Roosevelt Review Fall 2019


VOL. 2 FALL 2019








8 Curbing Obesity Amongst Vulnerable Communities: Subsidies and Price Caps on

Healthy Foods

By Kartikeya Juneja


10 Redeveloping Parking Lots as a Means of Temporary Housing

By Serena Allen

12 Law and Order: Implementing Public-Private Defenders in San Diego Immigration


By Stephen Kim

14 Instituting Financial Incentives to Increase Employment of Persons with Disabilities in


By Manushri Desai and Shivam Saran


16 Using By-Right Housing as a Solution to Cailfornia’s Housing Crisis

By Jacob Narvaez

18 Preventing Green Gentrification in the Taylor Yard Restoration: The Value Capture


By Liam Tsao


20 Regulating For-Profit Colleges in California: Disincentivising the Mismanagement of

Federal Funding

By Jaehee Cho



Established in Fall 2018, Roosevelt Institute at USC is a student-run policy think-tank focused on the research and advocacy

of progressive policy ideas. We offer a welcoming community for members to develop policy ideas that improve

access to public goods at the local, state, and federal levels. Supported by policy research committees and skills training

workshops, our members take on projects in the areas of education, environment, economy, health, human rights, transporation,

and urban development. Part of the Roosevelt Network, a national association of chapters at colleges across the

country, Roosevelt at USC works to rewrite the rules by combinding strong policy research with meangingful advocacy.

Manushri Desai, Executive Director

Issues related to energy and the environment are often seen as removed from public policy but, in reality, hold immense

political contention. Issues such as land tenure, green gentrification, and renewable energy are merely examples

of a collection topics occurring in the environment that hold significant political weight. It is essential that we

understand the political and ethical implications of human-environment interactions to make sure they don’t negatively

impact people or fragile ecologies. Outside of Roosevelt, I conduct research using satellite imagery to better

understand and model vegetative patterns in Southern California as a proxy to track the extent to which human’s

behaviors negatively impact vegetation. I bring this knowledge to my policy analysts interested in political ecology

to craft highly informed policies. I truly enjoy working with these policy analysts because they bring such diverse

interests to light in this field that I’m able to learn something from them as well through the policy writing process.

Cameron Levine, Policy Research Director

Policy analysts Kartikeya Juneja and Stephen Kim worked diligently in their policy research to address issues involving

disparities in access, proposing innovative and tangible solutions to close the resource gap for underserved communities.

Kartikeya investigated how communities associated with poverty and welfare dependency often suffer from food deserts

alongside a lack of available community wellness resources. In his memo, Kartikeya proposes a local initiative in the city

of Los Angeles that will help curb the rate of obesity and other health-related issues prevalent within ethnic and low-income

neighborhoods. Stephen dedicated his research to finding a tenable solution that addresses the shortcomings of the

current San Diego immigration court system. His memo proposed a city partnership with public and private defenders to

provide adequate legal representation for immigrant individuals and families, thus ensuring equal access to due process.

Through my role as policy director, I had the honor of working with analysts who are committed to eliminating discretionary

inequity and equalizing access for currently vulnerable identities. Their semester-long projects truly reflect

the nature of Roosevelt’s ultimate mission to restore “America’s promise of opportunity for all.” I have thoroughly

enjoyed working with Kartikeya and Stephen, and I am incredibly proud of the outcome of their policy proposals!

Rushawnda Russ, Policy Research Director


Sometimes being a student at USC, surrounded by students at USC, makes it easy to forget that many do not have the

opportunities to access college-level education. Thus when considering public policy, it is essential to remember its role

in education. This year, Jaehee Cho’s project confronts the for-profit college industry and its exploitation of both federal

funding and vulnerable student populations. By proposing a multi-tier penalty system to rein in for-profits from using

their federal aid for advertising and marketing rather than actual education, his proposal aims to benefit the students

targeted by those schools. These students are disproportionately racial minorities, women, over the age of 24, or single

parents. After all, among the obstacles to getting a college education are the colleges themselves, and this policy endeavors

to change that.

Yuna Jeong, Policy Research Director

The Housing and Urban Development Policy Committee passionately works to improve communities through the

thoughtful and careful stewardship of housing and transportation systems. As a team, we use our diverse background

in studies to creatively look at different issues and try to find non-traditional solutions. Our focus is to further explore

policy proposals for affordable housing, mixed use development, densification incentives. This year, policy analyst

Serena Allen explored how to use transitional housing development for the homeless to open up access to Los Angeles’

resources and increase the city’s density. Policy Analyst Jacob Narvaez designed a process to facilitate the construction

of affordable housing throughout California by introducing a streamlined approval process in the beginning of the

development phase.

Nicholas Cerdera, Policy Research Director


Letter from the Editor

Dear reader,

This is the second annual Roosevelt Review published by the USC Chapter of the Roosevelt Institute. We are proud

to present seven proposals written by undergraudate students from the University of Southern California. This

year’s authors come from various undergraduate colleges and class years.

The Roosevelt Institute fills a unique role in the political sphere at USC. As a nonpartisan but progressive policy

think tank, the Institute prioritizes a search for practical solutions to social problems rather than discussions of

party or ideology. At our weekly meetings, policy research directors lead coversations about how to use public policy

to tackle some of the world’s most pressing problems, from regulating profit colleges in California to preventing

green gentrifcation. The focus is always on workable solutions.

The Roosevelt Review was founded to encourage members to enact real progressive policy change at the campus,

city, and state levels. By addressing key developmental disparities that challenge target populations, policy analysts

of the Roosevelt Review reimagine the rules that guide our social and economic realities. In the second year of

publication, our policy analysts hope to use the Roosevelt Review to catalyze progressive thinking by effectively

bringing these affordable solutions to policymakers and igniting sustainable change.

I am honored to have served as the Founder and Editor-in-Chief of the Roosevelt Review in the 2019-2020 academic

year. In this publication, our authors address the most pressing and complex problems of our time. These

solutions are innovative in their conception and elegant in their presentation. I hope that you will find them both

informative and thought provoking.

To our policy analysts, policy research directors, and executive board members, thank you for your hard work. It

has culminated in the second successful issue of the Roosevelt Review.


Manushri Desai

Founding Editor-in-Chief of the Roosevelt Review




Executive Director

Director of Operations

Manushri Desai

Joan Lee


Nicholas Cerdera

Cameron Levine

Yuna Jeong

Rushawnda Russ


Editor in Cheif

Managing Editor

Policy Analysts

Manushri Desai

Joan Lee

Serena Allen

Jaehee Cho

Manushri Desai

Kartikeya Juneja

Stephen Kim

Jacob Narvaez

Liam Tsao


Curbing Obesity Amongst Vulnerable Communities:

Subsidies and Price Caps on Healthy Foods

By Kartikeya Juneja



To solve the issue of food deserts and

hence, curb obesity among vulnerable

populations, the city of Los Angeles

should implement economic policies

such as price caps and subsidies on

fruits and vegetables making them more

affordable to low-income communities.

Background & Analysis

The prevalence of adult obesity in California

has increased significantly in

the past decade. According to the California

Health Interview Survey (CHIS)

27 percent of adults in California were

diagnosed as obese in 2014, which is an

increase in obesity prevalence of nearly

40 percent since 2001. Ethnic minorities

and low income households are more

vulnerable to the issue of obesity. In a

2015 study conducted by UCLA Center

For Health Policy Research, 31%

of adult Californians with incomes below

200 percent of the Federal Poverty

Level (FPL) were obese compared to

20 % with incomes at or above 400%

FPL. In 2014, a study conducted by

the California Department of Public

Health concluded that obesity rates

among African Americans and Latinos

were higher than the Healthy People

2020 target while those for non- Latino

White and Asian Californians fell

below the target. For example, obesity

rates among African American women

(49.8 percent) were more than double

the rate of White women (22.9 percent).

The high levels of obesity amongst vulnerable

communities in California can

mainly be attributed to the issue of unavailability

and unaffordability of fruits

and vegetables. For example, there is a

lack of availability of healhty foods such

as fruits and vegetables as they are unaffordable

for low-income communities.

