> U. S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
>
> Office of Public and Indian Housing

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Special Attention of: NOTICE PIH 2003-9 (HA)

Regional Directors; Issued: March 27, 2003

HOPE VI Coordinators; Expires: March 31, 2004

Public Housing Directors;

Public Housing Agencies
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Cross References:

Notice PIH 99-19(HA)

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Subject: Demolition/Disposition Processing Requirements Under the 1998
Act

1\. [PURPOSE.]{.underline}

This Notice updates Notice 99-19 to reflect changes to the requirements
for demolition and disposition processing, as well as revisions made to
the associated application form HUD-52860 in 2002. The purpose of the
notice is as follows: (1) to clarify the applicability of Section 18 to
a HOPE VI related demolition; (2) to inform Public Housing Agencies
(PHAs) of the changes to Section 18 of the United States Housing Act of
1937, as amended, by Section 531 of the Quality Housing and Work
Responsibility Act (QHWRA) of 1998, (P.L. 105-276), (3) to provide
guidance on the criteria HUD will use to process demolition/disposition
applications; and (4) to discuss the new certification required under
QHWRA. The Quality Housing and Work Responsibility Act was signed on
October 21, 1998.

2\. [HOPE VI DEMOLITION.]{.underline}

Under Section 535 of QHWRA, where a PHA plans to demolish severely
distressed public housing units pursuant to an *approved* HOPE VI
Revitalization Plan, the demolition is [not]{.underline} required to
meet the provisions of Section 18 of the Act or the corresponding
regulations, 24 CFR Part 970. Therefore, a HOPE VI Grantee with an
*approved* Revitalization Plan after October 21, 1998, (the QHWRA date
of enactment) does [not have to submit]{.underline} a separate
demolition application to the SAC for approval. The Department's
requirements for demolition as a part of an *approved* HOPE VI
revitalization grant are defined in the HOPE VI Notices of Funding
Availability published in the Federal Register.

A HOPE VI Grantee with an *approved* Revitalization Plan is required to
complete Sections 1, 2, 3 - Table 1, Section 4, and 5 of HUD Form 52860,
OMB Approval No. 2577-0075

(exp.3/31/2005). The Department will use this information to enter the
demolition into HUD's data system and to track the date(s) of actual
demolition for purposes of operating subsidy and formula characteristics
for the Capital Fund. [The Department will not use this information to
determine whether a HOPE VI Grantee can demolish the units.]{.underline}
Once the demolition is completed, the HOPE VI Grantee must report the
actual date of demolition to the HUD Field Office or HUB.

Any demolition application related to a HOPE VI Demolition-Only grant
(as opposed to a Revitalization Grant) still requires the submission of
a separate demolition application in accordance with Section 18 of the
Act, for approval by HUD.

Finally, any proposed [disposition]{.underline}[^1] (i.e., land,
dwelling units, or nondwelling facilities) in a HOPE VI *approved*
Revitalization Plan is still subject to Section 18 and the corresponding
regulation. Therefore, if applicable, a HOPE VI grantee must submit a
separate [disposition]{.underline} application, in accordance with
Section 18 of the Act, to the Special Applications Center (SAC) for
approval of any proposed disposition activity.

3\. [INDIAN HOUSING AUTHORITIES.]{.underline}

This Notice does not apply to Indian housing authorities, Indian tribes
or their tribally designated housing entities.

4\. [SUMMARY OF THE CHANGES TO SECTION 18 OF THE ACT.]{.underline}

The significant changes to the demolition and disposition requirements
in the Quality Housing and Work Responsibility Act include the
following:

-   A Public Housing Agency (PHA) must certify that: (a) its demolition
    or disposition application meets the statutory criteria; (b) its
    demolition or disposition is authorized in the **[Public Housing
    Agency Plan]{.underline}** and is consistent with the Agency
    PLAN; (c) its plan for the relocation of residents meets the
    requirements of the statute; (d) its use of net proceeds of sale
    meets the statutory requirements; and (e) it has provided the
    resident offer to purchase in cases of [disposition (no longer
    required for demolition)]{.underline}.

