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2019.10.08 WS Packet
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2019.10.08 WS Packet
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14 <br /> <br />decades-long Congressional and federal agency consensus on the protections and compensation <br />necessary to protect people involuntarily displaced by public action. Unfortunately, state statutes <br />largely ignore a key requirement of the URA and no local government comes even close to <br />providing URA protections. Key provisions of the URA are: 1) substantial advance notice of the <br />need to move; 2) no one is required to move until referral to adequate replacement housing; 3) <br />provision of relocation counseling services; 4) payment of moving costs; and 5) replacement <br />housing payments. The maximum replacement housing payments are 42 months of increased <br />rent, up to $7,200, for renters and $ 31,000 for a replacement home for homeowners. These <br />payments can be increased over these maximums by the “last resort” provision of the URA if <br />adequate replacement housing cannot otherwise be found.37 Such increased payments are <br />required with regularity in the metro area housing market, where rent increases after <br />displacement from a lower rent apartment can easily eat up $7,200 in a year or so. <br /> <br />There are six other statutes which might apply to metro area projects: Section 104(d) of <br />the 1974 Community Development Act 38 requires that recipients of HUD CDBG and HOME <br />funds have a Residential Anti-displacement and Relocation Assistance Plan. Under this Plan, <br />any lower income person displaced by demolition or conversion of a lower income dwelling “in <br />connection with” a CDBG- or HOME-assisted activity” may choose assistance under the URA <br />or 104(d). Assistance required under 104(d) differs from the URA requirements by allowing <br />displaced persons to choose assistance which reduces rental payments to 30% of income for 60 <br />months or a somewhat similar payment to be applied to a purchase. These payments would be <br />substantially more useful to low income metro area renters than URA payments to extremely low <br />income households. Section 104(d) also requires replacement of lower income units lost to <br />demolition or conversion. The replacement requirement is typically meaningful only for <br />jurisdictions which are not otherwise regularly producing affordable housing. <br />The Community Development Act and related regulations also require jurisdictions receiving <br />CDBG and HOME funds to certify that they “will minimize displacement of persons as a result <br />of assisted activities.”39 <br /> <br />Minnesota has a state URA, for situations in which no federal funds are involved, which <br />incorporates the requirements of the federal URA.40 <br />Minn. Stat. §§ 469.126 Subd. 1 and 469.133 require that in City Development Districts, persons <br />displaced must be relocated in accordance with the provisions of the state URA. This is the only <br />state statute that requires URA-level protections when local funds cause displacement. <br /> <br />Minn. Stat. § 327C.095 Subds. 4 and 13 provide for at least a portion of the costs of <br />moving a manufactured home or payment for at least a portion of the appraised value of a home <br />that can’t be moved when a manufactured home park closes. <br /> <br /> <br />37 Pursuant to § 4626 of the Act. <br />38 42 U.S.C. § 5304(d) and regulations at 24 C.F.R pt. 42. <br />39 42 U.S.C. § 5304(a)(2)(A) and regulations at 24 C.F.R. §§ 42.325(a)(2), 91.225(a)(2), <br />570.606(a). <br />40 MINN. STAT. §§ 117.50-117.56.
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