Abbeville Housing Authority Relocation Plan | Abbeville Housing, South Carolina Skip to Main Content

Abbeville Housing Authority Relocation Plan

December 12, 2024
Prepared by: Abbeville Housing Authority


  1. Definitions
  2. Introduction
  3. Project Description
  4. Resident Relocation Plan
    1. Resident Demographic
    2. Relocation Plan for Affected Eligible Households
    3. Relocation Schedule
  5. Program Assurances and Standards
  6. Relocation Assistance and Benefits
    1. Staffing
    2. Advisory Services and Resident Relocation Assessment
    3. Comparable Relocation Housing
    4. Moving Benefits and Assistance
    5. Communication and Notices
  7. Record Keeping
  8. Relocation Tax Consequences
  9. Eviction Policy
  10. Appeal Process

Appendices

Appendix 1 Relocation Budget


  1. Definitions

    ADA Unit
    - Units compliant under the Americans with Disabilities Act (ADA).

    Affected Eligible Residents
    - All eligible household members at the time of relocation who are not unlawfully occupying a unit and are in good standing as tenants.

    Agency
    - The Housing Authority of the City of Abbeville is undertaking the project.

    Elderly Person
    - A person 62 years of age or older.

    Housing Authority of the City of Abbeville (AHA)
    - Provides affordable housing to 129 public housing households. 

    The United States Department of Housing and Urban Development (HUD)
    is the Federal agency responsible for national policy and programs that address America's housing needs, improve, and develop the Nation's communities, and enforce fair housing laws. HUD's business is helping to create decent homes and suitable living environments for all Americans, and it has given America's communities a robust national voice at the Cabinet level.

    Ineligible Residents
    - A resident who is not on a lease or authorized to be added to the lease and unlawfully occupies a unit shall not be eligible for relocation assistance.

    Person with a Disability
    - A person with a physical or mental impairment substantially limiting one or more major life activities.

    Public Housing
    - Public housing was established to provide decent and safe rental housing for eligible low-income families, the elderly, and persons with disabilities. Public housing comes in all sizes and types, from scattered single-family houses to high rise apartments for elderly families.

    Rehabilitation
    - The act or process of expanding, remodeling, altering, or renovating apartments and public areas within a housing development.

    Relocation Coordinator
    - A representative of AHA whose specific task is to relocate each affected resident, monitor and coordinate all day and temporary relocation activity, and implement the relocation plan to ensure compliance with applicable relocation regulations, guidelines, and laws.

    Relocation Unit
    - A decent, safe, and sanitary unit that is either on-site at the property or off¬ site. On-site units may be vacant apartments that will house residents who must relocate temporarily or an on-site renovated vacant apartment that will house residents who transfer there permanently. 

    Section 18
    - Section 18 of the 1937 Act governs public housing agency activities to demolish or dispose of part or all of a public housing project. Under this law, residents must receive advisory, moving, and housing assistance.

    Temporary Relocation
    - When residents must relocate for less than one year or permanently transfer to a comparable unit on-site.

    Uniform Relocation Act (URA)
    - A federal law establishing minimum standards for federally funded programs and projects requiring acquiring real property (real estate) or displaced persons from their homes, businesses, or farms. The URA's protections and assistance apply to acquiring, rehabilitating, or demolishing real property for federal or federally funded projects.

  2. Introduction

    The Housing Authority of the City of Abbeville ("AHA") was created in the 1951 to provide various affordable housing opportunities for low and moderate-income families. AHA is a public body, corporate and public, governed by a seven-member Board of Commissioners appointed to terms by the Mayor of Abbeville. The primary goal of AHA is to provide decent, safe, and sanitary housing for families that cannot afford standard private housing. 

    AHA programs are administered at the local level following state law. AHA owns, operates, and manages 129 public housing units at various locations throughout the City and County. 
    This Relocation Plan ("Plan") was explicitly developed for the residents affected by AHA's intent for testing and remediation of mold and lead based paint. Safe and thoughtful resident relocation is a priority for AHA. AHA has a designated a Relocation Coordinator who will collaborate directly with the affected residents through their temporary relocation. 

    The plan ensures that residents are treated fairly and follow the relocation requirements of Section 18 of the Housing Act of 1937 (42 U.S.C. 1 437p). Under this law, residents must receive advisory, moving, and housing assistance. HUD's implementing regulations for Section 18 are located at 24 CFR Part 970. 

    A draft version of this Plan shall be available to Households and other interested parties at 508 Haigler Street, Abbeville, SC 29649, for thirty (30) calendar days. Each Household shall be notified in writing where and how they can review the draft Plan, with instructions to provide written comments directly to the AHA Relocation Coordinator for analysis and inclusion in the definitive version of this Plan.

