Relocation Plans

I. PURPOSE OF THE RELOCATION PLAN

The Relocation Plan sets forth the specific policies, procedures and benefits that will govern the relocation of Colonial Village families. This plan is written in accordance with the relevant provisions of the 49 CFR 24.2, HUD Handbook 1378–the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, as amended (the URA), 42 U.S.C. Section 4601 et seq., Section 135 of the Connecticut General Statutes Department of Economic and Community Development: Uniform Relocation Assistance Act, Sec 8-266 et seq. and Section 104(d) of the Housing and Community Development Act (104 (d)) and its implementing regulations at 24 CFR Part 42.

The underlying objective of this plan is to ensure persons affected by this project are treated fairly, consistently and equitably so that they will not suffer disproportionate hardships as a direct result of activities designed for the benefit of the residents as a whole. Norwalk Housing Authority (NHA) will ensure that Colonial Village residents can continue to live in affordable housing that meets their housing needs throughout the relocation process, will strive to minimize the negative impacts of relocation to the greatest extent possible and will make certain that residents are made whole for eligible costs under governing federal and state relocation regulations.

The Colonial Village relocation plan is based upon a number of important goals:

  1. To provide support before, during and after initial relocation to educate residents about the range of options available to them and accommodate household priorities and preferences, whenever possible.
  2. To optimize relocation options and accommodate resident preferences, whenever possible.
  3. To ensure housing is adequate in size to accommodate legal occupants and meets the standard of decent, safe, and sanitary housing.
  4. To minimize the displacement of families during redevelopment through the phasing of construction and relocation.
  5. To minimize the disruption and negative impacts of relocation through comprehensive and coordinated supports.
  6. To reimburse all allowable resident costs under the URA.
  7. To support residents through the physical and psychological aspects of moving.
  8. To establish fair and equitable priorities to govern the order in which households are given choices about their relocation and re-occupancy as well as the timing of their moves.

II. PROJECT SUMMARY

The Norwalk Housing Authority is undertaking the redevelopment of the Colonial Village Housing Development located at Suncrest Road, Scribner Avenue, and West Cedar Street in Norwalk, CT 06854. The plan for Colonial Village involves the major physical transformation of the property including the renovation of the 200 public housing units over a 2-year phased redevelopment.

A. Redevelopment Unit Mix

See chart below for breakdown of units by bedroom size and unit type.

BR SIZE

Renovated

1BR

2BR

152

3BR

48

TOTAL 

%

200

100%

B. Funding Sources for Redevelopment

Anticipated and/or secured sources of funding for the Colonial Village redevelopment project include approximately $14 million dollars in private loans, $18 million dollars in NHA contributions and $1.3 million dollars in revenue from rental income and utility rebates.

C. Relocation Needs Summary

Of the 200 Colonial Village households, 152 require two-bedroom and 48 require three-bedroom units.

D. Relocation Phasing Summary

In order to minimize disruption to the residents, the renovation will occur in 18 phases over a 2-year period in approximately 5-6-week cycles. Residents were surveyed to find out their preference for moving. Option One: Approximately 10 families will be moved off site to housing where they will remain for approximately 11 months.. Once they are moved, those vacant units will be renovated. Six weeks later, the second group of approximately 10 families will be moved into those newly renovated units and their vacated units will be renovated. This cycle will continue until the last group of units have been renovated and those families that were moved off site have been resettled into new, renovated unit as Colonial Village. Option Two: Approximately 10 families will be moved off site to housing where they will remain for approximately 11 months. Once those families are moved, their vacant units will be renovated and the second group of approximately 10 families will be moved into those units while their units are being renovated. Once their original units are complete, they will move back. The next group of approximately 10 families will move into the initial set of vacant units while theirs are being renovated and will move back to their original unit once the work is complete. This cycle will continue until the last group of units have been renovated and those families that were moved off site at the commencement of the project have been resettled to new, renovated units at Colonial Village. Once the surveys are returned NHA will make a decision as to which option to proceed with.