-   Authorizes the Secretary to waive the requirement for the
    application of proceeds for repayment of debt in cases where the PHA
    has debt that has not been or cannot be forgiven (e.g., bonded debt
    and Federal Financing Bank Notes (FFB)). A PHA may request this
    action as part of its demolition or disposition application; \[PHAs
    with debt that is not permanently financed, and which has been
    earmarked for forgiveness, must complete the separate documentation
    required and provide it to the HUD Field Office, if they intend this
    to take place.\]

-   Permanently eliminates the requirement for one-for-one replacement
    of units demolished or disposed of;

-   Eliminates the requirement to offer for sale property proposed for
    *[demolition only]{.underline}* to the resident organization;

-   Requires consultation with the appropriate government officials in
    developing the application;

-   Eliminates the requirement that relocation for demolition or
    disposition in accordance with Section 18 be covered under the
    Uniform Relocation Act (URA)[^2] although other relocation
    provisions apply as outlined in Section 531(a)(4) of the Act and
    detailed in the application submission form, HUD 52860; and

-   Allows a PHA to demolish the lesser of 5 units or 5 percent of its
    inventory, in a five year period, without submitting an application
    to HUD for approval.

    5**.** [PROCESSING PENDING AND NEW APPLICATIONS.]{.underline}

    PHA Agency Plan Requirement - Under Section 531 of QHWRA, which
    amends Section 18(a)(3), in order for a demolition or disposition
    application to be approved after the effective date of the law, a
    PHA must have specifically authorized the demolition or disposition
    in the public housing agency plan, and must have certified that the
    actions contemplated in the public housing agency plan comply with
    this section; Rules governing Public Housing Agency Plans are
    contained in 24 CFR 903. Generally PHAs are required to submit a
    5-Year Plan and an Annual Plan. Annual plans must include a
    description of any public housing development, or portion thereof,
    for which the PHA has applied or will apply for demolition and/or
    disposition approval under section 18, and a timetable for
    demolition and/or disposition. A process exists for the application
    and approval of demolition and/or disposition that is separate, and
    in addition to, that for PHA Agency Plan approval, as set out in 24
    CFR 970.8 and form HUD-52860.

    PHA's must ensure that the Annual Plan is consistent with applicable
    Consolidated Plans. Consolidated Plans include a certification that
    requires the preparation of an Analysis of Impediments (AI) to Fair
    Housing Choice, and the taking of appropriate actions to overcome
    the effects of any impediments identified through the Analysis and
    the maintenance of records reflection the analysis and actions.

    The demolition or disposition application must be submitted to the
    Special Applications Center (SAC) for review and approval. As part
    of the application, a PHA must certify that the proposal is
    consistent with the Agency Plan and any voluntary compliance
    agreements, court orders final judgments, etc.

    > After the certification is received by the SAC, the SAC verifies
    > information including that the environmental review has been
    > completed. An application may not be approved until the
    > environmental review is completed. After the application has been
    > reviewed at the SAC, a letter from the Department stating whether
    > the application has been approved or disapproved is sent to the
    > PHA. The Field Office is also notified of this decision.

    C. Implementation of Four New Provisions -

    The Department has implemented four specific provisions of the
    Quality Housing and Work Responsibility Act for all applications.
    These four new provisions were effective as of October 21, 1998, the
    date of enactment of this Act, as described in the QHWRA Initial
    Guidance Notice in [Federal Register]{.underline}. The four
    provisions are as follows:

-   one-for-one replacement requirement **[is eliminated]{.underline}**;

-   PHAs requesting to demolish the lesser of 5 units or 5 percent of
    the units in the PHA's inventory in a 5-year period, where the
    vacant space will be used for meeting the service or other needs of
    the public housing residents or the unit to be demolished is beyond
    repair, may demolish such units without submitting an application
    and requesting HUD approval;

-   waiver of the requirement for the application of proceeds for
    repayment of debt (modernization or development debt) in cases where
    the PHA has debt that has not been or cannot be forgiven (e.g.,
    bonded or FFB notes funded developments); and

-   elimination of the requirement to make an offer to sell the property
    proposed for demolition to the resident organization where the PHA
    is requesting to *demolish* property.

    6\. [NEW APPLICATION SUBMISSION REQUIREMENTS]{.underline}

    A. Justification for Whole or Partial Demolition or Disposition:

    1\. The Department has dropped the certification form for
    demolition/disposition applications formerly found in Appendix 1 to
    Notice 99-19. The submission of this information has been simplified
    and in part incorporated into the demolition/disposition application
    itself.

