RELOCATION PLAN FOR THE GROVE PARK APARTMENTS PROJECT

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RELOCATION PLAN FOR THE GROVE PARK APARTMENTS PROJECT PREPARED FOR THE CITY OF GARDEN GROVE COMMUNITY DEVELOPMENT DEPARTMENT ON BEHALF OF JAMBOREE HOUSING CORPORATION BY OVERLAND, PACIFIC & CUTLER, INC. MAY 29, 2009

TABLE OF CONTENTS INTRODUCTION... 1 I. PROJECT LOCATION AND DESCRIPTION... 2 A. LOCATION... 2 B. PROJECT DESCRIPTION... 3 C. GENERAL AREA DEMOGRAPHIC AND HOUSING CHARACTERISTICS... 4 D. PROJECT NEIGHBORHOOD CHARACTERISTICS..................... 5 II. ASSESSMENT OF RELOCATION NEEDS... 6 A. METHODOLOGY... 6 B. PROJECT CHARACTERISTICS AND NEEDS......................... 6 III. HOUSING RESOURCES... 9 IV. THE RELOCATION PROGRAM... 10 A. PROGRAM ASSURANCES AND STANDARDS....................... 10 B. RELOCATION ASSISTANCE PROGRAM............................ 11 C. RELOCATION BENEFIT CATEGORIES............................. 12 D. PAYMENT OF RELOCATION BENEFITS............................ 14 E. IMMIGRATION STATUS... 14 F. RELOCATION TAX CONSEQUENCES... 15 G. GRIEVANCE PROCEDURES... 15 H. EVICTION POLICY... 15 I. PROJECTED DATES OF DISPLACEMENT........................... 16 J. CITIZEN PARTICIPATION... 16 K. ESTIMATED RELOCATION COSTS... 17 LIST OF TABLES TABLE 1: 2000 Census Population - City of Garden Grove & Impacted Tract............. 4 TABLE 2: 2000 Census Housing Units - City of Garden Grove & Impacted Tract.......... 4 TABLE 3: Project Neighborhood Amenities... 5 TABLE 4: Availability and Cost of Rental Housing.................................. 9 LIST OF EXHIBITS Exhibit A: Exhibit B: Exhibit C: Exhibit D: Exhibit E: Exhibit F: HUD Income Limits - Orange County List of Area Motels Informational Statement for Families and Individuals Fixed Moving Schedule Relocation Payments and Assistance Procedure Plan Addendum (Public Comments & Response to Public Comments)

INTRODUCTION The following relocation plan (the Plan) has been prepared for submission to the City of Garden Grove Community Development Department (the City) in conformance with the applicable provisions of the Uniform Relocation Act (46 U.S.C. 4600 et seq.), its implementing regulations (49 C.F.R. Part 24), the California Relocation Assistance Law, California Government Code Section 7260 et seq. (the CRAL) and the California Relocation Assistance and Real Property Acquisition Guidelines, Title 25, California Code of Regulations, Chapter 6, Section 6000 et seq. (the Guidelines) and Handbook 1378 of the United States Department of Housing and Urban Development (HUD). The subject of the Plan is rehabilitation of the Grove Park Apartments (the Project) in Garden Grove, California being undertaken by the Jamboree Housing Corporation (the Developer). The Project involves the acquisition of 13 land parcels, each improved with an eight-unit complex and the rehabilitation of 104 multi-family housing units as well as the temporary or permanent relocation of the current occupants. The Developer will rehabilitate the units and make them available to households with incomes between 30% and 60% of area median income (AMI) for Orange County. The statutory basis for this plan arises from the anticipated need to permanently displace the households with income above 60% AMI from their Project units as well as to identify requirements, special needs and preferences for these households and the relocation assistance program the Developer will follow. The Plan is presented in four Sections: Section I: Project description and general demographic data Section II: Profile of tenants who may be affected and an assessment of their needs Section III: Description of available housing resources Section IV: Description of the relocation assistance program The Plan has been prepared by Overland, Pacific & Cutler, Inc. (OPC) located at 10 Hughes, Suite A-207 in Irvine, California. The general telephone number is (800) 901-5263, which is attended between 8 a.m. and 5 p.m., Monday through Friday. Prepared by Overland, Pacific & Cutler, Inc. Page 1

