hud section 504, fair housing and ada vantoria clay, housing and transportation coordinator...

HUD Section 504, Fair Housing and ADA

Vantoria Clay, Housing and Transportation Coordinator

Endependence Center, Inc.

6300 E Virginia Beach Blvd

Norfolk, VA 23502

757-351-1595

757-461-7527 TDD

757-461-5375 FAX

[email protected]

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Fair Housing and Related Laws

Section 504 of Rehabilitation Act 1973 Fair Housing Amendments Act of 1988 Impact of ADA Title II State & Local Govt and

Title III Public Accommodations

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HUD Section 504 Regulations

Federally-Assisted Programs, Services and Activities

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Rehabilitation Act of 1973,Section 504

Section 504 prohibits discrimination on the basis of disability in any program or activity receiving federal financial assistance. – Whether housing or non-housing– “No otherwise qualified individual with handicaps in

the United States…shall, solely by reason of his/her handicap, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance or any program or activity conducted by any Executive agency or by the United States Postal Service.”

HUD Section 504

24 CFR Part 8

Nondiscrimination Based on Handicap in Federally Assisted Programs and Activities; Final Rule

Online:

www.hud.gov/offices/fheo/disabilities/sect504docs.cfm

Order copy:

Contact HUD’s Direct Distribution Center

800-767-7468 or email [email protected]

Order through Center’s online ordering system

www.hud.gov/offices/adm/dds/

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HUD Section 504: Who is covered?

– Public Housing Agencies (PHAs)– Cities and towns that receive funds such as CDBG– Section 8 and other PHA program and activities – Private, HUD-assisted housing providers– Student housing– Military housing– Non-profits developing housing activities with:

Section 811, HOME, CDBG, HOPWA, HOPE, Homeless Programs – Emergency Shelter Grants, Supportive Housing Program, Shelter Plus Care, and SRO Moderate Rehab Program

– Any organization receiving funds from HUD6

Section 504:Who is covered? cont.

Private, HUD-assisted housing providers– Multifamily Housing Divisionhttp://www.hud.gov/local/va/working/mf/emaillist.cfm

804-822-4875

--MFH Inventory Survey of Units for the Elderly and Disabled, Mar 2009

www.hud.gov/offices/hsg/mfh/hto/inventorysurvey.cfm

Click on Virginia

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HUD 504:What is discrimination? § 8.4

• To deny a person with a disability the opportunity to participate in or benefit from in any program solely on the basis of their disability

• What to do? – A housing provider has to provide accessible transportation if offers transportation to their tenants.

• To benefit from the Section 8 HCV program, a person with disability-related barriers that prevent him/her from being able to seek housing at all or seek housing to the extent as others without disabilities would need additional time to search.

• A PHA may have a policy that calls for one month for initial search and 1 30-day extension; and to accommodate people with disabilities, the individual can receive 1 additional 30-day notice.

• Is this an appropriate policy for a reasonable accommodation? 8


• To offer people with disabilities an opportunity to participate in any housing, program or service that is not equal to that afforded to others

• What to do? – Provide the same type and level of services. Do not require more sessions/ meetings than the home ownership program requires.

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• Provide a service that is not as effective as that provided to others

• Ex – The housing agency provides a section 8 landlord list but does not include a reasonable number of options for accessible housing.

• Ex – the housing agency chooses a location or building for housing that is not or cannot be altered to be accessible.

• An existing HUD-assisted development is making substantial alterations to a mix of 1, 2 and 3 bedroom units. Should the provider ensure that 1 bedroom units are accessible?

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• Provide separate aids or services unless it is necessary in order to provide an equal opportunity.

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HUD 504:What is discrimination? (§ 8.4 )

• Provide a significant aid or assistance to any agency that discriminated on the basis of disability

• Ex – A PHA should not provide land or funding to a housing developer that does not accommodate applicants and tenants with disabilities or is not in compliance with FHAA or Section 504 accessibility requirements.

• What to do? Have the developer to make assurances that they will comply with Section 504 and/or FHAA accessibility requirements. 12

HUD 504:What is discrimination? (§ 8.4 )

• Deny a person with a disability the opportunity to participate as a member of a planning or advisory board

• What to do? Ensure that people with disabilities are represented on the PHA’s Resident Advisory Board, or any boards or committees that a federally-assisted agency forms.