    Person of contact for this Relocation Plan are as follows:

    Larry Haqq
    Executive Director
    Abbeville Housing Authority
    508 Haigler Street, Abbeville, South Carolina 29620
    Office: 864.366.4549
    Fax: 864.366.4341
    lhaqq@abbevillehousing.org

  3. Project Description

    AHA has Eight (8) public housing communities that due to age require lead base paint and mold remediation reviews. AHA intends to remediate the property through HUD's Section 18 Program.

    AHA will complete the rehabilitation using awarded grants. For unit testing AHA has selected Apex Environmental Health and Safety, LLC to conduct the mold testing/mold remediation and Crossroads Environmental, LLC to conduct the lead-based paint testing. Apex Environmental Health and Safety, LLC is a contracting company based out of Mauldin, SC and Crossroads Environmental, LLC is a contractor based out of Spartanburg, SC.

    The project comprises 21 one-bedroom, 112 two-bedroom, 120 three-bedroom and 48 four-bedroom units housed in stand-alone buildings.

    The rehabilitation project will be completed in three (3) phases as follows:

    Project Name: Phase I - Bell Street Apartments
    Number of Units: 18
    Duration of Relocation: 1 - 10 Days
    Number of Families to be Relocated: TBD

    Project Name: Phase I - Louis Street Apartments
    Number of Units: 18
    Duration of Relocation: 1 - 10 Days
    Number of Families to be Relocated: TBD

    Project Name: Phase II - Washington Street Apartments
    Number of Units: 20
    Duration of Relocation: 1 - 10 Days
    Number of Families to be Relocated: TBD 

    Project Name: Phase II - Robinson Street Apartments
    Number of Units: 20
    Duration of Relocation: 1 - 10 Days
    Number of Families to be Relocated: TBD 

    Project Name: Phase II - Bowie Street Apartments
    Number of Units: 20
    Duration of Relocation: 1 - 10 Days
    Number of Families to be Relocated: TBD

    Project Name: Phase III - Carver Street Apartments
    Number of Units: 85
    Duration of Relocation: 1 - 10 Days
    Number of Families to be Relocated: TBD

    Project Name: Phase III - Calhoun Apartments
    Number of Units: 85
    Duration of Relocation: 1 - 10 Days
    Number of Families to be Relocated: TBD

    The requirement of Relocation activities is based on the results of the mold and lead based paint tests. 
    Below is the table showing the current breakdown of AHA's dwelling units.

    Unit Size: One (1) Bedroom
    Number of Units: 21
    Vacant: 0
    Occupied: 21

    Unit Size: Two (2) Bedroom
    Number of Units: 112
    Vacant: 3
    Occupied: 109

    Unit Size: Three (3) Bedroom
    Number of Units: 120
    Vacant: 1
    Occupied: 119

    Unit Size: Four (4) Bedroom
    Number of Units: 48
    Vacant: 0
    Occupied: 47

    Unit Size: Total Units
    Number of Units: 129
    Vacant: 4
    Occupied: 125

    The rehabilitation is anticipated to commence in January 2025, 

    Rents and Utilities
    Residents will continue to be responsible for rent and utilities during the temporary relocation.

  4. Resident Relocation Plan

    1. Resident Demographics

      As of December 1, 2024, AHA had 125 occupied apartment homes and 4 vacancies.

      Demographics of the AHA residents, based on December 1, 2024, data, include:

        • 82% of residents identify as African American and 17%, White and 1% as Hispanic.
        • 33% of heads of households are male, and 67% are female.

    2. Relocation Plan for Affected Eligible Households

      Temporary Off-site Relocation 
      The current plan will begin with testing units in Phase I, based on the test results a determination of relocation will be made. If a resident needs to relocate, it will be done on a temporary bases, a time limit of a minimum of one (1) day and a maximum of ten (10) days will be applied. Residents in the remaining phases will follow the same time limit listed above when testing begins in their phases. 

    3. Relocation Schedule 

      The relocation schedule is designed to provide minimum disruptions to residents without compromising the rehabilitation project. All households will receive notices as test results are received, their units will be scheduled to be rehabilitated within the phasing plan.

      Phase I: Loundesville 18 units
      Mold and Lead-Based Paint testing is anticipated to beginning January 20, 2025. The units for this Phase are occupied, and there will only be temporary displacements if the testing result represents a need for relocation. The rehabilitation / testing completion date is January 25, 2025.