I. PROJECT LOCATION AND DESCRIPTION A. LOCATION The Project complexes are located on Morningside and Keel Avenues in Garden Grove, generally between Keel Avenue to the north, Buena Street to the east, the northern boundaries of the Clinton Mobile Home Park to the south and Clinton Street to the west. The apartment complexes associated with the Project have the following street addresses: 12631, 12602, 12612, 12661, 12651, 12572, 12692 and 12682 Morningside Avenue, and 12622, 12632, 12652, 12662 and 12682 Keel Avenue. (see Figures 1 and 2). Figure 1: Regional Project Location Prepared by Overland, Pacific & Cutler, Inc. Page 2

Relocation Plan for the Grove Park Apartments Project in Garden Grove, California Figure 2: Project Site Location (pushpins depict a general location of complexes only) B. PROJECT DESCRIPTION The Developer is in the process of purchasing 13 complexes totaling 2.9 acres and modernizing the units that never had any major updates completed to better serve the lowincome tenant population. Although the units appear to be in good condition and satisfy the requirements of Section 8 Program s inspections, the worn carpet and old paint need to be replaced, and the current air conditioning/heating units could be more energy efficient. Therefore, the Developer intends to make these modifications. The extent of repairs will vary from unit to unit and may include new kitchen cabinets and bathroom fixtures. Exterior improvements will include paint and building facade improvements. The rehabilitation cycle per unit should not exceed 14-21 days, and the Developer will phase the rehabilitation process to not temporarily displace more than eight units at a time. Prepared by Overland, Pacific & Cutler, Inc. Page 3

Relocation Plan for the Grove Park Apartments Project in Garden Grove, California C. GENERAL AREA DEMOGRAPHIC AND HOUSING CHARACTERISTICS According to the 2000 U. S. Census, the population of the City of Garden Grove was 165,196 and the population of the impacted Census Tract 891.04 was 6,074 (see Table 1). Corresponding Census data concerning the housing mix is shown in Table 2. TABLE 1: 2000 Census Population - City of Garden Grove & Impacted Tract Population Tract 891.04 % City % Total Population 6,074 100.0% 165,196 100.0% White 2,356 38.8% 77,443 46.9% Black or African American 88 1.4% 2,168 1.3% American Indian and Alaska Native 84 1.4% 1,260 0.8% Asian 1,138 18.7% 51,078 30.9% Native Hawaiian and Other Pacific Islander 21 0.3% 1,081 0.7% Some Other Race 2,068 34.0% 25,362 15.4% Two or More Races 319 5.3% 6,804 4.1% Hispanic or Latino (of Any Race) 4,384 72.2% 53,608 32.5% Source: U.S. Census Bureau, Race, Hispanic or Latino, and Age: 2000 TABLE 2: 2000 Census Housing Units - City of Garden Grove & Impacted Tract Type Tract 891.04 % City % Total Units 1,358 100.0% 46,703 100.0% Owner-Occupied 412 30.3% 27,286 58.4% Renter-Occupied 911 67.1% 18,505 39.6% Vacant Housing Units 35 2.6% 912 2.0% Available for Sale Only (of Total Vacant Units) 0 0.0% 191 20.9% Available for Rent - Full Time Occupancy (of Total Vacant Units) 19 54.3% 372 40.8% Sold or Rented - Not Occupied 11 31.4% 78 8.6% Otherwise Not Available (e.g. seasonal, recreational, migratory, occasional use) 2 5.7% 83 9.1% Other Vacant 3 8.6% 188 20.6% Source: U.S. Census Bureau, General Housing Characteristics: 2000 Prepared by Overland, Pacific & Cutler, Inc. Page 4

