090704 Jt PH Adotpion Amend Merger SA Redvlp Proj Areas EXHIBIT 2

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VI. METHOD OR PLAN FOR RELOCATION Section 33352(f) of the CRL requires that the Agency's Report to the City Council contain a "Method or Plan" for "the relocation of families and persons to be temporarily or permanently displaced from housing facilities in the project area, which ... shall include the provision required by Section 33411.1." Additionally, Section 33411 of the CRL requires the Agency prepare a feasible "method or plan" for relocation of non - profit local community institutions to be `s temporarily or permanently displaced from facilities actually used for institutional purposes in the Project Areas. N Section 33411.1 requires the legislative body to insure that "...such method or plan of the Agency ... shall provide that no persons or families of low and moderate income shall be displaced unless and until there is a suitable housing unit available and ready for occupancy by such displaced person or family at rents comparable to those at the time of their displacement. Such housing units shall be suitable to the needs of such displaced persons or families and must be decent, safe, sanitary, and otherwise standard dwelling. The Agency shall not displace such person or family until such housing units are available and ready for occupancy." The Reports to the City Council initially prepared at the time of adoption of the Project Areas were required to contain a Method or Plan for Relocation for each of the Project Areas. This Plan or Method of Relocation restates the Agency's Plan or Method of Relocation for the proposed Merged Project Area. However, this Method or Plan for relocation is not intended to be a "Relocation Plan" within the meaning of Section 6038 of the "Relocation Assistance and Real Property Acquisition Guidelines" promulgated by the California Department of Housing and Community Development (California Code of Regulations, Division 1 of Title 25, commonly called the "State Guidelines "). As described below, a Section 6038 Relocation Plan is not prepared until the Agency initiates negotiations for the acquisition of real property and prior to proceeding with any phase of a public improvement or facility project or other implementation activity that would result in any displacement other than an insignificant amount of non- residential displacement. A. AGENCY DISPLACEMENT As noted in the Report, the Agency anticipates that its programs of land assembly and upgrading and installation of public improvements and facilities needed within the proposed Merged Project Area will provide an incentive for existing owners and the private sector to develop or redevelop vacant, underutilized and blighted properties and to achieve the goals and objectives for the redevelopment of the proposed Merged Project Area. To the extent that the Agency, directly or through agreements with owners, developers or others, cause occupants to be displaced, the Agency will be responsible for providing relocation benefits. The Agency is not responsible for any displacement that may occur as a result of private development activities not directly assisted by the Agency under a disposition and development agreement, participation agreement, or other similar agreement. Report to the City Council for the Merger of the Page 44 of 190 Keyser Marston Associates, Inc. Santa Ana Redevelopment Projects Page 33 PA0403012.8NTA:CK:gbd 19090.003,004106128/04 n5 is