The document provides recommendations from the Boston Center for Independent Living and Community Access Project to the Massachusetts Architectural Access Board regarding accessibility variances requested for the Wayne Apartments project.
It recommends: [1] continuing the variance for accessibility requirements related to existing buildings but requiring more analysis of feasibility from the applicant; [2] denying the variance request to consider all buildings as one complex; and [3] continuing variances for the percentage of accessible units and accessible entrances but requiring the applicant to provide more information on maximum achievable accessibility. It expresses concerns about the need for accessible housing in the area and argues the applicant needs to demonstrate infeasibility before being granted any variances.
The City of Duluth is seeking SPLOST funds to finance various transportation, road, sidewalk, and park improvement projects. The transportation projects include extensions of Ridgeway Road and Davenport Road, and construction of a hospital connector road. SPLOST funds of $2 million are requested for Ridgeway Road and $500,000 for the hospital connector. Sidewalk improvement projects along W. Lawrenceville Street and McClure Bridge Road are also proposed. Additional funds will go toward annual street resurfacing, park upgrades, and other infrastructure needs.
The document discusses a small area plan commissioned by the Town Manager for the Ephesus-Fordham district of Chapel Hill. This plan included proposals for new street connections within the Village Plaza commercial center to facilitate higher density redevelopment, including a new "Burger King Connector" road. However, the proposed connector's intersection with Elliott Road raises safety concerns due to limited sight distance and proximity to another intersection. While developers may benefit from a traffic signal at this intersection to access Elliott Road, it could negatively impact traffic flow for others. The document calls on the Town Council and Manager to remove the Burger King Connector from the plan.
The document discusses proposed transportation and parks projects for Duluth, Georgia to be funded by a 2008 SPLOST (Special Purpose Local Option Sales Tax). Key projects include extending and improving roads to reduce downtown traffic congestion, constructing sidewalks to promote pedestrian access, and renovating multiple city parks per a master park plan. The total cost of proposed projects is $16 million, with $23 million expected to be generated by the 2008 SPLOST.
The document outlines terms agreed upon by PARC and the project developer Lennar regarding the Sherwin Williams development project. Key points of agreement include: 1) Establishing a permanent public pass-through of an existing building from east to west; 2) Requiring 10 dedicated car share parking spaces and a bike share station; 3) Providing a 2,000 square foot public art gallery and meeting space. The terms were negotiated over two years to address community concerns about the project.
This draft document implement the strategies in this TDDP by encouraging design excellence and the creation of a safe pedestrian environment and attractive gathering places.
Características de la Experiencia de usuario y las metodologías utilizadas para desarrollarla, con ejemplos a partir de interfaces de sitios web de diarios digitales online.
The City of Duluth is seeking SPLOST funds to finance various transportation, road, sidewalk, and park improvement projects. The transportation projects include extensions of Ridgeway Road and Davenport Road, and construction of a hospital connector road. SPLOST funds of $2 million are requested for Ridgeway Road and $500,000 for the hospital connector. Sidewalk improvement projects along W. Lawrenceville Street and McClure Bridge Road are also proposed. Additional funds will go toward annual street resurfacing, park upgrades, and other infrastructure needs.
The document discusses a small area plan commissioned by the Town Manager for the Ephesus-Fordham district of Chapel Hill. This plan included proposals for new street connections within the Village Plaza commercial center to facilitate higher density redevelopment, including a new "Burger King Connector" road. However, the proposed connector's intersection with Elliott Road raises safety concerns due to limited sight distance and proximity to another intersection. While developers may benefit from a traffic signal at this intersection to access Elliott Road, it could negatively impact traffic flow for others. The document calls on the Town Council and Manager to remove the Burger King Connector from the plan.
The document discusses proposed transportation and parks projects for Duluth, Georgia to be funded by a 2008 SPLOST (Special Purpose Local Option Sales Tax). Key projects include extending and improving roads to reduce downtown traffic congestion, constructing sidewalks to promote pedestrian access, and renovating multiple city parks per a master park plan. The total cost of proposed projects is $16 million, with $23 million expected to be generated by the 2008 SPLOST.
The document outlines terms agreed upon by PARC and the project developer Lennar regarding the Sherwin Williams development project. Key points of agreement include: 1) Establishing a permanent public pass-through of an existing building from east to west; 2) Requiring 10 dedicated car share parking spaces and a bike share station; 3) Providing a 2,000 square foot public art gallery and meeting space. The terms were negotiated over two years to address community concerns about the project.
This draft document implement the strategies in this TDDP by encouraging design excellence and the creation of a safe pedestrian environment and attractive gathering places.
Características de la Experiencia de usuario y las metodologías utilizadas para desarrollarla, con ejemplos a partir de interfaces de sitios web de diarios digitales online.
This document summarizes a request for a Planned Unit Development (PUD) to allow the redevelopment of a 1.8 acre site containing vacant church and school buildings into a facility for the Resource and Crisis Center of Galveston County. The PUD would permit mixed uses including offices, daycare, storage, homeless shelter, nursing home, and residential services. The proposal includes renovating existing buildings for these uses while adding landscaping and fencing. City staff recommended approval with conditions including adhering to comments from departments and complying with development regulations. The Planning Commission voted to recommend approval with a condition regarding a utility easement.
Disability Rights and Fair Housing:
Eileen Feldman responds to City of Somerville and SCC. November 2006.
In fall, 2006, the City of Somerville contacted then-Disability Commission Chair Eileen Feldman regarding the Community Housing Development Organization's (CDHO) wish to request exemption from accessibility requirements for a substantial rehabilitation of a 6-unit development at 109 Gilman Street. They asked her to weigh in on supporting this request for an examption.
Instead, Eileen Feldman urged the City of Somerville and the Somerville Community Corporation to ensure maximum accessibility and to make the common areas and at least one of the 2 first-floor apartments accessible to current and future tenants of this HOME-funded project. In response, SCC informed Ms. Feldman that they would not be following this guidance, because, "it would be an administrative as well as a financial burden" to change their plans at this time.
(There were 2 alternate architectural plans drawn up to ensure that at least one unit would be accessible, as well as the common areas of this development. The extra cost for construction for one plan was $17,000; and other costed approximately double that.)
Eileen Feldman then responded to SCC's claims with this pro bono document, Response and Guidance to Somerville Department of Housing, written to the City of Somerville's Community Development office as well as the Somerville Community Corporation. She exhorted SCC and the City of Somerville to proactively address the numerous impediments to fair housing for people with disabilities in Somerville.
After receiving this document, SCC admitted that they could no longer argue that there was an administrative burden to creating at least one accessible unit, because of HUD's guidance regarding the need to plan for accessibility at the acquisition stage of developing such a project.
RFP for Reno's Community Assistance CenterThis Is Reno
Property appraisals completed in May for downtown Reno’s Community Assistance and Triage Centers (CAC) reveal that repairing the buildings to bring them back into service would cost an estimated $10.1 million—nearly four times the amount previously reported by city staff.