Relocation Plan for the Grove Park Apartments Project in Garden Grove, California D. PROJECT NEIGHBORHOOD CHARACTERISTICS The Project is located in the high density residential area of the City of Garden Grove, close to schools, shopping and with easy access to SR-22 Garden Grove Freeway. Table 3 lists some neighborhood amenities and their distance from the Project. TABLE 3: Project Neighborhood Amenities Medical School Library Entertainment Community Center Police/Safety Shopping Transportation Facility! Saint Mary Medical Clinic! Garden Grove Hospital and Medical Center! UC Irvine Medical Center! Orangewood Academy! Clinton Elementary School! Spurgeon Intermediate School! Leroy L. Doig Intermediate School! Fremont Elementary! Santiago High School! Middle College High School! Newhope Library! Nealley Library! Santa ana Public Library! Latino Talent House! AMC 30 Theaters! Bowers Museum of Cultural Art! Discovery Science Center! Santa Anita Community Center! Salgado Community Center! Santa Ana Police! Orange County Sheriff! Santa Ana Disaster Services! Amigo Food Mart! Stater Brothers! Seven -11! Garden Grove Shopping Plaza! Westfield Main Place! Greyhound - Santa Ana! Amtrak - Santa Ana! Amtrak - Anaheim! Greyhound - Anaheim Miles from Project 0.3 1.2 2.5 0.5 0.6 0.6 0.7 0.8 0.8 1.2 1.3 1.3 2.1 1.2 2.1 2.4 2.6 1.0 1.2 1.8 2.0 3.0 0.3 0.4 0.8 2.6 2.8 0.3 3.0 3.5 4.0 Prepared by Overland, Pacific & Cutler, Inc. Page 5

II. ASSESSMENT OF RELOCATION NEEDS A. METHODOLOGY This Plan provides the results of a needs assessment survey, their incorporation into the planning process, and details of the Developer's proposed relocation plan. This Plan sets forth policies and procedures necessary to conform with statutes and regulations established by the Uniform Relocation Act (46 U.S.C. 4600 et seq.), its implementing regulations (49 C.F.R. Part 24), the California Relocation Assistance Law, California Government Code Section 7260 et seq. (the CRAL) and the California Relocation Assistance and Real Property Acquisition Guidelines, Title 25, California Code of Regulations, Chapter 6, Section 6000 et seq. (the Guidelines) for residential displacements. With certain narrow exceptions, federal funds cannot be used for any displaced person who is an alien not lawfully present in the United States. Potential funding sources include HOME funds, redevelopment setaside funds, LIHTC equity and conventional construction loans. B. PROJECT CHARACTERISTICS AND NEEDS To obtain information necessary for the implementation of this Plan, interviews will be conducted with the current Project residents not on Garden Grove Housing assistance prior to commencement of any relocation activities. Inquiries made of the occupants will include household size and composition, ages of occupants, rental and income information, length and type of occupancy, ethnicity, primary language in the home, disabilities and health problems, and preferences related to replacement housing and location. At the time of the preparation of this Plan, the current property owner declined to allow tenant interviews of the Project occupants. The Developer and Garden Grove Housing and Neighborhood Services staff provided limited information about units and households currently on housing assistance through the Garden Grove Housing Authority, although no information was available about households with incomes potentially over 60% AMI which will need to be permanently relocated from the Project. The Developer anticipates that all households receiving housing assistance from the Garden Grove Housing Authority are at, or below, 50% AMI and will therefore be Prepared by Overland, Pacific & Cutler, Inc. Page 6

