HomeMy WebLinkAbout08-02-2023_Open Session_Item 16_ACLU Foundation_links sanitizedINLAND EMPIRE OFFICE • 3400 CENTRAL AVE, SUITE 230 • RIVERSIDE, CA 92506 • T 909.380.7510 • F 951.534.0453 • ACLUSOCAL.ORG
August 1, 2023
Mayor and City Council
City of San Bernardino
Via email: publiccomments@sbcity.org
RE: Public Comment on Agenda Item #16, 2021-2029 Draft Housing Element
Dear Mayor and City Councilmembers:
Please find attached for your consideration our public comment on the City of San Bernardino’s
2021-29 Draft Housing Element, which was previously submitted as a comment to you, to
futuresb2050@sbcity.org and to the Planning Commission.
Consistent with Council’s action at the April 5, 2023 City Council meeting, during which you
voted to move forward with repeal of the Crime Free Multi Housing Ordinance, we ask you to
take the following actions at tomorrow’s City Council Meeting:
1. Provide direction to staff to revise the 2021-29 Draft Housing Element in order to
eliminate Program 3.2, the Crime Free Multi-Housing Program, and to remove the
sections of the Draft Housing Element that make inaccurate statements about that
program;
2. Authorize, by motion, staff to make changes to the 2021-29 Draft Housing Element based
on Council’s directions to remove Program 3.2, the Crime Free Multi-Housing Program
and sections of the Draft Housing Element that make inaccurate statements about that
program, and in light of the issues raised in the attached public comment letter.
3. Authorize, by motion, the Community, Housing, and Economic Development
Department to submit the revised document to the State Department of Housing and
Community Development (HCD) for review only after making the changes urged here
and in the attached comment letter.
Sincerely,
Adrienna Wong
Sr. Staff Attorney
Mayor Helen Tran and City Councilmembers
290 North D Street
San Bernardino, CA 92401
mayor@sbcity.org
council@sbcity.org
Sonia R. Carvalho, City Attorney
290 North D Street
Third Floor
San Bernardino, CA 92401
Attorney@SBCity.org
Charles McNeely, City Manager
290 North D Street
San Bernardino, CA 92401
McNeely ch@sbcity.org
Via Email: FutureSB2050@sbcity.org
Re: Comments on City of San Bernardino’s Draft 2021-2029 Housing Element
Dear Mayor Tran and City Councilmembers,
We write on behalf of the ACLU of Southern California to provide public comment on the City
of San Bernardino (“City”) Draft 2021-2029 Housing Element (“Housing Element”).
Specifically, we write to correct certain factual and legal misstatements in the draft Housing
Element regarding: (1) the Crime Free Multi-Housing (“CFMH”) Program and the City’s
compliance with fair housing laws (see pages 1-7, below), and (2) the City’s plans concerning
homeless services and enforcement of its anti-camping ordinance (see pages 7-9, below). Given
the serious consequences that the CFMH Program and failure to adhere to Housing First best
practices approaches will cause to our members and the communities we serve, we call on the
City to terminate the CFMH Program and to amend its Homeless Services and anti-camping
enforcement plans outlined in the draft Housing Element.
I.THE DRAFT HOUSING ELEMENT SHOULD BE REVISED TO ELIMINATE
PROGRAM 3.2 – CRIME FREE MULTI-HOUSING PROGRAM
The draft Housing Element states that the City’s CFMH Program will be continued in the
Housing Element. The sections of the draft Housing Element describing the CFMH Program
contain multiple inaccuracies and conflict with the City’s Fair Housing Assessment. Further, the
draft Housing Element proposes that the City increase the resources it dedicates to staffing the
CFMH Program; these are public resources that could be more appropriately invested in housing
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AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF SOUTHERN CALIFORNIA
instead, especially given that the draft Housing Element fails to propose sufficient housing to
meet the needs of unhoused residents of the City (as discussed further below). For all the reasons
discussed below, the draft Housing Element should be revised to eliminate the CFMH Program.
A. The Draft Housing Element Misstates How The CFMH Program Operates
The draft Housing Element makes multiple claims about the City’s CFMH Program that are
simply false. The draft Housing Element must be revised to remove these factually inaccurate
statements so that the City does not provide false information to the California Department of
Housing and Community Development and to the people of San Bernardino.