Almost 1 in 4 low-income people in

California reported that they were usually

(10.6%), sometimes (9.3%), or never

(2.9 %) available and 20.9 % said that

they are sometimes affordable and 1.1

% said that they are never affordable.

Talking Points

• Implementing a 10% subsidy

on fruits and vegetables would

reduce production costs for

farmers and hence, supermarkets

would be able to buy fruits

and vegetables at a lower price

• In turn, implementing a price

cap on fruits and vegetables

would ensure that they are

more affordable for low-income

and vulnerable communities

• In the United Kingdom (UK), a 10%

subsidy on healthy foods reduced

obesity rates from 57% to about

13%. Although, implementing subsidies

cost about £991m ($1.3 bn) ,

the net benefit of the policy equated

to £6 billion in the long run.

Key Facts

• 27 percent of adults in California

were obese in 2014, which, is

an increase in obesity prevalence

of nearly 40 percent since 2001

• In a 2015 study conducted by

UCLA Center For Health Policy

Research, 31% of adult Californians

with incomes below 200 percent

of the Federal Poverty Level (FPL)

were obese compared to 20 % with

incomes at or above 400% FPL

• Obesity rates among African

American women (49.8 percent)

were more than double the rate

of White women (22.9 percent).

Policy Idea

The Los Angeles County Department of

Public Health should implement economic

policies in order to address the

issue of obesity by first, providing a 10%

subsidy to producers of fruits and vegetables

and second, capping new prices

for fruits and vegetables at 90% of the


original prices for these products. Implementing

a 10% subsidy on fruits

and vegetables would reduce production

costs for farmers and supermarkets

would be able to buy fruits and

vegetables at a lower price. In turn,

implementing a price cap on fruits

and vegetables would ensure that

they are more affordable for low-income

and vulnerable communities.

Policy Analysis

Implementing subsidies on healthy

foods have been successful in reducing

obesity rates in the United Kingdom. According

to a research by the “University

of Bath”, implementing a 10% subsidy on

healthy foods (fruits, vegetables, fish and

lean meats) was the more effective policy

in reducing obesity and benefiting the

government as compared to a 10% tax

on unhealthy food and cash incentives.

The 10% subsidy reduced obesity rates

from 57% to about 13%. The portion of

the NHS budget spent on overweight

and obese people has been calculated

to be about 16% a year i.e. around £6

billion ($7.7 bn). Hence, though implementing

subsidies cost about £991m

($1.3 bn) , the net benefit of the policy

equated to £6 billion in the long run.

Currently, the American government

provides subsidies on various types of

food such as corn, soybean, etc. which,

have instead caused a higher production

of unhealthy processed foods, and

high-calorie soft drinks and juices.

According to the Los Angeles Times,

more than half of the calories consumed

by American adults come from

government subsidized crops. Hence,

implementing subsidies on healthier

food options such as fruits and

vegetables would be more effective.

Although, a certain group of people may

argue that increasing subsidies would

increase costs for the government, the

cost of obesity to the government outweighs

the cost of the subsidy to the

government. A study published in

Health Affairs found that medical care

associated with obesity cost state-run

health programs $8 billion in 2013.

Implementation Plan

Raising increased awareness about the

issue of obesity amongst vulnerable

communities in LA would be the first

step since, economic policies and creating

awareness work hand in hand. The

Los Angeles County Office of Education

should introduce a compulsory subject

on health and nutrition in all middle

schools of LA. Price caps should also be

introduced on healthy food across college

campuses in LA in order to encourage

healthy eating habits amongst the

youth. Organisations such as Community

Health Council (CHC) can serve as

key allies during the lobbying and legislative

process. LA is a perfect city for

implementing policies in order to address

this issue since it is a very diverse

city with a huge proportion of racial

minorities. For example, today, 9% of all

Hispanics in the country live in Los Angeles

County, and it’s here that the population

has grown the most since 1980.

Action Plan Snapshot

The first step would be to contact local

allies such as CHC and statewide allies

such as “Alliance for a Healthier Generation”,

and seek their support. This would

be done by thoroughly explaining them

as to what my policy is and what advantages

would such a policy have. I also plan

on taking their feedback on the effectiveness

of my policy since they would be

more experienced policy-makers in this

matter. Hence, I will accordingly make

the suggested improvements and modifications

to my policy. I will also learn

more about their work around the issue

and try to play a part in volunteering

with one of the organizations and looking

to incorporate my policy with their work.

Then, I will reach out to the Los Angeles

County Office of Education and propose

the idea of making studies on nutrition

and obesity a part of middle school

curriculums since, mainly schools start

tackling health education later in high

school. This would be an important step

since education often plays a key role in

reaching out to a greater number of people

and economic policies would not be

successful unless it is backed up by creating

awareness around the issue. On a

personal level, I will also start creating

awareness around my college campus

by taking support from clubs on campus

that promote healthy eating and

nutrition. I will also propose the idea

of introducing a price cap on low-calorie

meals in all college campuses and

introducing compulsory classes on

healthy eating even in college campuses

in LA. After CHC and other similar

organisations get back to me with suggestions

and recommendations, I will

modify my policy and contact the Los

Angeles County Department of Public

Health and explain the nitty gritties of

my policy proposal. I will also look to

fix a meeting with a Public Policy professor

and seek his/her guidance on

further enhancing my policy proposal.

I will continue being a part of Roosevelt

Institute at USC and take guidance

from experienced Roosevelt members

as to what are other effective ways to

reach out to allies and stakeholders.


1. “California Department of Public

Health. “Obesity in California: The

Weight of the State, 2000-2014.” 2016.

2. Karlamangla, Soumya. “How much

does severe obesity cost California?

About $9.1 billion.” Los Angeles

Times, November 2, 2015.

3. “Los Angeles, California Population

2019.” Los Angeles, California

Population 2019 (Demographics,

Maps, Graphs).

Accessed November 23, 2019.

4. Rivas, Javier. “Subsidies for Healthy

Foods Are a Price Worth Paying

to Tackle Obesity.” The Conversation,

September 19, 2018.

5. Wolstein, Joelle. “Obesity in

California.” UCLA Center for

Health Policy Research, June, 2015.



Reveloping Parking Lots as a Means of Temporary Housing

By Serena Allen



The City of Los Angeles should implement

a two-pronged policy approach

to disincentivize single passenger

cars and create desperately

needed temporary housing structures

in Downtown Los Angeles.1, 2

Background & Analysis

Los Angeles is currently the sixth most

congested city in America.3 Even though

there have been numerous attempts to

expand driving lanes and parking lots,

providing more driving infrastructure

induces demand for driving.4 Induced

demand refers to the phenomena that

occurs when municipalities create more

lanes for automobiles and thereby encourage

more people to drive. In practice,

building this infrastructure increases

pressure on the system as a whole.5

Los Angeles is also ranked as the most

polluted city nineteen out of the past

twenty years.6 Combating congestion

in Los Angeles is especially important

because 41% of the city’s greenhouse gas

emissions come from transportation. 7

An equally pressing issue is the homelessness

crisis in LA. The homelessness

crisis must be addressed now if LA

hopes to prevent worsening the crisis

during the 2028 Olympics as in 1984. 8 In

2019, approximately 25,000 people have

nowhere to sleep at night. 9 In the 2017-

2018 fiscal year, over 250 million dollars

were invested by the City of Los Angeles

to help solve the homelesness issue. 10

A portion of this funding was meant to

create temporary housing structures,

but with funds for permanent housing

already running out, temporary housing

is being ignored. 11 Homeless encampments

are found concentrated around

the public resources that the city offers

and current initiatives ignore this need. 12

Talking Points

• Creating temporary housing

structures near the distribution of

government aide will make complying

with new regulations easier

on those experiencing homelessness.

Current temporary

19, 20, 21

housing initiatives neglects this.

