Housing Authorities and Language Access Plans

Housing Authorities and
Language Access Plans
NAVNEET GREWAL
LEP ADVOCACY 201:
BEYOND THE BASICS
NLADA ANNUAL CONFERENCE
NOVEMBER 19-22, 2009
What We’re Covering Today
 What is the PHA Planning Process?
 How can advocates get involved?
 Comments
 Public Hearing
 Follow Up
What are PHA Plans?
 Annual Plan
 Annual Process
 Must make civil rights certifications
 Must attach Administrative Plan and/or ACOP
 Administrative Plan
 Section 8
 ACOP
 Public Housing
 Language Access Plan
Sample Policy (Common)
How to Get Started
 Obtain relevant documents
 PHA office
 Hard Copy/Email
 PHA Website
 HUD web site
 Approved Plans
 http://www.hud.gov/offices/pih/pha
 Determine if there are partners in the community
 Residents
 Other advocates
Timeline
Jan 1
FY
Start date
April 1
FY Start
Date
July 1
FY Start
Date
Oct. 1
FY Start
Date
PHA should begin to develop plan for coming year. RAB and
tenants should review prior year plan, develop issues, determine
progress on prior year goals and strategies. Current year approved
plan attachments and supporting documents are available for review
May
(Prior Year)
Aug
(Prior Year)
Nov
(Prior Year)
Feb
8 mos
8 mos.
8 mos.
8 mos
PHA should have available a draft plan and should be discussing the
plan with RAB and tenants and other advocates, such as housing
advocates, disability rights groups, homeless advocates and other
agencies such as welfare and jurisdiction consolidated plan agency
Mid-July
(Prior
Year)
Mid-Oct
(Prior Year)
MidJan.
MidApril
5.5 mos
5.5 mos
5.5 mos
5.5 mos
Notice of hearing, proposed plan on file for review, RAB members
names published
Mid-Aug
(Prior Year)
Mid-Nov.
(Prior Year)
Mid-Feb
Mid-May
4.5 mos
4.5 mos
4.5mos
4.5 mos
Public hearing
(time should be allowed between public hearing and date plan is due
at HUD to make revisions based upon public comment)
First week
Oct
(Prior Year)
3 mos
First
week
Jan
3 mos
First
week
April
3 mos
First
week
July
3 mos
Plan due at HUD
Mid-Oct.
(Prior Year)
MidJan
MidApril
MidJuly
2.5 mos
2.5 mos
2.5 mos
2.5 mos
Jan 1
April 1
July 1
Oct. 1
Action
HUD approves plan and notifies PHA. PHA provides RAB with a
copy of approved plan, notice of approval and funding awards. Or
plan rejected
Key Players
 Public Housing Residents and Voucher Participants
 Resident Advisory Board
 Others in the community interested in the issue
 PHA Staff
 PHA Board of Commissioners
 HUD
 City/County
Case Study
Initial
Comments
(Submitted by NHLP
and Bay Area Legal Aid)
Initial
Comments
Public Hearing
 Who is on the Board of Commissioners?
 What is on the agenda?
 Who will attend?
 Often limited to 2-3 minutes
 Required to respond to RAB comments
 Will often respond to all public comments (see materials)
Follow Up
 Set up meetings between all interested parties and





housing authority - legal services, community
organizations, appropriate housing authority staff
Engage in drafting LAP
Education
Often a long process
Often incremental
Reassessment
Draft Plan
Adopted Plan
Training
List languages
Discourage use of
friends/children as
interpreters
Adopted Plan
Vital Documents
Ongoing Advocacy
 Continue to monitor plan and efficacy
 Engage in trainings
 Use next year’s plan process if necessary
 Informal complaint to Board of Commissioners
 Informal complaint to HUD FHEO – Regional Office
 Informal Hearings/Grievance Procedures
 Formal Administrative Complaint
Summary
 PHAs required to engage in annual planning process
 Most PHAs have not created a language access plan
 Ensure that all players are engaged in developing plan
 Advocates can influence the process significantly
 Requires ongoing interactive process and monitoring
NAVNEET GREWAL
STAFF ATTORNEY
NATIONAL HOUSING LAW PROJECT
[email protected]
(510)251-9400 EXT. 3102