First, the draft Housing Element inaccurately claims: “In implementing the crime-free lease
agreement, neither the City nor the Sheriff’s Department is involved in any way in a landlord's
decision on whether or not to exercise the rights under the addendum.” However, the reality is
that City Code Enforcement encourages law enforcement officers to complete “Crime Free
Housing Referrals/Complaints” when “dealing with a tenant causing issues or [who are] not
cooperative with law enforcement efforts,” which Code Enforcement then “handles” with
landlords. See Attachment A. Additionally, as a condition of certification as a “Crime Free
property,” the City requires landlords to “actively pursue the eviction of tenants who violate the
terms of the lease and/or crime-free lease addendum.”1
Second, the draft Housing Element incorrectly claims, “Nothing in the City’s program sanctions
or in any way condones any actions by a landlord that would violate any law related to fair
housing or anti-discrimination, and the requirement applies equally to all tenants regardless of
income or other household status.” However, the program only applies to tenants of multi-family
rental properties, not tenants of single-family homes, which means it will likely be applied more
often to lower-income and minority tenants.2 Moreover, the City’s “Crime-Free Multi-Housing
Referral Card” indicates that the program encourages violations of state fair housing law, in that
it not only ties potential housing consequences to “arrest information” but also specifically tracks
whether the tenant identified is in Section 8 housing.3 See Attachment B. And the CFMH
ordinance states that certification as a “Crime Free property” may be revoked “if there are 10 or
more calls for service in a one-year period" associated with a property.4 By punishing landlords
for calls for service originating from their properties, the CFMH ordinance violates the Right to a
Safe Home Act, Cal. Gov. Code sec. 53165(b).
Further, the draft Housing Element self-contradictorily states “that neither the City's ordinance,
nor the training program nor the City or Sheriff’s Department encourages or discourages
property owners to conduct criminal background checks of tenants, although the potential
benefits of doing so are discussed in the training.” By admitting that the CFMH Program training
focuses on the benefits of criminal background checks, the draft Housing Element also admits
that the program effectively encourages such background checks. Our review of the CFMH
1 San Bernardino Municipal Code sec. 15.27.060(a)(1)(d).
2 See Draft Housing Element at p. 5-7 (noting that affordable apartment properties and rent-stabilized mobile home
parks are concentrated in an area of City with much higher prevalence of minorities than the rest of the County).
3 2 CCR § 12269(a)(1); 2 CCR § 12141.
4 San Bernardino Municipal Code sec. 15.27.060(b).
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program training has confirmed that it encourages use of criminal history information to deny or
encourage self-screening in housing applications, without providing adequate guidance on how
such practices may violate fair housing laws.5 Indeed, the sample rental application provided as
part of that training both describes its purpose as enabling the landlord to “accept potential
residents who . . . do not have a criminal background” and specifically states that information
about participation in a deferred entry of judgment program is considered as part of the rental
application process, in violation of state housing regulations.6
B. Continuing The CFMH Program Conflicts With City Council Intent And
Community Input
The draft Housing Element states that the CFMH Program is in effect per the current municipal
code. However, at the April 5, 2023 City Council meeting, the Council voted to agendize a
motion to repeal the Crime Free Multi Housing ordinance, at the urging of community members
giving public comment at that meeting, and in recognition of multiple lawsuits and federal
enforcement actions in the region challenging similar ordinances.7 No such motion has been
considered yet at any City Council meeting since. The CFMH Program should be removed from
the Housing Element given this pending repeal process.
C. The CFMH Program Conflicts With The Draft Housing Element’s Fair Housing
Assessment And With Fair Housing Laws
The draft Housing Element claims that the City complies with fair housing law and is committed
to affirmatively furthering fair housing. However, it is well-established that nuisance and crime-
free housing programs like the City’s CFMH Program conflict with state and federal fair housing
laws.8 Indeed, the City has already been sued for the CFMH Program’s violations of the Fair
Housing Act and the Violence Against Women Act. See Gracia v. City of San Bernardino, Case
No. CIV SB 2301828 (filed Feb. 10, 2023).9 And the draft Housing Element itself notes that the
California Department of Housing and Community and federal agencies have raised concern that
the CFMH Program’s crime free lease agreement may violate CCR § 12264 and have a disparate
impact on Latinos, African Americans, and other minorities.
