How Are California Cities Addressing Housing Needs and Environmental Justice Concerns?

Summary
For this project, you’ll be writing a 4-pp single-spaced memo summarizing how one California
city (of your choice) has responded to the state’s requirement to plan for housing development.
How has the introduction of new “environmental justice” rules around cities’ general plan process
affected housing development plans?
Background
California cities are required to complete and updated general plans, extended documents meant
to coherently organize policies across multiple issue domains and remove inconsistencies in local
policies. It is meant to require cities to develop a strategic vision of future development strategies.
Within each General Plan are topic-specific “elements”—generally self-contained, detailed
medium-range city plans--that are revised and renewed on a regular basis. We are interested in
two such elements.
The first, the Housing Element, is required of all cities and counties, and includes the following
items:
1. An analysis of housing needs of the city’s population.
2. An inventory of housing sites to accommodate future growth.
3. An analysis of housing constraints that impact housing production,
4. Programs that implement the city's housing policies,
5. Action that promotes and furthers fair housing opportunities.

The Housing Element must be updated every eight years, and this update is usually a multi-year
process involving advisory committees, city council discussion, and public debate. Housing
Element updates have taken on added importance with revisions to the state’s Regional Housing
Needs Assessment (RHNA) process, which requires cities to demonstrate that they are permitting
development of needed housing. Each city’s Housing Element is reviewed and approved by the
California Department of Housing and Community Development.

The second element (or requirement) pertains to the logic of environmental justice (EJ). SB 1000,
passed in 2016, requires incorporation of an “environmental justice element” or “related goals,
policies, and objectives integrated in other elements” to be included in the General Plan. This EJ
requirement requires cities to identify and label “disadvantaged communities” that suffer from
both poverty and environmental threats (or determine if such communities exist). SB 1000
requires cities to

1. “Identify objectives and policies to reduce the unique or compounded health risks in
disadvantaged communities by means that include, but are not limited to, the reduction of
pollution exposure, including the improvement of air quality, and the promotion of public
facilities, food access, safe and sanitary homes, and physical activity.
2. “Identify objectives and policies to promote civil engagement in the public decisionmaking
process.
 3. “Identify objectives and policies that prioritize improvements and programs that address
the needs of disadvantaged communities. 1
“Disadvantaged communities” is a specific legal term. It “means an area identified by the
California Environmental Protection Agency pursuant to Section 39711 of the Health and Safety
Code or an area that is a low-income area that is disproportionately affected by environmental
pollution and other hazards that can lead to negative health effects, exposure, or environmental
degradation.” Cities have discretion over how to identify these elements.
Research Question
In a memo of no more than 4 single-spaced pages (in 12-pt font), please respond to the following
prompt about a large California city of your choice.
The SB 1000 environmental justice law adds additional, possibly conflicting policy demands to
cities’ housing and development efforts. In response to the law, how have cities identified
“disadvantaged communities” and proposed responses to environmental justice concerns? In your
opinion, have they done so appropriately? To what extent have such efforts succeeded at
advancing “environmental justice” goals simultaneously with housing affordability goals? Are EJ
concerns incorporated into the city’s housing element, and vice versa? Do the city’s actions around
the EJ requirements appear to be aimed at facilitating more housing development, impeding it, or
is it likely that it won’t make much difference?
In particular
In your answer, please address the following:
• Using the Cal Enviro Screen tool and Social Explorer, assess which portions of your city
are most likely to be designated as “DACs” (disadvantaged communities) under SB 1000.
If the city has already designated such areas, do you agree with the choices? [Check-in
4/20]
• What are your city’s new RHNA housing production requirements? Under RHNA and the
Housing Element revisions, cities are required to identify areas open to new housing
development. How do those areas overlap with areas that might be considered “EJ” or
“DAC” neighborhoods? [Check-in 4/27]
• Different cities are at different stages of their Housing and Environmental Justice revision
processes. Regardless of the stage, do EJ concerns seem to be incorporated into discussions
of housing (either sincerely or strategically) by supporters and opponents of more dense
housing development? [Check-in 5/4]
• To the extent your city has done a retrospective, how well have the city’s previous general
plans resulted in new housing growth? Do you believe the new EJ provisions will facilitate
better housing development—especially for low-income residents?
The final project memo will be due on Monday, May 31.
Useful Links:
Item Link

1
Yes, this is extremely
OPR Guidance to Cities on General Plan https://opr.ca.gov/docs/OPR_C4_final.pdf
Elements
Updated OPR Environmental Justice https://opr.ca.gov/docs/20200706-
GPG_Chapter_4_EJ.pdf

HCD Regional Housing Needs Assessment https://www.hcd.ca.gov/community-

Website
CEJA Environmental Justice Planning
Toolkit (written by advocacy group that
sponsored SB 1000)
Cal Enviro Screen (draft version 4.0)
development/housing-element/index.shtml
https://bit.ly/3dczvEu
https://oehha.ca.gov/calenviroscreen/report/draft-
calenviroscreen-40

Social Explorer https://www.socialexplorer.com/explore-maps