      Phase II: Donalds-Due West 28 units
      The anticipated Mold and Lead-Based Paint testing commence date is currently January 22, 2025. The units for this Phase are occupied, and there will only be temporary displacements if the testing result represents a need for relocation. The rehabilitation testing completion date is January 28, 2025

      Phase Ill: Calhoun - Carver 85 units
      The anticipated Mold and Lead-Based Paint testing commence date is currently January 27 2025. The units for this Phase are occupied, and there will only be temporary displacements if the testing result represents a need for relocation. Rehabilitation / testing is anticipated to be completed by February 10, 2025.

      All project households will receive the General Information Notice as required by the URA.

  5. Program Assurances and Standards

    The underlying objective of this relocation plan is to ensure that residents affected by this project are treated fairly and consistently and do not suffer disproportionate hardships as a direct result of activities designed for the benefit of the residents as a whole. This plan applies to all moves occurring as a result of the project's rehabilitation (testing and remediation of mold and lead-based paint). 

    Adequate funds are available for relocating all Households within the project's budget. Relocation assistance services will be provided to ensure that displacement does not result in different or separate treatment of households based on race, nationality, color, religion, national origin, sex, marital status, familial status, disability, or any other basis protected by the federal Fair Housing Amendments Act, the Americans with Disabilities Act, Title VI of the Civil Rights Act of 1964, Title VIII of the Civil Rights Act of 1968.

    This plan sets forth policies and procedures necessary to conform to statutes and regulations under the Uniform Relocation and Real Property Acquisition Policies Act of 1970 (URA), as amended, and implementing regulations at 49 CFR 24, Section 18 of the Housing Act of 1937 (the Act), as amended, Section 104 (d) of the Housing and Community Development Act of 1974, Notice H 2016-17, and all applicable local, state, and federal regulations. All residents residing on-site on the date they receive the General Information Notice (GIN) are eligible for relocation benefits. AHA will provide all affected households with relocation rights and benefits in accordance with Section 18 relocation requirements and the Uniform Relocation Assistance and Real Property Act of 1970 (URA).

    If a resident is evicted in accordance with applicable local and state law and the eviction is not undertaken for the purpose of evading the obligation to make available Section 18 and URA relocation payments and other assistance, the resident is generally not entitled to relocation assistance and payments under this Notice or the URA (49 C.F.R. § 24.206). If a resident voluntarily ends their participation in the public housing program, in the absence  of  evidence that the PHA induced the end of participation for the purpose of evading the obligation to make available Section 18 and URA payments and other assistance, the resident is generally not entitled to relocation assistance and payments under this Plan or the URA .

    Pursuant to Public Law 105-117, aliens not lawfully present in the United States are not eligible for relocation assistance unless such ineligibility would result in exceptional hardship to a qualifying spouse, parent, or child. All persons seeking relocation assistance will be required to certify that they are a United States citizen or national or an alien lawfully present in the United States.

  6. Relocation Assistance and Benefits

    1. Staffing

      AHA's Relocation Coordinator will assist the residents through the rehabilitation project and will be the primary contact for residents for all questions, concerns, and issues that may arise due to their relocation. AHA's Relocation Coordinator will provide residents with relocation assistance and benefits, including advisory services, comparable relocation housing resources, moving assistance and payment of other move-related expenses, and notifications/ongoing communication.

      Residents will have the full support and assistance of AHA's Relocation Coordinator throughout the rehabilitation of the project. Residents and their families will be able to meet personally with the Relocation Coordinator at their request throughout the rehabilitation and relocation process. 

    2. Advisory Services and Resident Relocation Assessment

      AHA's Relocation Coordinator will collaborate closely with the affected households to provide relocation counseling and advisory services as well as guidance and support throughout the rehabilitation and relocation process. Any resident concerns or questions should be directed to AHA's Relocation Coordinator, Mr. Larry Haqq. Mr. Haqq can be reached by phone at 864.366.4549 or lhaqq@abbevillehousing.org. Concerns should be submitted directly to the Relocations Coordinator, who will respond to residents to answer questions and address any reasonable accommodation requests.

      These advisory services will include:

      • Be accessible to residents and their families for their questions or concerns and communicate with residents with contact information and an office location.
      • As Needed, conduct community meetings about the project to solicit input and questions at 508 Haigler Street, Abbeville, South Carolina 29620. (Transportation is available upon resident request).
      • Meet with each household one-on-one (in whatever format makes residents feel most comfortable, including by phone, in-person, virtually, etc.) to explain their relocation rights and benefits. 
      • Provide required notices and all verbal and written correspondence by any translation/interpretation needs or other reasonable accommodation requests regarding relocation updates, progress, and additional vital information.
        • Provide appropriate counseling for residents who cannot read and understand notices.
        • Understand and anticipate the needs of the residents and their families and be able to meet the special advisory services they may need.
        • Explanation and details on the rehabilitation and relocation process and timeline.
        • Explanation of relocation benefits, assistance, and procedures.
        • Explanation of relocation schedule.
        • Close coordination of activities through individual ongoing contact.