5 See, e.g., 2 CCR § 12269(a)(3)-(5), (b); see also U.S. Dep’t of Housing & Urban Dev., Office of General Counsel
Guidance on Application of Fair Housing Act Standards to the Use of Criminal Records by Providers of Housing
and Real Estate-Related Transactions (Apr. 4, 2016),
https://www.hud.gov/sites/documents/HUD_OGCGUIDAPPFHASTANDCR.PDF.
6 2 CCR § 12269(a)(2).
7 See Regular Meeting of the Mayor and City Council 4-05-2023,
https://www.youtube.com/watch?v=N_XtKunQkXM&t=9566s, at 2:39:34.
8 See Letter for Attorney General Rob Bonta to All Cities & Counties, Re: Crime-Free Housing Policies (“AG
Letter”) (Apr. 21, 2023), https://oag.ca.gov/system/files/attachments/press-
docs/Crime%20Free%20Housing%20Guidance 4.21.23.pdf; Office of General Counsel Guidance on Application of
Fair Housing Act Standards to the Enforcement of Local Nuisance and Crime-Free Housing Ordinances Against
Victims of Domestic Violence, Other Crime Victims, and Others Who Require Police or Emergency Services (Sept.
13, 2016), https://www.hud.gov/sites/documents/FINALNUISANCEORDGDNCE.PDF.
9 The draft Housing Element omits any discussion of this litigation in its section on “Findings, Lawsuits,
Enforcement Actions, Settlements, or Judgments.”
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The draft Housing Element acknowledges that the lease addendum likely violates state and
federal fair housing law – yet it proposes continuing the current program even though the
proposed timeline for updating the lease addendum is not until the end of 2024.10 For this reason
alone – that it proposes continuation of an admittedly illegal program – the draft Housing
Element must be revised to provide for termination of the CFMH Program.
Further, the draft Housing Element incorrectly suggests that by revising the lease addendum
alone, the City can bring the CFMH Program into compliance with fair housing laws. But the
content of the lease addendum is, in part, specified in the municipal code.11 Accordingly, the
CFMH ordinance must also be substantially amended or repealed.
Further, the Attorney General’s guidance on Crime-Free Housing Policies and the corresponding
state fair housing regulations make clear that it is not merely lease addenda and eviction
requirements, but also Crime-Free Housing “ordinances, programs, and training materials” that
may raise conflict with fair housing law.12 The Attorney’s General guidance specifically
identifies several Crime-Free Housing practices as potentially running afoul of fair housing
laws.13 The City’s CFMH Program includes each of those identified problematic practices as set
forth below:
Practice Identified by AG Guidance San Bernardino CFMH Program Practice
“Using dehumanizing, derogatory, or racially
charged or coded language in . . . training
materials, manuals, and workbooks on Crime-
Free Housing Policies”
CFMH training refers to “criminals” as a
“two-legged urban breed of predator”
(emphasis added), compares “criminals” to
“weeds” and a dinosaur that must be killed in
the egg.
“Instructing or encouraging property owners
to adopt screening practices or rental policies
under which landlords broadly deny tenancy
to applicants with a criminal history or
encourage tenants to ‘screen themselves’”
Draft Housing Element states that CFMH
Program training highlights benefits of
conducting criminal background checks.
CFMH Program training states that it is not
illegal to deny housing on the basis of
criminal history. States that if an applicant is
made aware of screening criteria, especially a
thorough check of criminal history, they are
less likely to apply (“self refusal”). Example
of housing application provided in CFMH
training states: “RENTAL POLICIES ARE
GUIDELINES, WHICH ENABLE US TO
ACCEPT AS PROSPECTIVE RESIDENTS
THOSE INDIVIDUALS WHO . . . DO NOT
10 See City of San Bernardino draft 2021-2029 Housing Element (May 2023) (“Draft Housing Element”) at p. 7-31.
11 See San Bernardino Municipal Code sec. 15.27.050(C).
12 AG Letter at p. 4.
13 Id. at p. 7.
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AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF SOUTHERN CALIFORNIA
HAVE A CRIMINAL BACKGROUND.”
Example of housing application states that
information about participation in a deferred
entry of judgment program will be
considered.
