Sonoma General Plan (GP) Existing Conditions Report (ECR) comments: Economics and Demographics chapter

 

Fred Allebach

6/11/24

Public comment

Economics and demographics chapter

General Plan (GP) Existing Conditions Report (ECR)

 

Data

ESRI Business Analyst and other ESRI private data sources can’t be double checked or examined for what was left out; for a public study there needs to be public data sources. Otherwise the GP ECR faces a built-in lack of trust and confidence.

 

The ECR uses ESRI tapestry segments, life mode groups to breakdown local city and SV demographic groups. How do we know what groups may be left out? The use of private, pay data is not fair for a public document. More community of interest (“life mode groups”) data detail is available from other sources, with local indicators, for social sustainability and equity. For social tapestry, why is there no group for the lower-income working class? BIPOC?  Why are they not in report? Nowhere, erased. Major oversight, especially on the city west side and in the unincorporated, contiguous Springs.

 

Recommended data sources and SV studies, these all sent by me before, with no traction

-SVUSD redistricting demographic studies, GenH studies, Los Cien Latino Scorecard, United Way Real Cost Burden, Sonoma Valley Collaborative, Hidden in Plain Sight, La Luz equity study, Hanna Fortulezas study, Catalyst Fund food scarcity study, State of Working Sonoma 2018, TCAC maps from the last five years showing trends. Also my own 2020 ACS Survey Block Group-level DAC and demographic studies. 

 

By taking too general a view, the GP ECR whitewashes city east side/ west side inequities and inequities between an incorporated, elite tourist town and a poor, unincorporated low-income, contiguous workforce. Normative boilerplate is presented that fails to see actual, significant local demographic differences. The ECR takes a perspective that normalizes inequity; the status quo is presented in a stilted way and then is unquestioned. This ECR is analysis light, paints a Pollyanna picture of Sonoma and SV.

 

Data is suspect on many counts, inaccurate, lacks local calibration. For example the ECR says “more detailed population and demographic information can be seen in Housing Element (HE)”, but this HE info is only at a Tract level, which erased east/west side differences. The HE low-balled substantial local demographic variances and now the GP is “consistent” with that. This is a concertedly inaccurate view of local demographics.

 

Examples of inaccurate data method below

I find ECR conclusions suspect; any discerning critic or analyst can’t take this ECR hook, line and sinker given the level of data misrepresentations.

 

 

Food insecurity?

For example, the ECR says “that 0.3% of adults in the City of Sonoma are food insecure due to low income.” What about the Cathy Capriola study by Catalyst Fund that showed drastically different food insecurity results than this citation by DeNovo? This illustrates how the DeNovo existing conditions report is in many ways fundamentally out of touch with what is actually going on in SV.

 

The Catalyst Fund study says one in five SV residents, 8000 people, are food insecure. This cohort lives 200% below the poverty level. How is it that various local studies paint such a different picture of Sonoma Valley than does DeNovo and the city? 

 

Well educated labor force?

The GP ECR says the “City has a well-educated labor force”, but since the GP method averages high and low educational attainment, averages east and west sides, this does not ipso facto make the labor force well educated. The east side drags education scores up.

 

Household and healthcare spending?

The ECR says city household spending is $37,000 annually? What planet are we on? How can this possibly be true? This is at Very Low and Low-income spending levels. The ECR says city residents spend $900 per year on healthcare?  WRONG! If there are so many seniors, Medicare costs alone can be $5000 plus per year plus dental, vision, hearing. It seems that DeNovo, like with its initial HE assertion that Sonoma had no history or pattern of segregation, is out of touch with what exists on the ground here.

 

Average rent?

ECR cites an average rent that is too low, this rent can’t be found anywhere; wrong data. At least explore data sources that show the high prices everyone knows are here.

 

Lacking younger population?

The ECR mentions low population of under 18 and 18-36 age cohorts and overall low city household size. Why is this? The ECR does not say, and should say it is too expensive for young families to live in elite tourist town. Dysfunctional and inequitable demographic realities can’t just be listed and then act as if it is normal.

