February 14, 2013 Wendy Greuel PO Box 492001

The City Project * Asian Pacific Policy & Planning Council, EJTF
Asian and Pacific Islander Obesity Prevention Alliance * California League of United Latin American Citizens
Concerned Citizens of South Central Los Angeles * Latino Coalition for a Healthy California * PolicyLink
Search To Involve Pilipino Americans * Marc Brenman, Social Justice Consultancy
February 14, 2013
Wendy Greuel
P.O. Box 492001
Los Angeles, CA 90049
Fax: (310) 861-0642
Via First Class Mail and Fax
Dear Ms. Greuel:
As part of a diverse and growing alliance of committed advocates for equal justice, public health, and
green space, we work to create healthy, livable communities for all Los Angeles residents. Currently,
people of color and low-income communities are significantly disadvantaged in access to parks,
recreation, and places for physical activity. It is no coincidence that children in these communities are
at increased risk for obesity and diabetes.
As a candidate for Mayor, we ask that you support a healthy, livable community for all by:
(1) Funding projects that create green jobs for local workers, small and disadvantaged
enterprises, and youth.
(2) Ensuring compliance with physical education and healthy food laws in public schools.
(3) Ensuring the implementation of an equity plan for City parks.
(4) Reforming the way Quimby park development fees are invested.
(5) Ensuring the equitable revitalization of the Los Angeles River.
(6) Supporting the proposed San Gabriel National Recreation Area and the proposed
expansion of the Santa Monica Mountains National Recreation Area.
(7) Ensuring all city agencies comply with equal protection laws and principles including
Title VI of the Civil Rights Act of 1964, California Government Code Section 11135, and
their implementing regulations, which guarantee equal access to public resources.
(8) Promoting transportation justice by improving bus service, bike routes, safe routes to
schools, and complete green streets.
(9) Supporting joint use of parks, schools, and pools.
(10) Supporting immigration reform to ensure that undocumented immigrants already in the
country have a path to citizenship.
(11) Committing to transparency in government by making public records available and
searchable online.
Wendy Gruel
February 14, 2013
Page 2 of 6
A. The City Should Fund Projects that Create Green Jobs for Local Workers, Small and
Disadvantaged Enterprises, and Youth
The Civilian Conservation Corps is a best practice example to get the people of Los Angeles back to
work in the worst economic crisis since the Great Depression. A similar program for the City can
dramatically increase green space and improve the health of its workers. Such programs can keep
young people in school, physically active and health, and provide a positive alternative to gangs.
Youth programs lead to permanent jobs and careers as stewards of the environment.
B. The City Should Prioritize Compliance with Physical Education and Nutrition Laws in
Public Schools
State law requires 200 and 400 minutes of physical education every ten school days in elementary and
secondary schools, respectively. Half the school districts audited by the California Department of
Education between 2005 and 2009 did not comply. The City Project, Healthy Parks, Schools and
Communities: Mapping Green Access and Equity for Southern California 28-29 (2011). Elementary
schools in districts that did not comply with physical education requirements had a higher percentage
of Hispanic and black students than in school districts that did comply. Emma V. Sanchez-Vaznaugh
et al., Physical Education Policy Compliance and Children’s Physical Fitness, Am. J. Perve. Med.
452, 456 (2012). These disparities in compliance mirror health disparities in child obesity. In Los
Angeles, children of color disproportionately live in the areas with the highest levels of child obesity
and the worst access to parks and schools fields. The City Project, Healthy Parks, Schools and
Communities: Mapping Green Access and Equity for Southern California 28-29. On the state level,
Latino and black children are disproportionately overweight compared to non-Hispanic white and
Asian children. Id.
A study by the California Senate in February 2012 found that school districts, including the Los
Angeles Unified School District, are impermissibly redirecting federal food funds from children who
qualify for free and reduced meals to other purposes.
