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in conformity with FHWA requirements, these assurances relied on "turnover" rates, ignored concurrent displacements, and failed to consider adequately how many of the units in the available housing supply were "decent, safe and sanitary." The court sharply criticized the turnover approach and enjoined displacements pending preparation of a satisfactory relocation program by the state. A New Standard. Questionable relocation practices by state highway departments, and the FHWA's failure to counter them, may well compel other courts to face the question of what constitutes satisfactory highway reloca- tion assurances. A thorough evaluation of the market effects of highway displacement in an urban area would appear to require the following as essential elements of "satisfactory assurances." 1. A determination of the relevant submarkets in the housing market-- rental, sale, neighborhood, racial, and price--and analysis of the inter-relationship between these various submarkets. 2. A determination of vacancy rates for all affected submarkets which takes account of apartment sizes and the adequacy of available units under the decent, safe, and sanitary standard. 3. A determination of expected concurrent displacements, both public and private. 4. An estimate of the average a~ount of relocation payment necessary to enable tenants and owners to obtain comparable decent, safe and sanitary dwellings. These determinations should give a clear indication of the ability of the low-income housing market to respond to the loss of units from the supply. Replacement Housing. When the housing market is tight, relocation assur- ances cannot be "satisfactory" unless they also indicate that new replacement housing will be built on a one-to-one basis for every unit demolished. Under section 206(2) of the URA, provision of replacement housing is authorized as reimbursable project expense, FHWA regulations should require construction of replacement housing when the vacancy rate in the relevant housing submarket is below some previously-established minimum figure which represents the point at which significant inflationary effects can be expected in the relevant submarket. When the vacancy rate is below this minimum figure, the burden should be on state highway departments to demonstrate that replacement housing is not required. Congress clearly felt that the replacement housing provision was critical to the successful operation of the URA. As the House Report accompanying the Act stated: [P]erhaps most important of all, [the URA] gets to the heart of the dislocation problem by providing the means for positive action to increase the available housing supply for displaced low and moderate income families and individuals. III-6