E. Relocation Services Provider

NHA has a staff member to provide comprehensive relocation services to the residents of Colonial Village who must move due to redevelopment of the property. That staff person will be supported by consultants from the Glendower Group.

III. ELIGIBILITY FOR RELOCATION ASSISTANCE

A. Eligible Households

Any household that lives at Colonial Village at the time the GIN was issued on June 26, 2020 is an affected resident. The following provides more detail regarding the categories of Eligible Households:

  1. Displaced Persons
  2. Residents who must move away from their current Colonial Village unit permanently (defined as a period longer than one year) are considered Displaced Persons under the Colonial Village Relocation Plan and eligible for full relocation benefits.
  3. Persons Subject to Imminent Renovation
  4. Residents living in the area of units designated for imminent renovation will be eligible for temporary relocation benefits.

B. Ineligible Households

  1. Persons Not Displaced
    Since the renovation will be phased, only residents living in the area of the units designated for imminent renovation will be issued a Notice of Eligibility entitling them to relocation benefits. Those households who live in a unit designated for a later phase of renovation will be issued a Notice of Non-Displacement.
  2. Transfers for Reasons not Related to the Redevelopment
    Residents who transfer for reasons not related to the redevelopment will be subject to NHA’s existing rules for transfers and will only be eligible for moving and related services in accordance with HUD Handbook 4350.
  3. Early Movers who Voluntarily Move prior to Issuance of Notice of Eligibility
    During the redevelopment period, some residents may transfer within Colonial Village or to another Norwalk Housing Authority community for routine reasons unrelated to relocation (i.e., approved reasonable accommodation request, right-sizing of an under/over-housing situation, unit inhabitability, etc.). These moves could be by the request of the resident or by the request of NHA. Transfers unrelated to the redevelopment do not qualify a resident as a “Displaced Person” and will not result in eligibility for relocation benefits. NHA will clearly document the reason for a resident move when it is not subject to the URA.
  4. Evictions
    Any Displaced Person who is evicted for cause from Colonial Village will no longer be entitled to relocation assistance. A household’s eligibility for relocation assistance will not be a factor in any decision to proceed with eviction. Until the household has been evicted or received formal notice of a judgment for eviction, they will be entitled to relocation assistance. If a judgment for eviction is entered, the household will not be Lease Compliant and therefore not eligible to return to the redeveloped Colonial Village. Residents may avail themselves of the appeals and grievance processes.
  5. Household Members Added to Lease After Issuance of Notice of Eligibility
    Approved lease additions will be limited to marriage, adoption or birth and will be subject to the current NHA screening process during the relocation process.
  6. Ineligible Non-Citizens/Undocumented Immigration Status
    Households with members that have undocumented immigration status are not eligible for full relocation benefits. If a household member is not eligible for relocation assistance under this section, NHA will pro-rate relocation assistance to the household by counting only those members who are lawful residents. NHA may count an unlawful resident as a member of the household for relocation purposes only if the household can demonstrate that the exclusion would cause exception and unusual hardship to the lawful resident.

IV. RELOCATION ASSISTANCE

A. Comparable Replacement Unit

The URA requires that displaced residents be offered at least one comparable replacement unit, which will be identified in the (90) Ninety-Day Notice. The Relocation Program at Colonial Village will offer each household one comparable replacement unit that will be:

  • decent, safe, and sanitary
  • functionally equivalent to (and equal or better than) the resident’s present unit
  • adequate in size for the household,
  • currently available for rent,
  • within the financial means of the displaced household
  • reasonably accessible to resident’s place of employment,
  • generally, as well located with respect to public and commercial facilities,
  • not subject to unreasonable adverse environmental conditions and
  • available to all persons regardless of race, color, religion, sex or national origin or other protected classes

