. 4.est-?0 6:6 9(4) US. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT WASHINGTON, DC 20410-7000 ?muse ?9 OFFICE or THE ASSISTANT SECRETARY roa EC 5 COMMUNITY PLANNING AND DEVELOPMENT MEMORANDUM FOR: The Deputy Secretary FROM: Harriet Tregoning, Principal Deputy Assistant Secretary for Community Planning and Development, SUBJECT: Signature and Agreement to Participation in Interagency Efforts to Manage Retreat and Support Community?Led Relocation Away from Vulnerable Areas This memo is to request your signature on a new interagency Memorandum of Understanding (MOU) which will commit Federal agencies to work together to collaborate to support communities? migration away from vulnerable areas, particularly those threatened by recurring natural disasters and the cumulative effects of severe environmental changes. This MOU commits career staff at 1.1 agencies, including HUD, to participate in a working group to develop resources and strategies to better support communities that voluntarily seek to retreat in whole from vulnerable areas. The working group intends to develop a framework for managed retreat that identifies the Federal role in a community?led process to address current and future needs. In addition, the group will serve as an information~shariug forum for lessons learned by communities in Alaska, Washington, and Louisiana currently pursuing these risk reduction strategies, and identify obstacles and solutions within the Federal Government to communityded managed retreat or voluntary relocation. Finally, the group will, as appropriate, coordinate with communities currently considering relocation or managed retreat, and relevant State, local, and tribal governments, nongovernmental entities, and the private sector, to plan for and implement strategies for communitywled managed retreat and relocation. The working group will support and complement efforts of the Denali Commission, a Federal entity working directly with communities on relocation in the Arctic region, and will report progress annually to the Council on Climate Preparedness and Resilience. BACKGROUND: As more communities consider managed retreat and relocation as options of last resort to protect human life and avoid future property damage associated with the risks of extreme environmental changes (such as melting permafrost, land subsidence, and sea level rise) and recurrent natural disasters (such as flooding), there is a critical need to better define the Federal role in these efforts and to coordinate Federal assistance for managed retreat and relocation at the national level. The need for improved Federal coordination to support relocation was one of several recommendations in the 2014 Recommendations of the State, Local, and Tribal Leaders Task Force on Climate Preparedness and Resilience. That recommendation reinforced and expanded the focus of a 2009 GAO (US. Government Accountability Office) report that cited the lack of a Federal framework as an impediment to 3i villages in Alaska that face imminent threats associated with climate change. Four of the most threatened villages named in that report (Newtok, Kivalina, Shaktoolik, and Shishmaret) are currently in the process of relocating, and HUD staff from the Office of Native American Programs (ONAP), Community Planning and Development (CPD), and Field Policy Management (FPM) in Anchorage are playing an active role in these efforts. These staff members have identi?ed several recurring challenges emerging in that process that require an improved interagency response, including how to fund and authorize new infrastructure investments in a ?pioneering? context when the settlement is not yet in place); how to resolve complicated and duplicative environmental review processes across agencies; and how to maintain enough Federal investments to ensure safe and healthy communities once a decision has been reached to relocate. HUD is also supporting whole~community relocation in Louisiana, where the State is investing 55 percent of its $87 million award to relocate the Isle de Jean Charles community in whole from its current location (an offshore barrier island that has undergone 98 percent land loss since 1950) to a more secure, inland site. HUD expects this National Disaster Resilience Competition (.NDRC) grant will serve as a national model for relocation, and one that would inform involvement in this working group. RECOMMENDATION Given that the issue of relocation has implications for the work of HUD, and that the efforts of the group have the potential to resolve challenges HUD staff currently face with other agencies on the subject, we recommend that HUD Sign the MOU and agree to serve as vicemchair of the interagency group. CONTACT: For further information, contact Danielle Arigoni, Acting Director, Office of Economic Development, 202-402?3097 or Danielle.m.ariaoni@hud.nov. Attachment DECISION: W?m 1/3/2017, Approve Disapprove Date MEMORANDUM OF UNDERSTANDING TO FORM AN INTERAGEN CY