R.S. Griffin, Architect

April 17, 1992

Stewart B. Oneglia, Chief, Coordination and Review Section
Civil Rights Division
U.S. Department of Justice
Washington, D.C. 20530

Re: Manor Inn Apartments
    Asheville, NC

Dear Mr. Oneglia:

We are currently underway with renovations of The Manor Inn. This
is a Federal Register identified historic building constructed
1899-1913 being converted into forty-four rental apartments.

The Americans with Disabilities Act is applicable to all private
entities providing places of public accommodations, including
places of lodging and places of public gathering. It is our
understanding that "places of lodging would exclude solely
residential facilities because the nature of a place of lodging
contemplates the use of the facility for short term stays" (28 CFR
PART 36, p.23) and therefore this solely residential project is
excluded from conformance with the ADA. Spaces intended for lease
for public use or events shall, however, conform with ADA
recommendations as places of public gathering.

At the request of our client, we seek your confirmation of our
understanding of the ADA as noted above. We appreciate your
assistance in this matter.

Sincerely,

Robert Sweetser, RA
RHS/dr

cc: Manor Inn Apt Group

        32 All Souls Crescent * Asheville, N.C. 28803 * (704)274-5979
01-01479