1. Decent, Safe and Sanitary Housing
Decent, safe, and sanitary housing is housing that meets the requirements of Housing Quality Standards (HQS), detailed in 24 CFR 982.401, and includes housing that:

    • meets applicable housing and occupancy requirements,
    • is structurally sound, weather tight and in good repair,
    • contains a safe, adequate electrical wiring system,
    • has adequate living space for the occupants, has a kitchen with a sink, hot and cold running water and connections for a stove and refrigerator
    • has a separate, complete bathroom with hot and cold running water,
    • has heating as required by climatic conditions,
    • has an unobstructed exit to safe, open space at ground level,
    • meets standards protecting occupants from lead-based paint hazards,

B. Relocation Options

The following relocation options will be available to all Colonial Village residents relocated due to redevelopment. NHA will attempt to accommodate household preference but cannot guarantee a specific unit type to any household.

  • Moving to a unit off-site. As renovation will be phased, some residents will be moved to comparable housing off-site for all or part of the transformation project. NHA will facilitate a housing search to identify currently available units in the private sector for rent. NHA will be responsible for communicating availabilities and will provide relocation assistance to these affected families.
  • Moving directly to a redeveloped unit. Residents living in units scheduled for imminent renovation will be prioritized for re-occupancy assignments for newly renovated units over those living in other phases.
  • Transfer to another on-site unit. Households will have the option of relocating to a vacant on-site unit temporarily as vacancies arise. As displaced persons, these households will have “super-priority” status and, therefore, be offered units before other NHA transfers or new applicants, with the exception of domestic violence victims or other emergencies. The temporary on-site relocation option will only be available to residents in the first phase of relocation.
  • Private Sector housing with a Replacement Housing Payment (RHP). A family who may be found ineligible for a voucher and for whom there is not an available unit at a NHA development may be eligible for an RHP, a monthly rental assistance payment, under the URA or Section 104 (d) of the Housing and Community Development Act (HCD).

1. Move performed free of charge to the household. NHA will contract with a state-approved, licensed, and insured moving company, at no cost to the household being displaced. The household will be entitled to a $100 Dislocation Allowance and the following:

  • Packing and unpacking assistance, if requested, will be provided to elderly and disabled residents.
  • Boxes, packing paper and tape as well as packing instructions.
  • Storage of personal property for a period not to exceed 12 months, unless NHA determines that a longer period is necessary. Any items that could pose a health or safety hazard (i.e., infested furniture) will not be stored.
  • Inspection for and extermination of pests prior to relocation. No furniture or belongings will be moved or stored if they are determined to be infested.
  • Disconnecting, dismantling, removing, reassembling and reinstalling relocated household appliances and other personal property, including personal computer set-up, as long as they have been installed with the approval of Colonial Village management and are done so in compliance with the lease.
  • The replacement value of property lost, stolen or damaged in the moving process (that is not the result of the fault or negligence of the displaced person or his/her family member, agent, or employee).

D. Relocation Advisory Services and Other Supports

All advisory services will be provided in the household’s primary language, using interpreters and translation services, as needed. NHA Relocation staff will make themselves available through scheduled appointments and information sessions that are held on evenings and weekends to accommodate Colonial Village residents who work during regular business hours. All appointments and information sessions will be conducted virtually or over the phone. Relocation advisory services and other support NHA will provide include the following:

1. Relocation Community Meetings and Information Sessions

In order to ensure that households receive sufficient information to make well informed housing decisions, NHA staff will conduct community meetings and information sessions on relocation-related topics. All meetings and information sessions will be conducted virtually. Topics include, but are not limited to, the following:

  • NHA transfer process
  • Establishing and maintaining utilities
  • Budgeting and utility conservation, including energy assistance and winterization programs
  • Preparing to move
  • Meeting neighbors and being a “good neighbor”
  • Housekeeping and home maintenance
  • Tenant rights and responsibilities, including the importance of lease compliance

2. Translation and Interpreter Services

The Colonial Village community has three predominant language groups: Spanish, Haitian-Creole, and English. NHA Relocation staff will ensure that the residents who speak these are able to complete their relocation needs assessment, understand their relocation options, and most importantly, make informed decisions about their relocation. NHA’s current staff are fluent in these languages. The services of professional interpreters will be enlisted as needed.