 

Areas around city are wealthier?

For example, the ECR says the “area around city has significantly higher MHI.” Wrong! Core Springs Census Tracts and Block Groups have significantly lower incomes than wealthy areas in the city and SV foothills areas. How can this be ignored?  

 

Sustainability

GP/city needs to use formal Sustainability paradigm triple bottom line (TBL), full cost accounting framing. Where is economic and social sustainability? It’s not proper to use sustainability as a weasel word concept

-See my EJ Element chapter comments, it’s not proper to try and colipase all equity in environmental issues and EJ, this is a failure to see the world accurately.

 

An emphasis on sustainable tourism is called for that uses TBL, full cost accounting methods. City web pages on sustainability and sustainable tourism are heavily greenwashed and lack any sense of social and economic equity.

 

Failing to see and address local segregation

There is no mention of race and class segregation in the city or in SV. Real history is forgotten, almost like a grand conspiracy to say nothing about it.

 

RHNA inventory

The ECR says there are 564 potential 6^th cycle RHNA units and assumes 2.05 persons per household. The ECR says if this potential was fulfilled it would be population increase of 1,156, “potentially more if affordable housing (AH) is built to meet state requirements is targeted to families.” This assumes that the city is set as a primarily single family-zoned entity. If the state requires AH for younger families, requires means you do it, not if you might do it.

 

General impression: the city seems content to be and become a low-density, wealthy senior haven, a 2^nd home haven, an elite haven. The GP and ECR seem targeted to that general view.

 

The ECR says “AH developed under the HE will likely bring larger households into the community and diversify community’s demand for retail goods and services.” I’m sorry, but how much BS can we get here? What AH developed under the HE? Housing Opportunity Sites are constantly lost to market rate projects. High baseline costs that rich residents can pay make it so low-income residents can’t shop here or if they do, with a heavy cost burden. Local exclusivity, especially for retail is not adequately fleshed out, the ECR spins to hide disparities.

 

Wine-tourism-hospitality (WTH) combine

The ECR says that one in four SoCo jobs are in the WTH combine and that this is a multi-billion-dollar industry. What is not said is that there are lot of low wage jobs here, while the cream and gravy get skimmed off top. Benefits are not being shared appropriately; this is economically unsustainable.

 

GenH data says there are five low wage jobs in Sonoma for every lower income housing unit; let’s see this and other GenH housing research conclusions in the GP analysis.

 

Aging population

With an aging population there are more healthcare jobs but the cost of living (COL) is too high for providers to hire the needed workforce. The GP needs to open this up. High city and SV COL and high housing costs are preventing necessary workforce hires. This needs to be made clear in the ECR.

 

City budget

The ECR says property owners pay one fourth of the city budget, and the wine-tourism-hospitality combine pays 56% of city budget. It seems there is a quid pro quo to favor these two cohorts and that Sonoma is essentially a top-down syndicate to serve these cohort’s interests. Labor and renters are not seen as equal stakeholders and are not represented adequately. This is a hidden bias the GP plays into.  

 

Low wage labor is nixed out of the demographic report even as it is the working class on whose backs the whole system rides.  

 

In its GP ECR work DeNovo favors the syndicate that is paying them, why else such bias that fails to account for? The city serves wealthy clients and visitors; DeNovo serves the city, was not commissioned with an equity mandate but to get a GOP passed .

 

 

Sonoma General Plan (GP) comments: Land Use and Socioeconomics chapter of Existing Conditions Report (ECR)

 

Fred Allebach

6/5/24

Public comment

Land Use and Socioeconomics chapter of General Plan (GP) Existing Conditions Report (ECR)

 

My advice, there’s one land use choice, upzone all residential areas to an equal mix of high, medium and mixed use, make low density only 25% of total residential zoning. Single family zoning (SFZ) and single-family homes (SFHs) are a significant majority of city land use. This is synonymous with exclusionary zoning and needs to change a LOT. SFHs, stand alone and attached are 75% of all city residential units. The city is currently 70+% SFZ when the rural residential zoning category is included. How can land use diversity be achieved when preserving suburban segregated zoning is a top goal? All lower income people must live in commercial areas? The Land Use map needs serious changes.

