Comment submitted by C. Grove

DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT [Docket ID HUD-2005-0032, Document ID HUD-2005-0032-0001] Monday, November 07, 2005 Regulations Division Office of General Council Department of Housing and Urban Development 451 Seventh Street, SW, Room 10276 Washington, DC 20410-0500 Thank you for this opportunity to submit public comment on ?HUD?s Draft Section 504 Self-Evaluation Report on HUD-Conducted Programs and Activities?; Reopening of Comment Period [Docket ID HUD-2005-0032]. While it is heartwarming to see attention to wheelchair accessibility and some other most recognized disabilities, we see no recognition of breathing disability, particularly for those most medically dire like myself for whom it is a matter of life and death, not just quality-of-life and inclusion in some programs. The most obvious omission is not addressed in this draft. That is lawful right to habitability in HUD funded housing which, for breathing disabled persons requires protection from neighbor nuisance irritant fumes unachievable under current multi-housing construction standards. Each repetitive and preventable irritant-induced respiratory exacerbation leads to increased fibrosis and progression of disease, potentially to known pollution-induced outcomes as irreversible emphysema and cancer. Taxpayer burden from this lack of effective preventative measures that proper accommodation could provide include increased medical expenses including predictable earlier loss of function and resultant institutionalization (including assisted living and nursing home placement) and prevention of path off declining spiral of welfare not easily adjustable to by the infirm and former high income tax contributors. This ?soft? cost taxpayer burden is in fact quite high when we consider that only one small segregated (as required by this special needs disability population) Section 811 unit has been reported provided since the 1990?s thereby providing only .000001% accessibility according to statistics provided in US Government funded disability report. Technology, availability and affordability are no longer obstacles that faced this commendable accommodation effort of the 1990?s. ?Green? building, including affordable green building, is booming. However, to be accessible to the most medically dire of breathing disabled persons, modifications which address both indoor and outdoor air quality issues must be addressed in the design phase. In the interim, the most medically dire breathing disabled persons as myself should be afforded special assistance in single family or segregated multi-housing units shared by others with these accessibility requirements and protected by protective covenants. Credible government and accepted standard-of-care medical and scientific advances of the last few years would not be represented in accessibility standards identified as used for your report, however they fully support the need for immediate accessibility attention for the most medically dire breathing disabled persons, some of whom have concomitant communication and cognitive complications. I would be happy to provide technical assistance including referral to credible and current data sources to assist in this most critical priority and travesty of the most basic of civil rights, the right to breathe. Respectfully submitted, C. Grove seagrove62@yahoo.com P.O. Box 6114 Middletown, R.I. 02842