Relocation layers: state schedules, the federal URA, and coastal replacement

Relocation is priced at three layers. The state layer (AB 1482 no-fault relocation, Housing Crisis Act packages, Ellis Act schedules) and the local layer (city relocation ordinances that can run to tens of thousands per household) apply based on the tenancy and the ordinance. The federal layer — the Uniform Relocation Act, 42 U.S.C. ch. 61, implemented government-wide at 49 C.F.R. Part 24 — attaches whenever federal financial assistance touches the project, and its benefits usually dwarf the state floor.

A separate coastal layer, the Mello Act (Gov. Code §§ 65590–65590.1, archived with the Housing Element chapter), adds replacement duties for low- and moderate-income housing demolished or converted in the coastal zone.

The trigger is money, not permits: HOME or HTF in the capital stack, CDBG-funded acquisition or predevelopment, project-based rental assistance tied to rehab — any of these makes displaced tenants "displaced persons" under the URA (with HUD's program overlay at 24 C.F.R. Part 92 for HOME).

• Core benefits to model:
• General-information and 90-day notices on a defined sequence — a notice defect converts voluntary moves into compensable displacement.
• Actual reasonable moving expenses.
• Rental-assistance payments covering the rent differential to comparable replacement housing — up to 42 months (and "housing of last resort" beyond statutory caps where comparables are short).
• Advisory services and comparable-unit referrals before displacement.

• Underwriting watch-outs:
• URA planning starts at the application for federal funds — moves "in anticipation" of the project can be compensable; do not clear the building before the funding decision without URA counsel.
• HOME/CDBG carry one-for-one replacement rules for demolished lower-income units on top of relocation.
• Budget line: on occupied buildings, URA relocation routinely exceeds the state/local schedule several-fold; grants administrators will require a relocation plan and budget upfront.

The layers do not stack payments — the tenant is made whole once — but compliance obligations stack: notices under each applicable regime, the richest benefit schedule as the operative one. A federally assisted project in Los Angeles runs URA notices and benefits and RSO procedures; an unassisted teardown in the same city runs the HCA package plus RSO relocation.

• Practical sequencing:
• Decide early whether federal soft money is worth its relocation and replacement tail on an occupied site — sometimes conventional debt on a lighter displacement budget nets better.
• Local ordinances often key payments to tenure, age, disability and income — get a unit-by-unit census before the LOI, not after.
• Keep one relocation consultant across regimes; conflicting notices are the classic source of claims.

In the coastal zone, Gov. Code § 65590 requires that conversion or demolition of dwellings occupied by low- or moderate-income households be replaced (on site or nearby, within specified distance) where feasible, and imposes affordable-unit duties on some new coastal residential development. It operates through local implementation — several coastal cities run formal Mello ordinances — and sits alongside Coastal Act development-permit review (see the environmental topic).

• Underwriting watch-outs:
• Mello replacement applies even to condo conversions with no demolition — coastal conversion deals need the analysis.
• The coastal overlay is parcel-specific: confirm zone boundaries before assuming the layer applies (or doesn't).