    B. Appropriate Local Government Consultation:

-   In addition to consultation with residents of the development,
    resident advisory boards and the PHA-wide resident organization, the
    statute requires consultation with the appropriate local government
    officials.

-   The PHA must submit, with the application, a description of the
    process of consultation with the local government. The issues raised
    by the local government and the PHA's response to the general issues
    should be summarized. The PHA shall include in the application a
    letter signed and dated from the chief executive officer of the unit
    of local government, which demonstrates that the PHA has consulted
    with appropriate local government officials on the proposed
    demolition or disposition. The appropriate local government official
    is the elected official or the legally designated official, who has
    the primary responsibility for the conduct of the entity's
    governmental affairs. Examples of the "chief executive officer of a
    unit of general local government" are: the elected mayor of a
    municipality, the elected county executive of the county; the
    chairperson of a county commission or board in a county that has no
    elected county executive; and the official designated pursuant to
    law by the governing body of a unit of general local government. The
    PHA is not required under the law to have approval of the
    appropriate local government official.

    C. Offer to Sell to the Resident Organization -
    **[Disposition]{.underline}**:

-   In the case of a proposed partial or total disposition of a project,
    the PHA is required under the statute to offer to sell the property
    (i.e., vacant land, community building or dwelling units), in
    appropriate circumstances. The exceptions to the offer of sale, for
    a disposition application, are defined in 24 CFR 970.13(a)(2)(v) and
    (vi). If a PHA has determined that it meets one of the exceptions
    identified in 24 CFR 970.13(a)(2)(v) and (vi), it must provide a
    justification in writing in the application of how it meets the
    exception.

-   A PHA must make the offer of sale to any eligible resident
    organization, resident management corporation at the development or
    a nonprofit organization acting on behalf of the residents of the
    development which has expressed an interest in writing, in a timely
    manner, in purchasing the property for continued use as low-income
    housing. The requirement that the resident organization purchase the
    property for "*continued use as low-income housing*" is a new
    condition of purchase that was added in the QHWRA Act.

-   The requirement for the resident offer [no longer
    applies]{.underline} to PHAs proposing partial or total
    [demolition]{.underline} of PHA property (i.e., a community building
    or housing units). This is a major change from the previous
    regulation.

-   Expression of Interest - The PHA must notify the existing eligible
    resident organization, eligible resident management corporation, or
    nonprofit organization acting on behalf of the residents of its
    intent to dispose of the property in writing and give the resident
    organization 30 days to express its interest in writing of the
    intent to purchase the property for use as low-income housing. The
    30-day period begins on the date of notification by the PHA of the
    proposed sale of the property.

-   Opportunity to Arrange Purchase - If a resident organization or
    other entity as previously identified, expresses a written interest
    in purchasing the property, no disposition (other than to the
    entity) can take place for 60 days beginning on the date of the
    receipt of the written response from the entity.

-   The resident organization has 60 days to develop and submit a
    proposal to the PHA along with a firm financial commitment for
    financing the purchase of the property. For guidance on the content
    of the proposal, see 24 CFR Part 970.13(g), Contents of Proposal.

-   For guidance on the PHA review of the resident organization's
    proposal and notification of acceptance or rejection of the
    proposal, see 24 CFR Part 970.13(e), PHA Review of Proposals.

-   See Appendix 1 for revisions to 970.13 to determine which provisions
    of the regulation about resident organization opportunity to
    purchase continue to be effective.

-   PHAs should note that the statutory basis for 24 CFR 970.13(b) has
    been eliminated. Therefore, where no resident organization exists [a
    PHA is no longer required to give the residents the opportunity to
    organize to form a resident organization]{.underline}.

D.  Uniform Relocation and Real Property Acquisition Policies Act of
    1970 (URA):

The statute eliminates the requirement for compliance with the URA for
demolition or disposition activities under Section 18 of the USH Act.
(N.B., Relocation related to the demolition of severely distressed
public housing pursuant to a Revitalization Plan is still covered under
the URA.) PHAs must comply with certain actions where demolition or
disposition is proposed including: 90-day advance notice of move,
provision of comparable housing which meets the HQS, payment of actual
and reasonable relocation expenses for each resident to be displaced;
provision of any necessary counseling to include Mobility Counseling,
and assurance that the demolition or disposition will not begin until
relocation is completed. Statements that these actions will be taken is
included among the certifications PHA Directors must make in Section 2
on form HUD 52860. Section 8 assistance is available from the Department
to assist in the relocation of residents, depending on funding
availability.

