Have you Considered RAD?
HUD strongly encourages PHAs contemplating demolition/disposition applications for their public housing units to consider HUD’s Rental Assistance Demonstration (RAD) program. RAD offers various advantages to residents and PHAs over Section 18 such as resident protections, extensive waivers of statutes and regulations to enable long-term preservation (e.g. ability to retain reserves at the project). Accordingly, prior to submitting a demolition or disposition application, HUD strongly encourages PHAs to complete the RAD Inventory Assessment Tool to make a first-level assessment (as potential RAD candidates) of all units they are considering for demolition or disposition. HUD staff (at the SAC and the RAD team) are available to assist PHAs in completing this assessment tool. In addition, in accordance with PIH Notice 2018-04, PHAs are able to blend RAD with disposition if certain conditions are met. HUD staff are available to provide PHAs with technical assistance on the best HUD tool for repositioning their particular housing units. PHAs should contact firstname.lastname@example.org to request such technical assistance. See also RAD Conversion Guide for PHAs.
Already have an approved CHAP under RAD? Instructions for submitting a removal application via IMS/PIC are available here. Read the explanation of property in RAD PIC application (MS-Word).
What We Do
The Special Applications Center (SAC) enables the Office of Public and Indian Housing to assist Housing Authorities in their efforts to efficiently and effectively meet the housing needs of their communities through the specialized review and approval of non-funded, non-competitive applications, related to:
- Demolition/Disposition - removal of public housing units from the public housing stock by razing, sale or lease (in whole or part).
- De Minimis Demolition - demolition of not more than the lesser of 5 dwelling units or 5 percent of a PHA’s total public housing dwelling units in a 5-year period (no HUD approval required).
- Eminent Domain - the taking of public housing property for a public use.
- Homeownership - sale of public housing units to public housing residents or public housing eligible residents.
- Conversion - the conversion of a development to tenant-based assistance.
- Retentions - the ability of PHAs to retain certain public housing property free from public housing use restrictions in accordance with the requirements of 2 CFR part 200.
Helpful Tools and Resources
- PIH Notice 2019-13: Public Housing ACC Termination and PHA closeout - This notice provides information and guidance regarding program activities that PHAs must complete when they submit a demolition and/or disposition application (or other removal application) that proposes to remove the last of their public housing dwelling units.
- PIH Notice 2017-24 - Guidance on Third-Party Agreements Encumbering Public Housing Property.
- Public Housing Property Damaged or Destroyed by Casualty Loss of Natural Disaster
- PIH Notice 2016-22: Environmental Review Requirements for PHAs - This notice provides information and guidance regarding PHAs’ compliance with the National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321) and other related laws and authorities. This notice clarifies the applicability of environmental reviews under 24 CFR parts 50 and 58 to all PHA activities at project site(s) assisted or to be assisted by HUD and to the use of all HUD funds. This notice includes information about the environmental review requirements applicable to proposed demolitions and/or disposition applications (and other removal applications).
- Impact on Operating Funds & Asset Repositioning Fee: Units and other property removed from the PHA’s public housing stock are no longer eligible to receive Operating Funds assistance, but the PHA may be eligible to receive an asset-repositioning fee pursuant to 24 CFR 990.190. See Notice PIH 2017-22.
- PHAs should note the Implications of "Days to Relocation" in SAC Application on Operating Fund
- Impact on Capital Funds and Demolition Transitional Funding (DDTF): Units and other property removed from the PHA’s public housing stock are no longer eligible to receive standard Capital Funds assistance, but the PHA may be eligible to receive DDTF pursuant to 24 CFR § 905.326(j). DDTF funds are Capital Fund Grants that are awarded to PHAs that have removed units from their public housing inventories.
- Tenant-Protection Vouchers: PHAs may be eligible to receive Section 8 housing choice vouchers (known as TPVs) for certain (occupied) units that have been approved by HUD for removal (e.g. disposition, demolition, homeownership, conversion) in accordance with PIH Notice 2018-09.
- Declaration of Trust (DOT) and Annual Contributions Contract (ACC) requirements: HUD requires that all public housing property have a current Declaration of Trust (DOT) of record and requires all public housing property to be under an Annual Contributions Contact (ACC) with HUD. PIH Notice 2011-61 indefinitely extended PIH Notice 2010-44 provides detailed guidance to PHAs and HUD Field Offices of Public Housing and Field Counsel on DOTs and adding and removing units from the ACC (and PIC) based on HUD approvals. See also Terminating Developments under IMS/PIC Inventory Removals on this page.
IMS/PIC Inventory Removals