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As presently conceived, the proposed CalEPA approaches to
identifying disadvantaged communities will entirely leave out many,
real disadvantaged populations around the state. The proposed
CalEnviroScreen methods are highly selective and result in serious
geographic inequity in the identification of disadvantaged
populations.  There is inequity because many excluded areas,
including most of Santa Cruz County, actually do have populations
that should be recognized as “disadvantaged”, and are recognized as
such under most understandings of the term such as those set by HUD
for CFBG, UC Davis Center for Regional Change metrics (ratio of
low-wage jobs to affordable housing units), Department of Water
Resources, California Transportation Commission (CTC), and U.S.
DOT. In area's with a high cost of living, poverty is not a good
measure of income. Instead more accurate methods for getting at a
community's low-income (or financially disadvantaged) population
would be to look at the % of income spent on housing (housing cost
burden), homelessness per capita, persons living in overcrowded or
inadequate living conditions; or housing affordability (for sale
and rental).  

Original File Name:

Date and Time Comment Was Submitted: 2014-09-15 15:43:17