“[I]nducing landlords to evict tenants based
solely on arrests or other interactions with law
enforcement”
“Taking adverse actions against tenants who
seek law enforcement assistance, or
discouraging tenants from seeking such
assistance”
Code Enforcement in cooperation with police
issues “Crime Free Housing
Referrals/Complaints” for law enforcement
interactions with tenants, including tenants
“not cooperati[ng] with law enforcement
efforts.”
CFMH Referral Card specifically documents
“arrest information.”
CFMH Ordinance threatens termination of
Crime-Free Property certification based solely
on calls for service, incentivizing landlords to
impose housing consequences on tenants
responsible for such calls.
Moreover, the CFMH Program is essentially discriminatory, because it ascribes criminality to
tenants of multi-unit housing that the City does not attribute to homeowners and residents of
single-family homes. This is blatant economic and racial discrimination.14 Data shows Black and
Latine residents of San Bernardino are more likely to be renters and are less likely to become
homeowners than White residents.15 The discriminatory stereotyping and disparate impact
inherent in this program are made further evident by the City’s suggestion that it may expand the
program to cover mobile homes – but no other types of homes.16 Because the CFMH Program is
an impediment to fair housing for all the reasons stated above, it should be removed from San
Bernardino’s draft Housing Element.
D. The Draft Housing Element Makes Unsupported And Inaccurate Claims About
The CFMH Program’s Deterrence Of Crime
The draft Housing Element states, without any evidentiary support, that the CFMH Program has
been an effective deterrent for crime. Studies show that Crime-Free Rental Housing programs do
14 See supra n. 2.
15 See Race Counts - San Bernardino, https://www.racecounts.org/county/san-bernardino/ (citing US
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT (HUD), COMPREHENSIVE HOUSING
AFFORDABILITY STRATEGY (CHAS) (2014-2018)); San Bernardino County, Housing Affordability,
https://indicators.sbcounty.gov/housing/housing-affordability (citing Ford, Carmen. Homeownership Rates by Race
and Ethnicity. NAHB Economics and Housing Policy Group. Special Studies March 1, 2018) (“In San Bernardino
County, the Black homeownership rate in 2018 was 37.5% compared to 68.1% for White households for a
homeownership gap of 30.6 between Black and White households. The Latino homeownership rate in 2018 was
53.7% for a homeownership gap of 14.4 between Latino and White households.”).
16 See supra n.10.
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not achieve the goals they purport to serve, but instead undermine public safety.17 As a matter of
common sense, there are at least three ways that the CFMH Program hurts public safety:
1. It deters people from reporting crime. The CFMH Program requires tenants to
sign a lease addendum that addresses consequences for criminal activity. The
lease addendum links the occurrence of any criminal activity on a multi-housing
property with housing consequences (i.e. the possibility of eviction). That lease
addendum creates the threat of eviction for a resident when “any member of the
resident’s household, a guest, or other person under the resident’s control” is
accused of illegal activity.18 Thus, the CFMH Program threatens the housing of
innocent residents, by indiscriminately targeting the housing of victims and
bystanders as well as perpetrators of alleged criminal activity. The program could
threaten a young child with the loss of her home if, for example, a lone member of
her household or even a one-time guest caused a disturbance on a single occasion.
This deters crime victims, family members, and concerned neighbors and
bystanders from coming forward to report crime or reaching out for help—
because doing so could lead to housing consequences for them. The program also
places a tenant in a terrible, dangerous dilemma when her safety is threatened by a
co-tenant. In order to call the police for help, she may trigger a "Crime-Free
Housing Referral” or call for service notice to her landlord, which could be
construed as a violation of the lease addendum. If victims or concerned family
members know that calling 911 can cause them and/or their children to lose their
homes, they may avoid seeking protection from the police and suffer the abuse in
silence or take matters into their own hands. In short, the CFMH Program gives
criminals greater leeway to harass, control, and torment their victims. Similarly,
as discussed, the CFMH Program imposes consequences on landlords for the
number of calls for service originating from their property. This deters landlords,
property managers, neighbors, and tenants from calling for help.
2. It forces people onto the street. The program encourages and provides a basis for
more evictions. Forcing someone onto the street does not ensure that the person
will leave town or refrain from engaging in harmful conduct. Rather, eviction
destabilizes people’s lives and undermines public health and safety, which is
detrimental for the community’s wellbeing.
3. It builds barriers to housing. By encouraging landlords to conduct criminal
background checks and to use the results of those background checks to
discriminate against or deter prospective tenants, the program encourages greater
discrimination against prospective tenants based on information about their pasts.