 

The City is in a pickle in that preserving an unjust status quo is a top priority.

 

The GP has two core competing priorities, being inclusive vs. being exclusive

There is no clear policy path to finesse this tension; this tension needs to be put on the table and addressed by the Council. The GP needs plans to reconcile these conflicting goals. Having fundamentally conflicting goals is inconsistent. The GP can’t be “consistent” with such a wide-open gulf of priorities. Diversity and equity are claimed as city values but protecting exclusivity is the dominant theme. Something has to give here.

 

Low density character and neighborhood compatibility are code for maintaining exclusivity and segregation. Part-ways the inclusive/ exclusive dynamic is one of a conflict of interests between  40% renters and 60% property owners. In the US, the unlanded are equal citizens and stakeholders and suburban cities should not be syndicates to protect owners over renters.    

 

Long term RHNA deficit

The facts not on the table for city RHNA performance from 2000 – 2020. In this time frame, Very Low, Low and Moderate units were underproduced by 263 and Above Moderate were overproduced by 296. Why is there such resistance from the city to cite this? The city has a housing equity deficit running and won’t admit it. 

 

UGB

The UGB’s four poison pill clauses are a gov’t constraint on housing. The UGB is not sufficiently flexible. What we have in Sonoma is a Green Checkmate, a choice that maintains segregation; green values and neighborhood character values eclipse equity values.

 

The UGB “encourage(s) sustainable growth.” With sustainable used as such a weasel word, who can say what sustainable growth is?  The GP needs to include economic and social factors here.

 

Data

Data used presents a no-equity, anodyne view. Segregation not seen, ignored, therefore there is none, justified away. DACs are defined by DWR differently than by Cal EnviroScreen, by choosing certain views, the city is methodologically blind, does not see real patterns. If the ECR set the baseline of how things are, the assumption seems to be to make it so general as to elide many serious issues that need attention.

 

ACS data can suss out a lot of demographic info as I did in my own ACS studies. The Housing Element (HE) low-balled local geographies with a Tract-level view, now a foolish consistency with this HE view and too general a GP view foils seeing the actual in existing conditions. 

The GP too-general view is inaccurate and misses critical demographic facts. The GP is not catching significant wealth disparities, not seeing it.

 

GP monthly housing costs seem unrealistically low. If prices were as GP says there would not be a housing crisis. I cannot find anything for those prices.

 

There are DACs in contiguous unincorporated areas in the GP analysis period that cuts off in 2023. No excuse to not see the actual.

 

Land Use Map: Please increase diversity of land uses

Sonoma has 65% single family zoning (SFZ), 70% if the rural residential category is included.  How to get to demographic diversity when protecting exclusionary zoning is a top city goal?

 

SFZ and SFH residential areas qualify as underutilized space; if this space is not pursued for higher density infill, the city is not serious about land use changes to amplify needed race and class diversity. Martinez v Clovis case law shows that SFZ is indeed underutilized space and is linked to segregation and lack of AFFH

 

Housing Element and current zoning land use now puts all equity chips and onus on the Hwy 12 commercial strip. 88% of 6^th cycle RHNA for Low and Very Low-income units is put on three sites on Hwy 12, two of these on West Napa have feasibility issues. These two W. Napa sites are also in the poorest part of town while the wealthier, SFZ east side will have only one Low income unit for the whole 6^th cycle.

 

The UGB deal in a two square mile city is for the city to take denser infill and to support more inclusion and diversity, so much single-family housing (SFH) and SFZ has to change if land use equity values are to succeed. All equity can’t be foisted on a commercial strip on the poorest side of town. This just preserves a segregated suburban stasis.