• Driving infrastructure creates induced

demand leading to more drivers

on the road and therefore more

pollution. Infrastructure reduction

22, 23, 24

would create an inverse effect.

• With a promise to be the greenest

Olympics ever, the 2028 LA Olympics

puts considerable pressure on

policymakers to act now to reduce

greenhouse gas emissions. Because

the world will be watching

in 2028, LA must work proactively

to solve the homeless crisis now. 25

Key Facts

• Los Angeles’s air quality is ranked

as the worst of all American cities. 26

• In the three years since Prop

HHH passed to fund 10,000

units of supportive housing, not

a single unit has been created and

funds are running out. Temporary

housing remains undeveloped.

25,000 in Los Angeles will

27, 28

have nowhere to sleep tonight.

• There is a lack of open land on

which to develop affordable

temporary housing, but 14% of

29, 30

Los Angeles is parking lots.

Policy Idea

To simultaneously reduce homelessness

and promote sustainability, the City of

Los Angeles should convert parking lots

in Downtown LA into temporary housing

structures for people experiencing

homelessness, thereby incentivizing the

use of public transit. First, the Los Angeles

Homeless Services Authority would

purchase the Los Angeles Department

of Transit’s parking lots near Downtown

resources 13 to create temporary housing

structures. The Department of Transit’s


proceeds would then go to incentivizing

occupational carpools and expanding

low cost multimodal transit

infrastructure, such as bus lanes.

Policy Analysis

The city needs to purchase undeveloped

lots to create temporary housing

structures. There is an undersupply of

affordable private land proximate to the

resources of Downtown, although 14%

of Los Angeles is parking. 14, 15 Long term

housing solutions from the city neglect

the immediacy of the problem. 16 There

is a lack of interdepartmental policy

attempts to create innovative solutions.

Symptoms of the two problems lack

a holistic approach, rarely looking to

other city departments to see how respective

problems can be solved together.

Frequently, groups of homeless

individuals themselves are left out of

this discussion. The Los Angeles Poverty

Department (LAPD) advises that

housing needs to be near resources and

amongst the community culture people

experiencing homelessness have. 17

I suggest an intercity business deal

where both housing initiatives and LA’s

Green New Deal are supported.18 With

the mayor’s office serving as a liaison,

LAHSA will use funds from Prop HHH

to purchase the city parking lots that are

located near the distribution of government

resources in Downtown. LADOT

would use these proceeds to not only expand

current programs, but also sponsor

the creation of a platform to incentivize

businesses to create employee carpools,

providing desirable transportation for

Downtown workers. The deal would

be done with the stipulation that these

parking lots can be repurposed as green

space in the long-term, creating an incentive

for community members who

may initially lack support for this initiative.

Together, this innovative business

action will bring about significant health

decongestion and safety

benefits to all Angelenos.

Implementation Plan

The City of Los Angeles must accept and

spearhead this proposal. Before pitching

to the city, the University of Southern

California shall launch a research

study to determine which parking lots

are best suited for development and to

gain the opinions of both the business,

public and homeless community. With

this data, a combination of Los Angeles

housing and environmental advocacy

organizations, including LAHSA and

LADOT as mentioned above, will be

approached for support of this policy.

Together, the City of Los Angeles will

pursue the project in phases. At the end

of each phase, data collection on the

effectiveness of the policy will be taken

to adapt and strengthen the next phase.

Action Plan Snapshot

January 2020 To start, more data needs

to be collected from people experiencing

homelessness on what they need. Furthermore,

initial data collection must be

done to see what is preventing employees

from carpooling to work.

July 2020 The data collected in the first

six months of 2020 will serve as a tool

to convince the City of Los Angeles

to pursue this policy. Once accepted,

the city will begin pricing negotiations

between LADOT and LAHSA.

January 2021 A briefing would be conducted

with private business that will be

impacted by new carpooling initiatives

and less parking. Community organizations

in Downtown will also be briefed

and asked their opinion on the process.

Based on this data, as well as data collected

from the previous year, the sites for

the temporary housing would be chosen.


1. Home, A Bridge. “A Bridge Home.”

Office of Los Angeles Mayor Eric

Garcetti. Office of Los Angeles

MayorEric Garcetti, n.d. https://

2. “Los Angeles County Department

of Public Social Services.”

County of Los Angeles DPSS -

3. Inrix. “INRIX 2019 Global Traffic

Scorecard.” Inrix, February 11,


4. Schneider, Benjamin, and Benjamin

Schneider. “You Can’t Build Your

Way Out of Traffic Congestion. Or

Can You?” CityLab, April 25, 2019.

5. Ibid

6. “Most Polluted Cities: State of the Air.”

American Lung Association, n.d.

7. “GHG Current California Emission

Inventory Data.” GHG Current

California Emission Inventory

Data, n.d. https://ww2.

8. Chandler, Jenna. “How Will LA

Treat the Homeless When It Hosts

the Olympics in 2028?” Curbed

LA. Curbed LA, July 12, 2018.

9. “A Bridge Home: FAQ for LA’s

Temporary Homeless Housing Initiative.”

EmpowerLA, July 8, 2019.

10. LAist Staff in News on October

8, 2019 10:40 AM. “Three

Years And Zero Homeless Housing

Units Later, LA’s Auditor

Looks At Prop HHH Money.”

11. LAist Staff in News on October

8, 2019 10:40 AM. “Three Years

And Zero Homeless Housing

Units Later, LA’s Auditor Looks

At Prop HHH Money.” LAist, n.d.

12. 12. “Los Angeles County Department

of Public Social Services.”

County of Los Angeles

DPSS - Office Locations, n.d

13. “Parking in LA.” Parking in LA,


14. “Downtown Los Angeles Vacant

Land for Sale.” Land for Sale

Downtown Los Angeles, CA - Vacant

Lots for Sale in Downtown

Los Angeles | Point2 Homes, n.d.

15. Chester, Mikhail, Andrew Fraser,

Juan Matute, Carolyn Flower, and

Ram Pendyala. “Parking Infrastructure:

A Constraint on or Opportunity

for Urban Redevelopment?

A Study of Los Angeles County

Parking Supply and Growth.”

Arizona State University. Routledge,

December 31, 2015.

16. LAist Staff in News on October

8, 2019 10:40 AM. “Three Years

And Zero Homeless Housing

Units Later, LA’s Auditor Looks

At Prop HHH Money.” LAist, n.d.


17. Jackson, Maria, and John Malpede.

“Making The Case For Skid Row

Culture.” Los Angeles Poverty Department

& the Urban Institute, n.d.

18. “LA’s Green New Deal Sustainability

Plan 2019.” pLAn. City of Los Angeles,


19. Jackson, Maria, and John Malpede.

“Making The Case For Skid Row

Culture.” Los Angeles Poverty Department

& the Urban Institute, n.d.

20. “Los Angeles County Department

of Public Social Services.”

County of Los Angeles

DPSS - Office Locations, n.d.

21. Scott, Anna. “Rental Vouchers for

L.A.’s Homeless Provide Short-

Term Fix For Long-Term Problem.”

NPR. NPR, April 24, 2019.

22. Chester, Mikhail, Andrew Fraser,

Juan Matute, Carolyn Flower,

and Ram Pendyala. “Parking

Infrastructure: A Constraint on

or Opportunity for Urban Redevelopment?

A Study of Los Angeles

County Parking Supply and

Growth.” Arizona State University.

Routledge, December 31, 2015.

23. Schneider, Benjamin, and Benjamin

Schneider. “You Can’t Build Your

Way Out of Traffic Congestion. Or

CanYou?” CityLab, April 25, 2019.

24. “Parking in LA.” Parking in LA, n.d.

25. Chandler, Jenna. “How Will LA

Treat the Homeless When It Hosts

the Olympics in 2028?” Curbed

LA. Curbed LA, July 12, 2018.

26. “Most Polluted Cities: State of the Air.”

American Lung Association, n.d.

27. 27. “A Bridge Home: FAQ for LA’s

Temporary Homeless Housing Initiative.”

