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13 <br /> <br />metro cities on how to structure rehab programs that would attract owner interest. Minnesota <br />Housing is considering extending its multifamily rehab program for Greater Minnesota, the <br />Rental Rehabilitation Deferred Loan program,34 to cover the metro area as well. <br /> <br />Note that 4(d) may also play a useful role in helping preservation buyers keep buildings <br />affordable, so cities should be responsive to requests for investment of at least modest funds and <br />49d) agreements. Finally, 4(d) combined with city investments may be a way to encourage <br />market rate purchasers to keep some of their units affordable – especially, affordable to housing <br />choice voucher tenants. Relatively modest investments in these buildings, as non-amortizing <br />loans repayable only when 4(d) is no longer in effect, could be attractive even to market rate <br />buyers, as the City money would replace equity requirements. <br /> <br /> <br />MINIMIZING DISPLACEMENT FROM REDEVELOPMENT <br /> <br />Minimizing Displacement from Public Projects and Activities <br /> <br />Given the metro area’s very tight rental housing market, failure to come close to meeting <br />the annual need for new affordable housing, and large backlog of severely cost burdened <br />households, it is critical that public projects and activities minimize displacement where possible <br />and provide adequate relocation assistance where displacement is necessary. Lower income <br />households displaced by public projects typically face very large rent increases in the metro <br />area’s difficult rental market. This section summarizes the federal public policy consensus on <br />what relocation protections and assistance should be provided, discusses gaps in when such <br />assistance is legally required, and suggests voluntary city policies which address those gaps. <br /> <br />Displacement and Relocation Assistance under the Uniform Relocation Act and Related <br />Statutes <br /> <br />There are two considerations for local governments here. One is simply to make sure <br />they are in full compliance with any relocation obligations their activities may trigger, but an <br />additional consideration is to provide for relocation assistance in situations where the city or <br />county is not legally obligated but where a clear and compelling need for assistance is present. <br /> <br /> The federal act providing for Uniform Relocation Assistance, 42 U.S.C. §§ 4601-4655 <br />(the URA), was adopted in 1970 after extensive study of the “inequitable distribution of <br />hardship”35 associated with federally funded projects. Under the statute, the Department of <br />Transportation has adopted regulations implementing the URA at 49 C.F.R. Chapter 24. The <br />statute and regulations have been regularly updated, most recently in 2014.36 They represent a <br /> <br />34 Rental Rehabilitation Deferred Loan (RRDL), MINN. HOUSING, <br />http://www.mnhousing.gov/wcs/Satellite?c=Page&cid=1358905404900&pagename=External%2 <br />FPage%2FEXTStandardLayout (last visited July 9, 2018). <br />35 Moorer v. HUD, 417 F. Supp. 1261,1267 (W.D. Mo. 1976). <br />36 For some reason, the updated relocation payment standards made effective as of 2014 by <br />P.L.112-141 have not yet made it into the Dept. of Transportation’s regulations.