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For program accessibility, an agency must provide effective communication. For verbal and written communications/material.

All information must be available in alternate formats or through an auxiliary aid. Examples: Sign language interpreters, Braille,

audio cassette, computer disk, large print, personal listening devices (amplifies speech), note-taking, etc.

HUD 504: CommunicationsSection 8.6

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HUD 504: Communications cont.

Type of alternate format or auxiliary aid Primary consideration given to individual’s

preference; if the format would cause a fundamental

alteration to the program or an undue financial/ administrative burden, another format must be selected that would be equally effective.

HUD 504: Communications - cont.

Phone communication: TDD Virginia Relay Training on TDD and Virginia Relay

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HUD 504: Accessibility Standards (§ 8.32)

Accessibility standard used: UFAS – Uniform Federal Accessibility Standards

– Facilities– site/office for a non-housing program – alterations and new construction

– Residential: Common and public areas Dwelling units (multifamily and home ownership)

Or, other standard that is equal or more strict– Design and New construction– Additions to existing buildings– Alterations and substantial alterations

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Section 504: UFAS

Residential– Apartment housing

Federally assisted – minimum of 5% of dwelling units, or greater according to a local needs assessment

Federally owned – minimum of 5% of dwelling units

– Single family homes and duplexes Rental – minimum of 5% of the total, or greater according

to a local needs assessment Home ownership – 5% of total; if built per home buyer,

accessibility determined by the home buyer. 18

HUD 504: Accessibility Standards

Published by the Access Board (Architectural, Transportation Barriers Compliance Board)– www.access-board.gov/ufas/ufas-html/ufas.htm

Enforced by HUD Note: bedrooms of accessible dwelling units

– UFAS requires at least 2 bedrooms to be on an accessible route within the unit

– However, because of HUD 504 regulation to provide equal benefit, all bedrooms in an accessible dwelling are required to be on an accessible route.19

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If the recipient has a facility or housing that is not accessible, people with disabilities cannot be excluded from accessing, participating in or benefiting from a federally-assisted program or activity. -- Section 8.20

– Non-housing facilities Facilities existing at time HUD regulations were published in 1988

Alterations, other methods and Transition Plans Locating an existing facility New construction

- Housing buildings and dwelling units Alterations Substantial alterations Transition Plan

HUD Section 504: Program AccessExisting Programs

Program Accessibility: Non-housing programs

• Non-housing facilities• Alterations – to the maximum extent feasible

be made readily accessible to and usable by people with disabilities.

• That does not impose an undue administrative and financial burden on the operation of the program or activity.

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• A program or activity has to be viewed in its entirety to determine whether it is accessible to people with disabilities

• Not every non-housing facility has to be made accessible

• Applies to existing programs at the time HUD 504 regulations were made final.

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Other ways to make a program accessible– Recipient can relocate its program to another

building that is accessible Currently owns; acquire new building or new-construct

– Relocate program to another floor or area of the building that is accessible

– Make alterations to a certain area or rooms of the building to be accessed by the public

– Make home visits

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In selecting methods, the agency must ensure that the program or activity is provided in the most integrated setting– If the program involves group sessions, consider

that location to be made accessible or relocate the sessions to another location vs. meeting individuals with disabilities separately at another location.

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Impact of equal access, benefit and participation in Program Accessibility

Now that HUD’s 504 implementation regulations have been around since 1988, agencies and housing providers should be familiar with the need for physical access to support program accessibility.– HUD 504 regulation requires under the

discrimination prohibited section:In determining a site or location to operate a

federally-assisted program, should not make selections which would exclude people with disabilities or deny the benefits of.

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Program Accessibility: Existing Housing & Transition Plans

If private, HUD-assisted provider is to make structural modifications (Sec 8.24)

Recipients had to develop a transition plan – which initially was due by Jan 1989.

Must continue to update Transition Plans as barriers are identified through self-evaluations.

Transition Plans are required to be made available for public review.

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Program Accessibility: Transition Plans cont.

Identify physical obstacles Describe in details the methods that will be used to

make the facilities accessible Specify the schedule for taking the steps needed to

remove physical obstacles Indicate the staff person responsible in overseeing

the plan Identify the persons or groups involved in

preparation for the plan.