 

AFFH is methodologically elided in HE and GP by too general a focus

The city west side is significantly poorer with lower scores overall. The GP and HE are not seeing the actual with tract and city level analysis. Why be consistent with a wrong view?

 

Suggestions for land use changes

Upzone a lot

Sonoma’s 70% SFZ and SFH segregates by class and race; the poor, the bottom of the hourglass, get Mixed Use and Commercial zoning, this with the stilted lower income RHNA site inventory seems to add up to AFFH violations. All the poor in high density Commercial is a feudal living arrangement. The workers can get no neighborhood character?

 

Land use map

Fig 1.1-2 fails to note Sonoma Valley hop scotch development of sanitation plant, Temelec, and 8^th E industrial area. The Urban service area of developable land needs to be noted

 

With the chart showing dates of earlier residential development patterns, if cross-town variances can be shown for building ages, why not for other indicators like race, MHI, why can’t we see local texture socially like is presented here for buildings? Clearly more social detail can be noted, the GP ECR needs to do this. 

 

Sonoma Residential zoning is for “middle income households.” What area median income (AMI)/ and median household income (MHI) is that? The city needs consistency with terms like missing middle, middle income. With an hourglass economy there is no more middle class.

 

Housing Opportunity Sites

One more is now lost to the First Street East (FSE) project, almost all these HO sites go market rate. It’s a farce, Sonoma has not done sufficient work to stem this trend of loss of HO sites. This HO category should be tossed or else made to have teeth.

 

Get rid of the 850 sf exemption in the inclusionary ordinance ASAP, make the inclusionary ordinance a stand-alone law that supports lower income units and not with any loopholes. 

 

Upshot is that Lower-income cohorts don’t get to enjoy any neighborhood character.

 

Hillside zoning, it’s ironic that all of SV has lots of hillside housing, a lot in the hills right behind city hall. SV views are already ruined by wealthy mansions.

 

Open space zoning, use the city-owned  St Francis preserve area fir a big 100% AH project ASAP, get moving, give the land to SAHA.

 

Housing policy make a stronger push on AFFH

HE goals H-1,2,3,4,5 are countermanded by all the SFZ and character protection. This stems from the core GP city conflicting priorities of inclusion vs exclusion. Consistency and compatibility with small town/ neighborhood character is code for maintaining segregation, a modern redlining Trojan Horse. HE and GP should not wishy wash segregation. 

 

If Sonoma is not a syndicate to protect SFZ and harvest elite tourism revenue to fund the city, then a much stronger push on AFFH is needed in the GP.

 

 

Sonoma General Plan Environmental Justice and Equity comments

 

Fred Allebach

6/5/24

City of Sonoma General Plan (GP), Existing Conditions Report

Public comments on GP Chapter 9 ENVIRONMENTAL JUSTICE (EJ) AND EQUITY

 

Chapter heading wording unclear

It’s not clear if this chapter heading means EJ and Environmental Equity, or if Equity stands alone and is distinct from EJ? EJ appears to be acting as a proxy for a stand-alone equity pillar here, is that the GP intent? The concept and wording here needs to be clearer, what is the intent?

 

Suggestion. The GP needs a stand-alone Equity plan embedded in Chapter 9, not equity as only conflated with EJ.

 

What is EJ?

The GP EJ chapter says, “Under state law: ‘Environmental justice’ means the fair treatment of people of all races, cultures, and incomes with respect to the development, adoption, implementation, and enforcement of environmental laws, regulations, and policies.” (emphasis mine)

 

This is all about environmental laws, not economic laws (fair labor and business practices) or social justice laws like AFFH (Affirmatively Furthering Fair Housing) or voting rights. EJ is tightly focused on the sustainability paradigm’s environmental pillar, see Venn diagram below.

 

 

Where is equity?