EmpowerLA, July 8, 2019.

28. LAist Staff in News on October

8, 2019 10:40 AM. “Three Years

And Zero Homeless Housing

Units Later, LA’s Auditor Looks

At Prop HHH Money.” LAist, n.d.

29. 29. “Downtown Los Angeles

Vacant Land for Sale.”

30. Chester, Mikhail, Andrew Fraser,

Juan Matute, Carolyn Flower, and

Ram Pendyala. “Parking Infrastructure:

A Constraint on or Opportunity

for Urban Redevelopment?

A Study of Los Angeles County

Parking Supply and Growth.”


Law and Order:

Implementing Public-Private Defenders in San Diego Immigration Courts

By Stephen Kim



Throughout America, but particularly

in Southern California, there are

lacking humanitarian and democratic

practices in immigration detention

centers. The San Diego Immigration

Court should provide attorneys for

immigrants in immigration courts

to provide proper due process.

Background & Analysis

At San Diego’s United States-Mexico

border, immigration courts lack fair and

speedy trials for asylum-seeking or deportation-vulnerable

immigrants. There

are multiple causes, but the primary one

lies within legislation limiting the presence

of attorneys. Due to deportation

being classified as a civil rather than a

criminal violation, immigrants are not

afforded the Sixth Amendment constitutional

protections of defendants. In addition,

on July 23, 2019, expedited removal

procedures under the Department of

Homeland Security have expanded the

1996 Illegal Immigration Reform and

Immigration Responsibility Act (IRAI-

RA) which procedurally allowed U.S.

Customs and Border Protection (CBP)

officials to rapidly deport undocumented

or fraudulent noncitizens. Both legal

inhibitions have achieved their goals,

as in 2016, the American Immigration

Council found that only 37 percent of

immigrants secured legal representation

in their deportation proceedings. An influx

of immigrants fleeing regional conflicts—estimated

to be nearly 1% of Guatemala

and Honduras population—led

to nearly 132,887 migrants apprehended

by Border Control at the US Mexico

Border in May of 2019, comprised

primarily of protected groups that cannot

be detained or deported—children,

families, and asylum seekers. San Diego’s

immigration court system lacks in handling

such cases, with AIC reports estimating

that Mexicans face the highest

detention rate (78%) while recieving the

lowest representation rate (21%) of all

races, showing the disproportionate racial

disadvantages specific to Hispanic

immigrants within the city of San Diego.

Talking Points

• Providing free, expert legal assistance

through state-sponsored

defense allows vulnerable

groups—children, families, asylum-seekers—to

access as well

as undergo proper due process.

• Practices such as NYIFUP decrease

taxpayers’ burden by decreasing

the average length of

expensive detention center stays

and court hearing waits, which

averages 1,400 days in California.

• Current legal practices such as expedited

removal practices undermine

noncitizens’ legal rights, particularly

Hispanic minorities, who are

consistently underinformed about

and blocked from these legal rights.

Key Facts

• The American Immigration Council

found that only 37 percent of

immigrants secured legal representation

in their deportation proceedings,

with Mexicans facing

the highest detention rate (78%)

while receiving the lowest representation

rate (21%) of all races.

• The NYIFUP program saves an

additional $5.9 million in positive

externalities such as health

care and turnover-related costs

• The number of detainees in immigration

detention center

camps and “tent cities” jumped

to 51,748 daily detainees in 2018

from 30,000 in the years prior

Policy Idea

To increase efficacy and fairness in immigration

court hearings for noncitizens,

the city of San Diego ought to partner

with public and private defenders in their


local Immigration Court system. Currently,

no government service provides

free or affordable access, which simultaneously

reduces noncitizens’ awareness

of their legal rights to an attorney.

The city should organize and support

noncitizen-law experts through hiring

such attorneys for immigration-specific

cases, until the backlog of immigration

hearings clears or the public achieves a

sufficient equilibrium of available defendant

attorneys, public/private, to

governmental deportation attorneys.

Policy Analysis

The growing number of detainees in

immigration detention center camps

and “tent cities”, jumping to 51,748

daily detainees in 2018 from 30,000

in the years prior, represents an enormous

economic and social cost to San

Diego. At the national level, the U.S

president’s requested 2017 detention

portion of the immigration enforcement

budget was roughly $1.75 billion—nearly

$159 per detainee/day.

New York City implemented the New

York Family Immigrant Family Unity

Project (NYIFUP) in 2016 to connect

detained immigrants and high-quality

legal counsel, which is projected to

increase the chance for successful cases

by 1,000 percent. Furthermore, the

initial costs of the program ($7.4 million)

are largely offset by the related

lowered costs of reduced health insurance

spending/tax revenue losses ($1.9

million) and turnover-related costs of

detentions/deportations ($4 million),

while costing less than 78-cents per

personal income taxpayer per year.

This proposal provides free and quality

counsel—two factors that increase

winning by 500%--for those previously

without counsel which have historically

been disproportionately Hispanic.

The Immigrant Justic Corps attracts

and available removal-defense lawyers.

These lawyers can be used to prove the

absence of serious crimes and reduce

the need to monitor detainees, as removing

these two categories would save

$1.44 billion per year (80 percent reduction

in annual costs), saving rather than

costing taxpayers. San Diego ought to

implement a similar project to protect

noncitizens and reduce external costs.

Implementation Plan

The San Diego Immigration Court underlies

the jurisdictional authority of

the Office of the Chief of Immigration

Judge, which comprises a part of the

Executive Office for Immigration Review

(EOIR) under the Department

of Justice. Related but separate powers

from the EOIR are U.S Citizenship and

Immigration Services (USCIS) and Immigration

and Customs Enforcement

(ICE), which are part of the Department

of Homeland Security (DHS). Both authorities

will need to be contacted at

local offices to localize their powers to

San Diego while applying federal pressure.

Further national government influences

will be found in the Immigration

and Citizenship Subcommittee in

the House, where Zoe Lofgren (CA)

and J. Luis Correa (CA) will provide the

local influence/pressure as well as pass

federal groundwork for bill appropriations

supporting the attorney task-force,

reached through in-person lobbying

efforts and open forums in their districts

discussing immigration reform.

Action Plan Snapshot

After power-mapping key players in the

San Diego Immigration Court system,

the targeted Californian legislators provide

the baseline for building the necessary

coalition efforts. First, senators and

congress members will be contacted via

email with a one-pager within a month

delineating the key elements of the proposal,

highlighting the necessity and the

benefits to the city of San Diego. A campus-based

base will be built through

campus tables promoting the policy,

with students from San Diego contacting

their local legislators with the same

one-pager and the author contacting the

aforementioned members of the Immigration

and Citizenship Subcommittee

in the House, also within the same

month. Members of this campus-based

group will be subscribed to a newsletter

reminding them when and how to contact

their local legislators to continue

their involvement in the year 2020, which

will likely hold the most prominent

pushes preceding the bill appropriations

on October 1 and following the November

elections. If bill appropriations are

secured or supported in October 2020,

then the November push will have the

legal groundwork for the campus-base

to further lobby for the city of San Diego

to implement the attorney system. If not

secured in October, public forums and

direct lobbying to legislators, who will be

sitting before the November elections.

Specific techniques will include direct

meetings between legislators, the author,

members of the Immigrant Justice

Corps and their clients to increase the

clarity of the proposal as well as its efficacy,

also happening in the same timeframe

between October and November.


1. American Immigration Council.

“Access to Counsel in Immigration

Court,” September 27, 2016.

2. “AILA - Practice Alert: Implementation

of Expedited Removal Expansion.”

Accessed November 30, 2019.

3. National Immigration Law Center.

“Blazing a Trail: The Fight for Right

to Counsel in Detention and Beyond.”

Accessed November 30, 2019.

4. Global Detention Project | Mapping

immigration detention

around the world. “Countries.”

Accessed November 30, 2019.

5. National Immigration Forum.

“Fact Sheet: Expedited Removal.”

Accessed November 30, 2019.

