Somerville OSPCD response- CDBG 2010 complaint


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This is how the City of Somerville responded to
"CDBG COMPLAINT for Somerville MA program year 2010/2011"

This response reflects an enormously deficient knowledge base within the City of Somerville's office of Sponsored Programs and Community Development with regards to fundamental disability-inclusive statutes, regulations and codes.

For example: In response to concerns regarding how many accessible and adaptable units have been developed in Somerville, the Director for the office of Sponsored Programs and Community Development claims that, out of a total of 376 units completed, 46 accessible units had been recently created.

However: All but 2 units out of the 46 that she listed are supportive/nursing care residences. Supportive residences are basically institutions- and entirely inappropriate for nonelderly persons with disAbilities who are seeking accessible, affordable, integrated housing in Somerville, MA.

and so on.

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Somerville OSPCD response- CDBG 2010 complaint

  1. 1. 4 CITY OF SOMERVILLE, MASSACHUSETTS OFFICE OF STRATEGIC PLANNING & COMMUNITY DEVELOPMENT JOSEPH A. CURTATONE MAYOROFFICE OF THE EXECUTIVE DIRECTORJune 24, 2010Ms. Eileen FeldmanDirector, Community Access & Inclusion ProjectWard 3Somerville, MARE: May 10, 2010 Comment Letter – HUD One-Year Action Plan (FY 2010-2011)Dear Ms. Feldman,Thank you for your May 10, 2010 comment letter, submitted during the public comment periodfor the HUD One-Year Action Plan (FY 2010-2011). The City of Somerville is committed toensuring accessibility, eliminating barriers to equal opportunity and improving the quality of lifefor all community members in the city.Below are my responses to the issues raised in your May 10th comment letter.1. You contend that the City of Somerville has fraudulently certified that it affirmatively furthers Fair Housing and that residents with disabilities are confined to substandard, environmentally inaccessible housing in poverty-concentrated areas of the City.Somerville has seen the recent design and construction of a number of well designed, state-ofthe-art housing developments that have provided accessible and adaptable units. Recentlyproduced units in HUD-assisted large development rental projects include the following: Development Project Units Accessible Units Adaptable Capen Court (Somerville Housing Authority) 95 20 St. Polycarp’s Village Phase I Rental (SCC) 24 3 St. Polycarp’s Village Phase II Rental (SCC) 29 3 (awaiting funding) Linden Street (SCC) 34 2 VNA Assisted Living (Lowell Street) 95 10 100% VNA Assisted Living (Conwell Capen) 99 8 100% Total 376 46 (12.2%) CITY HALL ● 93 HIGHLAND AVENUE ● SOMERVILLE, MASSACHUSETTS 02143 (617) 625-6600 EXT. 2500 ● TTY: (617) 666-0001 ● FAX: (617) 625-0722
  2. 2. E. FELDMANJUNE 24, 2010PAGE 2In addition to above projects, existing elderly and other subsidized rental housing facilities arescattered throughout the city under the ownership and operation of the Somerville HousingAuthority and other non-profit developers. These include the Massachusetts Department ofMental Health and Mental Retardation housing units that are earmarked for disabled residents.Further, if anyone is seeking a handicapped accessible unit particularly in a HUD-Assisted unit,the owner must make accommodations dependent on the need.You indicate that 76.4% of disabled Somerville residents are not seniors. However, what youhave not acknowledged is that handicapped accessibility is broader than mobility impairment andfederal definition of disability includes a much broader spectrum of physical and mentalimpairments as well. As a result, not all non-senior disabled residents require an ADA accessibleunit.2. You express concern that the City’s Building Inspectors and the designated ADA Coordinator have demonstrated a lack of expertise and knowledge regarding architectural and communications standards.All City of Somerville Building Inspectors are certified by the Commonwealth of Massachusetts.Under M.G.L. c.22, Section 13A, local and state building inspectors are required to enforce theRules and Regulations of the Architectural Access Board (521 CMR). In addition, Inspectors arerequired to complete a minimum of 45 hours of continuing education every 3 years. The City ofSomerville Building Inspectors perform ongoing training and are educated in the federaldisability rights laws that affect housing for people with disabilities, including:  Architectural Barriers Act (ABA) which covers all buildings owned or leased by the federal government;  Section 504 of the Rehabilitation Act (504) which covers housing if built with federal funds;  American with Disabilities Act (ADA) which has provisions that apply to discrimination in