From a Sustainability paradigm, triple bottom line, full cost accounting standpoint, equity resides in the overlap between the social and economic pillars. From a pollution and EJ standpoint, it is unviable and unbearable economic and social impacts by people that are the primary problem. The reason there is a need for EJ is not because of some amorphous environmental problems that exist separately from human economic and societal causes.

 

When it comes to justice and equity, economic causes and issues are primary. It’s not right to collapse what are essentially economic and social issues into an environmental category. Failing to finger economic and social causes as primary is a conceptual failing in the GP.

 

In the GP, there needs to be an Economic Justice and Equity category too, because it is our large-scale, exploitive, profit-driven industrial economy that is creates environmental problems and creates poor people. The equity part doesn’t just magically come in with environmental issues. Economic causation needs to be fingered for its overall unjust, disparate impacts on people.

There are stand-alone disproportionate economic impacts that have nothing to do with environment.  

 

This GP section has a lot of boilerplate space filler that elides the true causes of EJ issues. A more apt analysis could be given in this chapter.  

 

Housing Element policies and the inclusionary ordinance

The GP says that Housing Element (HE) policies and the inclusionary ordinance are serving lower income residents. This is largely untrue; there is no mention of displacement rate or how many have been displaced since 2008 in Sonoma. As well, from 2000 – 2020, the city has a long-term RHNA underproduction of 263 units for Moderate, Very Low, and Low categories. 293 market rates units were RHNA overproduced in this same time frame. This inconvenient truth is never mentioned by the city. (see RHNA performance on ABAG website.) Failing to disclose this recent poor RHNA performance in the GP is an inexplicable loss of real context by the city. This data needs to be cited in the GP existing conditions report. Poor city RHNA performance from 2000- 2020 is an existing condition.   

 

Disproportionate impacts

GP Chapter 9 mentions disproportionate impacts but is not clear on the source of them, only the symptoms. The source is people, class society, and their economy. Winners game the system to their advantage and in the US, white suburban property owners are the winners. They make the rules that put poor working class people in the worst locations so they get the short end of the stick in all regards, not just environmental.

 

Disadvantaged communities (DACs)

The GP says “the term ‘Disadvantaged Community’ is a broad designation that may include any community that lacks appropriate resources or is confronted with any exceptional economic, health, or environmental burden.”

 

DACs are more than Cal EnviroScreen-defined.  

 

The minimum DAC definition for DWR, LAFCO, and SB-244 is: a community of interest with a certain number of people and residences that make less than 80% state MHI (median household income.) The Springs, the city west side and city/ valley mobile home parks have economic DACs in the GP analysis period that cuts off in 2023. See my demographic studies submitted as GP public comments.

 

Need for an EJ Element and SV EJ communities

Chapt. 9 says: “Localities must make an environmental justice element of their General Plan when one or more disadvantaged communities is identified within their General Plan planning area.”

 

There is a SoCo EJ Element draft out that identifies two EJ communities in unincorporated Sonoma Valley (SV), the city southeast side and the Latino Springs. Both of these EJ communities are contiguous to the city by reasonable, objective measure. The GP cites the SoCo EJ working committee (that I am on) but misses mentioning that the city southeast side SoCo EJ community is in the city sphere and thus in the Planning Area. This means there should be a city EJ Element.

 

Chapt.9 says: “the Equity Working Committee will help Permit Sonoma integrate the experiences of low-income residents, communities of color, communities experiencing disproportionate poor health outcomes, and people with disabilities to improve policy making, planning, and public participation programs”.

 

The city follows the County lead for climate issues, transportation etc., so the city should be consistent and follow the County lead on EJ communities in SV.

 

Note, an EJ Element draft is out, there are two projected EJ communities in SV. The city should account for these EJ communities in the GP. Just how these people will actually influence any policy is a matter open to question.   

 

Equity pillar

SoCo has an Office of Equity and an official equity pillar policy going. This is straight up equity that addresses socioeconomic as well as environmental issues.

