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Comment 86 for Public Workshops on Investment of Cap-and-Trade Auction Proceeds to Benefit Disadvantaged Communities (sb-535-guidance-ws) - 1st Workshop.
First Name: Ellen
Last Name: Timberlake
Email Address: Ellen.Timberlake@santacruzcounty.us
Affiliation: County of Santa Cruz Human Services Dept
Subject: Recommendations for revising disadvantaged population determinations
Comment:
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).
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Date and Time Comment Was Submitted: 2014-09-15 15:43:17
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