WORKING GROUP ON COMMUNITY-LED MANAGED RETREAT AND VOLUNTARY RELOCATION I. PARTIES This Memorandum of Understanding (MOU) is entered into by the following Federal agencies and Departments: Defense Homeland Security (DHS), Agriculture (USDA), Energy (DOE), Health and Human Services (HHS), Interior (DOI), Army Corps of Engineers Civil Works (U SAGE), Housing and Urban Development (HUD), Commerce (DOC), Transportation (DOT), and Environmental Protection Agency (EPA) (collectively, the Partner Agencies). This MOU describes the principles of cooperation and roles and responsibilities of the Partner Agencies. II. PURPOSE The purpose of this MOU is to establish an interagency working group (Working Group) on community-led managed retreat and voluntary relocation. Community?led managed retreat and voluntary relocation are proactive hazard risk reduction strategies for communities threatened by repeated natural disasters or similar environmental risks to public health and safety, where all or part of a community chooses to move to a safer location using a participatory, whole~community approach. A wholewcornrnunity approach is scalable and not tied to jurisdictions; rather it describes a process by which residents, organizational and cornrnunity leaders, Federal, State, local and tribal government officials, and the private and nonprofit sectors collectively work to assess the needs of their respective communities and collaborate to organize and strengthen their assets, capacities, and interests.1 For the purposes of this Working Group, managed retreat describes a process by which at?risk infrastructure and homes are shifted away from the processes or events that threaten theme This may include individual households or entire neighborhoods and some infrastructure? Voluntary relocation is a form of managed retreat that may be when an entire community is threatened with repeated disasters or inevitable impacts due to changes in their surrounding 1 Adapted?am FEMA, A Wotan COMMUNITY APPROACH TO Manaoesrertr: Pamcwres, THEMES, AND Parrovavs FOR ACTION (201 1) amt/awe at lm2m.pdf, 2 See Catais?romraa Tuaeor'r ANDREW STEWART LTD, ENVIRONMENT Warmro, Memos}; RETREAT FROM COASTAL Hazaapsz OPTIONS FOR IMPLEMENTATION (2006) mini/able at http: /PageFiles 5405 environment, including most or all of that community?s critical infrastructure,3 leading to a complete abandonment of that community for a new site or as part of an existing locality. This MOU describes voluntary relocation separately because of the coordination and resource challenges associated with moving an entire community and abandoning the original site. The Working Group?s efforts will support communities considering managed retreat and voluntary relocation as hazard mitigation strategies, recognizing that these activities tend to be technically, socially, and legally complex and require partnerships on a caseeby?case basis with non?Federal entities, including but not limited to State, tribal, and local governments, the private sector, and nongovernmental organizations. This MOU recognizes that the Federal Government will not be the sole provider of resources and services to communities considering managed retreat or voluntary relocation, and will need to work with other entities in support of community efforts to plan for and implement managed retreat and voluntary relocation efforts. To this end, as described in the Working Group Priority Goals (Section VI below), the Partner Agencies should work toward developing a framework for collaboration with noneFederal entities that will help define the Federal role in support of communities undertaking these adaptation strategies. In addition, the MOU highlights the unique Federal trust responsibility and government-togovernment relationships with federally recognized lndian tribes. This MOU recognizes'the emerging nature of the issues associated with community?led managed retreat and relocation. It does not attempt to resolve policy positions or approaches, but, rather, establishes a forum for communication and coordination between agencies on this emerging topic. As outlined in the Working Group Priority Goals (Section VI, below), the Working Group?s efforts may lead to the development of new policy positions or approaches, but this MOU does not in itself guarantee such an outcome or make binding commitments of agency resources. AUTHORITIES General authorities for entry into this MOU include: 1. Executive Memorandum of April 29, 1.994, on Government?to?Government Relations with Native American Tribal Governments. 3 The USA Patriot Act of 2001 defines ?critical infrastructure? as systems and assets, whether physical or virtual, so vital to the United States that the incapacity or destruction of such systems and assets would have a debilitating impact on security, national economic security, national public health or safety, or any combination of those matters. USA Patriot Act 2001, Pub. L. No. 108?56, 2.73:: wrramwmw g?a??i?l '1 if a slime ?newwcm?rnr on - tr MEMORANDUM OF UNDERSTANDING TO FORM AN WORKING GROUP ON MANAGED RETREAT AND VOLUNTARY RELOCATION .2. Executive Order l3l75, 65 ed. Reg. 67249 (Nov. 9, 2000), Consultation and Coordination with Indian Tribal Governments. 