Thank you for your interest in what we are doing to make our programs and services more accessible. Any comments listed below were provided during the public comment period prior to the publication of the initial final Five-Year Accessibility Plan. Each year we will be posting a Progress Report, so check back.
7 Responses
During evacuations and other emergencies leading to fire alarms in the past two years, communication over the public address system has been a combination of vague or unclear (e.g. evacuate if you choose to), muffled or inaudible, unaccompanied by audible alarms, and/or stated once and not repeated. The agency should consider internally publishing the procedures for the types of communication and corresponding action staff should take in the event of an alarm based on the status of the emergency (e.g. under investigation, evacuation required, evacuation recommended).
For plain language documents, the current language access plan does not sufficiently address scenarios where due to the complexity of the issue, language needed to describe it, and/or need to be comprehensive to avoid legal liability a document cannot meet plain language standards. This has contributed to the delayed, partial, and/or incomplete implementation of the language access plan. For such documents, the agency should consider amending the plan to allow for or encourage a plain-language summary followed by a more comprehensive document that may not meet plain language standards.
Would you please include “captions” as part of online meetings (e.g. Zoom and Microsoft Teams) so it is easier to understand what is being said?
accommodations for people with low vision include large print text, handouts, signs, and equipment labels.
Other examples of accommodation for people with low vision include providing seating where the lighting best meets their individual needs.
Individuals with hearing impairments may have difficulty following instructions when delivered in large and open settings, particularly if the acoustics cause echoes or if the speaker talks quietly, rapidly, or unclearly.
Visual warning systems for emergencies may also need to be installed, mobility impairments range from lower body impairments, which may require use of canes, walkers, or wheelchairs, to upper body impairments, which may result in limited or no use of the hands. It may take longer for individuals with mobility impairments.
HPD has the potential to leverage digital technology platforms, including QR codes, to enhance accessibility for individuals with visual impairments. This initiative will streamline the process of public document completion by providing audio descriptions of the document’s contents, which can be accessed by scanning the QR codes with a smartphone or other compatible devices.
Digital Accessibility, Robinson, Jeraine
Physical access and programmatic access:
The five year plan does not mention HPDs work ensuring that Section 8 and other subsidy program participants can find accessible housing. HPD should consider assessing participant awareness and fair and timely processing of reasonable accommodation requests, especially for accommodations which HPD would provide, such as subsidizing living space for personal care assistants.
Workplace inclusion:
The EEO office held an Employee Resource Group launch meeting on July 14, 2023. I asked about recognizing Disability Pride Month (July), in keeping with other EEO programming such as French American Heritage Month. HPD should consider adding Disability Pride Month, National Disability Employment Awareness Month, and/or National Deaf History Month to its calendar of EEO programming.
The five year plan expresses a lot of confidence about HPDs handling of employee requests for reasonable accommodation. My experience as a disabled employee who needs an accommodation has been difficult, and I have heard from others that I am not alone. Once I had to appeal a wrongful denial (my appeal was successful). The agency makes what should be a simple process exceptionally difficult, often seeking unnecessary additional information from doctors and requiring repeated documentation of the same need for the same accommodation at arbitrary times. Whether through training or policies, HPD should simplify the process and ensure that no more documentation is requested than is actually required to conduct a genuinely collaborative dialog, and that requests for accommodation are not wrongly denied.
Accomodations for effective communication for people with hearing loss today should include the availalbiltiy of captioning of all videos, zoom meetings, and in person encounters when requested. These are readily available today on many apps and devices.
Disabled In Action of Metropolitan New York, Inc. (“DIA”) submits these comments, in the annexed letter, in response to the New York City Department of Housing Preservation and Development’s (“HPD”) request for comments concerning its Proposed Five-Year Accessibility Plan (“Plan”), posted online on or about January 2, 2024.
2-16-2024 Final DIA Comments to NYC Dept of Housing Preservation and Development Proposed 5 Year Accessibility Plan