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.
No comments:
Post a Comment