Draft MTP/SCS Comments Received - sacog

from SHA to SACOG re MTP/SCS 2035
Letter
9, 2012
January
fair housing opportunity should be conducted would help SACOG ensure that its MTP/SCS
of
not perpetuate existing racial and ethnic segregation patterns. 14
does
Indeed, SACOG set a
deadline of December 31, 2011 by which to complete such assessment, is
access to opportunity and d•mographic changes, and the strength of fair housing
impact
and activities. Specifically, HUD recommends utilizing three measures of segregation:
services
a dissimilarity index that measures the evenness with which white residents and residents of
(1)
are distributed across a jurisdiction or region (2) predicted racial and ethnic composition,
color
employed a
fact that only 57 percent of households in Marin would be non-Hispanic white in an equal
the
housing market in contrast to Marin's actual 72 percent white population and that
opportunity
percent white. •6 SACOG, in conducting its required fair housing assessment and regional
58.5
housing analysis, should consider utilizing this methodology to see where in the region
fair
However, a
14. and
Source of data: 2005-2009 American Community Survey 5-Year Estimates, Tables B19001 and
16
B19001H.
See also, Kirwan Institute Opportunity Mapping at http://www.kirwaninstitute.org/research/opportunit¥-
17
as SACOG is aware, all recipients of HUD's Partnership for Sustainable
Relatedly,
grants are required to conduct a Regional Fair Housing and Equity Assessment.
Communities
assessment must include analyses of segregation patterns, racially/ethnically concentrated
The
of poverty, access to existing areas of high opportunity, major public investments that
areas
(3) ethnically concentrated areas of poverty. HUD also recommends an analysis of access to
and
areas of high opportunity. Regarding the second metric, Bay Area equity advocates
existing
methodology that calculates what one would expect the race and ethnic diversity
a city to be if all households regardless of race or ethnicity were free to live where others at
of
income level live. Application of this methodology produced interesting results, including
their
City of Pleasanton, which is
70.8 percent non-Hispanic white, would be expected to be only
exclusive housing patterns lie and take steps to address these patterns in its MTP/SCS. 17
8 of the MTP/SCS appropriately focuses the "equity and choice" analysis on EJ
Chapter
in Sacramento. However, the MTP/SCS should also state clearly that most of the equity
areas
related to ensuring fair housing and transportation access governing the Plan
mandates
and implementation apply to the Plan in its entirety, not just EJ areas.
development
concern regarding the EJ analysis is that that it is•purely place-based, as
Another
people-based. A geographic unit may provide a proxy for some of the protected
opposed•to
categories of persons under Title Vl
and the Fair Housing Act, such as race and ethnicity.
purely place-based analysis does not directly analyze the Plan based on race nor
http://www.hud.gov/offices/fheo/ima•es/fho•.pdf.
14See
Sacramento Region Consortium Sustainable Communities Planning Grant Project description/timeline, pp. 9, 10
is
communities/maooinz/.
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