The Department published on September 17, 2002, CPD Notice 02-08,
"Guidance on the Application of the Uniform Relocation Assistance and
Real Property Acquisition Policies Act of 1970 (URA), As Amended, in
HOPE VI Projects." Although the Notice outlines URA requirements and
addresses issues related to only the HOPE VI Program, PHAs may use this
document as a framework for operating its relocation assistance
activities as they apply to this portion of the Act as well. The
principles outlined in this Notice are sound and have been used
successfully for many years.

E. Replacement Units:

The statute eliminates the requirement for one-for-one replacement of
units proposed for demolition or disposition for all applicants.
Replacement for public housing units demolished may be built on the same
site or in the same neighborhood as the original location, without a
site and neighborhood standards review, if the number of replacement
public housing units is significantly fewer than the number of units
demolished.

F.  Deconcentration:

    The PHA must consider its deconcentration policy when preparing its
    Plan for Demolition/Disposition. The PHA must have a relocation plan
    which assures that every displaced tenant receives a full range of
    housing choices and receives adequate counseling (which includes
    counseling that provides tenants their rights under the Fair Housing
    Act and Mobility Counseling) to fully explore these choices. If
    Section 8 tenant-based assistance is to be used, the PHA's efforts
    should be focused on the Section 8 Management Assessment Program
    (SEMAP) Housing Opportunities Factor.

G.  Consolidation of Occupancy:

Nothing in Section 18 may be construed to prevent a PHA from
consolidating the occupancy within or among buildings in a development
or among projects or with other housing in order to improve the living
conditions or to provide more efficient services to the residents.

H. De Minimis Exception for Demolition:

A PHA may demolish units without submitting an application, when it is
proposing to demolish not more than the lesser of 5 dwelling units or 5
percent of the total dwelling units owned by the PHA over a 5-year
period, but only if the space is used for service or other needs of the
public housing residents, or the demolished project or portion thereof
is beyond repair.

A PHA using the De Minimis exception is required to complete Sections 1,
2, 3 - Table 1, Section 4 and 5 of HUD Form 52860. The Department will
use this information to enter the demolition into HUD's data system and
to track the date(s) of actual demolition for purposes of operating
subsidy and formula characteristics for the Capital Fund (CFP) Program.
[The Department will not use this information to determine whether a PHA
can demolish the units.]{.underline} Once the demolition is completed,
the PHA must report the actual date of demolition to the local HUD
office or HUB.

I. 24 CFR Part 970 -

In addition to the new provisions identified in this Notice, the chart
below identifies specific sections of the regulation that remain in
effect until a new regulation is issued. All other provisions of the
regulation are no longer in effect.

+-----------------------------------+-----------------------------------+
| PROVISIONS OF 24 CFR PART 970 IN  |                                   |
| EFFECT                            |                                   |
+-----------------------------------+-----------------------------------+
|                                   |                                   |
+-----------------------------------+-----------------------------------+
| 24 CFR 970.1                      | Purpose                           |
+-----------------------------------+-----------------------------------+
| 24 CFR 970.2                      | Applicability                     |
+-----------------------------------+-----------------------------------+
| 24 CFR 970.3                      | Definitions                       |
+-----------------------------------+-----------------------------------+
| 24 CFR 970.4(a)(c)(e)             | General Requirements for HUD      |
|                                   | Approval                          |
+-----------------------------------+-----------------------------------+
| 24 CFR 970.8(a),b),(c)            | PHA Application for HUD Approval  |
| (e),(g),(k)(l),(m),(n),           |                                   |
|                                   |                                   |
| \(p\)                             |                                   |
+-----------------------------------+-----------------------------------+
| 24 CFR 970.9(a)                   | Method of Sale                    |
+-----------------------------------+-----------------------------------+
| 24 CFR 970.10                     | Costs of Demolition & Relocation  |
+-----------------------------------+-----------------------------------+
| 24 CFR 970.12                     | Required & Permitted Actions      |
|                                   | Prior to Approval                 |
+-----------------------------------+-----------------------------------+
| 24 CFR 970.13                     | Resident Organization Opportunity |
|                                   | to Purchase                       |
| (See Appendix 1)                  |                                   |
+-----------------------------------+-----------------------------------+
| 24 CFR 970.14 (a) and (b)         | Reports & Records                 |
+-----------------------------------+-----------------------------------+