Response to draft changes to the Somerville Zoning Ordinance brought before the public by the Mayor, to allow developers to come in and create small units with greater density in commercial and certain residential districts of this condensed city- and call that "Senior/Disabled Housing.".
the Ordinance was not passed.
The applicant is seeking approval to replat three lots that make up the backyard of a property located at 231 Encino Ave in Alamo Heights, Texas. The replat would divide the eastern portion of the property into two new lots. Several residents have submitted letters opposing the replat, arguing it would destroy the historic character of the neighborhood. The Planning and Zoning Commission must decide whether to approve the replat request.
The document is a 9-page complaint form submitted to the Commonwealth of Massachusetts Architectural Access Board regarding accessibility issues at a 4-level commercial building in Somerville, MA. It details 16 alleged violations of the Board's 1987 accessibility regulations, including lack of an accessible route between entrances, insufficient signage, inaccessible features like bathroom stalls and conference room slopes, and lack of elevator access to all floors. The complaint provides photos and details for each alleged violation.
The document is a complaint form submitted to the Commonwealth of Massachusetts Architectural Access Board regarding accessibility issues at a four-story commercial building in Somerville, MA. The 16-page complaint details 16 alleged violations of the Board's regulations from 1987 regarding an accessible route, entrance signage, thresholds, doors, stairs, elevators, restrooms, and signage. Photos are provided as evidence, such as of excessive slopes on routes to entrances, thresholds over 1/2 inch, doors requiring two hands to open, and restroom stalls under the minimum width. The building had undergone renovations since 1988 but still lacked full accessibility according to the regulations at the time.
The document is a manual created by the U.S. Department of Housing and Urban Development (HUD) to assist designers and builders in meeting the accessibility requirements of the Fair Housing Act. It provides guidance on the seven design requirements in the Fair Housing Accessibility Guidelines, which were established by HUD to clarify how to design multifamily housing in compliance with the Fair Housing Act. The manual includes an introduction to the Fair Housing Act and other relevant laws, as well as detailed explanations and illustrations of the Guidelines' requirements.
This document summarizes a request to redevelop a 1.8 acre site containing vacant structures into a mixed-use development through a Planned Unit Development (PUD) overlay. The site is currently zoned Residential-Duplex-EightPlex and contains five vacant structures. The proposed PUD would allow uses including a homeless shelter, nursing home, offices, daycare and residential services. It details the applicant's development plan, surrounding land uses, compliance with zoning regulations and the city's comprehensive plan. City planning staff and commission recommend approving the PUD with conditions.
This document establishes level of service standards for various public facilities and services in the Town of Colonial Beach, including transportation, stormwater management, and other infrastructure. It defines level of service standards for road networks, natural drainage facilities, and man-made drainage facilities. The goals are to maintain and improve levels of service as development occurs to maximize infrastructure use and minimize impacts. Regional stormwater management plans and supplemental best management practices are recommended to effectively manage stormwater.
This ordinance amends the city's zoning ordinance and subdivision regulations to include standards for assisted living facilities. It defines assisted living facilities and aged persons. It establishes performance standards for assisted living facilities regarding general standards, location, site standards, area regulations, and administrative procedures. It also amends the zoning ordinance to include assisted living facilities as conditional uses in residential and professional office districts. Finally, it establishes a parking requirement of three spaces for every five residential units for assisted living facilities.
Item # 6 - 4821 Broadway ARB Case # 909Fahcitycouncil
The applicant is seeking final design review for proposed improvements to the existing HEB Central Market located at 4821 Broadway St in Alamo Heights, including expansion of the commercial building and reconstruction of the parking lot. The improvements aim to repair the parking deck, reconfigure the curbside receiving area, restrip parking spaces, and add new sidewalks and landscaping. The proposal complies with city zoning regulations regarding lot width, off-street parking, landscaping, and setbacks. A nearby resident expressed concerns about potential noise pollution and impacts during construction.
The letter responds to concerns raised in a comment letter about accessibility for disabled residents in Somerville. It summarizes recent housing developments that included accessible units. It also details training that building inspectors receive and accessibility features of municipal buildings. While acknowledging some limitations, it emphasizes efforts to improve pedestrian safety, such as a study that identified priority locations and an aggressive program to install compliant ramps. The letter aims to address the issues raised while highlighting the city's efforts to promote accessibility.
Item # 6 --- 333 Ogden Lane Sign. Reviewahcitycouncil
The document provides background information on a request to demolish an existing single-family residence at 333 Ogden Ln in Alamo Heights and construct a new single-family home and detached garage. It discusses the existing and proposed lot coverage, floor area ratio, and details of the main structure and accessory structure. The Architectural Review Board voted unanimously to declare the existing main structure as not significant and recommended approval of the proposed design.
Item # 6 - 333 Ogden Lane Significance Reviewahcitycouncil
The document provides background information on a request to demolish an existing single-family residence at 333 Ogden Ln in Alamo Heights and construct a new single-family home and detached garage. It discusses details of the existing and proposed structures, relevant city policies on demolition and architectural compatibility. The Architectural Review Board voted unanimously that the existing structure was not significant and recommended approval of the proposed design with a suggestion for consistent fenestration.
CAPS filed a Motion for Reconsideration with the MA Architectural Access Board on March 5, 2012 after the AAB's Compliance officer failed to track down certain details.
The AAB thereupon sent the City a copy of this Motion, requesting those details.
7/13/12: CAPS has still not received any follow-up from the AAB on whether the City provided the requested information
The summary provides the following key points in 3 sentences:
The City of Alamo Heights is seeking approval of a contract with Miller Brothers for a water main installation project using horizontal directional drilling. This project is part of the City's ongoing effort to separate water and sewer mains by the deadline of 2030 as mandated by the Texas Commission on Environmental Quality. The project bids exceeded the budgeted amount but funds are available in the Utility Fund balance to cover the $970,052 contract with Miller Brothers, which was selected as the most qualified bidder.
The applicant is requesting approval to replat two properties into a single lot for future commercial development and is seeking three variances to current zoning regulations. The properties are located on Broadway St between College Blvd and Inslee St and are zoned Business District (B-1). The replat would combine 6401, 6403, and 6421 Broadway St into a single lot meeting the minimum width and area requirements. However, the replat requires variances to the landscape buffer, parking placement, and parking ratio regulations. The Planning and Zoning Commission will consider the request on November 7th, with the City Council to hold a public hearing on November 14th.
PLNPCM2016-00600, Planned Development Ordinance Amendments
Salt Lake City Planning Commission
From: Wayne Mills, Senior Planner
801-535-7282
Date: January 25, 2017
Re: PLNPCM2016-00600, Planned Development Ordinance Amendments
These comments are submitted as part of the public participation for Somerville, MA amendments to its 08/09 and 09/10 Action Plans. Amendments were necessary because Somerville received additional CDBG funding of $772,044 per ARRA HUD investments, in addition to existing 09/10 CDBG/HOME/ESG funding of $5,234,351. These recommendations by a community disAbility rights and accessibility advocate encourage the city to use these funds to provide employment opportunities to expert residents in order to affirmatively overcome the effects of ongoing municipal practices and conditions that have the effect of limiting the participation of people with disAbilities from all ethnic cultures and within all age groups.