Relocation Plan for the Grove Park Apartments Project in Garden Grove, California temporarily relocated for the duration of the rehabilitation and move back to the Project once the units are completed. They will be allowed to move back to their original unit or another suitable unit within the Project. It is the intent of the Developer to make one eightplex serve as a hotel/motel for the temporarily displaced households while their units are undergoing rehabilitation. If the Developer is unable to accomplish this at the time of required temporary displacements, they will make arrangements with one of the nearby motels to provide accommodations to temporary displacees for the duration of the repairs. The list of the motels within two miles from the Project is presented as Exhibit B in this Plan. The rehabilitation of each eight-plex is not expected to last more than 2-3 weeks, and the Developer will cover all lodging and pre-approved out-of-pocket household expenses while residing in the motel, if necessary. In addition, the Developer will cover the cost of moving the tenants personal property out of their current units and back into their permanent units once the repairs have been completed. Based on the known tenant data, 80 households receive Garden Grove Housing assistance and have incomes at, or below, 50% of AMI per income levels as published by the United States Department of Housing and Urban Development (HUD) for the County of Orange (see Exhibit A). Four units are vacant per April 2009 rent roll data. Sixteen households are receiving housing assistance from another Housing Authority (County of Orange, City of Santa Ana or another City). The tenants contributory portion of rent paid was made available to OPC staff for the households receiving housing assistance. Based on the assumption that the tenants would not be allowed to pay in excess of 30% of gross household monthly income towards rent, all households receiving housing assistance from any source appear to be below 60% AMI and will qualify to remain in a Project unit. However, one household receiving Section 8 assistance is considered overcrowded based on the Developer s occupancy standard and will have to be permanently relocated to a larger unit than the Developer can accommodate on site. The remaining 14 households are paying market rent. For the purpose of this Plan, an assumption was made that all 14 of these households earn income above 60% of AMI and will need to be permanently relocated, since they do not satisfy the criteria of the postrehabilitation Project requirements. (After tenant surveys are completed with the 30 non- Garden Grove Housing Authority assisted households, the number of permanent displacees will be adjusted based on actual information.) Prepared by Overland, Pacific & Cutler, Inc. Page 7

Relocation Plan for the Grove Park Apartments Project in Garden Grove, California Among the 15 total units subject to potential permanent relocation, six are one-bedroom units with approximately 465 square feet, two are two-bedroom units with 784 square feet and seven are three-bedroom units with 975 square feet. Current rents for these units are $950 for one-bedroom units, $1,150 for two-bedroom units and $1,450 for three-bedroom units. The presence of disabilities in the Project is unknown at this time, but it will be considered at the time of displacement to the extent it may affect the physical move. The Developer pledges to appropriate special care for households requiring additional assistance due to potential disabilities. The ethnic distribution in the Project is unknown at this time and will be verified at the time of personal surveys with Project households. The standard housing density utilized is two persons per bedroom and one person in a common living area for tenant occupied units. All households currently on Garden Grove Housing assistance, with the exception of the one household mentioned previously, satisfy the occupancy standard and will remain in units of the same size. Personal interviews with potentially permanently displaced households will determine the need for larger accommodations; at this time an assumption is made that there is only one household requiring a larger unit based on this occupancy standard. Relocation activities for permanent displacees will consider individual household needs to be close to public transportation, employment, schools, public/social services and agencies, recreational services, parks, community centers, or shopping. Relocation assistance information and counseling will be provided in the primary language of the displaced occupants, in order to assure that all displaced occupants obtain a complete understanding of the relocation program and eligible benefits. Prepared by Overland, Pacific & Cutler, Inc. Page 8

III. HOUSING RESOURCES A resource survey was conducted to identify available rental units within the general Project area and Garden Grove. The following sources were utilized: S S S Classified rental listings from The Orange County Register and For Rent publications Contacts with property management companies serving the community Internet sources and multiple listings The rental replacement housing survey considered multi-family units as comparable replacement units. The rental housing survey, summarized in Table 4, identified a total of 139 available one-, two-, three-, and four-bedroom housing units for rent. The individual figures for number of units found by bedroom size are presented in the table alongside the number of units needed (shown in parentheses) to meet re-housing obligations. TABLE 4: Availability and Cost of Rental Housing Bedroom Size One Two Three Four # Found (# Needed) 64 (6) 53 (2) 13 (6) 9 (1) Rent Range $700 - $1,050 $850 - $1,350 $1,295 - $2,000 $1,650 - $2,300 Median Rent $950 $1,250 $1,700 $2,100 The median rent amounts shown in the table above are among the figures used to make benefit and budget projections for the Plan. These amounts are, naturally, subject to change according to the market rates prevailing at the time of displacement. Concurrent Displacement There are no other known projects currently underway, or planned for the immediate future, within the City of Garden Grove jurisdiction that could negatively impact the pool of available replacement housing resources. No residential displacee will be required to move without both adequate notice and access to available affordable decent, safe and sanitary housing. Prepared by Overland, Pacific & Cutler, Inc. Page 9