3. Relocation Program

Relocation staff will work to meet the relocation needs of Colonial Village households. The Relocation Program will undertake the following:

  • Ensure relocation does not create impediments to current and/or future employment and/or educational opportunities by identifying relocation options proximate to work, school, etc.
  • Assist residents with Lease Compliance requirements regarding rent and utility payment as well as home maintenance (e.g. recycling requirements).
  • Establish and implement a pest control program that includes educating households regarding housekeeping and pest control prior to occupancy.
  • Assist residents with successful transition to their relocation housing by keeping ongoing communication with relocated residents.

4. Special Assistance

NHA Relocation staff will provide more intensive relocation services and support to residents who have special needs, including seniors and disabled individuals, individuals with significant housekeeping/hoarding issues, those with reasonable accommodation needs, and those who will require assistance with packing. NHA Relocation staff will assist households requiring accommodations, such as need for handicap-accessibility, roll-in shower, first-floor unit, extra bedroom for a live-in aide etc. in completing and submitting requisite paperwork to NHA.

5. Fair Housing Counseling and Assistance

Relocation staff will counsel and assist any Colonial Village resident who feels their rights have been violated under the Fair Housing Act. This will include completion of the online Housing Discrimination complaint form and referral to Norwalk’s Fair Housing Officer.

V. OVERVIEW OF RELOCATION PROCESS AND PROCEDURES

The following outlines the relocation process and procedures that will be undertaken with households in implementing Colonial Village relocation and re-occupancy.

A. Roles & Responsibilities

NHA’s Relocation Coordinator and Project Director will work closely with the Colonial Village Maintenance, NHA Operations and NHA Finance Department to ensure seamless, successful relocation and re-occupancy for Colonial Village residents. Appropriate processes and communications protocol (i.e., formats and timelines for reporting on the progress of relocation counseling, problems and complaints and related matters) will be established well in advance of the relocation of Colonial Village residents, and NHA will ensure that the necessary resources are provided, including the following:

  • Occupancy staff will communicate information regarding housing units available for relocation, processing NHA transfer applications and requests for reasonable accommodations. Admission Specialist staff will participate in regular meetings with NHA relocation staff at which time the status of transfer applications, reasonable accommodation requests, and lease signings will be discussed.
  • In conjunction with the NHA Finance Department, Relocation Program staff will develop and implement process that ensures timely disbursement of relocation benefits checks to Colonial Village residents.
  • Redevelopment team will work closely with the relocation team to coordinate construction and planning efforts to minimize the negative impacts to residents and make the transition as smooth as possible.

B. Relocation File Set-up

Relocation staff will set up and maintain relocation files that will contain hard copies of documents given to each affected household. These files will be maintained confidentially in a locked file cabinet and will contain, at a minimum, the following information:

Required relocation notices (General Information Notice, Notice of Eligibility for Relocation Assistance/Notice of Non-displacement, Move-in Notice, Notice of Right to Return & Notice of Right to Access Program Services, 90-Day Notice, and 30-Day Notice)

  • Resident contact tracking, documenting all contact with the household and all activities directly related to the relocation assistance services offered
  • Housing referral forms and comparable replacements identified and presented to the household
  • Move Confirmation and Resident Responsibilities Form
  • Moving Assistance and Benefits Declaration Form
  • Unit Check Out Form
  • Calculation of benefits
  • Check Request Form and copies of all relocation benefit checks issued
  • Check Receipt Form
  • Handouts/brochures/flyers/letters provided all households
  • Change of address documentation
  • Other documents relative to the household’s relocation
  • Notification of address change procedure for Admissions Specialists

C. Required Notices

The following are all required relocation notices. They must be individually addressed to each household, written in plain language, in the predominant languages of the resident population and must either be hand-delivered, with proof of receipt signed for by head-of-household or sent by mail with return receipt requested.

