2019 Analysis of Impediments to Fair Housing: Phase 1 Report

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although a formal request will be encouraged—within 10 days. The PHA Administrative Document also states, "If the PHA denies a request for an accommodation because it is not reasonable (it would impose an undue financial and administrative burden or fundamentally alter the nature of the PHA's operations), the PHA will discuss with the family whether an alternative accommodation could effectively address the family's disability -related needs without a fundamental alteration to the HCV program and without imposing an undue financial and administrative burden." Id. at 2-11. 2.2.3 Language Access There is some question regarding the sufficiency of the agency's language access plan. In regards to improving access to services for persons with limited English proficiency (LEP), the PHA Administrative Plan appropriately identifies and summarizes the legal guidelines, including the four balancing factors for determining the level of access needed by LEP persons. The PHA Administrative Plan also dictates, "The PHA will utilize a language line for telephone interpreter services," which is an important and effective part of compliance to the legal language access requirements. The PHA Administrative also has an appropriate guideline for determining written translation needs: In order to comply with written -translation obligations, the PHA will take the following steps: The PHA will provide written translations of vital documents for each eligible LEP language group that constitutes 5 percent or 1,000 persons, whichever is less, of the population of persons eligible to be served or likely to be affected or encountered. Translation of other documents, if needed, can be provided orally; or If there are fewer than 50 persons in a language group that reaches the 5 percent trigger, the PHA does not translate vital written materials, but provides written notice in the primary language of the LEP language group of the right to receive competent oral interpretation of those written materials, free of cost. However, the PHA Administrative Plan also references a language assistance plan (LAP) and further analysis: The PHA will analyze the various kinds of contacts it has with the public, to assess language needs and decide what reasonable steps should be taken. "Reasonable steps" may not be reasonable where the costs imposed substantially exceed the benefits. Where feasible and possible, according to its language assistance plan (LAP), the PHA will train and hire bilingual staff to be available to act as interpreters and translators, will pool resources with other PHAs, and will standardize documents. If it is determined that the PHA serves very few LEP persons, and the PHA has very limited resources, the PHA will not develop a written LEP plan, but will consider 30