mobile home is determined to be personal property and CAN BE MOVED, the cost of moving and reconnecting the mobile home is eligible and there will be no supplement for the mobile home. There are situations which could make the displacee eligible for a supplement when the mobile home is determined to be personal property  Mobile home is non DSS and cannot be made DSS  Mobile home cannot be relocated without substantial damage or unreasonable costs  Mobile home cannot be relocated because there is no comparable replacement site  Mobile home cannot be relocated because it does not meet mobile home park entrance requirements

36. When it Cannot be Moved… The eligible supplement will be based on the list price of the comparable minus the Agency’s estimate of the salvage or trade-in value for the mobile home from which the person is displaced

37. What About??? -Study and Ask Questions - 49CFR Part 24 Uniform Relocation Assistance and Real Property Acquisition for Federal and Federally-Assisted Programs, Subpart F–Mobile Homes

38. CLAIMS FOR RELOCATION PAYMENTS-- DOCUMENTATION  Documentation as may be reasonably required to support expenses incurred…  Bills  Certified prices  Appraisals  Other evidence 49 CFR 24.207(a)

39. 90-DAY OCCUPANT REPLACEMENT HOUSING PAYMENT COMPONENTS 1.Length of occupancy 2.Household income 3.Household composition 4.Current monthly rent 5.Estimated average utilities 6.Low income criteria 7.Welfare assistance payments 8.Base monthly rental determination 9.Monthly rent of selected comparable 10.New estimated utilities 11.Actual replacement property (49 CFR 24.402)

40. ELIGIBLE INCIDENTAL EXPENSES 1.Legal closing and related costs 2.Loan application fees 3.Loan origination (not prepaid interest) 4.Professional home inspections 5.Credit Report 6.Title Insurance (not to exceed comparable) 7.Escrow agent’s fee 8.Doc stamps 9.Other incidental costs as determined by the Agency 49 CFR 24.401(e)

41. QUESTIONS AND ANSWERS