Summary
May 13, 2024
Matt Maloney, Director of Regional Planning Program
Metropolitan Transportation Commission (MTC)
375 Beale St, Suite 800
San Francisco, CA 94105
Dear Mr. Maloney,
The Marin County Board of Supervisors is appreciative of the opportunity to provide feedback on MTC’s Draft 2024 Equity Priority Communities Update. We commend MTC’s equity-centered approach to long-range planning, and we appreciate the meaningful work the agency does in improving regional transportation and our local communities. However, we are writing to express our deep concern that the 2024 EPC Draft Update proposes to eliminate Marin City as an EPC – which has been designated an EPC since MTC adopted the designations for the Bay Area in 2001. We urge MTC to reconsider the findings in the Draft EPC Update and maintain Marin City’s EPC designation in Plan Bay Area 2050+.
The EPC designation under MTC is a critical tool to direct regional, state and federal resources to underserved communities, and ensure these dollars are used to improve transportation for Bay Area residents most in need, who also disproportionately rely on public transit. Additionally, the designation is an essential part of long-range, regional transportation planning: as planning efforts and eventual project implementation are long processes that can take years and even decades.
Therefore, the abrupt elimination of the EPC designation for a community with a long history of needs for enhanced transportation resources, based on slight shifts in census data known to have high margins of error, is very concerning to us. It would also have negative implications on long-range planning efforts that are intended to support Marin City’s needs and protect current residents from displacement. We feel strongly that eliminating Marin City in the 2024 EPC Update would be poor public policy, and would contribute to inequitable outcomes and racialized disparities for a historically marginalized, underrepresented and underserved community in Marin.
In conversations with MTC staff, we understand that the change in Marin City’s designation was due to utilizing updated Census data from the 2022 American Community Survey. In the updated data, Marin City remained within the low-income threshold to qualify as an EPC (exceeding the 24% regional threshold by 10.6%), but saw a decline in the share of people of color. Specifically, MTC’s people of color threshold increased from 70% to 72%, and Marin City’s concentration of people of color decreased from 76% to 65%.
We appreciate the critical role of data, both qualitative and quantitative, in understanding our geographic inequities – and how important it is to understand our communities. Quantitative data is a tool that must be accompanied by meaningful, qualitative feedback to make holistic determinations of a region’s needs. MTC recognizes some of this nuance in utilizing data for designations; and allows a community to be defined as an EPC if it meets either of the following:
- Meeting concentration thresholds for Low-Income and People of Color; OR
- Meeting thresholds for Low-Income AND 3 or more of the following:
- Limited English Proficiency
- Zero-Vehicle Households
- Seniors 75 Years and Over
- People with a Disability
- Single-Parent Families
- Rent-Burdened Households
As noted, Marin City well exceeds the 2024 EPC criteria for low-income concentration. Additionally, Marin City exceeds the established EPC criteria for 2 additional criteria: Single-Parent Families and Rent Burdened Households. Factoring in the wide margins of error from the 2022 American Community Survey, Marin City would also meet additional criteria under #2 above – meaning that it could still meet MTC’s established criteria for an EPC in Plan Bay Area 2050+. The issue of atypically wide margin of errors from this data is acknowledged by MTC in their EPC Update Memo: “ACS 2018-2022 estimates which are used for Plan Bay Area 2050+ EPC mapping were also affected” by “a notable increase in margins of Error.”
Speaking beyond the data, we want to recognize what a regional government’s removal of an “Equity Priority Community” designation would mean to Marin City, given its explicit history as the only community in Marin County where Black residents could live. In the 1940s, Marin City was created by the federal government for the Sausalito Marinship Shipyard workers and their families to support World War II. This included thousands of Black Americans who moved from the Midwest and the South to Marin for employment.
When World War II ended, many Marinship workers lost their jobs. While Marin City’s White residents were able to relocate elsewhere in the County, racially discriminatory laws and policies severely limited housing and employment opportunities for Black residents. Many remained in underfunded federal housing in Marin City. While Marin City’s Black community is proud of its rich cultural history and heritage of resilience and self-reliance – it is undoubtful that this was achieved by the community despite decades of underinvestment by regional, local, state and federal governments.
The designation of Marin City as an EPC by MTC in 2001 was an important step in a long, multifaceted approach to right the many decades of wrong to this community. However, it is just as critical that Bay Area governments demonstrate strong commitment to investments in these communities which have long mistrusted government agencies for justified reasons. The abrupt reversal of the EPC’s acknowledgment of the additional transportation and resource support that Marin City deserves – that the current 2024 Draft EPC Update proposes – would cause tremendous harm to the trust-building local leaders have achieved in this community.
We thank you for taking these comments into consideration, and urge you to maintain the EPC designation for the Marin City census tract in the Final 2024 Equity Priority Communities Update and Plan Bay Area 2050+. We would welcome the opportunity to discuss this issue further and share our local perspective, and we invite MTC to seek feedback from Marin City residents directly as well.
Respectfully,
Dennis Rodoni, President
Marin County Board of Supervisors
Cc: Marin County Board of Supervisors
Senator Mike McGuire
Assemblymember Damon Connolly
Transportation Authority of Marin Board of Commissioners
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