Draft MTP/SCS Comments Received - sacog

from SHA to SACOG re MTP/SCS 2035
Letter
9, 2012
January
region particularly hard. 18 SACOG has both a legal obligation to utilize its MTP/SCS
Sacramento
its fullest capacity to close this gap, as well as an economic interest in ensuring that all
to
jurisdictions and neighborhoods are thriving and that the region does not devolve
SACOG
into an unequal, more racially and economically segregated and divided region due to
further
the adopted policies.
•
Include language in Chapter 8 that clarifies that the MTP/SCS must comply with Title
•
Consistent with the HUD-required Regional Fair Housing Assessment and SACOG's
other fair-housing obligations, conduct a
and future MTP/SCS and make policy, methodology and implementation
current
adjustments to ensure the Plan decreases segregation and affirmatively
measure
fair housing throughout the region. SHA recommends a deadline of June 30,
furthers
2012.
• Continue to collaborate closely with equity organizations such as the Center for
Direct significant investment into projects and policies that have the greatest
•
to promote and achieve equity in the first 5 to 10 years of the planning
potential
period.
Add a Strategy to Policy 4 to address potential segregation and gentrification in
•
transit-rich areas throughout the SACOG region.
comments submitted to SACOG on December 23, 2011.)
Equity's
Absent clear evidence of absence of bias in sources or studies, remove language in
•
Additional recommendations regarding specific changes and additions to MTPlSCS
•
and strategies, consistent with SHA's comments above, are attached.
policies
See Wealth Gaps Rise to Record High Between Whites, Black, Hispanics: Twenty to One (Pew Charitable Trust,
18
26, 2011) at http://www.pews•cia•trends.•rg/2•11/•7/26/wea•th-gaps-rise-t•-rec•rd-hi•hs-between-whites-
July
jump in third quarter, October 29, 2011 at http://www.sacbee.com/2011/09/15/3911662/after-
foreclosures
years-lull-sacramento-area.html#ixzz:lfdQRTWsD.
19 SHA's concern is that such language in the MTP/SCS will form the basis for land use and housing policy decisions
Recommendations:
VI and the federal Fair Housing Act in its entirety, in addition with regard to EJ areas.
comprehensive fair housing analysis of the
Regional Change and the Coalition on Regional Equity to assess the current
MTPISCS,
and SACOG's performance under it,
against federal and state equity mandates and
Plan methodologies, metrics and implementation actions accordingly to
improve
compliance with these mandates.
ensure
(See the Coalition on Regional
that suggests that families of certain races and ethnicities primarily double-
MTPlSCS
or crowd into fewer housing units overall for cultural reasons or for other reasons
up
other than out of economic choice. (See Plan, pp. 8 12 and 8 16.) 19
blacks-hispanics/; Rick Daysog, Sacramento Bee, Foreclosures surge in
region, September 15, 2011; New
that perpetuate biases to the detriment of people and communities of color.
8
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