The SHIP and the Failure to Follow Public Participation Principles

This letter was sent by the T1NC Steering Committee/ Public Participation Committee/ Affordable Housing & Displacement Committee to each council member on November 1, 2021

Update: Strategic Housing Implementation Plan (SHIP) was posted on SHIP website on November 1st.

Dear Council Member, 

On November 3rd at the City Council B Session, you will receive a presentation on the draft version of the SHIP (Strategic Housing Implementation Plan). We’re writing ahead to let you know that we have some serious concerns and think that you will find that you have the same concerns out of consideration for your constituents. We are concerned that the Public Participation Principles, which play such an important part of the SHIP, are not being followed in this public input stage: There is not enough time for meaningful input on a 68-page document has yet to be released on the website at the time of this writing (days before input begins.)  

We feel the Public Participation Principles are not being taken seriously as necessary metrics that ensure the inclusivity of the public in decisions that will have decades worth of impacts. Those impacts will either decrease or increase the housing crisis. The language throughout the presentations and documents regarding the SHIP, the Housing Bond Evaluation Framework, and the Housing Bond, etc. all talk about connecting to the most vulnerable populations.

As one Westside resident put it, “We’re suppose to go to bond meetings, ARPA meetings, be concerned about UDC amendments, and keep up with other issues like zoning cases, and read 68 pages and give input within a couple of weeks along with our jobs and our families? We feel like we are always left out in the cold because we can’t keep up, and here we are again. This feels like it is on purpose.”    

The draft SHIP was not available until two months after the intended August deadline. It was decided at the Housing Commission that the timeline would not be adjusted to the right so as to keep the adoption of the SHIP on schedule for December. Because of this delay, and the decision not to shift the timeline, there is now the negative consequence that our communities are facing.  

The first public input session is scheduled for November 1st on the Westside, one of our most vulnerable populations, without the adequate time to receive the information or the proper accessibility to ensure that they are able to give input. The flyer information in English and Spanish were not made available until Friday, October 29th. The Neighborhood Housing Services Department (NHSD) site is not updated with the draft SHIP nor the intended Summary needed to make the information accessible prior to the input session. 

What exacerbates this issue is the lack of accessibility to information has been a primary topic in all of the meetings, as a part of insuring the Public Participation Principles.  NHSD, which facilitated the SHIP task force meetings and the production of the document, is responsible for the task of meaningful public input in a short window before adoption by City Council. 

At a Housing Commission Public Engagement and Outreach Committee, NHSD have recognized the challenges and have admitted to not being able to meet certain accessibility criteria.

Is this not serious enough that the Housing Commission could anticipate the problems for public participation when they decided not to shift their timeline?

The Administrative Directive AD 10.1 Public Participation and Engagement has guiding principles such as “inclusive”, “accessible”, “informative”, “timely” and “convenient”, that are the minimum criteria to be met when engaging the public. Determined milestones that keep everything (ethically) in check. It is the people that body our governance structure and, the people that are the majority, are left out of critical policy making processes. Public input is scheduled for three input sessions, by person and by webex and phone, as well as a survey that will close on November 15th.

Again, the draft and the summary have not been made available to the public on the NHSD site (as of Sunday October 31st; the first input session is Monday November 1st). And it should be reiterated that the most vulnerable populations who need to know whether or not they are included in the Strategic Housing Implementation Plan and who deserve a voice in this policy, need accessible engagement and outreach. 

 If it is not corrected now, in this first step, there will be consequences in the near future that include the growing mistrust of CoSA to remove the barriers to affordable housing and to solve the housing crisis.  There is a lot of language that protects neighborhoods but there are concerns about certain portions regarding removing barriers to housing production which opens a door that could compromise everything we have worked towards if housing production includes market rate housing and those barriers are the protections we have fought for to prevent displacement.

This is a discussion that needs to be had in full length. In order to build trust in the process, a process that residents feel is skewed towards the benefit of the development community, we are asking that more time be given for public input and more is done to ensure accessibility.

Attachment:

SHIP Recommendation for Public Participation  EAP 5 (pg 56) of the SHIP states the goal of meaningful public input as recommended in the Public Participation Principles. If the Public Participation Principles are not used to adopt the SHIP, how can residents trust they will be implemented as part of the plan? 

EAP 5: APPLY PUBLIC ENGAGEMENT PRINCIPLES WHEN CREATING & IMPLEMENTING NEW POLICY (pg 56)Goal: Create a truly participatory and inclusive process that is focused on marginalized and overlooked communities.This strategy is to create public engagement process that focuses on active community input and participation in policy development. It would focus on equity related to specificvulnerable populations and creating stable housing for these community members. The strategy would need to build trust and support participation in substantive issues. The focus will be on the processes that are impactful. Intentional paths will be created that make it easy for people to engage so that partners can come together in the city. This is needed to counteract how information has not been as well received. There needs to be dialogue atthe table of participants. Community concerns sometimes do not make it to the agenda, and this can place a checkpoint on that. The data gathered can be reported back to ensure thatpeople are engaging, and decisions are made together. This will need to occur in multiple settings to include the digital space. This will help to ensure that the community feedback isincorporated, transparent, and that members feel empowered.This will require cross-department collaboration and engagement from people with lived experience and various community partners including the department of Human Services,LISC, CHDOs, Housing Commission, and NHSD.  The adopted Public Participation Principlesare found in Appendix A. Performance Indicators/Measures:• Increase in public participation rate• Continuously engaged participants• Number of people that participate from vulnerable populations• Funding invested in community driven engagement