6. National Immigration Forum.

“Fact Sheet: Immigration Courts.”

Accessed November 30, 2019.

7. “Federal Judge Blocks Trump Rule

Requiring Immigrants to Prove

Health Insurance.” Accessed

November 30, 2019.

8. Hyperakt. “Evaluation of the

New York Immigrant Family

Unity Project.” Text/html.

Vera, November 30, 2019.

9. Committee on the Judiciary - Democrats.

“Immigration and Citizenship


(116th Congress).” Accessed

November 30, 2019.

10. Public Radio International. “In

New York City, Lawyers Make

All the Difference for Immigrant

Detainees Facing Deportation.”

Accessed November 30, 2019.

11. “Supreme Court Curbs Rights of

Immigrants Awaiting Deportation.”

Reuters, February 28, 2018.

12. Urbi, Jaden. “This Is How Much

It Costs to Detain an Immigrant

in the US.” CNBC, June 20, 2018.


Instituting Financial Incentives:

Increasing Employment of Persons with Disabilities in California

By Manushri Desai and Shivam Saran



To decrease unemployment rates for

PWDs, California’s Employment Development

Department should provide

a fiscal incentive for hiring

PWDs by expanding the Work Opportunity

Tax Credit to include all

individuals determined disabled by

the Social Security Administration.

Background & Analysis

In 1974, California passed its first law to

ensure that PWDs were protected in the

workplace. In an effort to (1) protect and

(2) employ PWDs into the workforce,

California’s Workforce Inclusion Act

in 2002 required the EDD to create “a

sustainable, comprehensive strategy to

bring PWDs into employment.” Today,

the Employment Development Department

(EDD) ensures that all applicants

with disabilities will receive equal employment

opportunities in California.

Despite continued efforts to provide

greater employment opportunities to

PWDs, California has the fifth highest

unemployment rate for PWDs in the

U.S., amounting to a staggering 66.2%.

The top two reasons businesses are

hesitant to hire PWDs, identified in an

analysis by Rutgers University, include

employers’ fears that (1) PWDs are less

productive and (2) that PWDs will incur

“costly adaptations.”. However, a

meta-analysis released by the Cerebral

Palsy Research Foundation , explicitly

finds that there is “no productivity

difference between PWDs and people

without disabilities.” Moreover, a Cornell

University report concluded that

employers’ fear of additional costs such

as “special transport costs for PWDs”

and “pension costs, should the employee

become permanently incapacitated

for work” is not a rational fear; the report

concludes that while a cost difference

between employees with and

without disabilities exists, it is marginal.

A lack of financial incentives to hire

PWDs perpetuates employers’ fear

of costly adaptations and only serves

to increase the staggering unemployment

rate for PWDs in California.

Talking Points

• Only providing equal treatment

for PWDs once they have entered

the workplace has been

historically ineffective at increasing

employment rates for PWDs.

• The biggest barrier to employment

is created by employers’ fear of potential

additional costs. However,

a Cornell University report analyzing

the engagement of PWDs

in the workforce noted that while

the cost difference between people

with disabilities and people without

disabilities exists, it is marginal.

• A lack of disability inclusivity in

“eligible groups” under the WOTC

has prevented PWDs from gaining

access to employment opportunities.

Expansion of the

WOTC to include PWDs would

integrate them into the workforce.

Key Facts

• The employment rate of PWDs in

California was a mere 33.9 percent,

while the employment rate

of people without disabilities was

75.7 percent. The gap between the

employment rates of working-age

people with and without disabilities

was 41.8 percentage points.

• The disabled community consists

of a significant portion

of the California’s adult

population—nearly 21.9%.

• Only three states in the U.S.

(New York, Maryland, & Tennessee)

provide tax incentives

to employers who hire PWDs.

• Companies that succeed in incorporating

candidates with

disabilities “have seen 28


percent higher revenue and

two times higher net income.”

Policy Idea

Given California’s staggering unemployment

rate for PWDs, due to employers’

fears that PWDs are (1) less productive

and (2) incur “costly adaptations,”

California’s Employment Development

Department should provide employers

with a financial incentive to hire PWDs

by expanding the “eligible target groups”

under the Work Opportunity Tax Credit

(WOTC) to include “all individuals determined

disabled according to criteria

established by the Social Security Administration.”

Furthermore, the EDD

should promote the WOTC to private

sector employers of large and small businesses

to combat the underrepresentation

of PWDs in California’s workforce.

Policy Analysis

While California has promoted the

inclusion of PWDs in the workforce

through “employment-first” policies,

California’s EDD has not provided any

fiscal incentives to encourage employers

to hire PWDs. Recognizing that

businesses face challenges while hiring

underserved populations, Congress

designed the WOTC in 2014 aimed at

providing businesses with incentives for

employing economically disadvantaged

individuals including those with disabilities

vocational rehabilitation referrals

and Supplemental Security Income

recipients. However, as the Center on

Budget and Policy Priorities finds, these

two WOTC-eligible categories of PWDs

make up an extremely small subset of the

total population of PWDs in California.

As a result of the narrow scope of eligibility

under the WOTC, only three

states in the U.S. (New York, Maryland,

and Tennessee) have implemented

tax incentives aimed at increasing

the employment rate for PWDs.

New York’s Workers with Disabilities Tax

Credit, most similar to California’s proposed

expansion of the WOTC, was introduced

as recently as May 2018, so the

effect on the employment rate for PWDs

has yet to be measured. However, California’s

unique legislative success with

increasing employment of other eligible

groups under the WOTC reaffirms the

implementation of a reformed WOTC

which would prevent the alienation of

disabled individuals in the labor market.

An expansion of the WOTC to include

all PWDs would be beneficial in three

main regards: (1) removing barriers of

employment for PWDs, hence, reducing

costs spent on government-issued

disability benefits, (2) lowering California’s

overall unemployment rate, hence,

increasing GDP growth and (3) increasing

productivity within the workplace.

Implementation Plan

Integrating PWDs into California’s

workforce is an effort that requires the

inclusion of PWDs as an eligible group

under the WOTC. This action would

be procured by the Employment Development

Department (EDD) of the

State of California. While the EDD is

the primary institution responsible for

the admired change, other sources may

help. An important next step would be

working with nonprofit agencies with

like-minded goals such as Disability

Rights California, the largest disability

rights group in the nation. Establishing

relationships with them would help

procure a better understanding of the

issue at hand and help bring notice to

the urgency of the situation. Moving

forward, in order to introduce the legislation,

it is important to work with representatives

who share a desire to bring

about equality for the disabled. These

include those such as Congresswoman

Katie Porter who has had a long history

of advocating & fighting for PWDs.

Action Plan Snapshot

The first month of the action plan will

constitute formulating this policy into a

one-pager which we can introduce a few

key stakeholders in our policy. In order

to propose this policy, we would first

have to engage with Congresswoman

Porter. We plan on obtaining her support

by developing and sending a brief paper

that outlines the main issue, proposes

our solution, and highlights why our

solution would be effective at mitigating

the problem. By incorporating a detailed

but concise overview of the expansion

of the WOTC and comparing the proposed

policy to legislative precedents in

New York, Maryland, and Tennessee, we

will prepare the one-pager focusing on

why the policy is attractive and urgent

in the state of California. Prior to submitting

our paper to Congresswoman

Porter, we would like to gain more support

from the community. With their resources,

we would plan to spread awareness

of the issue of low employment for

PWDs. This can be done by creating a

petition, in which we gather signatures

to showcase the support for our policy.

Within the first month, we would

have an initial goal of 1000 signatures.

The second month of the action plan

would include reaching out to stakeholders.

The first stakeholder would be

Disabled People’s Organizations (DPOs)

in the State of California including Voice

of Specially Abled People and Disability

Rights California. Because many DPOs

work directly with state level government

officials to advocate for the rights

of PWDs, DPOs can provide us with

access to contacts in the Employment

Development Department which oversees

the Work Opportunity Tax Credit.