IV. THE RELOCATION PROGRAM The relocation program and assistance offered by the Developer will conform to provisions of the California Relocation Law, Government Code Section 7260, et seq., the California Relocation Guidelines, California Code of Regulations Title 25, Chapter 6, as amended January 1, 1998, the federal Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (URA) and the implementing regulations of Handbook 1378 of the Department of Housing and Urban Development (HUD), as appropriate. A. PROGRAM ASSURANCES AND STANDARDS There are adequate funds available to relocate all households. 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 VII of The Civil Rights Act of 1964; Title VIII of The Civil Rights Act of 1968; and, the California Fair Employment & Housing Act; and the Unruh Act. No households will be displaced without at least 90 days notice and unless comparable replacement housing can be located. Comparable housing includes standards such as: decent, safe and sanitary (as defined in 6008[d] of the Guidelines); comparable as to the number of bedrooms, living space, and type and quality of construction of the acquired unit, but not lesser in rooms or living space than necessary to accommodate the displaced household; in an area that does not have unreasonable environmental conditions; not generally less desirable than the acquired unit with respect to proximity to schools, employment, health and medical facilities, and other public and commercial facilities and services; and within the financial means of the displaced household as defined in Section 6008, subdivision (c)(5) of the Guidelines. B. RELOCATION ASSISTANCE PROGRAM A relocation representative from OPC will assist the tenants to be displaced as a consequence of the Project. OPC staff will maintain personal contact with them until the Prepared by Overland, Pacific & Cutler, Inc. Page 10

Relocation Plan for the Grove Park Apartments Project in Garden Grove, California relocation process has been completed. OPC maintains a toll-free phone number (800) 901-5263, which is attended to from 8:00 a.m. to 5:00 p.m., Monday through Friday. The relocation offices are located at: 10 Hughes, Suite A-207 Irvine, CA 92618 As a function of the overall relocation assistance program, technical and advisory assistance will be provided to all residents by the Developer and contracted relocation representatives. The following services and tasks will be undertaken: 1. Each permanently displaced household will be personally interviewed to gather information appropriate to determine needs and preferences with regard to the replacement of existing accommodations. Inquiries made of residential occupants by relocation personnel will cover the following areas: family size, ethnic background, immigration status, age and health considerations, current employment status, family income, transportation needs, and preferences relative to replacement housing. 2. As soon as feasible, the relocation representative shall explain the relocation payments and other assistance for which households and individuals may be eligible, including related eligibility requirements and the procedures for obtaining such assistance. 3. Assistance will be provided to complete appropriate forms and coordinate moving arrangements. Displacees will be kept informed of Project timing and receive appropriate notice to prepare for required moves. Claims for compensable expenses associated with the move will be processed expeditiously. 4. Special assistance in the form of referrals to governmental and social service agencies will be made, as appropriate. 5. Bilingual assistance will be provided, as needed. Prepared by Overland, Pacific & Cutler, Inc. Page 11

