Section 18 Demolition and Disposition: Relocation Requirements

Section 18 of the U.S. Housing Act of 1937 lets housing authorities demolish or dispose of public housing with HUD approval. It is used on its own and alongside RAD in "blended" repositioning strategies. Either way, 24 CFR Part 970 sets resident relocation requirements that apply when residents must move.

Core requirements

The relocation provisions in Part 970 generally require the housing authority to:

• Notify each affected family in writing at least 90 days before the displacement date, describing the action and the comparable housing being offered;
• Offer comparable housing to each family before requiring the family to move. This may include tenant-based assistance, other public housing or other comparable housing;
• Pay actual and reasonable relocation expenses;
• Provide counseling and advisory services to help residents make informed choices; and
• not complete the demolition or disposition until all residents have been relocated in accordance with these rules.

Where URA fits

Some Section 18 actions also trigger the URA, for example where there is federally assisted acquisition, or where federal funds are used in the project. Where URA applies, its requirements govern in addition to Part 970. Determine early which framework applies to each phase.

Tenant protection vouchers

Section 18 actions often make tenant protection vouchers available for affected families, subject to HUD's current guidance and appropriations. Vouchers are a common relocation resource, but they work only if families can actually lease up. Counseling, landlord outreach and adequate search time are critical in tight markets.

Section 18 and RAD together

In RAD/Section 18 blends, the same property may be governed by both sets of rules. Map each requirement, including notice periods, relocation payments and the right to return, to the households it applies to, and use the more protective rule where they overlap.

Practical steps

• Include the relocation plan in the Section 18 application planning, not after approval.
• Start the needs survey early to size voucher demand and accessible unit needs.
• Coordinate with the HCV program on payment standards and lease-up support.
• Keep detailed records for each household; HUD may review them.