3. Executive Order 13653, 78 Fed. Reg. 66817 (Nov. 1, 2013), Preparing the United States for the Impacts of Climate Change. 4. Respective authorities of the Partner Agencies that enter this MOU in support of their agency missions. Each Partner Agency shall engage in any activity under this MOU only to the extent it is within its authorities, and subject to the availability of funds and resources. Additional agency authorities include, but are not limited to: a. D01: i. Bureau of lndian Affairs: he Snyder Act of November 2, 1921: 25 U.S.C. 13. ii. Of?ce of Insular Affairs: 96 Stat. 818?840, Pub. L. No. 97?257. b. HHS: . i. Section 281 ofthe Public Health Service Act, 42 U.S.C. 300hh?1 1. c. DHS: i. Robert T. Stafford Disaster Relief and Emergency Assistance Act, Pub. L. No. 100-707, signed into law November 23, 1988; amended the Disaster Relief Act of 1974, Pub. L. No. 93-288. ii. The National Flood Insurance Act of 1968, as amended, and The Flood Disaster Protection Act of 1.973, as amended, 42 U.S.C. 4001 et. seq. Presidential Policy Directive 8, establishing the National Response Framework, National Mitigation. Framework, and National Preparedness Framework. d. DOT: i. 49 e. 1301): l. The Sikes Act Improvement Act, as amended, 16 U.S.C. 670a~670o ii. Agreements to Limit Encroachments and Other Constraints on Military Training, Testing, and Operations: 10 U.S.C. 2684a. The Economy Act, 31 U.S.C. l535 and l536. is. Robert T. Stafford Disaster Relief and Emergency Assistance Act, Public Law 93-288, as amended, 42 U.S.C. 512i et seq. f. HUD: i. 12 U.S.C. 1701c, 12 U.S.C. 17012?1, and 12 U.S.C. and IV. BACKGROUND The 2014 Recommendations ot?the State, Local, and Tribal Leaders Task Force on Climate Preparedness and Resilience called for the Federal Government to explore its tole in assisting MEMORANDUM OF UNDERSTANDING TO FORM AN WORKING GROUP ON COMMUNITY-LED MANAGED RETREAT AND VOLUNTARY RELOCATION communities threatened by repeated natural disasters or other foreseeable risks, including but not limited to: coastal erosion, permafrost thaw, increased incidents of nuisance ?ooding, and greater storm surges.4 This recommendation came at a time when several communities throughout the United States, mostly tribal, were considering or had decided that managed retreat or voluntary relocation were the only viable long-term options to protect community residents? health and safety. The lack of a Federal framework to assist communities threatened by natural hazards has been cited as an impediment to relocation in both a 2009 GAO report on Alaskan communities5 and the 2014 National Climate Assessrnent.6 As more communities consider managed retreat and relocation as options of last resort to protect human life and avoid future property damage, there is a critical need to better define the Federal role in these efforts and to coordinate Federal assistance for managed retreat and relocation at the national level. In the last few decades, the United States has seen an increased frequency and intensity of certain extremoweather events and an increasing number of communities affeCted by subsidence, coastal erosion, and king tides. In low-lying areas, this has caused numerous threats to public safety, including saltwater intrusion on drinking water supplies, inundation of low~lying areas, and new areas at risk of nuisance ?ooding and storm surges, among other impacts. These changes have also resulted in significant economic losses; since 1980, the freQuency of billion? dollar disasters7 has increased, on average, 5 percent per year.8 Between 2006 and 20l6, the 4 STATE, Loon, Talent, Lnaonns Tasr: FORCE ON (Etta-Lire Pneranaoans AND RESILIENCE: RECOMMENDATIONS To THE PRESIDENT 30 (2014) a: sites default/ ?les docs task_force_report_0.pdf. 5 US. Gov. Accountability Of?ce, Alarka Nam Vii/agar: harried Progress Her Bear: [Made on Relocating Vil/ngrr Threatened by Weeding and Erotica (2009) http: .pdf. ?3 US. GLOBAL CHANGE RESEARCH PROGRAM, Indigo-10m Prop/er, Lands, am! Karol/frat, Nartouar Cursors AssassatENT: CHANGE IN THE UNITED STATES (2014) of http: ncaZOl 4. globalchangegov rep ort sectors /indigenous?peoples. 