1. General Information Notice (GIN)
The purpose of the GIN is to inform residents about the plans for redevelopment and about their potential eligibility for receiving relocation assistance under the URA. The GIN, along with HUD brochure detailing URA relocation rights, will be mailed June 30, 2020 to Colonial Village Residents, with a self-addressed envelope to return the confirmation of receipt of the GIN notice.

2. Transfer Notice
Residents will be given a transfer notice when their phase of relocation begins.

3. Notice of Eligibility for Relocation Assistance (NOE)
Residents who will be displaced from their original Colonial Village unit will be provided with a Notice of Eligibility for Relocation Assistance (NOE) when their phase of relocation begins. This notice will provide information on residents’ eligibility and advise them to make sure they seek out relocation staff prior to moving from their Colonial Village unit.

4. Notice of Non-Displacement
The Notice of Non-Displacement will inform households who can remain at Colonial Village of their rights and of the terms and conditions of remaining at the property. As redevelopment progresses, households that were previously given a Notice of Non-displacement will subsequently receive a Notice of Eligibility for Relocation Assistance if they must move to make way for renovation of their unit.

5. 90-Day Notice
NHA will not require any family to move unless at least one comparable relocation unit is made available at least 90 days before the required move.

6. 30-Day Notice
Any resident who is not being displaced but either temporarily relocated or moving directly to from their Colonial Village unit to a redeveloped Colonial Village unit will be provided with a 30-Day Notice. This notice will contain the address of the unit to which the resident is relocating as well as the date of their move.

D. Relocation Assessment

1. Relocation Survey
A relocation survey will be circulated to all households to ascertain moving preference. Once surveys have been returned, NHA will make an informed decision about the best way forward and will inform residents of its determination

2. Relocation Kick-off meetings
The Relocation Program staff will hold initial relocation informational sessions that will introduce the relocation staff, an overview of the relocation process, information regarding relocation options, moving assistance and relocation benefits. Residents will be informed that they will receive relocation advisory services.

3. Scheduling Moves

Once a transfer unit is deemed ready for occupancy by NHA staff, the Relocation staff can coordinate the move for the resident. At this time, the resident will meet with the Relocation staff either virtually or by phone. The staff will confirm the resident’s move date and outline the resident responsibilities for removing all belongings from the unit.

4. Utility Transfers/Coordinating New Utility Service
At this time, should residents need assistance with transferring utilities or establishing new utilities in the relocation unit, Relocation staff will be available to provide information/guidance as needed. In order to be eligible for reimbursement of utility reconnection fees, the utility account must be in the head-of-household’s name, which must appear on the bill. Residents must file all relocation claims within 18 months after the date of their move.

5. Unit Extermination
At least two weeks prior to relocation, a mandatory unit extermination will be conducted of each Colonial Village household’s unit to ensure no infestation issues are relocated with the household. Each household will receive a minimum of forty-eight hours’ notice of this pest control treatment and the preparations they must undertake prior to the treatment. Households will be informed that failure to properly prepare for the pest control visit will result in a rescheduled visit, for which they will be assessed a fee.

6. Follow Up
At two weeks, one week, and one day prior to move day, the Relocation staff will meet virtually* with the resident to make sure they are packing and otherwise prepared for their upcoming move. On move day, Relocation staff will meet virtually with the resident after they have moved to ensure there are no belongings remaining in their unit and complete a Unit Check Out form with an NHA staff member. * Some meetings may be in person with NHA staff.

E. Relocation Benefits Reimbursement Procedure

1.  Relocation Check Request Process
NHA Relocation Program staff will develop a system that ensures timely payment of relocation benefits to Colonial Village residents. NHA Relocation staff will submit relocation-related check requests to NHA in accordance with a pre-determined schedule provided by the NHA.