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Public Housing Agencies:Transition Plan and Needs Assessment

Assess the needs of current tenants and applicants for accessible units to determine how many accessible units are needed.– Continue to be encouraged by HUD to conduct a

needs assessment at least annually.– Work with people with disabilities and advocacy

groups.

Were to develop a transition plan to show what will be done over the next 4 years.

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Self-Evaluation Plan:All assisted programs (§8.51)

Required by Section 504 If state and locally funded, ADA Title II Agency is required to consult with people with

disabilities and advocate groups Evaluate all policies and procedures to identify

any discrimination and to ensure program accessibility

Review employment policies Review of housing policies

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Self-Evaluation Plan cont.

Rewrite those policies that do not meet 504 requirements

Write corrective action plan and take corrective steps to remedy the discrimination

Self-Evaluation Plan cont.

Areas to be evaluated: Buildings or facilities for physical accessibility Program outreach and communication Eligibility and admission criteria and practice Distribution and Occupancy policy and practice Percentage of accessible units Employment (including pre-employment) Complaint processing procedure

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New Construction – Section 8.22Housing built after 1988; rental and salesA minimum of 5% of the total of the dwelling

units or least one unit whichever is greater, shall be designed and constructed to be accessible for persons with mobility impairments. An additional 2% of the units (but not less than one unit) shall be accessible to persons with vision or hearing impairments.

Program Accessibility:Housing Programs

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Existing Housing Facilities – (as of June 1988)Substantial alterations – Section 8.23 (a)

If alterations 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, then the provisions of §8.22 for new construction shall apply.* apply UFAS accessibility standards (or stricter)

Dwelling units Common and public areas



Other alterations–Section 8.23 (b)Other alterations made to dwelling units and common

areas must, to the maximum extent feasible, be made accessible.

Up to the point where it would not impose an undue financial and administrative burden

For example, if the front entrance was renovated, instead of replacing the 2 steps, the entrance walkway should be graded.

If alterations include both kitchen and bathroom then entire unit must be made accessible, including entrance door.

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Need for more than 5 percent accessible units

For both new construction and alterations to existing housing:

A recipient of a federally-assisted housing activity may request to HUD to make more than minimum required amount accessible based upon documentation showing need (using census data or other current data).

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Program Accessibility – Housing Providers

Accessible units should be evenly distributed throughout the different sites, to include comparable number of bedroom sizes and amenities

Advertising and outreach to people with disabilities

Maximize the use of available accessible units Lease agreements for renters without

disabilities occupying accessible units

Program Accessibility: Reasonable Accommodations

Must provide reasonable accommodations Make a change, adaptation or modification to a rule,

policy, practice, procedures or to a workplace which will allow a person with a disability to participate fully in a program, to use and enjoy a dwelling unit, common and public areas, take advantage of a service, or perform a job.

Examples:Assisting an individual with limited mobility with

filling out an application.Home visit if the person has no transportation to

get to the facility or site.37

Program Accessibility: Reasonable Accommodations

Mail a rental or program application to the individual who is not able to come to the site because of their disability.

Provide services in another location that is served by paratransit.Accepting a professional or personal reference if an applicant

does not have a recent rental reference after being in a nursing home for several years.

Post reminders on apartment door for rent due for a tenant with a brain injury.

Unit modifications – ramps, grab bars, wall-hung bath sink, automatic door opener

Assigning a larger sized unit to accommodate a live-in aide.

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Reasonable accommodation requests

Who covers costs for reasonable accommodations? Housing provider or the agency operating the

program, activity or service What is reasonable?

Will not impose an undue financial and administrative burden on the agency/housing provider

Will not result in a fundamental alteration in the nature of the program or operations

Ex – a request to provide housekeeping services which are not already included in the housing program39

Reasonable Accommodations

If the request is determined to be unreasonable, the agency or housing provider can offer another accommodation.– Will need to meet the needs of the individual.– Or, the individual can request another type of

accommodation.

Staff needs to be aware that the individual may not use the term “reasonable accommodation” when requesting an accommodation.

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Section 8 HCV Program: Program Accessibility

• Ensure that public notices and advertisements reach people with disabilities.• Send to organizations and interest and advocate

groups that assist people with disabilities.• Include nursing homes, long-stay hospitals and

ICFs/MR.• Provide various ways to advertise – internet,

churches, social service programs, senior service agencies, libraries, etc.