7 Billion?dollar disaster numbers account for in?ation adjusted using the Consumer Price index and include direct loss estimates from numerous weather disasters including tropical cyclones, ?oods, droughts heat waves, severe local storms, wild?res, crop freeze events and winter storms. Insured and uninsured direct losses include: physical damage to residential, commercial and government/ municipal buildings, material assets within a building, time element losses time? cost for businesses and hotel~costs for loss of living quarters), vehicles, public and private infrastrucmre, and agricultural assets. it does not take into account losses to natural capital or assets, healthcare related losses, or values associated with the loss of life. 8 Smith Katz, U5 wear/Jar and d?rarl?err: data ran/rear, treadr, artsy/rig], and Mara, NATURAL HAZARDS June 2013, at 67, pp. 387?410. Ami/able or monitoring?content billions docs sirntli-?aiid?katszOl 3 .pdf. MANAGED RETREAT AND VOLUNTARY RELOCATION Federal Government has expended $357 billion in response to extreme weather and wildfire events alone.g Disaster losses are costly and are likely to become more so, as socioeconomic changes drive more wealth and infrastructure development in coastal communities. For example, estimates of average annual losses due to flooding and storm impacts by the year 2050 exceed $100 million each in New York, New Orleans, and Miami.? Developing proactive policies to assist with managed retreat and relocation not only protects human health and safety, but also helps prevent costly economic losses that can devastate neighborhoods and communities. Throughout the United States, the type and magnitude of risks communities face is changing. An increasing number of communities and neighborhoods will face the decision of Whether they can protect in place or must consider managed retreat or relocation. Community-led managed retreat and voluntary relocation use a Whole?commitnity1i approach to achieve goals, including building resilient physical infrastructure, providing economic and educational opportunities, maintaining social cohesion, and promoting human well-being. In Alaska, the Denali Commission is already working to coordinate Federal, State, and Tribal resources to assist rural communities in developing solutions to decrease risks from natural disasters, including relocating entire communities where no other protect~in-place option is financially viable. However, there is no agency with such a mandate for the rest of the states and Insular Areas of the United States. As communities beyond Alaska are faced with considering voluntary relocation or other managed retreat efforts, there is an urgent need for broader Federal agency coordination and collaboration with other levels of government and nongovernmental entities to increase efficiency and reduce the costs of these efforts to protect human health and safety. 9 US. GOVT. ACCOUNTABILITY OFF ICE, GAOWISQQO, High-Rite Series 67~93 (2015), cztrarlab/e at OFFICE OF MGMT. dc BUDGET, EXEC. OFFICE OF THE PRESIDENT, idiirzivfz'ru/ Preparatory, Badger oft/ya 5 Government Firta/ Year 2017 361 (2016), altar/awe (If Whitehouse .gov/omb/budget; Analytical Perspectives. 1? I-Iallegatte, Green, Nicholls, and Corfee? Merlot, Peril/re?ned [arses in major (aerial trfzar, NATURE CHANGE, Aug 18, 2013, at 3, pp 802 806 Aver/able of raw him/l. dniilrrz?onrl/ i 2508/ Airliners/fie Narrated/f FIEMA developed the Whole community approach as part of a larger effort to build an integrated, layered, all~of Nation approach to preparedness, as called for by Presidential Policy Directive (PM) 8): Attila/12M Plepcrredaerr FEIVIA defined the Whole community philosophical approach to preparedness as ?a means by which residents, emergency management practitioners, organizational and community leaders, and government officials can collectively understand and assess the needs of their respective communities and determine the best ways to organize and strengthen their assets, capacities, and interests. By doing so, a more effective path. to societal security and resilience is built. FEMA, A WHOLE-COMMUNITY APPROACH To EMERGENCY PRINCIPLES, THEMES, AND FOR ACTION 3 (2011) arm/able at http: Avww. fema. gov/media? library .. data/90130776 i813 25045 0649/Whole com-1 MEMORANDUM OF UNDERSTANDING TO FORM AN INTERAGENCY WORKING GROUP ON COMMUNITY LED MANAGED RETREAT AND VOLUNTARY RELOCATION This MOU is intended to provide the foundation for Federal coordination for US. states, other than Alaska, on communitymled managed retreat and voluntary relocation. The MOU is not meant to supplant the Denali Commission in its lead coordination role for rural Alaskan communities considering relocation as a way to decrease exposure to hazards and reduce risk to property and human life, though the goals and priorities of this Working Group and the Denali Commission are closely aligned in many respects. The Working Group will, therefore, coordinate on matters of mutual interest with the Denali Commission, including learning from the experiences of the Denali Commission?s work with Alaskan communities and providing support to the Denali Commission when the Commission and the Working Group deem it appropriate. As the need arises, the Working Group may also address coordination related to Insular Areas. V. ESTABLISHMENT OF WORKING GROUP The Partner Agencies will meet as the Working Group every other month, or more frequently as deemed necessary by the Working Group?s chair(s), to achieve the goals set forth in Section VI of this MOU. The