Comment focusing on Section 583.325 under Department of Housing and Urban Development's (HUD) Proposed Rule submitted by Ajaz Fiazuddin, Disability Rights Center of Maine

I am a staff attorney with the Disability Rights Center of Maine. I am a little concerned with the language of Section 583.325 of the proposed rule, which is entitled: "Relationship between grantee and supportive housing residents". The plain language of the section can be read to mean that a persons tenancy in a supportive housing can be terminated immediately by written notice stating a reason. There is no provision, at least within the text of this section, that defines some period of days before the termination takes effect. For persons with disabilities, particulary mental illness, it is critical that they have opportunity to seek counsel and consider seeking reasonable accommodations when faced with a termination of any housing. The time period between being served with a Notice of Termination and the actual termination itself is the only practical opportunity to address the situation that the tenant with disabilities has. There should be some reasonable amount of time required, therefore, in the text of the termination regulating when it actually becomes effective. State law in Maine provides, in the absence of a lease, for notice periods running from 7 to 30 days based on the circumstances. In this section, at least a 7 day notice period would be in order - and a 30 day period would most certainly afford the time needed to seek counsel and accommodations to most tenants with disabilities. Thank you for your consideration of this comment. Disability Rights Center of Maine This record submitted to HUD-2004-0001 was incomplete. There was no actual comment entered.