Relocation Plan for the Grove Park Apartments Project in Garden Grove, California 6. Distribution of informational brochures to residential tenants (Exhibit C); 7. Timely referrals to at least three comparable replacement units and, if necessary, transportation will be provided to inspect potential replacement units. C. RELOCATION BENEFIT CATEGORIES Relocation benefits will be provided in accordance with the Law; the Guidelines; and other applicable regulations and requirements. Benefits will be paid upon submission of required claim forms and documentation in accordance with approved procedures. The Developer will provide appropriate benefits for each displaced household as required by the abovereferenced laws and requirements. 1. Residential Moving Expense Payments The subject households will be eligible to receive a payment for moving expenses. Payments will be made based upon either a fixed room count schedule, or an invoice for actual reasonable moving expenses from a licensed professional mover. a. Fixed Payment - A fixed payment for moving expenses based on the number of rooms containing furniture or other personal property to be moved. The fixed moving payment will be based upon the most recent Federal Highway Administration (FHWA) schedules maintained by the California Department of Transportation (See Fixed Payment Moving Schedule - Exhibit D). - OR - b. Actual Reasonable Moving Expense Payments - The displaced households may elect to have a licensed, professional mover perform the move; if so, the displacing entity will pay for the actual cost of the move, up to 50 miles, and all reasonable charges for packing, Prepared by Overland, Pacific & Cutler, Inc. Page 12

Relocation Plan for the Grove Park Apartments Project in Garden Grove, California unpacking, insurance, and utility connection charges at the replacement location. The payment for moving will be made directly to the mover, or as reimbursement to the displaced household. 2. Rental Assistance/Downpayment Assistance Residential tenants who have established residency at the Project site and who choose to re-rent, may be eligible to receive a Rental Assistance Payment in addition to compensation for moving expenses. Rental Assistance Payments will be limited to a maximum of $5,250, based upon the monthly housing need over a 42 month period, prior to consideration of Last Resort Housing needs. Eligible households may opt to apply the full amount of their rental assistance eligibility toward the purchase of a replacement dwelling. 3. Assistance to Recipients of Section 8 Housing Assistance Households currently receiving assistance through the Section 8 Housing program, that are not satisfying the criteria to remain in the Project after the rehabilitation, will be provided referrals to available rental units whose owners have indicated a willingness to participate in the program. As long as there are available replacement units, Section 8 recipients will not qualify for cash rental assistance payments. Assistance will be provided, as appropriate, with one time security deposits and credit check fees. Section 8 recipients are also entitled to a payment for physical moving expenses on the same basis as market-rate tenants. 4. Last Resort Housing Payments The displaced persons will be entitled to consideration for supplementary benefits in the form of Last Resort Housing assistance when the computed total of their rental or replacement housing assistance eligibility exceeds either $5,250 in the case of tenants or when a tenant does not meet applicable occupancy requirements. Prepared by Overland, Pacific & Cutler, Inc. Page 13

Relocation Plan for the Grove Park Apartments Project in Garden Grove, California D. PAYMENT OF RELOCATION BENEFITS Relocation benefit payments will be made expeditiously. Claims and supporting documentation for relocation benefits must be filed with the Developer within 18 months from: i) the date the claimant moves from the acquired property; or, ii) the date on which final payment for the acquisition of real property is made, whichever is later. Procedures for preparing, filing of and processing of claims and delivering of payments are attached (Exhibit E). E. IMMIGRATION STATUS Federal legislation (PL105-117) prohibits the payment of relocation assistance benefits under the Uniform Act to any alien not lawfully present in the United States unless such ineligibility would result in an exceptional and extremely unusual hardship to the alien's spouse, parent, or child any of whom is a citizen or an alien admitted for permanent residence. Exceptional and extremely unusual hardship is defined as significant and demonstrable adverse impact on the health or safety, continued existence of the family unit, and any other impact determined by the Developer to negatively affect the alien's spouse, parent or child. The Developer may elect to authorize the payment of relocation assistance benefits to any otherwise eligible displacee from non-federally authorized reimbursable funds. In order to track and account for relocation assistance and benefit payments, relocation staff will be required to seek immigration status information from each displacee 18 years and older by having them self-certify as to their legal status. Prepared by Overland, Pacific & Cutler, Inc. Page 14

