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Notice Listings on Demoliton/Disposition
Notice Section 1.5.B Section 18 Applications and RAD Notice Section 1.4.A.9 Demolition
Questions on Demoliton/Disposition

Demolished Project Eligibility under RAD

A PHA is considering applying for RAD for a project that has already been demolished. Is this project still eligible for RAD?

No. Only projects with units under ACC and in PIC are eligible for RAD.

RAD Conversion of Demolished ACC Units

Can a housing authority that has demolished units counted in their ACC rebuild and covert to RAD for the new building with the same unit count?

RAD is a "current funding" program. Therefore if you have units that have been demolished but are still in PIC and being funded by operating and capital funds, you can convert those units to RAD. The RAD rents will be set by the amounts currently funded in the operating and capital funds. Thus, if there has been a phase down of funding, the RAD rents will be set at the lower (current) levels. If the demolished units are not still in PIC, they are not eligible for RAD conversion. For the most part, units that are being built back under "Faircloth" must first be brought into the public housing program under either the traditional development method or the mixed-finance method, and then they would be eligible for RAD. Some PHAs have inquired as to whether there could be a "joint" or "simultaneous" closing. The Department is looking into that possibility.

Demo/Dispo, Transfer of Assistance and RPCA Requirement

If a HA is proposing to do a RAD conversion of Public Housing that involves demolishing an existing project and rebuilding an equal or greater number of units on the same site, is this treated in essentially the same way as for a RAD conversion with rehab? Is it unnecessary to do a transfer of assistance as long as the units are being rebuilt on the same site? Where and how does the RAD PCA fit into this scenario?

In the situation you describe, a transfer of assistance would not be needed, because the RAD project would be located on the same site as the current public housing. In demolition-and-reconstruction projects, a RAD PCA is not required. See Notice PIH-2012-32, page 26, footnote 6; and Attachment 1A.1 paragraph B. [Updated 7.29.13]

De-minimis Reductions

Can a PHA apply the de-minimis standard for replacement across properties?

A PHA may apply the de-minimis standard for any group of properties that are undergoing conversion. For example, if the PHA has two CHAPs, each consisting of 100 units, and the PHA has six units at the first project that have rehab costs that would be exorbitant, the PHA could apply the de-minimis standard across both properties. Thus, because the PHA would, combined, be able to reduce 10 units (5%), the PHA would be permitted to reduce the 6 units at the first property (provided it does not reduce more than 4 units at the second property). However, the project utilizing the greatest reductions has to be the latest to convert (or converts simultaneously).

FHEO Review for Unit Reduction

If I am using both the de minimus reduction and the 75%/25% RAD/Section 18 blend provisions on a RAD transaction, do I need to submit the FHEO Change in Unit Configuration review? All reduced units will be replaced by other PBV units and Tenant Protection Vouchers (TPV), so the number of low-income dwelling units is the same.

If all of the reduced units are being replaced with project-based assistance, an FHEO Change in Unit Configuration review is not needed.