Working Group will be chaired by USDA, with HUD serving as a vice-chair. The chair and vice-chair will: i. Regularly convene and preside at meetings of the Working Group and determine its agendas to support goals set furth in Section VI of this 2. Within 9 months after the signing of this MOU, coordinate the development of an action plan that includes recommendations for a multiyear, interagency approach to achieve the goals set forth in Section VI of this 3. Coordinate the efforts of executive departments, agencies, and offices related to the goals of the Working Group as outlined in Section VI of this 4. Invite other executive departments, agencies, and offices to participate in the Working Group, as the Working Group deems appropriate, and maintain an up?to- date list of each Partner Agency?s Working Group members; and; 5. As needed, lead the Working Group in creating an administrative structure or charter to improve the functions of the Working Group, which will be submitted to the full Working Group for approval. The Working Group will consist of career?level staff from the Partner Agencies. Each Partner Agency will designate members to act as that agency?s representatives in the Working Group. Multiple offices within agencies or Departments may participate in the Working Group. Agency Working Group members will be responsible for coordinating across their Agency to facilitate Working Group participation by relevant offices, divisions, or components as appropriate or necessary to support a comprehensive interdisciplinary, and successful approach to managed retreat and relocation. MEMORANDUM OF UNDERSTANDING TO FORM AN INTERAGENCY WORKING GROUP ON COMMUNITY-LED MANAGED RETREAT AND VOLUNTARY RELOCATION The Working Group may choose to develop subcommittees to address specific goals or actions identified in the priority goals below or in the forthcoming action plan. To the extent practicable within existing authorities and resource limitations, Working Group members will work within their Departments or Agencies to staff these subcommittees as appropriate. Subcommittees will determine their own meeting and work schedules, and report back to the Working Group at their regular meetings. VI. WORKING GROUP PRIORITY GOALS Within existing authorities and resource limitations, the Working Group, acting on behalf of the Partner Agencies, intends to: 1. With input from stakeholders, (State, local, and tribal governments, nongovernmental entities, and the private sector) and in coordination with regional Federal agencies or offices that operate in areas where communities are currently pursuing managed retreat or relocation, develop a framework for managed retreat that identifies the Federal role in a communityded process to address current and future needs. This may include: a. A set of principles on community?led relocation to guide Federal assistance developed in consultation with stakeholders; and/or b. Protocols for communication and coordination with State, tribal, and local governments, the private sector, and other nongovernmental entities involved in the process of assisting with communitywled managed retreat or voluntary relocation; and/or c. An analysis of existing authorities and mechanisms within each agency that could assist communities with planning for and implementing community?led managed retreat and voluntary relocation, including a process for designating a lead Federal agency for communities that self-identify as considering these adaptation strategies. 2. Learning from the experiences of communities in Alaska, Washington, and Louisiana currently pursuing these risk reduction strategies, identify obstacles within the Federal Government to community?led managed retreat or voluntary relocation and, where possible, develop solutions to remove those obstacles, including recommendations for appropriate legislative changes to statutory obstacles. 3. Within existing authorities and with existing and available resources, coordinate with communities currently considering relocation or managed retreat, and relevant State, local, and tribal governments, nongovernmental entities, and the private sector, to plan for and implement strategies for communityded managed retreat and relocation. This includes identifying and pursuing opportunities to gather information and advice from tribal governments concerning how Partner Agencies can more effectively assist communities consrdering managed retreat or relocation as an adaptation option MEMORANDUM OF UNDERSTANDING TO FORM AN INTERAGENCY WORKING GROUP ON COMMUNETY LED MANAGED RETREAT AND VOLUNTARY RELOCATION 4. Identify and pursue opportunities to gather information and advice from tribal governments, nongovernmental organizations, academia, and community leaders . concerning how Partner Agencies can more effectively assist. communities considering managed retreat as an adaptation option. 