If a townhouse development does not have any single story only units than it is exempt from the Fair Housing Act requirements including site requirements such as parking, mail kiosks, accessible dumpsters. If the site contains a place of employment or a facility that is rented out to the general public, handicap parking would be required for those uses.
From the Fair Housing Act Design Manual (1998) - PUBLIC AND COMMON USE AREAS
NOT COVERED BY THE GUIDELINES - Where a newly constructed development consists entirely of buildings of four or more multistory dwelling units without elevators (e.g., two-story townhouses), the development is not required to comply with the Fair Housing Act or the Guidelines. Since there are no covered multifamily
dwellings on the site, no public and common use areas anywhere on the site are required to be accessible. Note, however, that the Americans with Disabilities Act (ADA) of 1990 may apply. This is per the Fair Housing Act, however local jurisdictions may require accessible parking to be provided per their local zoning code requirements.
I agree with Larry Schneider's comments.
