When RAD Requires a Written Relocation Plan and What Belongs in It

Under Section 6.1 of HUD's RAD relocation Notice, a PHA or Project Owner must prepare a written relocation plan for any RAD transaction that involves permanent relocation, or temporary relocation that is anticipated to last more than 12 months. For shorter, simpler moves a written plan is not strictly required. HUD still strongly encourages one, and in practice lenders, tax credit investors and resident organizations expect it.

Why the 12-month line matters

Twelve months is the threshold that changes a project's risk profile. Temporary relocation that is expected to run longer than a year:

• triggers the written plan requirement,
• triggers a HUD front-end civil rights review of the conversion, and
• brings URA displacement protections into play, including the resident's option to accept permanent relocation assistance instead of waiting.

Because construction schedules slip, it is worth asking early whether a "nine-month" relocation could realistically run past twelve. If it could, plan as though it will.

What a strong plan covers

Appendix II of the Notice lists HUD's recommended relocation plan contents. A complete plan generally addresses:

• Project description: scope of work, phasing, and why relocation is needed.
• Resident data: household counts, sizes, accessibility needs, and language needs, typically drawn from a resident survey.
• Type and length of each move: on-site, off-site temporary, or permanent, with estimated durations.
• Temporary housing resources: where residents will go and how comparability is assured.
• Right to return: how return will be offered, sequenced, and documented.
• Notices and timeline: which notices will be issued and when.
• Advisory services: who will counsel residents and how.
• Payments and costs covered: moving expenses, utility transfers, and any URA payments.
• Accessibility and reasonable accommodation: how existing accommodations follow the household.
• Appeals: how residents can dispute eligibility or payment decisions.
• Budget and funding source for all relocation costs.

Make the plan do real work

The best plans are operating documents, not compliance exhibits. Tie the plan's schedule to the construction schedule, its budget to the development budget, and its resident data to the resident log. When those three documents disagree, HUD reviewers and investors notice.