Disability Rights expert Eileen Feldman submitted complaint to Federal Highway Administration #CivilRights division based on City of Somerville, MA noncompliance with ADA requirements on March 12, 2012. Result: City of Somerville agreed to hire a full time ADA Coordinator, to produce a current ADA Self Evaluation and to develop the subsequent ADA Transition Plan.
disAbility + human rights activist Eileen Feldman submits public comments on the Massachusetts 2013 draft, Analysis of Impediments to Fair Housing (AI). The Massachusetts 2013 draft is here: http://www.mass.gov/hed/docs/dhcd/hd/fair/draft2013analysis.pdf
More Related Content
Similar to Community Access Project re Wayne Apartments Project May 2012
This document summarizes a request for a Planned Unit Development (PUD) to allow the redevelopment of a 1.8 acre site containing vacant church and school buildings into a facility for the Resource and Crisis Center of Galveston County. The PUD would permit mixed uses including offices, daycare, storage, homeless shelter, nursing home, and residential services. The proposal includes renovating existing buildings for these uses while adding landscaping and fencing. City staff recommended approval with conditions including adhering to comments from departments and complying with development regulations. The Planning Commission voted to recommend approval with a condition regarding a utility easement.
Disability Rights and Fair Housing:
Eileen Feldman responds to City of Somerville and SCC. November 2006.
In fall, 2006, the City of Somerville contacted then-Disability Commission Chair Eileen Feldman regarding the Community Housing Development Organization's (CDHO) wish to request exemption from accessibility requirements for a substantial rehabilitation of a 6-unit development at 109 Gilman Street. They asked her to weigh in on supporting this request for an examption.
Instead, Eileen Feldman urged the City of Somerville and the Somerville Community Corporation to ensure maximum accessibility and to make the common areas and at least one of the 2 first-floor apartments accessible to current and future tenants of this HOME-funded project. In response, SCC informed Ms. Feldman that they would not be following this guidance, because, "it would be an administrative as well as a financial burden" to change their plans at this time.
(There were 2 alternate architectural plans drawn up to ensure that at least one unit would be accessible, as well as the common areas of this development. The extra cost for construction for one plan was $17,000; and other costed approximately double that.)
Eileen Feldman then responded to SCC's claims with this pro bono document, Response and Guidance to Somerville Department of Housing, written to the City of Somerville's Community Development office as well as the Somerville Community Corporation. She exhorted SCC and the City of Somerville to proactively address the numerous impediments to fair housing for people with disabilities in Somerville.
After receiving this document, SCC admitted that they could no longer argue that there was an administrative burden to creating at least one accessible unit, because of HUD's guidance regarding the need to plan for accessibility at the acquisition stage of developing such a project.
RFP for Reno's Community Assistance CenterThis Is Reno
Property appraisals completed in May for downtown Reno’s Community Assistance and Triage Centers (CAC) reveal that repairing the buildings to bring them back into service would cost an estimated $10.1 million—nearly four times the amount previously reported by city staff.
Response to draft changes to the Somerville Zoning Ordinance brought before the public by the Mayor, to allow developers to come in and create small units with greater density in commercial and certain residential districts of this condensed city- and call that "Senior/Disabled Housing.".
the Ordinance was not passed.
The applicant is seeking approval to replat three lots that make up the backyard of a property located at 231 Encino Ave in Alamo Heights, Texas. The replat would divide the eastern portion of the property into two new lots. Several residents have submitted letters opposing the replat, arguing it would destroy the historic character of the neighborhood. The Planning and Zoning Commission must decide whether to approve the replat request.
The document is a 9-page complaint form submitted to the Commonwealth of Massachusetts Architectural Access Board regarding accessibility issues at a 4-level commercial building in Somerville, MA. It details 16 alleged violations of the Board's 1987 accessibility regulations, including lack of an accessible route between entrances, insufficient signage, inaccessible features like bathroom stalls and conference room slopes, and lack of elevator access to all floors. The complaint provides photos and details for each alleged violation.
The document is a complaint form submitted to the Commonwealth of Massachusetts Architectural Access Board regarding accessibility issues at a four-story commercial building in Somerville, MA. The 16-page complaint details 16 alleged violations of the Board's regulations from 1987 regarding an accessible route, entrance signage, thresholds, doors, stairs, elevators, restrooms, and signage. Photos are provided as evidence, such as of excessive slopes on routes to entrances, thresholds over 1/2 inch, doors requiring two hands to open, and restroom stalls under the minimum width. The building had undergone renovations since 1988 but still lacked full accessibility according to the regulations at the time.
The document is a manual created by the U.S. Department of Housing and Urban Development (HUD) to assist designers and builders in meeting the accessibility requirements of the Fair Housing Act. It provides guidance on the seven design requirements in the Fair Housing Accessibility Guidelines, which were established by HUD to clarify how to design multifamily housing in compliance with the Fair Housing Act. The manual includes an introduction to the Fair Housing Act and other relevant laws, as well as detailed explanations and illustrations of the Guidelines' requirements.
This document summarizes a request to redevelop a 1.8 acre site containing vacant structures into a mixed-use development through a Planned Unit Development (PUD) overlay. The site is currently zoned Residential-Duplex-EightPlex and contains five vacant structures. The proposed PUD would allow uses including a homeless shelter, nursing home, offices, daycare and residential services. It details the applicant's development plan, surrounding land uses, compliance with zoning regulations and the city's comprehensive plan. City planning staff and commission recommend approving the PUD with conditions.
This document establishes level of service standards for various public facilities and services in the Town of Colonial Beach, including transportation, stormwater management, and other infrastructure. It defines level of service standards for road networks, natural drainage facilities, and man-made drainage facilities. The goals are to maintain and improve levels of service as development occurs to maximize infrastructure use and minimize impacts. Regional stormwater management plans and supplemental best management practices are recommended to effectively manage stormwater.
This ordinance amends the city's zoning ordinance and subdivision regulations to include standards for assisted living facilities. It defines assisted living facilities and aged persons. It establishes performance standards for assisted living facilities regarding general standards, location, site standards, area regulations, and administrative procedures. It also amends the zoning ordinance to include assisted living facilities as conditional uses in residential and professional office districts. Finally, it establishes a parking requirement of three spaces for every five residential units for assisted living facilities.
Item # 6 - 4821 Broadway ARB Case # 909Fahcitycouncil
The applicant is seeking final design review for proposed improvements to the existing HEB Central Market located at 4821 Broadway St in Alamo Heights, including expansion of the commercial building and reconstruction of the parking lot. The improvements aim to repair the parking deck, reconfigure the curbside receiving area, restrip parking spaces, and add new sidewalks and landscaping. The proposal complies with city zoning regulations regarding lot width, off-street parking, landscaping, and setbacks. A nearby resident expressed concerns about potential noise pollution and impacts during construction.
The letter responds to concerns raised in a comment letter about accessibility for disabled residents in Somerville. It summarizes recent housing developments that included accessible units. It also details training that building inspectors receive and accessibility features of municipal buildings. While acknowledging some limitations, it emphasizes efforts to improve pedestrian safety, such as a study that identified priority locations and an aggressive program to install compliant ramps. The letter aims to address the issues raised while highlighting the city's efforts to promote accessibility.