    3. Comparable Temporary Relocation Housing
      Affected residents will not incur any interim housing costs due to the rehabilitation process. Residents may relocate to other public housing units in AHA's portfolio if they are available, and the calculation of their tenant-paid portion of the rent amount will remain the same. No resident will relocate longer than 10 days off-site. 

    4. Moving Benefits and Assistance
      Affected residents will not incur any actual or related relocation costs or increased housing costs due to the rehabilitation project. AHA will undertake the moving cost of each affected household to and from their rehabilitated unit at the project.

      Moving benefits and assistance that will be provided at no cost to the affected residents may include:

      • Packing and Moving Assistance:
      • AHA will pay for the services of a licensed, insured, and bonded moving company to complete moves from and to the project. Should residents require assistance with packing and unpacking, such will be provided at AHA's expense.
      • Boxes, tape, paper, and other moving materials will be provided to the affected resident by AHA.
      • AHA will purchase insurance via the moving company for the replacement value of the property in connection with the move and necessary storage and/or the replacement value.
      • Storage - in lieu of transporting personal items AHA will arrange for delivery of on-site storage units/pods, during their relocation, as needed.
      • Other out-of-pocket and relevant expenses will be provided to residents based on AHA's determination and the project's relocation plan.
      • In lieu of the AHA providing temporary housing, a resident that will be out of a unit for three (3) days or more may choose to accept a flat relocation fee of $ 1,150 and procure their own temporary housing. (Four (4) Bedroom Maximum Rent $ 900 + Utility $ 200 = $1,100).

        As approved by AHA, residents may choose to purchase or pay for these relocation costs and be reimbursed by AHA for actual, reasonable, and necessary expenses incurred due to their relocation (valid receipts must be provided). 

        An estimated Relocation Budget is attached as Appendix 1.

    5. Communication and Notices
      Residents will receive ongoing and frequent communication regarding the rehabilitation timeline from AHA's Relocation Coordinator. The required General Information Notice will be promptly sent to each affected household, along with phone calls and physical letter updates to provide residents with relocation information. Any requested translation and/or interpretation of these notices will be completed and delivered. Any identified friends/family/caregivers will also be given copies of these letters to help advise residents and be included in the relocation process. Required notices will include:
      • General Information Notice (GIN) - during November, the GIN was sent be to the affected households, providing a general description of the project, the activities planned, and the relocation assistance under the Section 18 and URA that may become available. All GIN letters have been signed by all residents. 
      • Notice of Relocation - This notice will include the anticipated duration of the resident's relocation and AHA's Relocation Coordinator's contact information. Affected households will receive a Notice or 30-Day Relocation Notice based on how long their relocation is expected.
      • GIN Notice - For residents relocating for less than 12 months, this notice provides a minimum of 30 days' notice before a resident is required to relocate. The notice will also explain how AHA will pay for all reasonable out-of-pocket expenses incurred in connection with any temporary move (including, but not limited to, increased housing costs and moving costs). The notice will also explain the resident's right to return to a renovated unit in the project.
      • Notification of Return - Residents who relocate temporarily will receive a reasonably timed notice on their expected return to a renovated unit at the project. The notice will provide AHA's Relocation Coordinator's contact information, the address of the resident's new assigned unit, and the expected return move date or time limit. This notice outlines that AHA will pay for the move cost, all reasonable out-of-pocket expenses incurred from the move, the resident's options, and the implications of those options if the resident determines that they do not want to return to the Covered Project and wants to decline the right of return.
      • Notice of Return - Ideally 14 days in advance of a newly renovated unit being ready that meets the needs of the household (Based on final Air Clearance 3 - 5 days).

        These notices will be hand-delivered and signed for by each resident or sent by certified first­ class mail with a return receipt requested to confirm receipt. All relocation notices, communications, relocation reimburses, and receipts will be documented in files for each affected household.

