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Facts: In 1999, a PHA launched a 10-year plan to update its housing. In 2000, HUD gave the PHA conditional approval for a prescribed period of five years during which time the PHA was to take certain actions to ensure it could adequately meet the needs of the disabled. The PHA planned its overall renovations to meet the requirements of Section 504 of the Rehabilitation Act by constructing a percentage of its units to accommodate mobility-impaired individuals and a percentage of units to be accessible to individuals with sensory impairments.