Item # 6 --- 333 Ogden Lane Sign. Reviewahcitycouncil
The document provides background information on a request to demolish an existing single-family residence at 333 Ogden Ln in Alamo Heights and construct a new single-family home and detached garage. It discusses the existing and proposed lot coverage, floor area ratio, and details of the main structure and accessory structure. The Architectural Review Board voted unanimously to declare the existing main structure as not significant and recommended approval of the proposed design.
Item # 6 - 333 Ogden Lane Significance Reviewahcitycouncil
The document provides background information on a request to demolish an existing single-family residence at 333 Ogden Ln in Alamo Heights and construct a new single-family home and detached garage. It discusses details of the existing and proposed structures, relevant city policies on demolition and architectural compatibility. The Architectural Review Board voted unanimously that the existing structure was not significant and recommended approval of the proposed design with a suggestion for consistent fenestration.
CAPS filed a Motion for Reconsideration with the MA Architectural Access Board on March 5, 2012 after the AAB's Compliance officer failed to track down certain details.
The AAB thereupon sent the City a copy of this Motion, requesting those details.
7/13/12: CAPS has still not received any follow-up from the AAB on whether the City provided the requested information
The summary provides the following key points in 3 sentences:
The City of Alamo Heights is seeking approval of a contract with Miller Brothers for a water main installation project using horizontal directional drilling. This project is part of the City's ongoing effort to separate water and sewer mains by the deadline of 2030 as mandated by the Texas Commission on Environmental Quality. The project bids exceeded the budgeted amount but funds are available in the Utility Fund balance to cover the $970,052 contract with Miller Brothers, which was selected as the most qualified bidder.
The applicant is requesting approval to replat two properties into a single lot for future commercial development and is seeking three variances to current zoning regulations. The properties are located on Broadway St between College Blvd and Inslee St and are zoned Business District (B-1). The replat would combine 6401, 6403, and 6421 Broadway St into a single lot meeting the minimum width and area requirements. However, the replat requires variances to the landscape buffer, parking placement, and parking ratio regulations. The Planning and Zoning Commission will consider the request on November 7th, with the City Council to hold a public hearing on November 14th.
PLNPCM2016-00600, Planned Development Ordinance Amendments
Salt Lake City Planning Commission
From: Wayne Mills, Senior Planner
801-535-7282
Date: January 25, 2017
Re: PLNPCM2016-00600, Planned Development Ordinance Amendments
These comments are submitted as part of the public participation for Somerville, MA amendments to its 08/09 and 09/10 Action Plans. Amendments were necessary because Somerville received additional CDBG funding of $772,044 per ARRA HUD investments, in addition to existing 09/10 CDBG/HOME/ESG funding of $5,234,351. These recommendations by a community disAbility rights and accessibility advocate encourage the city to use these funds to provide employment opportunities to expert residents in order to affirmatively overcome the effects of ongoing municipal practices and conditions that have the effect of limiting the participation of people with disAbilities from all ethnic cultures and within all age groups.
Similar to Community Access Project re Wayne Apartments Project May 2012 (20)
Disability Rights expert Eileen Feldman submitted complaint to Federal Highway Administration #CivilRights division based on City of Somerville, MA noncompliance with ADA requirements on March 12, 2012. Result: City of Somerville agreed to hire a full time ADA Coordinator, to produce a current ADA Self Evaluation and to develop the subsequent ADA Transition Plan.
disAbility + human rights activist Eileen Feldman submits public comments on the Massachusetts 2013 draft, Analysis of Impediments to Fair Housing (AI). The Massachusetts 2013 draft is here: http://www.mass.gov/hed/docs/dhcd/hd/fair/draft2013analysis.pdf
ACS 2012. Selected Economic Characteristics for the Civilian Noninstitutionalized Population By Disability Status, 1-Yr. Estimates, Table S1811.
Astonishing stats indicate that in 2012: 22.1% of Americans with Disabilities are below 100% of poverty level, compared with 12.7% of Americans without disabilities.
1 in 4 (25%) Americans with disabilities aged 25+ still don't have a high school diploma, compared with 11.1% of Americans without disabilities.
5.1% of the "Employed Population Age 16 and Over" are Americans living with disAbilities, compared to the 94.7% of the American workforce who still live without disabilities.
It doesn't make sense that Americans with disabilities are still not "presumed disadvantaged" for purposes of gaining advantages and resources in Federal SBA employment and entrepreneurship resources.
Congress needs to take note, show leadership and moral courage, and recognize that Americans with disAbilities are ready and waiting in the wings for a chance to shine.
Give us equal opportunities in education and employment, make much-needed infrastructure investments in accessibility in all public-service facilities (including the Capital and other GSA assets), and hire more ppl with disAbilities (PwD) in leadership positions at all Federal agencies, especially DOJ, HUD, DOL, and HHS.
The 2012 American Community Survey (ACS), Table B22010, shows that approx. 7 million of the approx. 16 million households receiving Food Stamps/SNAPS nationwide have 1 or more family member living with at least 1 disability. Yup- that's approx. 44% (43.7%)
H.97 is named ""An Act to promote employment for people with disabilities." My testimony summarized: Let's call it by its real name. This is a bill to promote subminimum-wage employment for a certain class called persons with disabilities (PwD), while promoting a situation in which a certain non-profit entity (to be designated by the Council proposed by this bill) would receive certain non-competitive lucrative state contracts while managing those low-wage workers in (generally) sheltered-workshop settings.
The Boston Commission for Persons with Disabilities wrote to Attorney General Martha Coakley to follow up on a previous request to allow remote participation in Commission meetings under the Open Meeting Law for people with disabilities. The Commission was disappointed that the new 940 CMR 29 regulations did not adequately address barriers people with disabilities face in physically attending meetings. The Commission requested written explanations from the Attorney General on these issues and proposed adding "Discrimination" as an additional justification for remote participation.
AAB complaint submitted in 2010. AAB sends First Notice approximately 1 year later, after reminder by FOIA. CAPS re-surveys portions of complaint in September 2011 and amends complaint to reflect certain corrections made by owner as a result of the complaint. As of 9/28/2013, no further correspondence from AAB on this docket.
House Bill no. 136, filed in January 2013, is a petition to increase the Commonwealth of Massachusett's compliance with federal law meeting requirements of the Amercians with DisAbilities Act. This written testimony explains that the US Dept. of Labor Office of Federal Contract Compliance Programs announced a Final Rule on August 27, 2013, which made changes to the regs implementing Section 503 of the Rehabilitation Act of 1973. Most important is the establishment of the 7 percent workforce utilization goal for individuals with disabilities (IWD). Massachusetts has an important opportunity at this time to develop into a Model Employer of Individuals with DisAbilities!