Permanently increasing the difficulty for people to obtain stable, independent
housing only serves to benefit no one. It stands in the way of people’s efforts to
17 See, e.g., Emily Werth, Sargent Shriver Nat. Ctr. On Poverty Law, The Cost of Being “Crime Free”: Legal and
Practical Consequences of Crime Free Rental Housing and Nuisance Property Ordinances 4 (2013),
http://povertylaw.org/files/docs/cost-of-being-crime-free.pdf.
18 Draft Housing Element at p. 3-32.
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AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF SOUTHERN CALIFORNIA
make positive change in their lives as it threatens to drive individuals and families
into homelessness.
By deterring people from reporting crimes, forcing people onto the street, and building barriers
to housing, the CFMH Program only serves to enable criminal activity and harm public safety.
At the same time, it diverts public resources that could be invested in real public safety supports
and affirmatively furthering fair housing. For all of these reasons, the draft Housing Element
should be revised to remove the CFMH Program.
II. THE DRAFT HOUSING ELEMENT SHOULD BE REVISED TO AMEND THE
SECTIONS ON ANTI-CAMPING ENFORCEMENT AND PROGRAM 5.5 –
HOMELESS SERVICES
A. The Homeless Services Program Is A Bad Faith Effort In Addressing The Needs
Of Unhoused Community Members
The City describes its approach to addressing houselessness as a commitment to the
implementation of a “housing first” strategy and “provision of a full continuum of housing and
services to address homelessness” as outlined in Program 5.5 of the draft Housing Element.19
While the City has done laudable work to secure some initial grant funding to address
houselessness, its plan to spend $20 million on “Housing Unsheltered Residents” is not fully
committed to a best practices “housing first” model, wherein safe, permanent, adequate and
affordable housing is provided to unhoused people as an immediate response to their needs.
Currently, the City’s plan includes some promising permanent supportive housing projects –
including the All Star Lodge and U.S. VETS Inland Empire projects.20 The draft Housing
Element describes other projects listed in the plan as providing emergency and transitional
“shelter beds,” however, and it is unclear whether those will be congregate shelter beds.
Studies have shown that congregate shelters are not an effective solution to houselessness and
often do not provide pathways to permanent housing. Congregate shelters subject individuals to
higher rates of communicable diseases like COVID-19, due to their tight quarters and
requirements that many people share facilities.21 Further, crowding large numbers of people
together can lead to social withdrawal, psychological distress, and other mental and physical
health conditions, and often do not put residents on a path to obtaining permanent housing.22
Importantly, people do not want to live in congregate settings: in a recent research study of
individuals experiencing houselessness in Los Angeles, 70% of individuals surveyed stated they
19 See Housing Element, p. 7-25.
20 Id.
21 National Low Income Housing Coalition, Moving Away from Congregate Shelter,
https://nlihc.org/resource/moving-away-congregate-shelter (Jun. 9, 2020). 22 Id. at 8, citing Gove, W., Hughes, M., & Galle, O. (1979). Overcrowding in the home: An empirical investigation
of possible pathological consequences. American Sociological Review 44(1), 59-80. See also Ann Oliva, Ending
Homelessness: Addressing Local Challenges in Housing the Most Vulnerable, CENTER ON BUDGET AND
POLICY PRIORITIES, https://www.cbpp.org/research/housing/ending-homelessness-addressing-local-challenges-
in-housing-the-most-vulnerable (Feb. 2, 2022).
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AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF SOUTHERN CALIFORNIA
would not accept offers to stay in group shelters, citing lack of privacy as a concern, suggesting a
limited role for congregate shelters in effectively moving people off the streets.23
We note that “Housing First” is the national best practice for solving houselessness, and that the
buildup of temporary or interim placements would create a bottleneck of unhoused community
members waiting for permanent and affordable housing. Under the state’s official Housing First
policy, placements for unhoused residents should be low-barrier and allow for people to stay
with their loved ones, pets, and personal property.24 We ask the City to ensure that all the funds
for “Housing Unsheltered Residents” go toward low-barrier, non-congregate, permanent housing
solutions based on Housing First principles.