5. Facilitate interagency progress towards these goals by identifying and providing opportunities for sharing information, lessons learned, and best practices between Partner Agencies and between regions where communities are pursuing managed retreat or voluntary relocation. 6. Identify opportunities for Federal training to build local capacity for planning and implementation in communities considering managed retreat or voluntary relocation. 7. Recognize that Federal program changes that result from MOUwrelated discussions and decisions must comply with each Partner Agency?s own tribal consultation policies. 8. Report progress on these goals and priorities annually to the Council on Climate Preparedness and Resilience. v11. ADMINISTRATIVE PROVISIONS a. This MOU becomes effective upon signature of all Partner Agencies and will remain effective until 5 years from its effective date. b. Upon invitation from the Working Group Chairs, as provided in Section VI or upon their own request, other administrative departments, agencies, and offices may join the Working Group by signing the MOU. c. Any Partner Agency may terminate its participation with a 60?day written notice to the other Partner Agencies. d. This MOU may be amended by the written concurrence of all Partner Agencies. c. This MOU may be terminated throogh written agreement by concurrence from all Partner Agencies. LIMITATIONS a. This MOU is not Iegally binding. b. This MOU is neither a fiscal nor a fundswobligation document. Activities contemplated or reonired by this MOU are subject to the availability of funds. Nothing in this MOU shall be construed as obligating any Partner Agency to expend funds, or to provide resources, or to enter any contract, assistance agreement, or interagency agreement, or to be involved in any obligation for future payment of money or provision of resources. Any endeavor involving reimbursement or contribution of funds among the Partner Agencies will be handled in accordance with applicable laws, regulations and procedures, including the Anti? Defrorency Act and requirements related to Federal MEMORANDUM OF UNDERSTANDING TO FORM AN INTERAGENCY WORKING GROUP ON LED MANAGED RETREAT AND VOLUNTARY RELOCATION Government procurement and printing requirements. Such endeavors will be outlined in separate agreements that shall be made in writing by representatives of the Partner Agencies and shall be independently authorized by appropriate statutory authority. This MOU does not provide such authority. c. Partner Agencies are entering into this MOU under their respective authorities in support of their agency missions. Each Partner Agency shall engage in any activity under this MOU only to the extent it is within its authorities, and subject to the availability of funds and resources. d. Each Partner Agency will bear its own expenses in connection with the preparation, negotiation, and execution of the MOU, and no Partner Agency shall be liable to the other Partner Agencies for these expenses. c. This MOU does not, and does not intend to, create any right or benefit, substantive or procedural, enforceable at law or in equity, by any person against the United States, its departments, agencies or entities, its officers, employees, or agents, or any other person. IX. AGENCY INFORMATION To carry out the joint work resulting from this MOU, each Partner Agency may, as necessary, disclose its agency?s proprietary information to other Partner Agencies to the extent permitted by law. Partner Agencies must adhere to the requirements of Federal law governing disclosure of information by a government agency to other agencies and the general public, including but not limited to: The Privacy Act, 5 U.S.C. 552a; the Trade Secrets Act, 18 U.S.C. 1905; and the Freedom of Information Act (FOIA), 5 U.S.C. 552. All. requests for information under FOIA shall be referred to the Partner Agency from which the information originated for processing. X. PUBLICITY The Partner Agencies will coordinate all public statements about the MOU or any deliverables developed by the Working Group under the MOU. Partner Agencies should consult in advance on the form, timing, and contents of any press release, media response, publicly available description, or other similar communication about the MOU or deliverables developed by the Working Group. MEMORANDUM OF UNDERSTANDING TO FORM AN INTERAGENCY WORKING GROUP ON MANAGED RETREAT AND VOLUNTARY RELOCATION 10 XI. SIGNATURES IN WITNESS WHEREOF, the Parties hereto have caused this Agreement. to be duly executed by their respective duly authorized representatives on the day and date written below. Made and executed in 10 counterparts, which taken together constitute one and the same instrument, with one copy of each counterpart having been submitted to each party. See attachments. ?m/W 1 {3/702} Nani AI, Coloretti Date Deputy Secretary US. Housing and Urban Development <5 i :33; We! wt, m4u~ yew? 55% wew?wmg?wWa MEMORANDUM OF UNDERSTANDING TO FORM AN INTERAGENCY WORKING GROUP ON MANAGED RETREAT AND VOLUNTARY RELOCATION