City of Somerville MA signed voluntary agreement with US Dept. of Education in May 2013. This is not a comprehensive list of Somerville's Library deficiencies
The Somerville Public Library agreed to resolve an ADA complaint by taking several accessibility measures, including designating an ADA coordinator, reviewing programs to ensure accessibility at multiple locations, updating policies and notices, and making physical alterations to improve accessibility of entrances, restrooms, signage and routes by June 2015. The library will submit documentation and reports to the Department of Education on its progress in implementing the agreement.
The Department of Public Works in Somerville, MA provided a list of roads that were paved between January 2004 and September 2008 in response to a public information request. The letter, from DPW Commissioner Stan Koty, included the list of roads as an attachment and was sent to Eileen Feldman, who had made the information request.
This document requests amendments to an existing complaint regarding accessibility issues at a building in Somerville, Massachusetts. It summarizes three requested amendments: 1) Require the owner to provide proof that a new accessible threshold also meets other accessibility requirements. 2) Dismiss one alleged violation regarding inaccessible entrances. 3) Add two new alleged violations regarding two-way communication systems and lack of an elevator to access a mezzanine level added after construction. The document provides context and photos to support the requested amendments.
This document is a parking lot complaint form submitted to the Commonwealth of Massachusetts Architectural Access Board. It details issues with handicapped parking at a building in Somerville, MA, including that the van accessible space is missing a sign designating it as such and the existing handicapped parking sign is not at the proper height. The complaint was filed by the Community Access Project on November 12, 2010 regarding violations observed on October 28, 2010 at the specified location.
The document is a request from the Community Access Project (CAPS) to the Massachusetts Architectural Access Board regarding fines imposed on the owners of the Armory for accessibility violations.
CAPS requests that the Board collect $45,500 in fines from the owners and use the funds to sponsor a series of community discussions at the Armory on civil rights issues. CAPS also requests conditions to ensure the City of Somerville does not financially benefit due to retaliatory actions against CAPS.
The document provides background on accessibility issues at the Armory dating back to 2009, summarizes the owners' request to reduce fines, and argues fines should not be reduced given losses to the disability community and lack of proof for owners
The document is an email from Eileen Feldman, Director of the Community Access Project in Somerville, following up from an Architectural Access Board hearing regarding 50 pedestrian locations needing accessibility remediation. It provides 3 priorities for how the locations should be addressed: prioritizing locations near government/public services, transportation, public accommodations, health facilities, and dense residential areas. It also notes funding from CDBG should supplement, not replace, the city's efforts. Finally, it questions the claim that none of the locations pose public safety issues, as any code violations by definition impact public safety.
The Massachusetts Architectural Access Board reviewed a case regarding accessibility issues at The Armory building in Somerville. Based on a site visit that found the entrance ramp slope was up to 8.7%, exceeding the maximum allowed slope of 8.3%, the Board voted to accept the slightly steeper slope and allow the building to be used for public events again. The Board also decided to review the abatement of accrued fines of $500 per day at their next meeting.
The City of Somerville hired an outside consultant to deal with curb cut and sidewalk accessibility complaints. The Community Access Project, an all-volunteer group of disAbility rights experts, responds to that document, pointing out gaps and problems with 2011 "remediations". We also remind the Architectural Access Board why they should enforce the code that prohibits apex curb cuts where perpendicular or parallel curb cuts are feasible to construct. Curb cuts need to be adequately oriented to the crosswalks; and, the crosswalks need to be perpendicular to the curb line. It's a public safety issue in addition to a human rights issue. We deserve safe, accessible and integrated Complete Streets.
The Architectural Access Board held a hearing regarding violations at The Armory building in Somerville, MA. Previously, the Board had granted variances for the ramp slope and lack of landing at the entrance ramp on the condition that an additional actuator be installed by April 2010. A new complaint was filed alleging that the entrance ramp slope still did not meet requirements. The Board heard testimony from the property owner, witnesses, and complainant. Based on the testimony and evidence presented, the Board considered whether penalties would be assessed for failure to comply with the previous order regarding the ramp slope.
The Architectural Access Board considered a variance request and complaint regarding accessibility issues at The Armory located in Somerville, MA. At a prior hearing, the Board granted variances for the ramp slope and lack of landing but required an additional actuator be installed. A new complaint alleged multiple additional violations including lack of assistive listening systems, improper parking and signage, excessive ramp and threshold slopes, and missing or non-compliant handrails. The Board scheduled a hearing to address the new complaint and determine if further variances or modifications were needed to comply with accessibility laws.
Discovering the Best Indian Architects A Spotlight on Design Forum Internatio...Designforuminternational
India’s architectural landscape is a vibrant tapestry that weaves together the country's rich cultural heritage and its modern aspirations. From majestic historical structures to cutting-edge contemporary designs, the work of Indian architects is celebrated worldwide. Among the many firms shaping this dynamic field, Design Forum International stands out as a leader in innovative and sustainable architecture. This blog explores some of the best Indian architects, highlighting their contributions and showcasing the most famous architects in India.
Architectural and constructions management experience since 2003 including 18 years located in UAE.
Coordinate and oversee all technical activities relating to architectural and construction projects,
including directing the design team, reviewing drafts and computer models, and approving design
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Organize and typically develop, and review building plans, ensuring that a project meets all safety and
environmental standards.
Prepare feasibility studies, construction contracts, and tender documents with specifications and
tender analyses.
Consulting with clients, work on formulating equipment and labor cost estimates, ensuring a project
meets environmental, safety, structural, zoning, and aesthetic standards.
Monitoring the progress of a project to assess whether or not it is in compliance with building plans
and project deadlines.
Attention to detail, exceptional time management, and strong problem-solving and communication
skills are required for this role.
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Community Access Project re Wayne Apartments Project May 2012
1. BCIL/CAPS Recommendations to MAAB on AAB Docket #V12-102, Wayne Apartments, multiple locations
May 9, 2012
FROM: Boston Center For Independent Living and Community Access Project
Karen Schneiderman, Senior Advocacy Specialist Eileen Feldman, Director
60 Temple Place P.O. Box 434
Boston, MA 02111 Somerville, MA 02143
TO: MA Architectural Access Board
Thomas Hopkins, Executive Director
Donald Lang, Chair
One Ashburton Place - Room 1310
Boston, MA 02108
RE: Public Comments on V12-102, Wayne Apartments Project/Wayne Apartments Project LP
One John Eliot Square
Roxbury, MA 02119
Dear AAB Board and Staff,
The Boston Center for Independent Living and the Community Access Project have a partnership in
reviewing, analyzing and providing comments and recommendations regarding architectural accessibility
topics impacting the Greater Boston area. We submit the following recommendations regarding AAB
Docket #V12-102 for the Wayne Apartments Project for the Board's review and for inclusion in the Hearing
packet and administrative file on this docket.
Bottom line on top: Please continue the Variance for 3.3/3.3.1/3.3.2. Please deny the Variance for 9.4.1.
Please continue the Variances for 9.4, 9.4.2 and 10.1.
