December 12, 2024
Mayor Jerry Dyer
Fresno City Councilmembers
Michelle Zumwalt, Planning and Development Department
2600 Fresno Street, Room Fresno, CA 93721
RE: City of Fresno 6th Cycle Housing Element
Sent via email:
Dear Mayor Dyer, Councilmember, and Ms. Zumwalt:
Leadership Counsel for Justice and Accountability (“LCJA”) and Public Interest Law Project (“PILP”) submit this comment letter in response to the City of Fresno’s city council agenda item ID 24-1626. The City was due to have adopted a revised Housing Element for the Sixth Cycle (2023-2031) by last December, but it has not yet adopted a Sixth Cycle Housing Element that substantially complies with Housing Element Law. The Draft presented to Council for adoption needs additional revisions to fully reflect the needs and input of the community. The existing Draft Housing Element draft does not adequately respond to the City’s housing crisis or the needs of its most vulnerable residents, such as those living in Racially and Ethnically Concentrated Areas of Poverty (R/ECAPs). Several of the Draft’s programs lack meaningful actions that, in addition to combating discrimination, will help to overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. Accordingly, we urge Council not to adopt the current Draft, and to direct staff to make further revisions before adoption, as discussed below.
Our organizations, along with allies and partners, have sent multiple rounds of comments to the City throughout the Housing Element process. While we appreciate that staff has incorporated many of the changes that we suggested, the current Draft still has several key areas that are lacking. Our previous comments have detailed community-identified programs that are needed to respond to critical housing needs. These programs, as well as recommended amendments to programs that already exist in the Draft, would affirmatively further fair housing and replace segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity. We strongly urge the City to amend language to programs 27 and 34 and to incorporate the additional community-identified programs described below.
● Program 27 – Environmental Justice. The program should include the following actions to improve the quality of life in R/ECAPs, specifically in the communities residing in South Fresno:
○ Implement land use changes to rezone industrial use and prohibit future industrial uses near sensitive receptors.
○ Prohibit the siting of polluting uses near impacted communities and impose impact fees on polluters operating near homes. The funds generated will go towards a community benefit fund managed by the impacted community and utilized to transform R/ECAPs into areas of opportunity. ○ Establish a moratorium on warehouses in or near R/ECAPs. ○ Create a community advisory committee that will work on the South Central Specific Plan.
● Program 34 - Eviction Protection Program. Tenants need legal representation, professional mediation, and guidance in navigating the eviction process as well as landlord/tenant law to avoid displacement. The Eviction Protection Program is a critical anti-displacement tool that is providing a significant benefit to tenant households and the community. The Housing Element should commit to ongoing funding of the program, and to codify it in the City’s municipal code by June 2025. ● Rent Stabilization and Just Cause Protection. We recommend that the City evaluate the feasibility of adopting measures to protect residents from displacement, including consideration of adoption of rent control and just cause eviction protections. ● Inclusionary Zoning. The Housing Element should commit to preparing a feasibility study to support preparing a feasibility study to support the consideration and potential adoption of an inclusionary housing ordinance that would require a percentage of units in new housing developments to be set aside for affordable housing cost for lower-income households. Such a study would help to ensure that any inclusionary housing requirement that the City considers is right-sized for local conditions and will deliver the number and type of affordable units that a community needs. It would also provides a data-driven foundation for the requirement, which can help overcome opposition by showing that it can be implemented without impeding new development ● Rental Assistance Program. The City should create a permanent program to provide emergency rental assistance to lower-income households that are unable to pay rent or have past due payments, regardless of immigration status. Such a program would help to prevent displacement, strengthen the existing Eviction Protection Program, and affirmatively further fair housing. In light of the expiration of ERAP, the City should commit to creating and funding such a program. Funding sources could include the General Fund and Local Housing Trust Fund, as well as other sources like ESG and HOPWA. The City could time the program to correspond with the adoption of its Consolidated Plan in 2025 to ensure consistency.
We encourage the City to consider and ultimately incorporate these programs that R/ECAP communities identified as necessary anti-displacement, environmental justice, and affordable housing measures, and which will substantially improve their quality of life and affirmatively further fair housing. Please reach out to us if you have any questions or concerns.
Sincerely,
/s/
Jovana Morales Tilgren
Housing Policy Coordinator Leadership Counsel for Justice and Accountability
/s/
Seth Alston
Legal Advocate
Leadership Counsel for Justice and Accountability
/s/
Melissa A. Morris,
Staff Attorney
Public Interest Law Project
Cc:
Architect, Michelle Zumwalt,
City Manager Georgeanne White,
Planning Director Jennifer Clark,
Council President Analisa Perea,
Councilmember Mike Karbassi,
Councilmember Miguel Arias,
Councilmember Tyler Maxwell,
Councilmember Luis Chavez,
Councilmember Garry Bredefeld,
Councilmember Nelson Esparza,
Mayor Jerry Dyer,
Thomas Brown, Policy Analyst, California Department of Housing and Community Development
Paul, McDougall, California Department of Housing and Community Development,
From: Arieana Castellanos
To: Clerk
Subject: Public comment item 24-1626
Date: Wednesday, December 11, 2024 1:36:00 AM
External Email: Use caution with links and attachments
Hello,
I am emailing in support of recommendations from the Leadership Counsel and Fresno Housing Coalition spoken at the Planning commission. Which is that the Housing Element not be accepted as it is non-compliant and also doesn't include community plans/ideas for solution. While the plan does say to focus on "housing first," I would also like to request an oversight body comprised of multidisciplinary officials from drs, social services, advocates, and most importantly people with lived experience being homeless in fresno. There is a couple folks who I know are interested. I would also like to see the operationalized definitions for housing first which fresno is planning to use.
Further, in homeless assistance, I see that it includes HART. Sweeps prolong homelessness and as a social worker who’s worked at Marjaree Mason Center and Ronald McDonald House Charities of the Central Valley, I can tell you what things people have on them are so important. It includes documents to receive payments, deceased family’s ashes, irreplaceable personal items, and necessary items to live. Both plans need lived experience community members.
A study in LA found housing 4 chronically homeless people saved the city 80k a year (which is the allocation of the sister city program in the 24-25 budget for Fresno).
A recent study in the Journal of American Medical Association explored progress of Downtown Emergency Service Center (DESC) in Seattle, WA. All residents in a Housing First-styled residence experienced severe alcohol useissues and varied medical and mental health diagnoses. “In accounting for all expenses – including housing costs – participants in the 1811 Eastlake program cost $2,449 less per person per month than those who in conventional city shelters.
A cost study of rural homelessness from Portland, ME found significant cost reductions when providing permanent supportive housing as opposed to serving the people while they remain homeless. The study specifically noted a 57 percent reduction in the cost of mental health services over a six-month period, partly due to a 79 percent drop in the cost of psychiatric hospitalization
Thank you for your time.
Warmly,
Arieana