Moreover, non-profit organizations that

work to move underserved communities

up the economic ladder through “employment-first

initiatives,” such as LAbased

non-profit Chrysalis, work with

large populations of PWDs in California.

In fact, 47% of Chrysalis’ clients include

PWDs; thus, working with Chrysalis to

understand how the non-profit works to

integrate PWDs into the workforce and

setbacks that PWDs face, can help us gain

a better understanding of the type of

structural change needed in the WOTC.

In order to create an effective campaign,

it is important that we (1) establish relationships

with political representatives

such as Congresswoman Orter in order

to introduce legislation and (2) work with


nonprofit organizations to increase

awareness for the issue and have

the resources to tackle the problem.


1. Services for People with Disabilities.”

Employment Development

Department. 2019. Accessed July

11, 2019.



2. Donnelly, Grace. “See How Your

State Ranks In Employment

Among Workers with Disabilities.”

Fortune. February 28, 2017.


3. Legnick-Hall, Mark L., and Philip

M. Gaunt. “Why Employers Don’t

Hire People With Disabilities: A Survey

of the Literature.” CPRF. https://

4. Linkow, Peter, and Linda Barrington.

“Leveling the Playing

Field.” Cornell University Employment

and Disability Institute.

2013. Accessed July 24, 2019.

5. “Incentives to Employ Workers

with Disabilities Receive Limited

Use and Have an Uncertain Impact.”


TIVES. December 2002. https://

6. Kansas University Center for Research

on Learning, ‘Help Wanted:

Diversifying and Strengthening

your Workforce by

Hiring People with Disabilities’, 2005

7. Sarah Hamersma and Carolyn

Heinrich, Temporary Help

Service Firms’ Use of Employer

Tax Credits: Implications for

Disadvantaged Workers’ Labor

Market Outcomes, Upjohn Institute

Staff. Working Paper No.

07-135, February 12, 2007, p. 5.


Using By-Right Zoning as a Solution to California’s Housing


By Jacob Narvaez



To lessen the effects of California’s

housing crisis and increase

the supply of affordable housing,

the State of California should utilize

by-right zoning laws to incentivize

the development of lower

and middle-income housing units.

Background & Analysis

Millions of individuals and families in

California fear that they are on the edge

of homelessness because they live paycheck-to-paycheck.

The average cost

of a single-family home in California

is one of the most expensive in the nation,

running around $607,900 as of

September 2019 (Collins 2019). With

the median household income in California

being around $71,000 per year,

the dream of owning a home has become

increasingly out of reach for

even middle-class residents of the state.

The housing supply in California is severely

restricted due to local zoning

ordinances. While local control of local

zoning laws is an integral piece of a

local government’s power, there needs

to be a happy medium between protecting

current homeowners and ensuring

the survival of the next generation of

homeowners and renters. Additionally,

a significant amount of housing developments

that end up being approved

and completed in the state are considered

to be luxury housing units. This

influx of luxury units has led to a shortage

of housing units meant to house

lower and middle-income families.

California needs to approve

the construction of millions of

new homes over the next decade

in order to prevent the housing

crisis from being exacerbated.

Talking Points

• Local zoning ordinances that severely

limit growth and the number of

permits being issued are a primary

factor in California’s affordable

housing shortage.

• There is increasing evidence that

shows that local controls on growth

and their discretion in the development

process have a significant impact

on segregation an inequality in

the housing market (Galante 2016).

• By-right zoning establishes

a market-oriented approach

to solving a complex social issue

in order to benefit consumers

and housing developers.

Key Facts

• California has the largest homeless

population in the nation, with

an estimated 130,000 people living

on the streets, representing nearly

a quarter of the nationwide homeless

population (Cowan 2019).

• Massachusetts streamlines the development

of affordable housing

developments and nearly half of the

state had at least 5% of its housing

stock made affordable to low-income

families (Galante 2016).

• California needs to build 3.5 million

additional housing units by

2025 to catch up with demand

(Dougherty 2019). By-right zoning

can assist the state in reaching

that goal in the desired timeframe.

Policy Idea

By-right zoning laws provide for a

streamlined approval process for housing

developers. This particular proposal

would provide that by-right zoning

process to developers seeking to build

lower and middle-income housing

developments. This policy provides

housing developers with a financial incentive

to construct additional lower

and middle-income housing units instead

of luxury units. By-right zoning

also allows for these developments to

be completed significantly sooner than


they would under a traditional approval

process. Thus, California could

more- quickly increase its housing

stock to bring down the cost of housing.

Policy Analysis

Supply and demand are some of the essential

ideas in the field of economics.

Since the goal is to stabilize housing

costs despite high demand, the solution

is to encourage a substantial increase in

the supply of housing. By-right zoning

laws would allow housing developers

producing lower and middle-income

housing to by-pass many of the steps

involved in getting a development

approved and ready to build. By doing so,

developers would be able to begin construction

immediately after the by-right

approval process. As a result, there would

be significantly more housing units constructed

in a shorter amount of time.

Streamlining the housing development

process also helps battle economic inequality.

Marin County, located in the

San Francisco Bay Area, has continued

to block housing developments and,

as a result, has the highest inequality

between racial groups of any county

in the state (Dillion 2018). By-right

housing for lower and middle-income

developments can combat the

rising economic and racial inequality

facing California’s largest cities.

A by-right zoning process also increases

housing developers’ revenues on affordable

housing units by providing for a

better cost to benefit ratio on these developments.

The incentives provided by

the by-right zoning process are enough

to encourage developers to produce affordable

housing units as opposed to

luxury ones. They could get many affordable

housing developments built in

the same timespan as it would build one

luxury development. The ability to begin

construction immediately following the

by-right approval can decrease

long-run construction costs.

Implementation Plan

Efforts to reform zoning laws require a

substantial amount of collaboration between

community groups, government,

and business organizations. AARP

California and Habitat for Humanity

are two large and well-known organization

that support by-right zoning

laws. Coordinating with these groups

to can provide the resources necessary

to educate communities on what

by-right zoning would mean for them.

5. Galante, Carol, and Carolina Reid.

“Expanding Housing Supply in

California: A New Framework for

State Land Use Regulation.” Journal

of Case Study Research: A Publication

of the Center for California

Real Estate 1, no. 1 (2016): 4–8.

We would also need to engage with the

Association or California Cities as well

as state representatives that stand in opposition

to by-right zoning laws. Much

of their opposition stems from the decrease

in local control and the thought of

stagnating home values. It is important

to discuss the outcomes that would result

in such a policy. An increased housing

supply and stabilized housing market

could get some of the homeless off the

streets and clean up some communities.


1. Collins, Gord. “California Housing

Market Report and Predictions

2019 2020.” ManageCasa,

November 22, 2019. https://

2. Cowan, Jill. “How Does Homelessness

in California Compare

With Other States?” The New

York Times. The New York Times,

October 17, 2019. https://www.


3. Dougherty, Conor. “Why $4.5

Billion From Big Tech Won’t

End California Housing Crisis.”

The New York Times. The New

York Times, November 6, 2019.

4. Galante, Carol. “Why By-Right

Affordable Housing in California

Is the Right Thing to Do.”

Terner Center Blog. Terner Center

for Housing Innovation at

UC Berkeley, May 24, 2016.



Preventing Green Gentrification in the Taylor Yard Restoration:

The Value Capture Solution

By Liam Tsao



To limit green gentrification in the

restoration of the Taylor Yard parcel

of the Los Angeles River corridor,

the LA city council should establish

an Enhanced Infrastructure Financing

District (EIFD) to preserve affordable

rental units in the surrounding

Cypress Park neighborhood.

Background & Analysis

Defined by the Barcelona Laboratory

for Urban Justice and Sustainability,

green gentrification is the “processes

started by the implementation of an

environmental planning agenda related

to green spaces that lead to the exclusion

and displacement of politically

disenfranchised residents.” The addition

of parks to marginalized communities

increases property values, displacing

existing residents and leading to

a whiter, more affluent demographic.