Enforcing physical education requirements and healthy food requirements will help reduce child
obesity. The physical education policy set forth by the Los Angeles Unified School District (LAUSD)
is a “best practice example for districts across the state to provide a quality education for the children
of California,” according to Dr. Robert Ross, President of the California Endowment. The resources
and professional development necessary to maintain a quality physical education should be provided
and compliance with minutes requirements monitored. Public officials must send the message that
physical education is required by law and paramount to children’s health.
C. The City Must Implement an Equity Plan for Parks
The City of Los Angeles has inequitably distributed its park resources. In 2006, City Controller Laura
Chick found that “not all areas of the City have the same level of service in programs and activities.
Lower income neighborhoods, including those predominately populated by Latinos, AfricanAmericans and Asian-Pacific Islander communities, have dramatically less access to park resources
than more affluent areas.” Letter from Laura Chick, City Controller, to Antonio Villaraigosa, Mayor,
Rockard J. Delgadillo, City Attorney, Members of City Council (Jan. 5, 2006) at 2 (on file with the
City Project). In City audits, City Controller Laura Chick has emphasized the need for (1) a strategic
plan to improve parks and recreation programs; (2) a fair system of park financing and fees, including
Wendy Gruel
February 14, 2013
Page 3 of 6
Quimby reform; (3) standards to measure equity and progress in achieving reform; (4) shared use of
parks and schools; and (5) improved park safety. Laura N. Chick, Performance Audit of Recreation
and Community Services in the Department of Recreation and Parks (Jan. 6, 2006); Laura N. Chick,
Audit of Quimby Fee Collections and Uses (Feb. 21, 2008). The city has not implemented those
recommendations. A city council district located in the inner city has .43 acres of parkland per 1,000
residents, whereas a district on the Westside has 57.68 acres of parkland per 1,000 residents based on
2000 Census data using 2000 council districts.
We ask you to ensure an equity plan that includes the following elements under equal protection laws
and principles:
(1) A clear description of what the Department of Parks and Recreation plans to do to serve all the
people of the City.
(2) An analysis of the burdens (taxes and costs) and benefits of parks and programs for all people.
(3) An analysis of alternatives.
(4) The full and fair inclusion of minority and low-income populations in the decision-making
process.
(5) An implementation plan to address any equity concerns identified in the analysis.
D. The City Should Reform the Way Quimby Park Development Fees Are Invested
Los Angeles is park poor, and there are unfair park, school, and health disparities throughout the City.
The distribution of Quimby funds has long exacerbated park inequities. The City Controller’s audits
have noted that park and recreation funding, whether through registration fees, Quimby fees, or any
other source, often exacerbate inequities unless they are strategically allocated to decrease such
inequities. Chick, Performance Audit of Recreation and Community Services in the Department of
Recreation and Parks 11 (Jan. 5, 2006).
In City audits, City Controller Laura Chick recommended a fair system of park financing and fees,
including Quimby reform. Chick, Performance Audit of Recreation and Community Services in the
Department of Recreation and Parks (Jan. 6, 2006); Chick, Audit of Quimby Fee Collections and Uses
(Feb. 21, 2008). She also found that as of January 31, 2008, the City had an unspent balance of more
than $112 million in Quimby and zone change fees. Chick, Audit of Quimby Fee Collections and Uses
17 (Feb. 21, 2008).
The City has not reformed the distribution of Quimby fees. The Department of Recreation and Parks
should develop a comprehensive plan to provide guidance on how funds collected would be used, in
conjunction with other available funding based on need. The City must reform the Quimby formula so
that park development fees are distributed equitably and the most underserved communities receive
their fair share.
E. The City Should Promote Environmental Justice Along the Los Angeles River
The Los Angeles River passes through some of the City’s most underserved communities. It is crucial
to ensure that low income communities and communities of color receive their fair share of river
revitalization especially as part of the America’s Great Outdoors and urban waters initiatives by the
Wendy Gruel
February 14, 2013
Page 4 of 6
federal government. Revitalization should maximize the opportunity to provide more parks,
multibenefit water and park projects, and jobs in these park poor and income poor communities.
F. The City Should Support the proposed San Gabriel National Recreation Area and the
proposed expansion of the Santa Monica Mountains National Recreation Area.
