Apply for Reasonable Accommodation

This is a step-by-step guide and application to request Reasonable Accommodations for a dwelling unit or a public or common use area for a person with a disability when zoning standards cannot be met. This process is required by the Americans with Disabilities Act (ADA) and the federal Fair Housing Act (FHA), as amended. 

Review Process for Reasonable Accommodation

Step 1.Plan Review

Project plans must be reviewed before zoning relief can be offered. Proposed project plans are submitted through E-permits, and a plan review record will be created based on the project type (examples of record types: LOG, ZONE, ZLAM, SDP, etc.). A plan reviewer will review the project plans to determine if it meets zoning requirements. If zoning violations are found, the plan reviewer will send you a plan review notice that describes the violations and explains your option to begin the zoning relief process.

Step 2.Zoning Relief Referral

Follow the instructions in the plan review notice to resubmit the project plans (revised as needed to address other plan review comments, or not) and request zoning relief. The assigned plan reviewer will send you a link to an electronic form to request a pre-application meeting with CPD to begin and learn more about the zoning relief process.

Step 3.Request Pre-Application Meeting

When filling out the form to request a pre-application meeting, choose the “Reasonable Accommodation” option from the drop-down menu “What best describes the justifying circumstance?”

The assigned zoning relief case manager will contact you within 5 business days to schedule the pre-application meeting, which is typically a virtual meeting.

It is important that you choose the “Reasonable Accommodation” option on the request form as the reason for zoning relief. If you do not, the request will be processed with all other zoning relief requests and delay the reasonable accommodation process.

Step 4.Pre-Application Meeting

The case manager will go over the process, review criteria, and how to apply using the Request for Reasonable Accommodation – Application and Decision Form. After the meeting, the case manager will email you a meeting summary and will upload the document to the project’s zoning relief record (“ZR” record) in E-permits. The summary will describe next steps and the information you need to submit your application.

Step 5.Submit Application

If you feel you can meet all the criteria for Reasonable Accommodation zoning relief and would like to move forward in the process, you should provide any necessary information preferably by completing the Reasonable Accommodation Request – Application and Decision Form.

 The application form will ask you to submit verification of the following:

  1. The dwelling unit or a public or common use area will be used by one or more individual(s) with a qualifying disability as defined and protected by the ADA and FHA; and
  2. The Reasonable Accommodation is necessary to allow the individual(s) with disabilities equal access to or equal opportunity to use and enjoy the dwelling unit or a public or common use area; and
  3. There is a reasonable connection between the specific accommodation requested and the individual’s disability.

Submit the application by emailing the form directly to your assigned case manager.

NOTE: You are not legally required to use the application form if you have provided your ZR case manager with all the necessary information the form requests about your need for the accommodation. However, using this form can help keep information organized and make communication between you and your case manager easier.

If you are not able to fill out a Microsoft Office Word document or need other help to physically fill out the form, please let us know so that we may accommodate you.

Step 6.Application Review

Within 15 business days after your submittal, the case manager will:

  • Provide comments to you if additional information is needed before a decision can be made;

or

  • Engage in Interactive Dialogue (defined at the bottom of this page) with you to explore an alternative accommodation;

or

  • Suggest an alternative path for zoning relief that might be more successful (for example, a different justifying circumstance other than a Reasonable Accommodation);

or

  • Issue a final, written decision that approves, approves with conditions, or denies the zoning relief based on providing a Reasonable Accommodation. No final decision to deny or approve the request will be issued before engaging in an Interactive Dialogue unless you choose not to participate in one.

Step 7.Final Decision

The case manager will email you the final decision and will update the status of the zoning relief record (ZR) in E-Permits. You will receive a final, written decision that shares the reasons why zoning relief was either approved, approved with conditions, or denied. The case manager will also provide specific instructions for next steps, as follows:

  • If approved, you will be instructed to continue the permitting process by resubmitting the most recent project plans, along with the zoning relief final decision document, to the original plan review record in E-permits (i.e., LOG, ZONE, ZLAM, SDP, etc.).
  • If approved with conditions, you will be instructed on the next steps required to meet the conditions to continue through the permitting process by resubmitting the most recent project plans, along with the zoning relief final decision document, to the original review record in E-permits (i.e., LOG, ZONE, ZLAM, SDP, etc.).
  • If denied, you will be given information on how to:
    • Appeal the decision to the Board of Adjustment; or
    • Try a different justifying circumstance to request zoning relief; or
    • Revise your project plans to comply with all zoning rules.