F. RELOCATION TAX CONSEQUENCES Relocation Plan for the Grove Park Apartments Project in Garden Grove, California In general, relocation payments are not considered income for the purpose of the Internal Revenue Code of 1968, or the Personal Income Tax Law, Part 10 of the Revenue and Taxation Code. Displaced persons are encouraged, however, to consult with personal tax advisors concerning the tax consequences or social service providers to obtain information concerning the tax consequences associated with relocation payments. G. GRIEVANCE PROCEDURES The Developer s Grievance Policy follows the standards described in Article 5, Section 6150 et seq., Title 25, Chapter 6, State of California, Department of Housing and Community Development Program guidelines. All displaced persons have the right to ask for administrative review concerning determinations of eligibility; relocation payment amount; the failure by the Developer to provide comparable replacement housing referrals; or, the property management practices of the Developer. H. EVICTION POLICY 1. Eviction will affect eligibility for relocation assistance and benefits. Relocation records will be documented to reflect the specific circumstances surrounding any eviction action. 2. Eviction may be undertaken for one, or more of the following reasons: (a) (b) Failure to pay rent, except in those cases where the failure to pay is due to the owner s failure to keep the premises in habitable condition; is the result of harassment or retaliatory action; or, is the result of discontinuation, or a substantial interruption of services; Performance of a dangerous, and/or illegal act in the unit; Prepared by Overland, Pacific & Cutler, Inc. Page 15

Relocation Plan for the Grove Park Apartments Project in Garden Grove, California (c) (d) (e) (f) A material breach of the rental agreement, and failure upon notification to correct said breach within 30 days of Notice; Maintenance of a nuisance, and failure to abate such nuisance upon notification within a reasonable time following Notice; Refusal to accept one of a reasonable number of offers of replacement dwellings; and/or, A requirement under State, or local law or emergency circumstances that cannot be prevented by reasonable efforts on the part of the Developer. I. PROJECTED DATES OF DISPLACEMENT It is anticipated that 90-day Notices-to-Vacate will be issued to the permanent displacees no earlier than September 2009. J. CITIZEN PARTICIPATION The Developer will fully meet its obligations under the Relocation Guidelines with respect to the following activities: 1. Full and timely access to documents relevant to the relocation program; 2. Provision of technical assistance necessary to interpret elements of the Relocation Plan and other pertinent materials; 3. Distribution of a general notice concerning the availability of this Plan for public review, as required, 30 days prior to its proposed approval. Notice recipients will include affected Project residents and all other interested parties; Prepared by Overland, Pacific & Cutler, Inc. Page 16

Relocation Plan for the Grove Park Apartments Project in Garden Grove, California 4. The opportunity to submit written or oral comments concerning the Plan and to have these comments attached to the Plan (as Exhibit F) when it is forwarded to the City of Garden Grove for approval; 5. Final review of the Plan to ensure its feasibility, compliance with applicable environmental standards and compatibility with the City of Garden Grove General Plan and relocation guidelines. K. ESTIMATED RELOCATION COSTS The Project will be funded with a combination of local, state and federal funds. The estimate of permanent relocation benefits is based on limited tenant data and current market rates for comparable units. Moving costs for the temporarily displaced households were also estimated. The estimated relocation cost for permanent benefits for the 15 potentially displaced Project households and temporary relocation benefits for the remaining 89 households is $393,000. The estimated relocation budget does not include any payments related to property acquisition and does not anticipate any overcrowding in the permanently displaced households requiring replacement units with more bedrooms than the displacement units. In addition, the budget does not consider the cost of any services necessary to implement the Plan and complete the relocation element of the Project. If the Project is implemented, and circumstances arise that should change either the number of permanently displaced occupants, or their replacement housing needs, the Developer will authorize any additional funds that may need to be appropriated. The Developer pledges to appropriate, on a timely basis, the funds necessary to ensure the successful completion of the Project, including funds necessary for LRH as indicated in Section IV, C, 5 of this Plan to meet its obligation under the relocation regulations. Prepared by Overland, Pacific & Cutler, Inc. Page 17