Formerly an industrial site, Taylor Yard

is a 42-acre parcel of land along the

Los Angeles River. Beginning in 2017,

the city of Los Angeles has worked

with the Army Corps of Engineers to

revitalize Taylor Yard as part of a $1.4

billion restoration plan for the LA

River. Current plans for Taylor Yard

green space, trails, and nature centers.

However, the city of Los Angeles has not

sufficiently addressed the issue of green

gentrification in these plans. The surrounding

Cypress Park neighborhood

is 82.1% Latinoiv with a median income

below the county average.v 53.08% of

housing units are renter occupied. These

groups are especially vulnerable to the

deleterious effects of gentrification.

Signs of gentrification have already begun.

Since the current iteration of the LA

River Restoration Plan, 39 commercial

and industrial properties have changed

ownership in the nearby Elysian Valley.

Moreover, from 2006 to 2015, the

riverfront Trópico neighborhood experienced

a 168% increase in the density of

non-Hispanic whites and an 18% increase

in median income. Similar processes

are occurring today in Cypress Park.

Talking Points

• Current proposals to restore Taylor

Yard parcel of the Los Angeles

River corridor exacerbate the

risk of green gentrification in the

low-income and majority-minority

Cypress Park neighborhood.

• Loss of affordable housing is widely

viewed as the primary cause of

gentrification-related displacement.

• Creating an Enhanced Infrastructure

Financing District that encompasses

Taylor Yard and Cypress

Park enables the reinvestment of

money back into affordable housing,

allowing existing residents

to remain in the community.

Key Facts

• After restoration of the LA River

began, the riverside Trópico

neighborhood experienced

a 168% increase in the density

of non-Hispanic whites and an

18% increase in median income.

• Cuts in Federal and State funding

have reduced investment in

affordable housing in Los Angeles

County by more than $496

million annually since 2008.

• With an EIFD in the LA River

Corridor creating $40,000,000 in

revenue, and affordable housing

costing an average of $425,000 per

unit, the EIFD could fund a total

of 94 affordable housing units.

Policy Idea

The Los Angeles city council should

establish an Enhanced Infrastructure

Financing District (EIDD) that encompasses

Taylor Yard and Cypress

Park. EIFDs are funding mechanisms


that capture the value gained from

higher property taxes to reinvest back

into community improvements. While

EIFDs have previously been proposed

to fund the Taylor Yard project, most

focus on environmental improvements

that exacerbate green gentrification.

Using the tax increment to fund affordable

housing, however, will ensure

that renters in the Cypress Park

neighborhood are not forced out because

of the Taylor Yard restoration.

Policy Analysis

Enhanced Infrastructure Financing Districts

make up a public funding system

established by the State of California

in 2014. Therefore, the infrastructure

needed to implement this. solution is

already in place. Additionally, EIFDs

have shown promise. In La Verne, California,

an EIFD was established in 2017

to fund infrastructure including affordable

housing. In 20 years, it is projected

to raise over $15,000,000 in revenue.

This solution also involves the Cypress

Park community. According to state

law, EIFDs must be managed by three

local officeholders and two residents.

Engagement with the local community

is integral to preventing gentrification—

by including residents in management,

EIFDs further limit green gentrification.

On a larger scale, this solution also addresses

the lack of affordable housing in

Los Angeles. Cuts in federal and state

funding have reduced investments in affordable

housing in Los Angeles County

by more than $496 million annually

since 2008. The California Community

Economic Development Association estimates

that an EIFD along the LA River

could generate $40,000,000 in community

improvements. Affordable housing in

California costs an average of $425,000

per unit; therefore, the EIFD could

fund 94 new units in the community.

That said, using property tax increments

to fund affordable rental units

will likely face opposition from environmental

organizations like the Friends

of the LA River. This EIFD takes away

funds from the restoration of Taylor

Yard and instead invests it into affordable

housing. However, equitable

greening that values both the interests

of residents and the environment

is ultimately a more tenable solution.

Implementation Plan

To prevent green gentrification in Taylor

Yard with value capture, the Los Angeles

City Council should approve an EIFD

along the LA River. In order to do this,

stakeholders such as the Los Angeles

Regional Open Space and Affordable

Housing Collaborative and the Greater

Cypress Park Neighborhood Council

should lobby the city government to

address this issue. Councilman Mitch

O’Farrell has previously expressed support

for an EIFD to fund river restoration.

The implementation of the EIFD

should also be subject to community

input. Before passing the EIFD, the

Los Angeles city council should host

several open forum stakeholder meetings

to ensure that the interests of residents

are met. Actively engaging with

the community will persuade residents

that restoration and gentrification are

not synonymous. Finally, at the top

level, efforts must be made to persuade

Mayor Eric Garcetti that green gentrification

is an important consideration

when restoring the Los Angeles River.

Action Plan Snapshot

To ensure the implementation of my

policy, I plan to engage with several

key stakeholders. First, I will schedule

a meeting with the Los Angeles Regional

Open Space and Affordable Housing

Collaborative (LAROSAH), an organization

devoted to balancing environmental

restoration with affordable housing.

During my visit with LAROSAH, I plan

to explain the benefits of value capture

in preventing green gentrification in the

Cypress Park neighborhood. I also intend

to engage with the Friends of the LA River

(FOLAR), an organization that supports

the current river restoration plan.

I will explain to this organization

why gentrification is intertwined

with park development. I am also interested

in the environmental community’s

perspective on my policy.

Overall, my strategy for equitably restoring

Taylor Yard hinges on unifying

a variety of stakeholders. While everyone

is important, I believe that the interests

of Cypress Park residents should

define the debate on the Taylor Yard

parcel. In this vein, I plan to attend forums

about the future of the Los Angeles

River corridor, specifically Taylor Yard.

I hope to listen to community input

and explain my value capture solution.

To promote my policy agenda, I first

need to educate the USC campus community

about the LA River and Taylor

Yard. To do this, I will write an article in

the Daily Trojan, the university newspaper.

One aspect of the policy-making

process that I found frustrating was the

dearth of information on the LA River

restoration. To remedy this lack of information,

I plan to create a bi-monthly

newsletter that updates people in the Los

Angeles community on the river. This

will serve a dual purpose. Not only will

the newsletter keep existing supporters

engaged, but it will raise awareness about

the challenges of restoring the LA River.

I look to spread these actions out over

twelve months. In December 2019 and

January 2020, I will meet with LARO-

SAH and FOLAR to get input on the

feasibility of my policy proposal. I

also plan to attend community forums

about the LA River. In the spring, I will

begin the advocacy phase, increasing

knowledge about green gentrification

in Taylor Yard in my campus and local

communities. During the summer, I

will continue to advocate for my policy,

lobbying LA city council members

and Mayor Garcetti’s office with emails

and one-pagers. In fall 2020, I finally

hope to see an affordable housing EIFD

being considered by the city council.


1. “Critical Sustainability Studies.”

Barcelona Laboratory for Urban

Environmental Justice and


Sustainability. Accessed November

24, 2019. http://www.

2. García, Robert, and Tim Mok.

Whitewashing the Los Angeles

River? Displacement and

Equitable Greening. Los Angeles,

CA: City Project, 2014.

3. City of Los Angeles. “Taylor Yard

G2 River Park Project.” Taylor

Yard. Accessed November 24, 2019.

4. Los Angeles Times. “Cypress

Park.” Mapping LA. Accessed

November 24, 2019.

5. Cypress Park Demographics.”

Cypress Park Population

& Demographics, Median

Income - Point2 Homes.

Accessed November 27, 2019.

6. Betancur, John. “Gentrification and

Community Fabric in Chicago.”

Urban Studies 48, no. 2 (February

1, 2011): 383-406. https://doi.

7. “Who Is Vulnerable to Gentrification’s

Effects?” Dealing with Gentrification.

Accessed November 24, 2019

8. Kim, Esther G. “Bring on the Yuppies

and the Guppies! Green Gentrification,

Environmental Justice,

and the Politics of Place in

Frogtown.” In Just Green Enough:

Urban Development and Environmental

Gentrification, edited

by Winifred Curran and Trina

Hamilton. Routledge, 2011.