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• Encourage owners with accessible units to participate• Single family homes – constructed or modified• Apartments – buildings with 4 or more units

constructed after March 1991 are to meet FHAA accessibility requirements

• Older apartments – modified by owner or previous tenant

• Educate owners on “value of accessibility” as an incentive to modifying existing housing

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• Include accessible housing in the current housing referral list• In most cases, which is required, the Section 8

worker will need to assist the individual in locating an available accessible unit.

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• Agency is required to provide search extensions to accommodate those having difficulty with locating accessible housing.• An accommodation can include allowing the

individual to port the voucher to another location.• To promote Money Follows the Person, HUD

encourages agencies to modify policies to include a longer initial search time for individuals transitioning from nursing homes and other institutions (HUD PIH Notice 2005-05).

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The only option for an accessible housing could be for a unit that has a higher rent than what the payment standard allows– The agency is required to request an exception

above 110% of the FMR to the HUD field office.– Above 120% to the Headquarters office.

Required to contract with landlords assuring that they will not discriminate applicants and renters on the basis of disability.

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It is recommended that Section 8 workers be knowledgeable of FHA protections concerning illegal questioning, providing reasonable accommodations, permitting reasonable modifications and if new construction, meeting FHAA accessibility requirements.– To effectively ensure that a HCV recipient has equal

opportunity to housing and able to fully use and enjoy the dwelling; thereby, have opportunity to benefit from the Section 8 program.

Section 504: Policy Evaluation and Grievance Procedures

Designate 504 Coordinator - Section 8.53– Federally-assisted entities with 15 or more

employees must designate at least one employee to oversee its compliance with Section 504. Grievance procedures must be established for recipients of federal assistance.

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HUD Section 504 Resources on CD

• HUD PIH Notice 2006-13 – Non-Discrimination and Accessibility For Persons with Disabilities

• Reasonable Accommodation Resource Guide, M Yohe, Office of Public Housing, US HUD

• HUD Notice H 01-02 – compliance with Section 504 and the Disability/Accessibility Provisions of the FHA of 1988 (private, MFH providers)

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Fair Housing Amendments Act

Disability Related Provisions

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Fair Housing ActProtections for People with Disabilities

Illegal Inquiries– it is illegal to inquire whether a person has a

disability– to make an inquiry as to the nature or

severity of a person’s disability

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Do you take medications?Why do you receive SSI?Have you been in a drug rehab program?Do you have a disability?Are you able to live independently?Are you sure you can live alone?

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Certain questions are permitted only if they are asked of all applicants

Whether the person can meet the requirements of ownership or tenancy

Whether the person is qualified for housing that is designated only to persons with disabilities or to persons with particular types of disabilities

– In assisted housing, HUD permits designated housing for people with physical disabilities, developmental disabilities, or chronic mental illness.

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The Act does not protect a person whose disability– would constitute a direct threat to the health

and safety of other individualsmust be supported with recent, credible,

objective evidence– would result in substantial physical damage

to the property of others

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Right to request a reasonable accommodation– it is illegal to refuse to make reasonable

accommodations in rules, policies, practices, or services, when such accommodations may be necessary to afford such person equal opportunity to use and enjoy a dwellingto include public and common use areas

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Examples:– Reserved accessible parking space– Notification in advance for tenant with chemical

sensitivity of painting and pest treatments.– Waiving parking fees for personal assistant.– A landlord assists an applicant with a cognitive

disability in completing an application.– A landlord makes an exception of the “no pet” policy

for a tenant who needs a service animal.

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When requesting an accommodation, person must show– has a disability as defined in the Act– notify the landlord that they have a disability (if

necessary, doctor’s note for verification)– Why the request is necessary to be able to use

and enjoy the dwellingExample – because of my disability, would not be

able to live in the dwelling without their service animal.

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Other facts:– To ignore or deny an accommodation

request is illegal– A person with a disability can request more

than one accommodation during their tenancy

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A housing provider can only deny an accommodation request if:– the request would impose an undue burden

an unreasonable financial or administrative burden look at the overall financial resources available to the

provider

– it would cause a fundamental alteration a significant change in the nature of services provided

(for instance, the housing provider paying for home care services, taking care of a pet for someone who could not because of their disability).

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Can be requested:– While applying for housing --

an accommodation can be requested that would help you meet tenancy requirements to qualify as a tenant

– An applicant may not have regular tenant histories because they have been living in a nursing home for several years. They can request accommodation to provide a letter from a service provider assuring the landlord that the person is reliable to pay the rent on time.