2. Reimbursement of Related Moving Expenses
For reimbursement of any reasonable related moving expenses, payments will be issued within 30 days following the submission of sufficient documentation to support the claim. However, advance payments may be made where they would avoid or reduce a hardship.

3. Reimbursement of Utility Reconnection Fees
Relocation staff will inform residents to submit reimbursement for utility reconnection fees upon their receipt of their first utility bills in their relocation unit.

4. Relocation Check Receipt
In all cases, Relocation staff will have the recipient sign a document acknowledging receipt of relocation payments and a copy of all relocation benefits checks will be kept in each household’s relocation file.

F. Tracking Relocated Residents

In order to maintain updated contact information and keep abreast of household composition changes that could impact unit assignment in the redeveloped Colonial Village, residents will self-report to Relocation staff and/or NHA Occupancy Specialists.

VI. RE-OCCUPANCY POLICY AND PROCEDURES

A. Lease Compliance with No Eviction Action Pending or Judgment of Eviction

Residents who are lease compliant are defined as:

  1. Those who are current on their rent payments and otherwise in compliance with respect to the lease requirements, including those who are current with any repayment agreement or court-ordered stipulated agreement that provides for their reinstatement.
  2. Those without a pending eviction action or a judgment of eviction for non-payment or for other “good cause”, as defined in the lease/federal regulations; and
  3. Those who are able to secure a utility account.

For residents with pending eviction actions, the resident may request an informal meeting to determine if the lease violation can or has been cured. The resident would be considered Lease Compliant if the violation is cured or can be remedied by repair or the payment of damages to NHA.

B. Re-Occupancy Eligibility
As new units are available for occupancy, Colonial Village residents (either on-site or relocated off-site) will receive notice of their right to return to the redevelopment. All affected residents have a right to return.

VII. GRIEVANCE PROCEDURES

Residents subject to relocation may request a review of any NHA determination concerning eligibility for relocation benefits, the amount of a relocation payment or the applicability of the 12 comparable relocation unit provided as well as any denial of eligibility to return to the redeveloped Colonial Village. The results of these appeals will be reported to the local Field Office of the Department of Housing and Urban Development (HUD). An appeals process for issues dealing with relocation is described below.

A. Residential Relocation Appeals

When relocation assistance is offered to a resident, Relocation staff will inform the resident of the relocation appeal procedures. A resident must file an appeal within ten (10) business days of the contested action/receipt of a written offer of relocation benefits. The appeal should be delivered in writing to the NHA Executive Director within ten (10) business days. If the resident needs help preparing the appeal, NHA Relocation staff will provide assistance. A Hearing Officer, an impartial, disinterested person appointed by the Housing Authority other than the person who made or approved the Housing Authority action under review or a subordinate of such person, will be appointed to review the complaint and may either schedule a hearing or render a decision without proceeding with the hearing if the Hearing Officer determines that the issue has been previously decided in another proceeding.

If the Hearing Officer determines that a hearing is warranted, within ten (10) business days of receipt of the written appeal, a relocation assistance dispute resolution meeting will be scheduled between the resident, the Relocation Coordinator, NHA Management and the Hearing Officer. Any person requesting an appeal shall have the opportunity to examine and to copy all documents, records and regulations that are relevant to the appeal prior to any hearing. NHA may charge a reasonable fee for copies of more than fifty (50) pages. Residents may choose a person to represent them at this meeting as well as bring other persons they deem necessary to present their appeal at their own expense. Interpreters will be provided upon request. The Hearing Officer will provide a written decision summarizing the findings of fact and specific reasons for the results within a reasonable time period. A copy of the decision shall be sent to the resident and Management, which shall retain a copy of the decision in the resident’s folder. The decision of the Hearing Officer shall be binding.