We recommend that the MAAB require the Applicant to
o submit additional and substantive information, including detailed architectural reviews and cost
estimates regarding "Unfeasibility/Cost Required" for each of the site locationsin this portfolio that contain
10 or more units (18 out of the 26 sites)
o submit information showing how maximum feasible accessibility in all public and common
areas (including accessible routes), plus 5% Group 2A units at each of these sites can be achieved by the
conclusion of this 5-phase rehabilitation project.
o submit evaluations for all buildings that are currently listed as containing "HP and "HI" units.
The Board can consider an application for a variance from the 5% rule if the applicant can demonstrate
with reasonable certainty that there is a lesser need for Group 2A units in the locations in question. In this
case, the municipalities are: Roxbury, Dorchester and Mattapan. The fact is that there is an urgent need for
accessible housing in the Greater Boston area.
Here is the written testimony of Bill Henning, Executive Director, Boston Center for Independent Living:
“The biggest need of people contacting BCIL for services is for affordable and accessible housing. During
the year we will directly assist approximately fifty people to find housing, and many others, perhaps
hundreds, will be indirectly assisted. There remains a severe shortage of affordable, accessible, and
integrated units in the city and surrounding communities. One serious result is that people live in
inaccessible units, perhaps having to use a portable commode or not being able to simply enter and exit
their unit at their convenience as most everyone else does because of the lack of a ramp or elevator.
Currently we are working with sixty people who wish to reside in the community but who are stuck in
page 1 of 8
2. BCIL/CAPS Recommendations to MAAB on AAB Docket #V12-102, Wayne Apartments, multiple locations
nursing homes, and far and away the biggest barrier to getting out is adequate housing—there are ample
services at this time— something reported by all independent living centers and elder services programs.”-
Bill Henning, Executive Director of the Boston Center for Independent Living. May 8, 2012.1
This project, although listed as a Mod Rehab in this application, falls under HUD's Section 504 Substantial
Alterations (24CFR 8.23(a) accessibility regulations; and, the provisions of 24 CFR 8.22(a) and (b) for new
construction apply.2
The applicant also needs to be aware that the most stringent regulations apply to this Five-phase project.
The only HUD exceptions that will apply to this project are: exceptions due to undue financial and
administrative burden (24 CFR 8.23(b)(1); or, exceptions regarding alterations that require removing or
altering load-bearing structures (24 CFR 8.32(c).
HUD's Office of Fair Housing and Equal Opportunity (FHEO) enforces the Fair Housing Act and other civil
rights laws. When Fair Housing and civil rights violations are found, all interested parties are potentially
held responsible. Review and approval by a government agency is irrelevant as a defense for design and
construction violations.3 Violations are subject to injunctive or other appropriate relief, actual damages,
and civil penalties. Appendix One is our attempt to make sure that the applicant is aware that of certain
accessibility requirements, civil rights and nondiscrimination requirements, and State agency obligations,
that are triggered by this Project at this time, on the basis of certain funding mechanisms mentioned in the
application.
Therefore, we strongly recommend that if any Variances are granted on this Project, that all due diligence
be applied in the evaluation phase, to ensure that maximum feasible accessibility retrofits will be achieved
upon completion. Not only should potential applicants and residents with physical and sensory disabilities
be provided equal opportunities to use and enjoy the units, common areas of these dwellings and sites; and
participate in, and access other activities conducted and sponsored by this applicant; but the applicant must
also ensure that all visitors to these sites have maximum feasible access to each type of common area and
amenity that is provided to the public.4
On the next pages are discussions for each of our three recommendations.
1
A limited review of the Boston Housing Authority's online inventory of UFAS- accessible units shows that, of the
units inventoried and reviewed online so far (a total of 10, 640 units), there are only 480 (4.5%) units called UFAS-
accessible, in sizes ranging from 1 BR to 5 BR, scattered throughout the Greater Boston area.
2
The applicant is considered a covered entity under HUD's Section 504 requirements, enforeceable since June 2,
1988. Regarding Alterations, HUD regulations state: If the project involves fewer than 15 units or the cost of
alterations is less than 75% of the replacement cost of the completed facility and the recipient has not made 5% of its
units in the development accessible to and usable by individuals with disabilities, then the requirements of 24 CFR
8.23(b) - Other Alterations apply.
However, "alterations are substantial if they are undertaken to a project that has 15 or more units and the cost
of the alterations is 75% or more of the replacement cost of the completed facility. [See 24 CFR 8.23(a)]. In such a
case, new construction provisions of 24 CFR 8.22 apply.
3
Review and approval by a government agency is irrelevant as a defense for design and construction violations. See
for example: Fair Housing Council et. al. v. Village of Olde St. Andrews, Inc. et. al (2000); and, U.S. v. Quality Built
Construction, Inc. et. al. (2003).
4
UFAS 4.1.3 (1)(b). see http://www.access-board.gov/ufas/ufas-html/ufas.htm
page 2 of 8
3. BCIL/CAPS Recommendations to MAAB on AAB Docket #V12-102, Wayne Apartments, multiple locations
1. Please continue the Variance for 3.3/3.3.1/3.3.2.
o Regarding 3.3, Existing Buildings, we turn to 521 CMR 9.2.1 to analyze the applicability of
521 CMR to existing multiple dwellings undergoing renovations.
9.2.1 Renovation and reuse: These buildings are exempt from applying State code 521 9.3,
Group 1 Dwelling units. However, the applicant is not exempt from the Section 504/UFAS standards to
ensure 5% wheelchair-accessible units; and 2% for hearing and visually impaired applicants and residents.
o Regarding 3.3.1, The work being performed is 179% of the assessed value of the portfolio.
The applicant should not be granted any exceptions regarding curb cuts; and, the applicant should be
aware of their Section 504/UFAS Minimum requirements, which include at least one accessible route
connecting accessible buildings, facilities, elements, and spaces that are on the same site.5 At least one
accessible route shall be provided within the boundary of the site from public transportation stops,
accessible parking spaces, passenger loading zones if provided, and public streets or sidewalks to an
accessible building entrance.6
o Regarding 3.3.2, the work being performed is 179% of the assessed value of the portfolio.
The applicant has not submitted any detailed design studies; and, the space matrixes (Exhibits 1A - 1D
show that there is at least interior space7 currently unaccounted for, that may be available for space
reallocations and redesigns.
Regarding Exhibits A - D pertinent to "Note A" the applicant states that installing HP ramps
would be inaccessible at some locations, or would encroach on public sidewalk, and that lifts within
vestibules would encroach on existing units.
Exterior analysis: The accessible route is a critical element of any site and building; and,
these renovations will providing these housing assets a second life. The applicant should provide the AAB
with a detailed analysis for a minimal clear width, ground and floor surfaces, level changes, slope and cross
slope, vertical clearance and protruding objects to ensure that all feasible options have been considered for
the exterior of the buildings.
Interior analysis: the applicant's Exhibits 1A - 1D space matrix shows that there is
unnaccounted-for additional square footage in each building. Space that is not currently accounted for in this
application's square footage matrix (exh. 1A - 1D) includes: units currently listed as abandoned; any floors without
active units; any units that have remained vacant since the last expiration of the HAP contract; and, all basement
spaces.
On page 3 of the Variance application, the unit breakdowns of Wayne Apartment's accessible units are
summarized. Out of a total 349 units, only 18 units are listed as "HP." The applicant provides no
information regarding how such units were evaluated for accessibility.