The City should support the proposed San Gabriel National Recreation Area, and the proposed
expansion of the Santa Monica Mountains National Recreation Area. State, regional, and local park
agencies—including the Department of Recreation and Parks—have the opportunity to work with the
National Park Service, the United States Forest Service, and community stakeholders to improve and
diversify access to parks.
G. The City Must Abide by Equal Protection Laws
The City and the Department of Recreation and Parks must comply with federal and state civil rights
laws that prohibit both intentional discrimination, and discriminatory impacts regardless of intent,
based on race, color or national origin.
The City signs agreements to comply with Title VI and its regulations as a condition of receiving
federal financial assistance. See, e.g., FY09 Grant Assurances to California Emergency Management
Agency, Laura Shin, Grants Director, City of Los Angeles (Sept. 21, 2009) (the City “[w]ill comply
with all federal statues [sic] relating to Civil Rights and Nondiscrimination. These include but are not
limited to: a. Title VI of the Civil Rights Act of 1964 (P.L. 88-352), as amended, which prohibits
discrimination on the basis of race, color or national origin. . . . [and] i. Title 28, Code of Federal
Regulations, Part 42, Subparts C [implementation of Title VI]”). Such compliance agreements cover
all of the city’s programs including the Recreation and Parks Department. See Civil Rights Restoration
Act of 1987, 20 U.S.C. 1681 et seq.; 68 Fed. Reg. 51334 (2003) (definition of “program or activity” or
“program” subject to Title VI).
We ask that you ensure that the City abides by these equal protection laws.
H. The City Should Promote Transportation Justice By Improving Bus Service, Bike Routes,
Safe Routes to Schools and Complete Green Streets
The City must ensure that transportation measures and projects serve all people. Allocating taxpayer
funds to ensure bus service is properly funded is necessary to ensure transportation justice for the
working poor. Furthermore, the implementation of effective transit routes should improve access to
parks and recreation. Transit to Trails should be implemented to improve access to green space and
physical activity by communities of color and low income communities. The City should also improve
bike routes, and create safe routes to schools and complete green streets. Proposed transportation
projects and tax measures such as Measure J (which would have raised $90 billion per year through a
half cent sales tax but failed at the ballot) require broad-based support to be successful. Such measures
should ensure everyone receives their fair share in order to broaden support from diverse voters.
Metropolitan Transportation Authority (MTA) can invest more money in the bus system to move more
people at a fraction of the cost. MTA spends more than eight times as much taxpayer money to move
people on rail than on bus. You couldn’t spend on bus the amount MTA spends on rail. MTA spends
Wendy Gruel
February 14, 2013
Page 5 of 6
almost twice as much on rail to carry about one fourth as many passengers, according to transportation
expert Tom Rubin based on an analysis of MTA’s own budget. MTA rail riders are twice as likely to
be non-Hispanic compared to MTA bus riders, and have a median household income that is 83%
higher, according to MTA’s FY2010 adopted budget.
I. The City Should Support Joint Use of Schools, Parks, and Pools As a Cost-Effective Measure
to Increase Physical Activity
The Centers for Disease Control and Prevention, the U.S. Department of Health and Human Services,
and the American Academy of Pediatrics recommend sharing school and community recreational
facilities to promote opportunities for physical activity. A Robert Wood Johnson Foundation survey
reports that lack of staffing, liability concerns, safety concerns, insufficient funding, and risk of
vandalism were cited by administrators from low-income school districts in California as the reasons
for restricting joint use. These perceived barriers can be addressed through joint use agreements.
Funding joint use agreements is a cost-effective means of increasing access to spaces for physical
activity. The City should promote joint use and instill a sense of ownership of public spaces among
Los Angeles residents.
J. The City Should Support Immigration Reform to Ensure a Path To Citizenship
The City should support immigration reform that ensures a path to citizenship. Undocumented workers
represent a large share of workers in the farming, cleaning, construction, and food preparation
industries. Persons who work hard and contribute to American society should be able to progress to
citizenship.