 

Sonoma has nothing like this because perhaps in Sonoma the segregation has become so normal that people don’t see an equity problem here. When all DACs have been displaced, by systemic discrimination, then there are no more issues? Sonoma segregation happened by accident and is merely the result of personal choices to work hard or not?

 

DeNovo on Measure of America Portrait of SoCo

Chapt. 9 says: “Taken as a whole, the updated report shows that people in Sonoma County live longer, earn more money, stay in school and earn college degrees at higher rates than in other counties across California and the United States. Yet the report also reveals that health and well-being continues to vary widely for many people and neighborhoods in Sonoma County.”

 

Why not mention Springs here? And the detailed Portrait of the Springs reports? This is immediate city environs, contiguous to the city, to not mention the significant disparity in Portrait Human Development Index (HDI) here in SV is willful ignorance in DeNovo’s analysis.

 

“The (Portrait) report also reveals widely varying conditions of health and well-being for many people and neighborhoods in Sonoma County. The key findings of this study show that Black, Indigenous, People of Color (BIPOC), immigrant and undocumented community members persistently scored lower than other populations of Sonoma County.”

 

Not just "lower", way lower, shockingly lower, the GP here needs to cite Portrait HDI Index differences in SV. This is a serious oversight. There are more indicators in Portrait and other studies I have noted and DeNovo’s analysis needs to include indicators and analysis that shows local socio-econ disparities.  

 

These significant specifics in SV are existing conditions that need to be seen and not hidden. Perhaps the city is trying to elide these disparity issues so as to not give any fuel to the annexation fire?

 

City and SV food insecurity

Chapt.9 says: “At the City level, the UCLA Center for Health Policy Research and the California Health Interview Survey (CHIS) reported that 0.3% of adults in the City of Sonoma are food insecure due to low income. In comparison, the same measure for the state of California is 5.0%.”

 

******What about the Cathy Capriola study by Catalyst Fund that showed a drastically different food insecurity results than this citation by DeNovo? This illustrates how the DeNovo existing conditions report shows a fundamentally out of touch view with what is actually going on in SV.

 

The Catalyst Fund study says one in five SV residents, 8000 people, are food insecure. This cohort lives 200% below the poverty level. How is it that various local studies paint such a different picture of Sonoma Valley than does DeNovo and the city?  

 

53.5 percent of the SVUSD students are socioeconomically disadvantaged

Chapt. 9 says: “Further, 53.5 percent of the Sonoma Valley Unified School District students are

socioeconomically disadvantaged, which includes students who are eligible for free or reduced priced meals; or have parents/guardians who did not receive a high school diploma”

 

This just refers to food, there are a host of socio-econ indicators to show how bad things are for perhaps 7000 undocumented SV residents, yet the gravity of this situation is entirely missed in the GP existing conditions report, despite my DAC studies, despite contiguity to the city. What could be more salient than to describe a classic case of local socio-eco inequity? The absence of GP notation on this is incredible, from an equity view.

 

Recent SVUSD demographic studies should be cited in the GP report

 

Housing as the #1 sustainability indicator

Chapt. 9 says: “The conditions of housing in a disadvantaged community may have negative impacts on the well-being of the community residents. These health impacts stem from issues such as poor air quality, toxic building materials, exposure to climate variation such as excess heat or cold, improper ventilation, and structural insecurity.”

 

What about economic causes? Societal lack of planning causes? Why limit a focus to household enviro-centered health impacts of poverty?  There are educational attainment disparities, lack of savings and economic security, low pay, lack of health insurance, cost burdening, insecurity from Trump and ICE. Good enough to clean your yard, take care of your kids, and clean your house? Not good enough to open up systemic racial and class discrimination in the GP? Even as the City Council opens it up in its Juneteenth Proclamation?

 

Missing the point and true causes

Chapt. 9 says, “Ensuring the safety and sanitation of housing stock within a community ensures that there are proper living conditions for all residents, including DACs.”