Even though the URA no longer applies to most forms of
Demolition/Disposition, PHAs must offer opportunities to all displaced
persons to relocate to decent, safe, sanitary and affordable housing of
their choice on a nondiscriminatory basis, without regard to race,
color, religion, sex, national origin, disability, familial status or
age. They must also carry out their relocation programs in accordance
with the civil rights certifications found on page 2 of Form HUD-52680,
Demolition/Disposition Application, i.e., compliance with Title VI of
the Civil Rights Act of 1964, the Fair Housing Act, Section 504 of the
Rehabilitation Act of 1973, the Americans with Disabilities Act of 1990,
and affirmatively furthering fair housing.

> J. Note: Section 970.4(c) does not yet reflect the applicability of
> environmental procedures under 24 CFR Part 58. However, Part 58 does
> apply to Part 970 and is the primary environmental procedure to be
> followed despite its omission from §970.4(c).

National Environmental Policy Act (NEPA) and Related Federal Laws and
Authorities:

Activities under part 970 are subject to HUD environmental regulations
in 24 CFR part 58 "Environmental Review Procedures for Entities Assuming
HUD Environmental Review Responsibilities". However, HUD may make a
finding in accordance with § 58.11(d) and may itself perform the
environmental review under the provisions of 24 CFR part 50 Protection
and Enhancement of Environmental Quality, if a PHA objects in writing to
the responsible entity performing the review under part 58.

The PHA, its project partners and their contractors may not dispose of
or demolish public housing under this Notice, or commit or expend HUD or
local funds for such activities, until the responsible entity (as
defined in § 58.2) has completed the environmental review procedures
required by part 58 and the environmental certification and RROF have
been approved or HUD has performed an environmental review under part 50
and has notified the PHA in writing of environmental approval of the
property. HUD will not release grant funds if the recipient or any other
party commits grant funds (i.e., incurs any costs or expenditures to be
paid or reimbursed with such funds) before the recipient submits and HUD
approves its RROF (where such submission is required).

Irrespective of whether the responsible entity in accord with part 58
(or HUD in accord with part 50) performs the environmental review, the
PHA shall supply all available, relevant information necessary for the
responsible entity (or HUD, if applicable) to perform for each property
any environmental review required by this part. The PHA also shall carry
out mitigating measures required by the responsible entity (or HUD, if
applicable) or select alternate eligible property.

The proposed demolition or disposition of four or less dwelling units is
categorically excluded from the environmental assessment required under
the National Environmental Policy Act, but subject to the applicable
related Federal laws and authorities cited in §§ 58.5, 58.6 and 50.4.

Where demolition is made necessary by disasters, expedited procedures
are allowed under § 58.33 and 40 CFR 1506.11.

PHA's are to integrate the NEPA process with other planning at the
earliest possible time to insure that planning and decisions reflect
environmental values, to avoid delays, and to head off potential
conflicts (40 CFR 1501.2).

7.  [HUD APPROVAL/DISAPPROVAL OF APPLICATIONS]{.underline}.

The Assistant Secretary for Public and Indian Housing shall disapprove
of a demolition or disposition application if it is determined that any
of the following conditions are present:

A.  any certification made by the PHA is clearly inconsistent with
    either information and data available to the Assistant Secretary or
    information requested by the Assistant Secretary; or

B.  the application was not developed in consultation with-

> 1\. residents of the development to be affected by the proposed
> demolition or disposition; and

2\. each resident advisory board and resident council, if any, of the
development to be affected by the proposed demolition or disposition;

3\. the appropriate local government officials.

8.  [DEMOLITION/DISPOSITION APPLICATION CHECKLIST]{.underline}.

  ------------------------------ ----------------------------- -----------
  Information Required           Brief Description             Submitted

  Form HUD 52860 - (OMB Number   Complete applicable sections  
  2577-0075)                     of the Form and submit all    
                                 attachments. See paragraph    
                                 6.A.2. Available on the HUD   
                                 Web.                          