K. The City Should Commit to Transparency in Government Can By Making Public records
Available and Searchable Online
City agency data sets should be easily accessible to the public and frequently updated. “An open and
transparent administration makes it easier for residents to hold their government accountable, but it
also serves as a platform for innovative tools that improve the lives of all residents,” said Mayor Rahm
Emanuel of Chicago. The City of Chicago provides an online data portal
(https://data.cityofchicago.org/) that allows residents to access much of the City’s information. If
Chicago can do it, we can do it!
The City of Chicago also offers a service tracker that allows residents to submit photos with service
requests. See http://www.cityofchicago.org/city/en/depts/311.html. Los Angeles should too.
The use of a data portal and a service tracker, as in Chicago, would increase communication between
Los Angeles residents and government and allow for more accurate and detailed reporting of issues to
City Departments.
L. Conclusion
Please state whether you are committed to these goals by returning a copy of the enclosure to The City
Project at 1055 Wilshire Blvd., Suite 1660, Los Angeles, CA 90017, or via facsimile at 213-977-5457.
Wendy Gruel
February 14, 2013
Page 6 of 6
Sincerely,
/s/
Robert García, Founding Director and Counsel
Ramya Sivasubramanian, Assistant Director and Counsel
Daphne Hsu, Staff Attorney
Lynnete Guzman, Program Manager
The City Project
/s/
Mark Masaoka, Policy Coordinator
Asian Pacific Policy & Planning Council, EJTF
/s/
Scott Chan, Project Coordinator
Asian and Pacific Islander Obesity Prevention Alliance
/s/
Benny Diaz, State Director
California League of United Latin American Citizens (LULAC)
/s/
Mark Williams, Youth Director
Concerned Citizens of South Central Los Angeles
/s/
Monica Blanco-Etheridge, Executive Director
Latino Coalition for a Healthy California
/s/
Mary M. Lee, Deputy Director
PolicyLink
/s/
Dennis G. Arguelles, Director of Programs
Search To Involve Pilipino Americans
/s/
Marc Brenman
Social Justice Consultancy, Principal
Enclosure
The City Project * Asian Pacific Policy & Planning Council, EJTF
Asian and Pacific Islander Obesity Prevention Alliance * California League of United Latin American Citizens
Concerned Citizens of South Central Los Angeles * Latino Coalition for a Healthy California * PolicyLink
Search To Involve Pilipino Americans * Marc Brenman, Social Justice Consultancy
Please state whether you are committed to the following objectives and goals and return a copy to The City
Project at 1055 Wilshire Blvd., Suite 1660, Los Angeles, CA 90017, or via fax at 213-977-5457.
(1) Fund projects that create green jobs for local workers, small and disadvantaged enterprises, and youth.
Yes _______________ No ______________
(2) Require compliance with physical education and healthy food laws in public schools.
Yes _______________ No ______________
(3) Implement an equity plan for City parks.
Yes _______________ No ______________
(4) Reform distribution of Quimby park development fees to improve access to parks for all.
Yes _______________ No ______________
(5) Ensure environmental justice along the Los Angeles River so that river revitalization benefits everyone
including low-income communities and communities of color.
Yes _______________ No ______________
(6) Support the proposed San Gabriel National Recreation Area to improve and diversify access to parks.
Yes _______________ No ______________
(7) Support the proposed Santa Monica Mountains National Recreation Area to improve and diversify
access to parks.
Yes _______________ No ______________
(8) Ensure compliance with equal justice laws and principles, including Title VI of the Civil Rights Act of
1964 and its regulations, and California Government Code Section 11135, which guarantee equal access
to public resources.
Yes _______________ No ______________
(9) Promote transportation justice by improving bus service, bike routes, safe routes to schools, and
complete green streets.
Yes _______________ No ______________
(10) Support joint use of parks, schools, and pools.
Yes _______________ No ______________
(11) Support immigration reform to ensure that undocumented immigrants already in the country have a path
to citizenship.
Yes _______________ No ______________
(12) Commit to transparency in government by making public records available and searchable online.
Yes _______________ No ______________
_____________________
Printed Name
_____________________
Signature and Date