Editor Note: The Civic San Diego Board of Directors is meeting today, April 29 at 1 pm to discuss adoption of their Community Benefit Policy (Item 8). You can read that policy here. The Community Budget Alliance supports a more concrete and comprehensive policy to address and protect the concerns of city of San Diego residents. A comparison chart of both policies is included at the end of their letter.
April 22, 2015
Dear Civic San Diego Board Members,
In light of the dissolution of the redevelopment agencies, the City of San Diego has a responsibility to establish clear policies and standards for publicly subsidized community economic development. In October 2014, the Public Safety and Livable Neighborhoods committee directed Civic San Diego to conduct a community outreach process. The goal of that process was to gather public feedback about what should go into a Community Benefits Policy for community economic development and to bring back recommendations for a policy in March 2015.
The Community Budget Alliance expressed concerns that the outreach process was not broad, robust or inclusive and shared these concerns with members of the City Council. The Community Budget Alliance is writing to the Board of Civic San Diego to share our recommendations for a community benefits policy. The purpose of a community benefits policy is to ensure that whenever public resources (i.e., funds, real estate, etc.) enable development, the collective needs, concerns and financial interests of the residents of San Diego are addressed and protected. A community benefits policy maximizes opportunities for good development projects with public returns on investments, especially in communities where development needs have been identified. The minimum standards outlined in our proposal must be consistent for all neighborhoods, rather than being created on a case-by-case basis, to ensure that basic community benefits are delivered to every San Diegan.
The community benefits policy framework proposed by Civic San Diego staff will not ensure responsible and responsive development. A comparison of the recommendations by the Community Budget Alliance and the proposed community policy framework by Civic San Diego staff is attached.
1. Increase the Availability of Affordable Housing. Consistent with redevelopment law’s focus on affordable housing, a community benefits policy should dedicate no less than thirty percent of any funds aggregated for community economic development to building affordable housing. Additionally no less than thirty percent of all housing units built as part of a project using any funds aggregated for community economic development shall be affordable to low, very-low, and extremely-low income households.
2. Conform to City Policies for Responsible Economic Activity. To be consistent with the City’s economic development strategy the community benefits policy should expand City policies to apply to development projects, including, but not limited to, the Living Wage Ordinance, Equal Employment Opportunity, Conflict of Interest, Service Worker Retention Ordinance, Non-Discrimination in Employment, Prevailing Wage Ordinance, Public Art, Debt Policy, the City’s General Plan, and the applicable community plan to developers, contractors, and tenants of projects, receiving a public subsidy as part of community economic development. Also, residents displaced by a Community Economic Development project should be provided relocation assistance pursuant to the California Relocation Assistance Law.
3. Create Quality Local Jobs and Provide Career Training. The policy should ensure that developers and contractors who receive the benefit of public support shall provide job and career development opportunities by making jobs and construction careers available to local residents, by setting the following goals and requirements:
a) no less than 70% of a project’s work hours will be performed by San Diego County residents;
b) no less than 30% of a project’s work hours will be performed by residents in low-income areas of the City of San Diego; and
c) through the use of joint labor/management apprenticeship programs.
4. Protect Public Investments by Creating Development Certainty. Because the City’s financial and proprietary interests are in protecting public investments, the policy should provide certainty to the timely completion and harmonious operation of publicly supported projects by requiring developers, contractors, and tenants to safeguard labor peace. A pre-qualification process to ensure the use of reputable contractors and subcontractors on its projects should be required as part of the community benefits policy.
5. Include and Respect the Community Voice. The policy should establish a community review process for each of the areas targeted for community economic development. Each geographic area should have its own standing community review board of either elected or City Council appointed community members structured similarly to the project area committees that have existed as part of redevelopment. The community review boards should be directly involved in the planning, approving, and implementing of new development projects that receive a public subsidy or benefit from other public support. As a way of building sustainable structures for ongoing economic development, CivicSD, or any other agent acting in the interest of the City of San Diego should partner with community-based nonprofit organizations in carrying out projects, unless there is no such organization active in the geographic area.
6. Inform the Community about the Benefits and Impact of Proposed Projects. The policy should require a Community Benefits and Impact Report for every project that will be reviewed by the community review board and the City Council. At minimum, the Report should explain how the project supports or adversely impacts the affected geographic area’s: 1) capital improvement needs, as identified as priorities in the City’s capital improvement program budget or listed as underfunded; 2) needs for retail, health, or social services; 3) small businesses; 4) minority-owned enterprises; 5) access to healthy food choices; 6) educational opportunities, day care services, or other community needs; 7) affordable housing stock; 8) access to new jobs; 9) access to jobs paying a sustainable wage and 10) tax base. The Report shall be made available to the public in advance of the community review board’s final review of the project.
7. Protect the Public Interest by Ensuring that Accountability and Authority Ultimately Rests with the Elected Representatives of the Public. As under redevelopment, every project agreement should be approved by the City Council. The policy should ensure that all projects: 1.) include compliance provisions in the project agreement; 2.) are monitored for compliance; and 3.) have deed restrictions filed, as appropriate. There should be quarterly reporting to the City Council regarding community economic development activity. And every five years, the community economic development program activities shall be evaluated and reported to the City Council.
8. Have Minimal Variances or Exceptions to the Policy. When a conflict between the community benefits policy and the requirements of a specific funding source arises, local requirements should be modified as narrowly as possible to conform to funding source requirements. And in that case a community benefits agreement that provides standards and community benefits to offset the modification must be created.
The Community Budget Alliance looks forward to working with members of the Civic San Diego Board and the San Diego City Council to develop a comprehensive Community Benefits Policy. If there are any questions, please contact coalition organizer Samer Naji at firstname.lastname@example.org, or at (619) 584-5744 x60.
Community Budget Alliance