  Local Government               Description, Letter from the  
  Consultation - §18(b)          Chief Executive Officer       

  Documentation of Offer to Sell                               
  to Resident Organization-                                    
  Disposition Only - §18(c)                                    

  De Minimis Exception - §18(f)  Form HUD 52860 Section 1-5    
                                 Only                          

  Field Office Certification     FO prepares and sends to SAC. 
  (See Appendix 2)               Revised form is attached.     

  Environmental Review - Part 50 Prepared by FO or the         
  or Part 58                     Designated Responsible Entity 
                                 (i.e., City, County, or       
                                 State) and sent to the SAC    

  Annual Agency Plan for         Not a part of the demolition  
  Demolition/Disposition         or disposition application.   
                                 Must be submitted to the FO   
                                 and approved for any          
                                 demolition or disposition     
                                 application to be approved by 
                                 the SAC.                      

  Relocation Plan                Including Certification to    
                                 Nondiscrimination and         
                                 Affirmatively Furthering Fair 
                                 Housing                       
  ------------------------------ ----------------------------- -----------

Completion of the FO certification form (new Appendix 2) has been a HUD
requirement for several years. The form allows the local HUD Office to
formally state whether it concurs that the conditions described in the
application are present and that demolition or disposition is the most
logical solution. The form has been revised to indicate that the FO has
approved the Public Housing Agency Plan.

The Department may waive the requirement for net proceeds from
disposition to be used to repay outstanding debt if the PHA intends to
use the proceeds for one of the purposes allowed by the Statute:

A.  for the provision of low-income housing or to benefit the residents
    of the PHA; or

B.  for leveraging amounts for securing commercial enterprises, on-site
    in the PHA, appropriate to serve the needs of the residents.

A PHA that intends to use disposition proceeds for these purposes and
wishes to request a waiver of the requirement to repay project debt
should check the box provided on form HUD-52860 under Section 5, item
12A.

10. [SUBMISSION AND REVIEW OF DEMOLITION/DISPOSITION
    APPLICATIONS]{.underline}.

The SAC is responsible for reviewing and approving demolition and
disposition applications. Any recommendations for disapproval of
applications are referred for decision to the Assistant Secretary for
Public and Indian Housing. Application review is done in coordination
with the local HUD Field Office and with its concurrence. The SAC also
coordinates, as necessary, with the Office of Litigation, the Office of
Fair Housing and Equal Opportunity, as well as other Centers such as,
the Troubled Agency Recovery Center (TARC). A PHA may call the SAC for
technical assistance in preparing its application. The Director of the
SAC is Ainars Rodins. The telephone number is (312)-886-9754, ext. 2816.

Demolition/Disposition applications are to be submitted to the SAC and a
copy provided to the local HUD Office. Demolition/Disposition
applications are to be submitted on the Form HUD 52860. The form is
available on the SAC website as noted below.

The Demolition/Disposition module for the PIH Information Center (PIC),
will be enabled soon. The capability will exist for PHAs to submit
electronically in PIC, applications for the removal of federal low-rent
public housing units. This will allow for a streamlined process, in
which the information required will be tailored for the category of the
request. Electronic submission requirements in PIC will help ensure that
PHAs are aware of the information needed to make their application
complete. This should shorten the time needed for the review of
applications. More information will be available on the PIC web site at:

<http://www.hud.gov/offices/pih/systems/pic/index.cfm>

The address of the SAC is:

The Office of Public Housing

Special Applications Center (SAC)

77 West Jackson Boulevard

Room 2401

Chicago, IL 60604-6413

The SAC web site address is:
[**http://www.hud.gov/offices/pih/centers/sac/**](http://www.hud.gov/offices/pih/centers/sac/)

/s/

> Michael Liu, Assistant Secretary

for Public and Indian Housing

Attachments (2)

[^1]: Any long term lease of more than one year is considered a
    disposition in accordance with 24 CFR Part 970.2 of the regulations.
    In the past, a large number of PHAs involved in HOPE VI
    revitalization and mixed finance transactions did not understand
    that they may be required to submit a separate disposition
    application in addition to the HOPE VI or mixed finance application.

[^2]: Demolition of severely distressed public housing units and the
    acquisition of replacement housing performed pursuant to an approved
    HOPE VI revitalization plan continues to be covered by the URA.