  7. Record Keeping and Resident Log
    Along with files for each resident holding all copies of the received relocation notices, AHA will maintain and update a Resident Log containing the information of all affected residents. Information tracked for all affected households since the first resident meeting will include, as applicable for each household:

    • Name of head of household/ID number/race & ethnicity/household members with disabilities/household members under 18 years old as reported on HUD Form 50058
    • Details of resident meetings (if needed)
    • Date(s) of all required notices
    • Date of relocation and changing housing status during the relocation process
    • Date of return
    • The type of move and form of temporary housing.
    • Address and unit size of any temporary relocation housing
    • The type and amount of any payments for moving expenses.
    • Payments for temporary rental assistance
    • Any other relocation-related compensation or assistance

  8. Relocation Tax Consequences

    In general, relocation payments are not considered income for the purpose of the Internal Revenue Code of 1986, or the Personal Income Tax Law, Part 10, of the Revenue and Taxation Code. The above statement on tax consequences is not intended to be the provision of tax advice by the Owner, their Agents, Consultants, or Assigns. Displaces are encouraged to consult with independent tax advisors concerning the tax consequences of relocation payments.

  9. Eviction Policy

    Eviction by AHA is permissible only as a last alternative. Except for persons considered to be in unlawful occupancy, a displaced person's eviction does not affect eligibility for relocation assistance and benefits. Relocation records will be documented to reflect the specific circumstances surrounding the eviction. Eviction may be undertaken only for one or more of the following reasons:
    1. Failure to pay rent, except in those cases where the failure to pay is due to AHA's failure to keep the premises in habitable condition, is the result of harassment or retaliatory action, or is the result of discontinuation or substantial interruption of services;
    2. Performance of a dangerous and/or illegal act in the unit by the tenant, tenant's guest(s), and/or invitee(s) or any combination thereof;
    3. A material breach of the rental agreement and failure to correct the breach within 14 days of notice;
    4. Expiration of the lease agreement and holdover of the unit by the tenant.

  10. Appeal Process

    If a resident contends that this Relocation Plan is not being appropriately implemented or believes AHA has failed to consider the person's request for relocation assistance properly, the resident may submit a written appeal to AHA at 508 Hagler Street, Abbeville, SC 29649, based on a determination of relocation assistance or any other part of the Relocation Plan not being implemented by AHA.

    Grounds for appeal shall not include suspension of discretionary relocation benefits to former residents. The agency must consider a written appeal regardless of the form set in the URA. The time limit shall not be less than 60 days after the person receives written notification of the Agency's determination on the person's claim.

    Promptly after receipt of all information submitted by a person supporting an appeal, AHA shall make a written determination, including an explanation of the decision's basis, and furnish the person with a copy. If the complete relief requested is not granted, the agency shall advise the person of their right to seek judicial review.

    The AHA official conducting the review of the appeal shall be either the head of the Agency or their authorized designee. However, the official shall not have been directly involved in the action appealed.

Appendix 1: Relocation Budget

  • Description: Relocation Flat Fee 
    • Cost: $1,100.00 
    • Number of Units: 
    • Totals: $
      • Total: $
  • Description: Air BNB - One (1) Bedroom
    • Cost: $588.00/wk.
    • Number of Units: 21
    • Pet Fee: Service Pet Only
    • Totals: $12,348.00
  • Description: Air BNB - Two (2) Bedroom
    • Cost: $673.00/wk.
    • Number of Units: 112
    • Pet Fee: 2 Max - No Deposit
    • Totals: $75,376.00
  • Description: Air BNB - Three (3) Bedroom
    • Cost: $708.00
    • Number of Units: 120
    • Pet Fee: 2 Max - No Deposit
    • Totals: $84,960.00
  • Description: Air BNB - Four (4) Bedroom
    • Cost: $1,201.00
    • Number of Units: 48
    • Pet Fee: 2 Max - No Deposit
    • Totals: $57,648.00
      • Total: $230,332.00
  • Description: Moving Assistance
    • Cost: $100.00
    • Number of Units: 64
    • Time Limit: 2 hours Max
    • Totals: $6,400.00
      • Total: $6,400.00
  • Description: Packing Supplies
    • Cost: $249.95
    • Number of Units: 64
    • Boxes, Tape, Etc.
    • Totals: $15,996,80
      • Total: $15,996,80
  • Description: U-Haul Truck - 15 Ft Truck
    • Cost: $104.00/day
    • Number of Units: 22
    • Number of Days: 2
    • Totals: $4,576.00
  • Description: U-Haul Truck - 20 Ft Truck
    • Cost: $114.00/day
    • Number of Units: 21
    • Number of Days: 2
    • Totals: $4,788.00
  • Description: U-Haul Truck - 26 Ft Truck
    • Cost: $130.00
    • Number of Units: 21
    • Number of Days: 2
    • Totals: $5,460.00
      • Total: $14,824.00
  • Description: Storage
    • Cost: $350.00 each
    • Number of Units: 15
    • Totals: $5,250,00
      • Total: $5,250.00
        • Final Budget Totals: $272,802.80