9. Christensen, Jon. “Green Gentrification

on the Los Angeles River:

A Battle for the Future of the City.”

KCET. Last modified February 20,

2018. Accessed November 26, 2019.

10. Sutkin, Carrie. “Critical City

Council Vote Could Destroy Latino

Neighborhoods Along the

Los Angeles River.” CityWatch

Los Angeles, November 25, 2019

11. Mathews, Joe. “How One Small

City Could Show Way for California

Housing Challenge.” San Francisco

Chronicle, June 8, 2019.

12. City of La Verne, City of La Verne

§. Accessed November 27, 2019.


Regulating For-Profit Colleges in California:

Disincentivizing the Mismanagement of Federal Funding

By Jaehee Cho



To mitigate the risk of financial mismanagement

and predatory recruitment

practices in for-profit

education institutions, the State of California

should institute a multi-tiered

penalty system regarding the permitted

proportion of an institution’s revenue

that constitutes federal funding.

Background & Analysis

It is estimated that the total sum of student

debt in the United States exceeds

1.5 trillion USD, with about one-third

of adults under the age of 30 possessing

at least some debt. A leading cause

for this astronomical figure is rising

tuition costs for colleges-- a phenomenon

most apparent in the for-profit

college industry. 88% of for-profit

college graduates hold an average of

39,950 USD in student debt. Moreover,

these students are disproportionately

minorities, women, and single parents.

In July of 2019, the Department of

Education, led by Secretary of Education

Betsy Devos, issued the final

repeal of an Obama-era regulation

of for-profits known as Gainful Employment.

The regulation penalized

programs that produced unmanageable

amounts of debt for graduates.

With this loosening of federal oversight

on for-profits, individual states have attempted

to protect underprivileged students

from excessive debt and impractical

degrees. In recent months, In 2019,

California introduced eight bills that

aimed to re-introduce past federal regulations

such as gainful employment and

enhance for-profit regulation on a state

level. However, the state has only been

able to pass one. For-profit colleges rely

primarily on federal funds, which can

legally constitute 90% of an institution’s

total revenue. However, there are no

specifications on how these funds can be


Talking Points

• Student loans are often seen as

more of an investment than a financial

burden; therefore, students

are more inclined to view

loans as less of a significant worry

and more of a minor concern.

• Enrollment at for-profit colleges

disproportionately consists of

non-traditional students including

students over the age of 24, minorities,

women, and single parents.

• By implementing a penalty system

on for-profit mismanagement

that specifically targets federal

funding, the California State

Government can disincentivize

predatory business practices as

well as penalize for-profits with

non-productive spending practices.

Key Facts

• A NCES study found that 24%

of students at 4-year for-profit

college are accepted without a

high school diploma, compared

to 4% at a public 4-year college.

• A NSC Research center study

found that the mean six-year

completion rate at for-profit

universities was 35% in 2011.

• The twelve-year default rate for

borrowers who started college

in 2003-2004 at for-profit colleges

was 52%, compared with

26% for those who started college

at a community college.

• Low-income students tend to

be overrepresented at for profit

institutions and less represented

at public and private nonprofit

four-year institutions.

Policy Idea

The California State government should

build upon the established 90:10 rule governing

for-profit funding by establishing


a penalty for for-profit colleges that

spend less than 50% of federal revenue

on direct tuition and/or more than 15%

on advertising and marketing to 85%

for 2-year and 80% for 3-year offenders.

The penalty would be lifted once

the college operates within the allocated

spending threshold for 2-3 years, depending

on the applicable funding cap.

Key Facts

With a legislative effort to place a hard

cap on funding percentage at 85% in California

having failed, it is clear that an alternative

solution is necessary. A penalty

system to regulate for-profits that largely

rely on federal funds for advertising,

marketing, and other expenses unrelated

to direct tuition would disincentivize

such spending allocations. The policy

will be targeting a select minority- only

0.9% of for-profits operate with a 90%

ratio of federal funding- of mismanaged

and unproductive for-profit colleges and

would have little to no bearing on the approximately

15% of colleges which operate

with a funding ratio of 85% or less.

The policy will have a direct effect on the

most vulnerable student demographics,

as for-profit institutions, particularly

those subsisting primarily on federal

funding, often divert resources towards

predatory recruitment practices that

target students who otherwise would

not be able to gain access to higher education.

Students attending for-profit

colleges operating at the 90% cap of federal

funds are particularly vulnerable to

sub-par education and impractical degrees;

placing a minimum requirement

of 50% of spending on tuition and cap

of 15% on advertising and marketing

will ensure that students are able to receive

a better value for their education.

In relation to past initiatives to regulate

for-profit education, which were strongly

opposed by special interest groups, this

policy differs in its approach. In making

a clear distinction between bad and

good actors, it utilizes an economic incentive

mechanism, which would therefore

mitigate any damage to an industry

which generally functions to enhance

the accessibility of higher education.

Implementation Plan

Due to lobbying efforts, most of the

bills introduced from the California

State Assembly regarding for for-profit

educational institutions have either

been voted down in the State Senate or

held in subcommittees. However, the

framework has been set in place for the

introduction of new measures. California

State Assembly members Susan

Talamantes Eggman, Rebecca Bauer-Kahan,

Marc Berman, David Chiu,

and Kevin McCarty could be potential

advocates of the policy idea, given their

history of having introduced a similar

85% revenue cap bill in early 2019. Furthermore,

collaboration with non-governmental

organizations advocating

for equity in education such as MDRC,

Veterans Educational Success and the

Education Trust can raise awareness

to underprivileged communities about

the potential impacts of the policy

and also rally support for its passing.


1. Anthony Cilluffo, “5 Facts

about Student Loans,” Pew Research

Center, Pew Research

Center, August 13, 2019.

2. “Beginning Postsecondary Students

(BPS),” National Center for

Education Statistics (NCES) Home

Page, U.S. Department of Education,

Accessed November 27, 2019,

3. Felicia Mello, “What Happened

to California’s Crackdown

on for-Profit Colleges?”

CalMatters, September 9, 2019.

4. Ibid

5. Matthew Baron Rotondi, “Making

Meaning of Student Debt: How Undergraduate

Students Make Sense

of Their Student Loan and Credit

Card Debt” (January 1, 2015): 316.

6. “Beginning Postsecondary Students

(BPS),” National Center for

Statistics (NCES) Home Page,

U.S. Department of Education,

Accessed November 27, 2019

7. Robert Kelchen, “How Much

Do for-Profit Colleges Rely on

Federal Funds?” Brookings,

Brookings, January 10, 2017,

8. Tressie McMillan Cottom,

“For-Profit Colleges Thrive Off of

Inequality,” The Atlantic, Atlantic

Media Company, February 22, 2017

9. “Bill Text - AB-1343 Private

Postsecondary Education: California

Private Postsecondary

Education Act of 2009,” California

Legislative Information,

Accessed November 27, 2019.

10. “MDRC,” MDRC, Accessed

November 27, 2019,

11. Trust, Ed. “The Education

Trust.” The Education Trust.

Accessed November 27, 2019.

12. “By the Numbers: For-Profit Colleges,”

Center for Analysis of Postsecondary

Education and Employment,

Accessed November 27, 2019,

13. D. Shapiro, A. Dunar, F. Huie,

P.K. Wakhungu, X. Yuan, A. Nathan,

A. Bhimdiwali, (2017, December),

“Completing College: A

National View of Student Completion

Rates – Fall 2011 Cohort”

(Signature Report No. 14),

Herndon, VA: National Student

Clearinghouse Research Center.

14. Judith Scott-Clayton, “The Looming

Student Loan Default Crisis Is

Worse Than We Thought,” Brookings,

Brookings, May 15, 2018.

15. Joselynn H. Fountain, “The Postsecondary

Undergraduate Population:

Student Income and Demographics,”

The Postsecondary

Undergraduate Population: Student

Income and Demographics, 2019.





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