Additionally, the City demonstrates its continued dedication to the criminalization of
houselessness through the proposed enforcement of its anti-camping ordinance. As outlined in
the draft Housing Element, “City has adopted plans that will result in the development of
additional beds that will address 60 percent of the unmet need” (i.e. Program 5.5).25 Based on a
flawed interpretation of the settlement agreement for Orange County Catholic Worker v. County
of Orange, 2019 U.S. Dist. LEXIS 247189 (2019), the City has determined that by achieving the
60 percent need threshold as identified in the settlement agreement, the City will then be given
free rein to enforce its anti-camping ordinance.26
We note that the Orange County Catholic Worker v. County of Orange settlement is a private
agreement that is binding only on the parties involved and does not establish a legal precedent
for San Bernardino County or any other jurisdiction to follow. Further, the City misrepresents the
nature of this settlement agreement in its Housing Element draft. The Catholic Worker case did
not permit Orange County to enforce its anti-camping ordinances upon 60 percent of its
unhoused population becoming housed. Rather, the reference to 60 percent in the settlement was
a requirement that a county planning area create enough placements for at least 60 percent of its
unsheltered population. This requirement was unrelated to the anti-camping code, and there has
not been any anti-camping enforcement in the jurisdictions subject to the settlement, despite the
opening of shelters.
Importantly, this settlement agreement does nothing to change the binding Ninth Circuit
precedent in Martin v. City of Boise, which struck down an anti-camping ordinance and held that
that cities may not criminalize people for their unhoused status. 920 F.3d 584 (9th Cir. 2019). As
long as there are more unhoused individuals in the City than housing options available to them, it
remains unconstitutional to criminalize individuals for engaging in life-sustaining activities like
camping in public. Further, building shelters to enable the City to enforce its anti-camping
ordinance is an adversarial policy that does nothing to end houselessness. This strategy also
implies that the City can effectively force unhoused community members into shelters,
segregating them in what are often unsafe and highly inappropriate places to live long term. The
23 Jason M. Ward, et al. Recent Trends Among the Unsheltered in Three Los Angeles Neighborhoods: An Interim
Report on the Los Angeles Longitudinal Enumeration and Demographic Survey (LA LEADS) Project, RAND
Corporation, https://www rand.org/pubs/research reports/RRA1890-1.html (last visited Oct. 15, 2022).
24 See SB 1380, Homeless Coordinating and Financing Council (Sept. 29, 2016).
25 See Housing Element, p. 3-48.
26 Id.
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City’s goal of enforcing its anti-camping code is misplaced. The goal should not be to
criminalize people, but rather to find ways to solve the underlying problem of lack of affordable
housing that forces people to live on the street in the first place.
We urge the City to pivot away from carceral and coercive approaches to what is, in essence, a
housing affordability crisis. The City should focus instead on meeting the immediate affordable
housing and service needs of its unhoused population. Any interim accommodations the City
provides while it develops sufficient permanent affordable housing should be non-congregate
(e.g., motel vouchers), voluntary, and free from restrictive rules and protocols. The City’s top
priority should be to meet the expressed needs and preferences of its unhoused residents while
committing maximum resources toward permanent and dignified housing solutions.
B. The Draft Housing Element Fails To Identify With Specificity The Services That
The City Intends to Provide As Part Of Its Homeless Services Program
Program 5.5 fails to identify with specificity the exact “health, social, and employment” services
that the City is providing.27 Given the City’s intentions in its Homeless Services proposal and its
dedication towards the enforcement of its anti-camping ordinance, the ambiguity in what these
services entail is concerning.
As such, while the provision of services for unhoused residents is potentially laudable, further
clarification of the exact services to be provided is required.
***
The monetary and societal costs of Program 3.2 far outweigh any benefits. In addition, Program
5.5 fails to genuinely address houselessness as it serves to enable the City’s subsequent
enforcement of the anti-camping ordinance. Consequently, we urge you to take this opportunity
to eliminate the Crime Free Multi-Housing Program and to amend its Homeless Services and
anti-camping enforcement plans outlined in the draft Housing Element.
Sincerely,
Adrienna Wong, Senior Staff Attorney Kath Attorney, Staff Attorney
CC: Melinda Coy, Melinda.Coy@hcd.ca.gov
David Zisser, David.Zisser@hcd.ca.gov
Cassandra Searcy, searcy ca@sbcity.org
27 See Housing Element, p. 7-25.
ATTACHMENT A
ATTACHMENT B