. EXHIBITS

. EXHIBIT A: HUD Income Limits - Orange County

The following figures are approved by the U. S. Department of Housing and Urban Development (H.U.D.) for use in the County of Orange to define and determine housing eligibility by income level. Figures are per the Department of Housing and Community Development, Division of Housing Policy Development, April 2, 2009. Area Median: $84,100 Family Size Extremely Low Very Low Lower Median Moderate 1 Person 19,550 32,550 52,100 60,250 72,300 2 Person 22,300 37,200 59,500 68,900 82,650 3 Person 25,100 41,850 66,950 77,500 92,950 4 Person 27,900 46,500 74,400 86,100 103,300 5 Person 30,150 50,200 80,350 93,000 111,550 6 Person 32,350 53,950 86,300 99,900 119,850 7 Person 34,600 57,650 92,250 106,750 128,100 8 Person 36,850 61,400 98,200 113,650 136,350

. EXHIBIT B: List of Area Motels

Motels Within Two Miles from Project Name Address Rates Miles Comments Pueblo Motel 1501 N. Harbor Blvd, Santa Ana $61.05/night/2 people 0.6 Coffeemaker West Coast Motel 1513 N. Harbor Blvd, Santa Ana $320/week/2 people 0.6 Bed & bathroom Days Inn& Suites 1108 N. Harbor Blvd, Santa Ana $400 +/week/ 2 beds 0.6 Coffeemaker Best Inn Motel 609 N Harbor Blvd, Santa Ana $50/person/ night 0.8 Fridge & microwave in room Econo Lodge - Maingate South 12091 Trask Ave, Garden Grove $395.50/1 bed/week 0.9 A/C & computer hook-ups Holiday Inn Express 12867 Garden Grove Blvd, Garden Grove $114/night/2 people 1.2 Coffeemaker Candlewood Suites 12901 Garden Grove Blvd, Garden Grove $560/week/2 people for a Queen studio 1.2 Full kitchenette Best Value Inn & Suites 12550 Lampson Ave, Garden Grove $60.86/night/2 people 1.7 Microwaves, mini fridge Hawthorn Suites 720 The City Dr South, Orange $98.56/night/2 people 1.8 Kitchenette Hampton Inn - Disneyland 11747 Harbor Blvd Garden Grove $159/night/2 people 1.9 Kitchenette Hilton Garden Inn 11777 Harbor Blvd, Garden Grove $139/night/ person 1.9 Fridge, microwave Embassy Suites - Anaheim South 11767 Harbor Blvd, Garden Grove $135-$185/ night/2 people 1.9 Fridge, microwave

. EXHIBIT C: Residential Informational Brochure

. EXHIBIT D: Fixed Moving Schedule

Fixed Payment Moving Schedule Occupant Owns Furniture One room $625.00 Two rooms $800.00 Three rooms $1,000.00 Four rooms $1,175.00 Five rooms $1,425.00 Six rooms $1,650.00 Seven rooms $1,900.00 Eight rooms $2,150.00 each additional room $225.00 Occupant Does NOT Own Furniture First Room $400.00 each additional room $65.00 Source: Federal Highway Administration

. EXHIBIT E: Relocation Payments and Assistance Procedures

Claims and supporting documentation for relocation benefits must be filed with the Developer within 18 months from: The date the claimant moves from the acquired property; or, The date on which final payment for the acquisition of real property is made, whichever is later. The procedure for the preparation and filing of claims, and the processing and delivery of payments will be as follows: 1. Claimant(s) will provide all necessary documentation to substantiate eligibility for assistance. 2. Assistance amounts will be determined in accordance with the provisions of the Law. 3. Required claim forms will be prepared by relocation personnel in conjunction with claimant(s). Signed claims and supporting documentation will be submitted by relocation personnel to the Developer. 4. The Developer will review and approve claims for payment or request additional information. 5. The Developer will issue benefit checks which will be available at the Developer s offices for pick-up by OPC, unless circumstances dictate otherwise. 6. Final payments will be issued after confirmation that the Project area premises have been completely vacated, and actual residency at the replacement unit is verified. 7. Receipts of payment will be maintained in the relocation case file.

. EXHIBIT F: Plan Addendum (Public Comments & Response)