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When the tenant is being evicted because of a lease violation– tenant has to show that the lease violation or behavior

was caused by his disability– the accommodation has to enable the tenant to

comply with the leaseExample, acquire treatment that would resolve

disturbing and threatening behavior to other tenants.

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During tenancy:– If tenant becomes disabled or disability becomes

more severe, they may need to move to an accessible or ground floor apartment.

Can request to transfer lease and security deposit to another unit.

Can request to be permitted to terminate the lease with loss of security deposit and other penalties.

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Reasonable Modifications

Right to request a reasonable modification– It is illegal for any person to refuse to permit, at

the expense of a person with a disability, reasonable modifications of existing premises occupied or to be occupied by such person if such modifications may be necessary to afford such person full enjoyment of the premises, except that, in the case of a rental, the landlord may where it is reasonable to do so condition permission for a modification on the renter agreeing to restore the interior of the premises to the condition that existed before the modification, reasonable wear and tear excepted.

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Modification - means any change to the public or common areas of a building or any change to a dwelling unit.

At the tenant’s expense May be required to make restorations.

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The tenant does not have to restore all modifications. – Example: a widened doorway would not interfere

with the next tenant’s use of the apartment.– Modifications made to the public and common

areas are not required to be restored.

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Tenant has to ensure that the work will be done in a workmanlike fashion.

For interior modifications, the tenant may be required to establish an escrow account to cover the costs of restoring major changes (that would interfere with the next tenant’s use of the unit) to its original condition; such as restoring kitchen cabinets to their original height.

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If the next tenant wishes to keep the modifications in place; then the landlord is required to return the escrow deposit to the previous tenant.

It is recommended that modifications remain in place to increase options for accessible housing and because there is a demand for these features.

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Fair Housing Act:Design and Construction Requirements

Applies to multifamily dwellings with four or more units which were constructed for first occupancy on or after March 13, 1991.

Design and construction requirements apply to the following:– all dwelling units in buildings containing 4 or more

units if the buildings have one or more elevators– all ground floor dwelling units in other buildings

containing 4 or more units (no elevator)

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Design and Construction Requirements

Buildings that are not covered: Detached single family homes Duplexes or triplexes Multistory townhouses (this is because the entire

unit is not on the ground floor)

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If the building contains multistory townhouses and single story units, the building as a whole is covered under the FHA, which means that the single story units on the ground floor have to be in compliance and all single story if there is an elevator.

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A multistory unit would be covered if it contains an elevator that provides access to the different levels of the townhouse.

If the entry level of the multistory unit has access to a public elevator, then that level must comply to accessibility requirements.

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HUD has adopted 7 “safe harbors” for accessibility standards ANSI A117.1 (1986, 1992, 1998) HUD FHAAG (issued 1991) The Fair Housing Act Design Manual (1998) Code Requirements for Housing Accessibility

2000 International Building Code 2000 with 2001

Supplement

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Meeting the Guidelines cannot be considered fully accessible; however it does give people with disabilities greater freedom to choose where they live.

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Design and Construction Requirements7 Technical Requirements

1. An accessible building entrance on an accessible route

• if there are separate entrances for ground floor units, each entrance must be accessible.

• if there are common entrances to a multi-unit building, at least one entrance--primarily used by residents for entering the building--must be accessible.

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An accessible entrance must be located on a route that a person in a wheelchair can easily travel, and must lead to and from meaningful locations such as parking, dumpsters, public transportation, other buildings in the complex, and amenities such as laundry rooms and recreational facilities.

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2. Accessible public and common use areas• Parking areas, passenger loading areas, lobbies,

lounges, halls and corridors, elevators, public restrooms, and rental or sales offices must be accessible.

• Drinking fountains, mailboxes, laundry rooms, community and exercise rooms, swimming pools, playgrounds, recreation facilities and nature trails must be accessible.


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At least half of the drinking fountains should be accessible.

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Bathrooms in a public area must be accessible with grab bars and maneuvering space.

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Dumpster should be accessible.

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3. Usable doors• Doors must be wide enough to enable a person in

wheelchair to maneuver through them easily.• Public and common use doors, doors leading into

an individual dwelling unit, and all doors within the unit are included.