Summary: We recommend that the Board continue this part of the Variance application, and require
applicant to provide a detailed analysis of infeasibility, taking into account all possible space8
reallocations and redesigns that may be possible, in exterior and interior portions of the site, prior to
completion of this project.
5
UFAS 4.1.1(2). see http://www.access-board.gov/ufas/ufas-html/ufas.htm
6
UFAS 4.3.2. see http://www.access-board.gov/ufas/ufas-html/ufas.htm
7
Space that is not currently accounted for in this application's square footage matrix (exh. 1A - 1D) includes: units
currently listed as abandoned; any floors without active units; any units that have remained vacant since the last
expiration of the HAP contract; and, all basement spaces.
8
This is not meant to include mechanical rooms and other spaces that, "because of their intended use, will not require
accessibility to the public or beneficiaries or result in the employment or residence therein of individuals with physical
disabilities" (24 CFR 8.32(6)).
page 3 of 8
4. BCIL/CAPS Recommendations to MAAB on AAB Docket #V12-102, Wayne Apartments, multiple locations
2. Please deny the Variance for 9.4.1.
521CMR 9.4.1: Total dwelling units in a complex: When multiple dwellings consist of more than one
building on a site or are located on several, non-contiguous sites, all dwelling units shall be added
together to determine applicability of 521 CMR 9.4.
3 administrative reasons why 9.4.1 should not be permitted as a blanket waiver for this multi-municipal
portfolio:
• 521 CMR 9.4.1 does not apply, because "Several" means more than two, but not many. This
application covers many sites, buildings and units, which are located in three distinct towns. We have
26 sites, and 55 buildings = a total of 349 units geographically scattered between Roxbury, Mattapan
and Dorchester.
•
• IRS reporting does not support the "complex" concept for this project. The applicant indicates that
historic tax credits (HTC) are being sought for 21 buildings (Exhibit 2).
Although a project can have a single financing package that includes multiple buildings and multiple
phases, IRS reporting is on a building-by-building basis.9
• HUD definition for multifamily housing projects do not support the "complex" concept for this project.
HUD says, "The definition of a multi-family housing project ... includes a property that is
either on a single site or a property that has multiple structures on the same site with less than
five units in each, but with a total of at least five units on the site."
Therefore, the Wayne Apartments Project does not fulfill HUD's definition of a single site or property,
because the 26 geographically distinct sites cannot be considered either "a single site;" or, "the same site."10
3. Please continue the Variances for 9.4, 9.4.2 and 10.1
• The applicant has not provided either architectural studies, nor cost estimates showing why the creation
of additional accessible units, accessible common areas, and accessible routes are an undue burden
without substantial benefit to persons with disabilities. The applicant should be aware that HUD defines
"Structural Impracticability" as:
Changes having little likelihood of being accomplished without removing or altering a load-
bearing structural member and/or incurring an increased cost of fifty percent (50%) or more of the
value of the element of the building or facility involved. UFAS § 3.5
9
LIHTC Database, p. 13, note 6. SEE http://www.huduser.org/Datasets/lihtc/topical9509.pdf
10
However, the applicant might examine the possibility that, if there are several buildings that expire together, and
are annually renewed as one HAP contract, these might be grouped together as "developments." (per Section 504)
page 4 of 8
5. BCIL/CAPS Recommendations to MAAB on AAB Docket #V12-102, Wayne Apartments, multiple locations
Summary
While we recognize that these are not ideal conditions, an investment in maximum feasible accessibility
retrofits at this time should be encouraged, while this entire portfolio is receiving new life. We encourage
the applicant to go "back to the drawing board" and take a second look at the space reallocation
possibilities in the interiors of these buildings; and the landscaping/walkway options that may be available
around the exterior boudaries of at least the 18 sites that offer 10 or more units.
We encourage all interested parties to the Variance, including developers, contractors, consultants involved
in the application or in the planning, development, implementation of the project; and, any other person
who has a financial interest in this project to consider the positive impact this rehabitation project can have
on these neighborhoods, should the diversity of children, adults and older people with disabilities gain
these housing opportunities in the same manner as the rest of the general public.
And those new residents would also gain access to the social, cultural, transportation, recreational,
educational and employment opportunities within walking distance of these sites.
All interested parties should also be aware that they are subject to Section 504/UFAS obligations, which
have already been in effect for 24 years11. Accessibility retrofits to the common and public areas, and
ensuring that the 5% requirement is met, at least in buildings with 10 or more units, can go far in helping
Wayne Apartments be a good neighbor and make sure that all parties in the Master leases can stay in
business.
It is our hope that the State Board will be able to guide this applicant to prioritize an outcome that includes
additions and improvements that will achieve the maximum accessible housing conditions possible
throughout this project portfolio that impacts low-income neighborhoods in Roxbury, Mattapan and and
Dorchester.
Thank you for your consideration of these comments from BCIL and CAPS. Please include this document
in full within all Hearing information provided to the Board; within the packets distributed at Public
Hearings for V12-102; and, in the permanent and complete administrative file that will be kept for #V12-
102.
Sincerely,
Eileen Feldman, Director, Bill Henning, Executive Director and
Karen Schneiderman, Senior Advocate
Community Access Project Boston Center for Independent Living
CAPSom @verizon.net KSchneiderman@bostoncil.org
11
HUD's Section 504 implementing regulations became enforceable on June 2, 1988.
page 5 of 8
6. BCIL/CAPS Recommendations to MAAB on AAB Docket #V12-102, Wayne Apartments, multiple locations
APPENDIX ONE
Applicant should conduct a detailed analysis of how they and their PHA and State partners will achieve
minimal Federal and State accessibility and civil rights obligations; including what types of waivers will be
sought alongside of this AAB Variance application.
The AAB, as a State agency, must not make any decisions that restrict, or have the effect
of restricting, the availability of housing choices based on race, color, religion,sex, disabilities, familial
status, or national origin.
When Fair Housing violations are found, all parties are potentially held responsible.1213
• The applicant has asked for a Variance per 521 CMR 3.3, stating "achieving compliance at all required
buildings would make the buildings less accessible to other users, would encroach on public rights of
ways accessible elements would have to be placed at inaccessible or areas of limited acccessibility."
o Irregardless of whether the MAAB grants this portion of the Variance, the applicant is subject
to HUD's Section 504/UFAS provisions (see 24 CFR §8.23, Existing Facilities and §8.22,
New Construction). At the very least, applicant needs to ensure that maximal feasible
accessibility retrofits for public and common use areas and dwelling units are an outcome of
this rehabiliation project. Case law fully supports this.14
• The applicant has not provided either architectural studies, nor cost estimates showing why the creation
of additional accessible units, accessible common areas, and accessible routes are an undue burden
without substantial benefit to persons with disabilities. The applicant should be aware that HUD defines
"Structural Impracticability" as:
o Changes having little likelihood of being accomplished without removing or altering a load-
bearing structural member and/or incurring an increased cost of fifty percent (50%) or more
of the value of the element of the building or facility involved. UFAS § 3.5
• HUD's definition of "accessible" is as follows:
o Accessible – When used with respect to the design, construction, or alteration of
housing and non-housing programs, “accessible” means that the program or portion of the program when
designed, constructed, altered or adapted, can be approached, entered, and used by individuals who use
wheelchairs. A program that is designed, constructed, altered or adapted to be in compliance with the
Uniform Federal Accessibility Standards (UFAS), 24 C.F.R. § 8.32, Appendix A to 24 C.F.R. § 40, and,
where applicable, the Americans with Disabilities Act Standards for Accessible Design (ADA Standards),
Appendix A to 28 C.F.R. § 36, meets the minimum standards for compliance and is accessible. Alterations
of facilities designed before July 11, 1988 shall conform to the provisions of the UFAS to the maximum
extent practicable.