Additional Information and Common Questions

For reference, these federal laws and local regulations govern the Reasonable Accommodation process:

  • Rehabilitation Act of 1973, Section 504 (29 U.S.C. § 794(a))
  • The Americans with Disabilities Act (42 U.S.C. § 12132)
  • Section 109 of the Community Development Act (42 U.S.C. § 5309)
  • Civil Rights Act, Title VI (42 U.S.C. § 2000d-1)
  • Fair Housing Act (42 U.S.C. § 3601-19)
  • Denver Mayor’s Executive Order #147, Compliance with and Implementation of the Americans with Disabilities Act, issued October 5, 2020.
  • Denver Zoning Code, Article 12, Zoning Procedures and Enforcement, Section 12.4.5, Administrative Adjustment.
  • Denver Revised Municipal Code, Section 59-2, Former Chapter 59, Subsection 59-2(c)(17) regarding applicable zoning law for reasonable accommodation requests under federal law.

Voluntary Compliance Agreement among the U.S. Department of Housing and Urban Development and Ben/Shawn/Catherine Johnson and City of Denver Board of Adjustment and City of Denver Community Planning and Development Department, Effective Date of August 16, 2024.

A person with a disability is someone who has a physical or mental impairment that substantially limits one or more major life activities, has a history or record of such an impairment (such as cancer that is in remission), or is perceived by others as having such an impairment (such as a person who has scars from a severe burn). If a person falls into any of these categories, the ADA and FHA protect them.

Major life activities are the kind of activities that you do every day, including your body’s own internal processes. There are many major life activities in addition to the examples listed here. Some examples include:

  • Actions like eating, sleeping, speaking, and breathing.
  • Movements like walking, standing, lifting, and bending.
  • Cognitive functions like thinking and concentrating.
  • Sensory functions like seeing and hearing.
  • Tasks like working, reading, learning, and communicating.
  • The operation of major bodily functions like circulation, reproduction, and individual organs.

Physical or structural changes to a dwelling unit or a public or common use area necessary to provide an equal opportunity for individuals with disabilities to use and enjoy the dwelling or participate in the program, service, or activity. The FHA requires Reasonable Accommodations unless they cause undue financial and/or administrative burden or significantly change the nature of the program or service.

 

Zoning relief is one way to address zoning violations discovered in the plan review or inspection phases of a development project or in the active use of a residential property. Violations can be addressed by bringing the development or activity into compliance with the zoning code or by being granted an exception from those standards through the zoning relief process. The zoning relief process grants exceptions when there is evidence of a “justifying circumstance” or condition. In Denver, there are two types of zoning relief possible: an administrative adjustment approved by CPD staff, or a zoning variance approved by an independent review body called the Board of Adjustment. All requests for reasonable accommodations from Denver’s zoning codes are processed as administrative adjustments by CPD staff.

Learn more about zoning relief

 

Plan reviewers determine whether a project complies with the city’s codes and identify any zoning violations in a development project. If violations are identified, you (or your design professional or any other representative) can work with a zoning relief case manager to request any exception(s) from the zoning code. Sometimes the two reviewers are the same staff person and sometimes they will be two different staff persons.

An Interactive Dialogue is a collaborative discussion with the assigned zoning relief case manager to find a Reasonable Accommodation that works for all people involved if your original request cannot be granted. This happens when the case manager has decided that the original request is not necessary and/or reasonable based on the information you provided. Interactive Dialogues might include brainstorming different options or suggesting changes to the original request that would make it reasonable while still meeting your disability-related needs. You are entitled to an Interactive Dialogue if your original request cannot be granted. You are not required to participate in an Interactive Dialogue but should know the original Reasonable Accommodation may be denied as a result.