 

This is a pure nothing burger. Why are improper living conditions present? ,Why exploitive labor relations and 2nd class citizenship? Is the GP just listing symptoms and conditions and not interested in causes? This is an unacceptably myopic and bland stance that misses big pieces of how SV is.

 

The GP needs to see the actual for existing conditions so that future policy based on the GP can address equity issues as they are accurately portrayed and not over-generalized so as to not see significant disparity issues in Sonoma and SV.

 

City housing mitigations

Chapt. 9 says: “Program 1 (Inclusionary Housing.)” The ECR does not mention the 850 sf exemption loophole; this needs to be noted, to show city has a way bypass the prime intent of the ordinance. 

With the FSE project, the city is continuing with pattern of lower income RHNA underproduction and market rate overproduction. Conclusion, the great liberal Inclusionary Ordinance is not working.

 

Chapt. 9 says: “Sonoma has partnered with several different non-profit developers in the provision of affordable ownership and rental housing.” But since Alta Madrone, NOTHING happening now, this partnering is all way in the past, this quote whitewashes the poor AH track record with a bland nothing burger statement.

 

Chapt. 9 says: “To promote housing maintenance and affordability for low income residents, the City of Sonoma’s 2023-2031 Housing Element includes policies to promote the construction of housing that is affordable to all income levels and policies to ensure healthy and safe housing.”

 

When will this ever get done and be more than talk?

 

 

EJ participation by hard-to-reach groups will fix everything? Need more than words in GP Chapter 9!

 

Chapt. 9 says: “An important aspect of planning for environmental justice is the development of effective policies and programs that enable all residents to participate in local decision making. Disadvantaged communities can often be excluded from decision-making when officials and policies do not focus on involving these communities in a strategic manner.”

 

Equity advocates who show up now are mostly ignored in Sonoma already, showing up is no panacea. There is no participating in decision making unless you have electeds and appointees who support the equity line and there are precious few of these in Sonoma, hardly ever a majority. This promise of action and EJ involvement is illusory, this GP plan is smoke and mirrors.  

 

Chapt. 9 says “By involving and engaging DACs in decision-making processes, policy-makers can effectively meet the needs of these community members.”

 

Wrong assumption, all these poverty issues exist now and little has been done, involvement gets you very little unless there is political will, and since Sonoma is pragmatically a syndicate for wealthier property owners, and segregation is totally ignored, what chance do we that equity will be taken seriously by a majority?  Not much. In my experience, they city does about  all it can to avoid having to deal with equity issues, only with a rare progressive majority can we get stuff like the city augmented minimum wage law and the 25% inclusionary ordinance. Otherwise there are plain not three votes for equity items, the no votes don’t understand the topic.

 

Chapt. 9 says: “The establishment of appropriate opportunities for those who are low-income,

minorities, and linguistically isolated to engage in local decision making will help ensure that environmental justice issues are identified and resolved.”

 

This is a boilerplate nothing burger.

 

Chapt. 9 says: “Disadvantaged communities are often not considered in regard to public investment decisions and new public programs. When disadvantaged communities are overlooked for public programs and investments, the specific needs of these communities are not met and the conditions in which they live often worsen.”

 

This GP statement conflates systemic economic exploitation with mere poor environmental conditions. In the GP, let’s counter the above statement with a better effort to not overlook DACs here in Sonoma and SV, make some concrete goals, more than just words.  

 

Chapt. 9 says: “Environmental justice practices across the United States have worked to improve the status of disadvantaged communities, through effective planning and policy decisions.”

 

More boilerplate nothing burger. The core socioeconomic causes that drive EJ issues are not addressed in any EJ program, it’s all symptom management.

 

 

 

 

Abstract of top Sonoma General Plan Land Use and Existing Conditions comments

 

Fred Allebach

6/8/24

Abstract of top Sonoma General Plan Existing Conditions Report (ECR) points

                      

General policy direction, more AFFH (Affirmatively Furthering Fair Housing) and equity focus, the ECR needs work to include local data sources and be more accurate.