12
overview, HUD Compliance Sanctions: http://www.hud.gov/library/bookshelf01/compsanctions.cfm
13
see also www.olmsteadva.com/mfp/downloads/HUDSection504FairHousingandADA.ppt
14
see note 3.
page 6 of 8
7. BCIL/CAPS Recommendations to MAAB on AAB Docket #V12-102, Wayne Apartments, multiple locations
STATE AGENCY OBLIGATIONS:
• At the very least, the State must remedy systemic discrimination and promote fair housing rights and fair
housing choice. Regionally, MAPC Metro Boston has stated a firm commitment to principles of
"Building Sustainable Communities of Opportunity" (2011)15.
• Massachusetts civil rights and affirmative furthering of fair housing obligations and policies include the
assurance that efforts will be taken to overcome barriers to housing choice, and to increase housing
opportunities to historically underserved residents. This project triggers the State's Federal civil rights and
nondiscrimination obligations and regulations, including:
o 24 CFR §903.7(o)(3)- AFFH regulations16
o 24 CFR §903.7(o)- Housing Choice Voucher and Project Based Vouchers
o 24 CFR §§200.600-640 - FHA-insured housing, Affirmative Fair Housing Marketing Plan
(AFHMP); and
o 24 CFR part 91 §91.325 (a)(1)- State CDBG regs
• The applicant states that this is a moderate rehabilitation project; this indicates that these units may be
under existing HAP contracts. HAP contracts are between the owner and the PHA. Along with the
PHA's obligations to the State and HUD, State agencies also have obligations to adhere to HUD
regulations and directives relevant to Mod Rehab HAP contracts. Mod Rehab HAP Accessibility and
civil rights regulations (referenced in 24CFR Part 883 Subpart D and E) at 24 CFR §5.10517 include:
o The Fair Housing Act (42 U.S.C. 3601-19) and implementing regulations at 24 CFR part 100
et seq.; and
o Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. 794) and implementing regulations
at part 8 of this title
• The applicant indicates that all but 5 buildings "have received or will be submitted for historic tax
credits." (page 13 of 62-page application). These HTC credits are administered at the state level under
the state's Qualified Allocation Plan (QAP).18
o Massachusetts 2010 QAP includes Appendix G, an accessibility checklist. The MA 2010
QAP states, "In addition to the requirements of the Massachusetts Architectural Access Board
(MAAB), projects may also be subject to other applicable federal, state and local statutes and
regulations such as the Fair Housing Act (FHA), Section 504 of the Rehabilitation Act of
1973, the Architectural Barriers Act of 1968 (ABA), and the Americans with Disabilities Act
(ADA)." (page 50)
15
Please note the MAPC Metro Boston commitment presentation by Tracy Brown (Fair Housing Center of Boston) and
Margeaux LeClair (Counsel/Specialist, DHCD) during the June 2011 meeting at
http://www.slideshare.net/MAPCMetroBoston/building-sustainable-communities-of-opportunity. this ppt provides an
overview of AFFH and Civil Rights obligations (but does not cite applicable regulations)
16
for more information about AFFH, also please see E.O. 11063
http://www.hud.gov/offices/fheo/FHLaws/EXO11063.cfm and about promoting fair housing, please see:
http://www.hud.gov/offices/fheo/promotingfh.cfm
17
full text at: http://www.gpo.gov/fdsys/pkg/CFR-2004-title24-vol1/xml/CFR-2004-title24-vol1-sec5-105.xml
18
Massachusetts Qualified Allocation Plan (2010) at http://www.docstoc.com/docs/45315131/Final-2010-Qualified-
Allocation-Plan
page 7 of 8
8. BCIL/CAPS Recommendations to MAAB on AAB Docket #V12-102, Wayne Apartments, multiple locations
Appendix Two- URGENT ACCESSIBLE HOUSING NEEDS IN GREATER BOSTON AREA
"There remains a severe shortage of affordable, accessible, and integrated units in the city and
surrounding communities." - - Bill Henning, Executive Director of the Boston Center for Independent
Living. May 8, 2012
In the Greater Boston area, the online listing of the Boston Housing Authority's (BHA) UFAS inventory may
be outdated; however, it demonstrates that there were only a handful of new BHA UFAS units created in
Roxury, Dorchester and Mattapan over the last decade. Reliable information regarding totals and % of
accessible section 8 units was not found in time for these comments.
Greater Boston area BHA totals- this is just a preliminary draft and not to be considered a final review:
The BHA has approximately 60 developments, serving ~27,000 people across ~14,000 public housing
units. Below, is a breakdown of the inventory that has been evaluated for UFAS-accessible units, and is
currently online. Out of 10,640 units, 480 are UFAS-accessible- 4.5%.:
4.2% of the total 1BR units (4355) are UFAS-accessible = 183 UFAS, 51 have roll-in showers.
4.09% of the total 2BR units (3492) are UFAS-accessible = 143 UFAS, 20 have roll-in showers.
4.63% of the total 3BR units (2180) are UFAS-accessible = 101 UFAS, 24 have roll-in showers.
6.6% of the total 4BR units (515) are UFAS-accessible = 34 UFAS, 12 have roll-in showers.
2.46% of the total 5BR units (81) are UFAS-accessible = 2 UFAS, 1 has roll-in shower.
There are 17 6 BR units, but 0 UFAS
Wayne Apartment's totals: On page 3 of the Variance application, the unit breakdowns of Wayne
Apartment's accessible units are summarized. Out of a total 349 units, only 18 units are listed as "HP." The
applicant provides no information regarding how such units were evaluated for accessibility.
This information shows that Wayne Apartments currently offers 2 accessible 1BR units in Dorchester; and, 2
1BR units in Roxbury and no 1BR units in Mattapan. Wayne Apartments currently offers 14 accessible 2BR
units in Roxbury and none in Dorchester or Mattapan. 7 of the 2BR units in Roxbury offer adaptability for
Hearing impaired tenants; and none in either Dorchester or Mattapan. Wayne apartments currently
provides no Group 1 or 2 3BR, 4BR or 5BR family units in Dorchester, Roxbury or Mattapan. No accessible
units in portfolio are located in Mattapan.
Maximizing accessibility at all site locations should be a top tier priority objective
of this Wayne Apartments rehabilitation project.
page 8 of 8