MEJAC’s UDC Version 5 Public Comment

MEJAC provided the following verbal and written Public Comments to the Mobile City Council during its Unified Development Code version 5 (UDCv5) Public Hearing on October 19, 2021.

“Good morning.

My name is Ramsey Sprague. I reside at [. . .].

I am President of the Mobile Environmental Justice Action Coalition, or MEJAC, as it’s been called since its founding by Africatown residents over eight years ago in partnership with regional advocates to address environmental justice concerns in and around Mobile.

I am also the Mobile NAACP Environmental and Climate Justice Committee Chair.

Environmental racism is an everyday occurrence in Mobile, and the UDC represents an opportunity to address the zoning sins of the past that must not be repeated in the future.

While we’ve seen valuable progress on many of our concerns, we still have some fundamental differences with both the public participation process and the text itself.

Now, the UDC’s Neighborhood Meeting standards are thoroughly reasonable. We feel encouraged by the creation of the UDC’s Low-Impact Development and Riparian Buffer standards, as well as the fact of the creation of the Africatown Overlay itself.

Unfortunately, the Africatown Overlay and other elements fall short of our expectations and in some cases offend the sensibilities of our organizations and partners. For instance, the Administration declined to respond in writing about any concerns raised about the Africatown Overlay at all, but not so with other Overlay districts, which gives a cursory impression that no concerns were raised about the Africatown Overlay at all.

But Africatown residents have been engaged over the last 3 years at every public participation opportunity regarding Industrial zoning standards, the Africatown Overlay, Protection Buffer standards, and landscaping requirements, the latter two of which have improved significantly in our estimation, but the following items represent areas yet to be appropriately addressed:

1) The Africatown Overlay district, which is surrounded by water on three sides, doesn’t include any provision for waterfront conservation despite the City ostensibly supporting two water-based heritage tourism efforts in Africatown. The proposed “water dependent maritime use” exemption to all Riparian Buffer standards is too broad, and if unchanged, effectively all of Africatown’s waterfront will be exempt from potential waterfront conservation standards in future development along Three Mile Creek, the Mobile River, Chickasaw Creek, and Hog Bayou. And that would be a crime against Africatown’s future.

2) The Africatown Overlay must prohibit new, non-replacement Above Ground Oil and Hazardous Substance Storage Tank creation in Africatown. If we all agree that we should be past the petrochemical tank farm expansion episode, then, please, let’s be completely past it.

And finally 3) In 2017, in its current Assessment of Fair Housing report to HUD, the City declared its intent to “accommodate and encourage access to innovative affordable housing” via then-anticipated zoning code revisions, but today’s proposed UDC standards are very often divergent from too many of the AFH report’s Metrics. Assertions to HUD about federal dollars designated for affordable housing efforts in such reports are generally considered binding, and transparency around the lack of alignment between the UDC and AFH is warranted.

In conclusion, the pandemic may have complicated every aspect of life, but the urgency of Environmental Justice in Mobile has not diminished. Thank you for your time and careful consideration of our agencies’ concerns.

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