4 Clearinghouse Rev. 515 (1970-1971)
Issue 11

handle is hein.journals/clear4 and id is 517 raw text is: NATIONAL CLEARINGHOUSE for LEGAL SERVICES

March 1971

The Legal Lawbreakers-A Study of the Non-
Administration of Federal Relocation Require-
ments
by Edgar S. Calm, Timothy Eichenberg, and Roberta V.
Romberg, Citizens Advocate Center, Washington, D.C.
[Editor's Note: This article is the major portion of a study
undertaken by the Citizens Advocate Center. The entire
study also includes appendices containing additional regula-
tory authority, further analysis of case law, HUD relocation
forms and a HUD press release. The article with appendices,
is available from the Citizens Advocate Center, 1211
Connecticut Avenue, N.W., Washington, D.C. 20036 at a
cost of $1.00.]
I.    The Lawless Implementation of Federal Relocation
Requirements
Federal funds for renewal and related construction
programs are given in reliance on assurances by a locality's
local public agency (hereinafter LPA) that persons dis-
placed by such projects will be relocated into decent, safe
and sanitary housing and that such housing is, or will be,
available when relocation occurs. The LPA enters into a
contract to construct a federall sponsored program and
therefore becomes bound to observe the conditions of the
contract regarding relocation, laid out in agency regulations
and federal statutes. Relative to the total costs of these
programs, relocating displacees into standard housing repre-
sents a minor financial burden for the LPA. (2.7% of total
costs according to one study.)'
Unfortunately, these assurances have not proven
sufficient to guarantee decent housing for displaced resi-
dents. LPA representations are often false or exaggerated
and federal officials are delinquent in checking out relo-
cation reports submitted to them. In addition insufficient
provisions are made to accommodate the increased housing
demands caused by displacees even though federal law
requires that assurances of the availability of decent
housing prior to displacement be given to the federal
government. The following represent some common prac-
tices that obstruct the legal requirements for adequate
relocation.
LPA records and statistics consistently overstate the
number of units available for relocation. Federal officials
1.    Statement by the Commissioner of Public Works for the City
of Chicago, illinois, Hearings on H.R. 14898 and S. I Before the
House Public Works Committee, 91st Cong., 1st and 2d Sess. at 251
(1970). [Hereinafter cited as Hearings on H.R. 14898 and S. 1.1

fail to check such submissions and, unless there is vigorous
and powerful opposition, certify the project despite such
misrepresentations.
The General Accounting Office (GAO) has uncovered
discrepancies between LPA office records and those sent to
HUD's regional offices. One LPA reported that only ten
families had been relocated into substandard housing, while
their office records showed that 29 families were living in
substandard dwellings.2 In St. Louis, 23 of 24 randomly
selected families from one project and 25 of 35 from
another were found to be living in substandard housing
although LPA reports indicated that all were relocated into
standard dwellings.3 In Camden, New Jersey, of the 22
displacees checked, 12 were found relocated into sub-
standard units while three no longer lived at the addresses
noted in the records.4
LPA submissions are noticeably silent regarding those
statistics revealing obstacles or indicating that relocation
housing in fact does not exist. Submissions contain only
statistics which support the feasibility of relocation. In
Poughkeepsie, New York, the urban renewal agency devel-
oped a relocation plan relying primarily on the existing
housing supply although the vacancy rate for low-income
housing was below three percent and for large family units
was below one percent. The Chairman of the Model Cities
Housing Committee, Clarence Johnson, found that 1,500
families and individuals had been inconsistently reported.
2.    Comp. Gen. Rep. B-118754 at 7 (1964), Inadequate Relo-
cation Assistance to Families Displaced by Certain Urban Renewal
Projects in Kansas and Missouri Administered by Fort Worth
Regional Office.
3.   Id. at 5.
4.    HUD, Task Force Preliminary Report on Camden, New
Jersey at 11 (July 1968, not released).
SPECIAL FEATURE IN THIS ISSUE
This issue of the Review contains an analysis of
Truth-in-Lending Regulation Z in convenient outline
form followed by a compilation of selected materials,
most of which are available from the Clearinghouse to
supplement the outline. This feature is intended to
serve as a permanent reference source for attorneys
with Truth-in-Lending problems. The analysis of
Regulation Z begins on page 525.

Vol. 4, No. I11

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