• Doors must have a minimum clear opening width of 32 inches (measure from face of the door to the stop, with the door open 90 degrees).


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3. Usable doors (cont.)• All types of doors are covered, including hinged

doors, sliding doors and folding doors.• Doors leading to any outdoor amenities the unit

may have, such as a balcony, patio or garage, are covered. If a deck or garage has doorways leading to two or more separate rooms, all these doors must be usable.

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4. Accessible routes into and through the dwelling unit. The threshold of a unit’s exterior doors may not ex-

ceed 3/4 inch (this also applies to sliding door tracks). In single-story units, changes in height of 1/4 to 1/2

inch must be beveled. Those greater than 1/2 inch must be ramped or have other means of access.

An accessible route inside the unit must have a minimum clear width of 36 inches.

Hallways, passages, and corridors must be wide enough to allow room to maneuver a wheelchair throughout the unit.


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5. Light switches, electrical outlets, thermostats, and other environmental controls in accessible locations

– Controls must be no lower than 15 inches from the floor and no higher than 48 inches.

6. Reinforced walls in the bathrooms– To allow later installation of grab bars around the

toilet, tub, shower and shower seat.


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7. Kitchen and bathrooms such that an individual in a wheelchair can maneuver about the space.

• Appliances must be located so they can be used by a person in a wheelchair. A 30 inch by 48 inch clear floor space is required for a parallel or forward approach.

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A minimum of 40 inches of clear space is required in kitchens to allow a person in a wheelchair to maneuver between opposing base cabinets, countertops, appliances, or walls.

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A U-shaped design requires a minimum of 5 feet in diameter clear space, or removable cabinets at the base of the “U”.

OR have removable cabinets under the sink with 40 inches between opposing counters.

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Design and Construction RequirementsUsable Kitchens and Bathrooms

Enough clear floor space is required in bathrooms so that a person in a wheelchair can easily enter, close the door, use the facilities and fixtures, and leave.

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Fair Housing Resources

Fair Housing Amendments Act of 1988

42 USC § 3601 et seq.

Implementing Regulation:

24 CFR Part 14 et al. Section 504 of the Rehabilitation Act of 1973

29 USC § 794

Implementing Regulation:

24 CFR Part 8

Fair Housing Resources (cont.)

DOJ/HUD Joint Statement: Reasonable Accommodations Under the FHA

DOJ/HUD Joint Statement: Reasonable Modifications Under the FHA

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Impact of Title II of ADA (State and Local Govt)

– Americans with Disabilities Act of 1990 – newest federal law that prohibits discrimination based on disability

– Title II covers housing programs, activities and services operated by state or local governments (for example, public housing, student housing operated by state colleges and universities)

– Ensures integration for people with disabilities


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Impact of Title II of ADA (State and Local Govt)

– Lack of physical access is discrimination– These programs must follow UFAS or ADAAG as

accessibility standard requires new construction and alterations to be free of

architectural barriers. each part of a facility built or altered after January 26, 1992

must be designed and constructed to be accessible.

– Requirements for effective communication, reasonable accommodations, program accessibility, self-evaluations and transition plans are similar to HUD 504.


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Public accommodations under Title III must be accessible to people with disabilities – (in housing they would be places that serve the public and not tenants only – – sales or rental office, laundry facilities, tennis courts,

recreation rooms, day care centers, or pool areas.

Buildings constructed for use after January 26, 1993 – must be accessible.

Fair Housing and Related LawsImpact of Title III of ADA (Public Accommodations)

Fair Housing and Related LawsImpact of Title III of ADA (Public Accommodations)

Existing buildings and offices must have physical barriers removed.– entrance, doors, parking and restrooms accessible.

Alterations (include renovations, repair, remodeling) made after Jan 26, 1992 to buildings and offices must be made accessible.– lobby, bathrooms, etc.

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Enforcement:

US Dept of Justice, Disability Rights Section, Civil Rights Division, P O Box 66738, Washington, DC 20035-6738.

Accessibility standards:– Title II covered entities must use UFAS or ADAAG– Title III entities must use ADAAG

Fair Housing and Related LawsTitle II and III of ADA

hud section 504, fair housing and ada vantoria clay, housing and transportation coordinator...

Documents

housing agency

hud section

housing activities

accessible housing

housing developer

supportive housing program

cdbg section

fair housing amendments