 

Reconcile conflicting goals of exclusivity and inclusivity. AFFH and equity are at odds with strong policy and planning emphasis on neighborhood character and compatibility.

 

Admit city and valley patterns of racial and class segregation. The city’s 70-75% single family homes and zoning maintains segregation. Clovis v. Martinez case law proves that too much single-family zoning and lack of integration therein is illegal. Valley segregation, of 7000+plus lower-income Latinos is significant, not to be ignored in the GP. How can this be ignored?  

 

GP has too general a view, significant local differences are not seen. Can’t be so general as to be inaccurate by omission. Need to see the actual, GP can do much better to show local socioeconomic diversity. Local DAC studies at the Block Group level by SVHG members show what is possible; these were sent to GP public comments, appear to have gone into a black hole.

 

ESRI private data, can’t double check private sources; can’t see what was left out; lower-income/ BIPOC communities appear to be nixed out of local demographic analysis.  It is improper to have private data in a public report; this does not build trust when equity issues already seems elided.

 

Data, many inaccurate citations, need local sources:

Ø  GP asserts “areas around city are wealthier”, ignores clear Latino Springs demographics

Ø  GP “average rent” is too low, no one can find anything at GP-quoted prices

Ø   GP say .3% experience food shortages, Catalyst Fund study say 1 in 5 or 8000 valley people experience food shortages

Ø  GP says “average household spending is $37,000”; average is really at a Very Low-income level? Wrong.

Ø  GP says “$900 per year per person spent on medical”, this is much too low for a city with many seniors

 

There are enough questionable and inaccurate ECR data assertions that the Council needs to direct staff and DeNovo to tighten this up a lot. Who red flags and double checks questionable assertions?   

 

Update land use map Acknowledge that single family zoning (SFZ) is equivalent to exclusionary zoning. Dial back SFZ to only 25% of total residential zoning, Upzone all SFZ residential areas to an equal mix of high, medium and mixed-use zoning, to capture the underutilized space in these exclusionary zoned areas. Generation Housing and the White House validate the concept of exclusionary zoning. The city’s Juneteenth Proclamation says systemic racism needs to be addressed. Why proclaim to be against segregation and then do nothing to fight it with local land use?

 

Change zoning and conditions of approval on vacant parcels at Armstrong Estates and the Sebastiani site.    

 

Housing Opportunity sites, get rid of this land use designation, it’s window dressing, it is not working, these sites almost all go market rate. Make it so 100 % AH projects can go anywhere by right with fee and regulatory streamlining. Take out 850 sf exemption in the 25% inclusionary ordinance that allows an unproven “affordable by design” concept to replace actual lower-income units.

 

Open Space, give St. Francis Preserve to SAHA and let them unwind the Fish and Wildlife issues.

 

Sustainability, GP needs triple bottom line, full cost accounting framing and more focus on the social and equity pillar. Sustainability policy view is not balanced when ignoring critical pillars. Sustainability needs clarity in EJ Element, that it is not just an environmental thing. GP consultant said sustainability touches all GP Elements; we need to be clear what it even is, especially if equity is conflated with environmental justice only.  

 

Environmental Justice (E J) and Equity

Ø  Make Equity a stand-alone category, not folded into EJ, it is no good to collapse all equity into EJ

Ø  The call for inclusion of EJ communities to have policy input means electeds have to have political will to back up calls for justice, like in this SVHG comment.

Ø  EJ has been very hard to get on the city radar, years of nada; comments are almost never responded to, what incentive is there to comment if comments are ignored and not engaged?

Ø   There are county EJ communities in the city sphere and planning area on the city south side and contiguous to city in Springs.  This justifies a GP EJ Element and needs mentioning in the ECR.

Ø  GP cites Measure of America Portrait studies but fails to include local HDI (human development index) data that show the same exact pattern in Glen Ellen/ Sonoma Mtn to Latino Springs as there is  in Roseland and Bennett Valley.