housing; and,  Fair Housing Act (FHA) as amended in 1998.3. You indicate that the City’s Fair Housing offices and OSPCD Housing Division offices are in violation of the ADA and Section 504 by making their programs inaccessible and unusable to residents with disabilities in the most integrated manner.The City Hall Annex, where the Offices to Fair Housing and the Housing Division are located,has a handicapped accessible parking space and an operational chair lift in the rear of thebuilding to accommodate mobility impaired individuals. The Offices have had many mobilityimpaired residents as visitors and clients to the facility.4. You assert that the Somerville Community Corporation (SCC) (the City’s designated Community Housing Development Organization (CHDO)) offices are not accessible and their programs and policies are not operated in a manner that considers the cultural, social, and economic needs of individuals with physical, sensory and communications disabilities.
  3. 3. E. FELDMANJUNE 24, 2010PAGE 3SCC is not the owner of 337 Somerville Avenue, but rather a renter of the space. The SCC officeat 337 Somerville Avenue has a limited use elevator in the rear of the building, with signage atthe front door to call the office if use of the elevator is needed. There was no elevator at all inthe building when the organization was negotiating its lease, so the existing elevator is a result oftheir negotiations with the owner. To the best of their knowledge, in four years at 337 SomervilleAvenue, they have not fielded a single complaint from a constituent or client who was unable toaccess the office. Further, it is not true, as commented, that either the front entrance or theentrance to SCC’s dedicated office space is locked during normal business hours. Both doors aretypically unlocked well before 9:00 am and well after 5:00 pm.5. You maintain that the City has used a substantial portion of its limited CDBG “ADA Streetscape Improvements” programming in 2009 in a low-moderate income area. Meanwhile, you state that the City is neglecting the crucial need to self assess and create a transition plan for the City’s entire inventory of sidewalk facilities and with specific relevance to Somerville’s CDBG planning, the crucial need to address sidewalks and crosswalk impediments with the (NRSAs).In early 2007, the City completed an in-depth self assessment conducted by the Safe, SustainableTransportation Assessment and Recommendation Team” (Safe-START). The report called forcity-wide pedestrian upgrades in the form of improved crosswalk painting (the City standard isnow thermoplastic whenever possible), mid-street pedestrian warning signs, countdown lights,updated safe routes to school maps, and bollards near schools. All of these recommendationshave been adopted and are visible across the city and the bollards will be installed when theschool year ends.The Safe-START report also identified 27 priority locations based on crash data and public input.The City controlled locations in the report have received significant upgrades or modificationssince the release of the report. The Safe-START team is currently updating the crash statisticsand will be focusing efforts on the remaining state-controlled intersections that representsignificant danger to residents and visitors.Additionally, the City created policies around major infrastructure projects that ensure theincorporation of bump-outs, expanded sidewalks, improved ramps, crosswalks, benches, lightsand other pedestrian accommodations into any major infrastructure project within the city.Designs for Somerville Ave, Washington Street, Broadway in East Somerville, Assembly SquareDrive and Magoun Square now include these substantial pedestrian improvements in terms ofboth safety and comfort.The Department of Public Works and Traffic & Parking (T&P) have also initiated an aggressiveand coordinated street repaving and ramp installation program. As you are likely aware, since2006, all street repaving projects funded by Chapter 90 funds have included ADA complianthandicapped ramps at all crosswalk locations. This spring alone Traffic & Parking has painted orrepainted 100 crosswalks (13,000 lineal feet), as well as 3 miles of bike sharrows.6. You comment that the city uses CDBG funding and creates new and inaccessible programs such as the Design Annex, in Union Square.
  4. 4. E. FELDMANJUNE 24, 2010PAGE 4The Design Annex is located on the first floor of the former Somerville Police Headquarters at66-70 Union Square. The first floor is accessible by a chair lift to the right of the main entrance. **Thank you for your comments and your ongoing commitment towards residents with disabilities.Please do not hesitate to contact me with any further concerns you may have.Sincerely,Monica R. LamboyExecutive DirectorCC: Board of Aldermen Mayor Joseph A. Curtatone