Subject: Resources for Council’s Consideration of Zoning Equity

Dear Members of City Council,

Several Council Members have raised questions about equity in Rochester, including what data, maps, studies, and policy directives informed the drafting of the Zoning Alignment Project.

The following report outlines types of analysis used in equitable zoning reform, organized around three key areas:

The Process (Procedural Equity): Who has historically held, and currently holds, the authority to draft, amend, interpret, and enforce zoning regulations, and whether affected communities are represented in those decisions.
The Map (Corrective & Distributional Equity): How past zoning decisions and public investments have contributed to segregation, unequal access to opportunity, and environmental burdens.
The Future (Operational Equity): How proposed zoning changes are evaluated and monitored to reduce segregation, prevent displacement, and ensure equitable outcomes.

These approaches reflect established planning principles, including those promoted by the American Planning Association. They help cities identify and address past harms, remove discriminatory barriers, protect vulnerable residents, and ensure meaningful participation in land-use decisions.

I hope this report helps Council understand the types of evidence and analysis that can inform zoning legislation intended to advance equity throughout Rochester.

Sincerely,

Ames J. Grigg

Northeast Quadrant

Equity Analysis Baseline Report

Zoning Alignment Project

This report was drafted to help community members and lawmakers understand the types of data city planners and administrators use to identify discrimination, measure inequities, and reform zoning laws with a well-documented history of discrimination.

Rochester needs meaningful zoning reform, not simply an update to a code that has contributed to a housing crisis and environmental injustice. It also needs accountability for administrators whose violations of the law have led to the blatant neglect of representation for the poorest neighborhoods in our city.

Equitable zoning begins with understanding best practices and recognizing the policies that created and maintained current disparities. Future equity depends on both.

1. Disparate Impact & Racial Equity Analysis

Types of Analysis: Reports, data, and maps examining historical exclusion and racial disparities.

Historical Land Use Overlays: Maps comparing historic redlining and racial covenants with current zoning.
Spatial Economic Analysis: Statistical links between historically redlined areas, household wealth, homeownership, and mortgage denials.
Representation Audits: Historical geographic and demographic makeup of Planning Commissions, Zoning Boards, and advisory panels to identify disparities in decision-making power.

2. Housing Affordability, Displacement, & Gentrification Analysis

Recommended Records: Housing market studies, economic analyses, and displacement risk data.

Zoning Exclusion Audits: Percentage of residential land restricted to single-family homes, correlated with regional rent burdens.
Displacement Risk Analysis: Mapping eviction rates, property tax increases, and corporate acquisitions to identify physical and cultural displacement risks.
Fair Housing Land Use Scoring (FHLUS): Quantitative assessment of whether multifamily and low-income housing distribution promotes integration or reinforces income segregation.

3. Environmental Justice & Cumulative Burdens

Recommended Records: Environmental health assessments, exposure maps, and infrastructure audits.

Incompatible Land Uses: Maps showing where industrial and heavy commercial zones border historically marginalized neighborhoods.
Environmental Inequities: Neighborhood data on tree cover, extreme heat, air pollution, and noise in historically neglected areas.
Public Investment Disparities: Historical spending differences across neighborhoods for sidewalks, green space, and stormwater systems.
Cumulative Burden Mapping: Maps showing where multiple environmental, health, and infrastructure burdens overlap.

4. Equity Impact & Accountability

Recommended Records: Policy impact assessments, equity metrics, and accountability audits.

Zoning Equity Impact Assessments: Predict how proposed changes affect housing capacity, property values, and displacement risks before adoption.
Administrative Enforcement Audits: Compare zoning approvals, denials, variances, permits, and violations across neighborhoods and demographics.
Equity Performance Measures: Public data tracking progress toward zoning equity and integration goals.
Zoning Accountability Audits: Assess fairness and consistency in code interpretation, enforcement, appeals, legal compliance, complaint resolution, and corrective action across communities.

Bibliography

Zoning Alignment Project: Equity Analysis Baseline Report

1. American Planning Association (2023). Equity in Zoning Policy Guide.
Zoning reform, representation, public participation, enforcement, and equitable land-use planning.
https://www.planning.org/publications/document/9264386/

2. U.S. Department of Housing and Urban Development (2024). AFFH-T Data Documentation, Version AFFHT0007.
Fair housing data, segregation, demographics, housing disparities, and access to opportunity.
https://docs.huduser.gov/archives/sites/default/files/datasets/affh/AFFH-T-Data-Documentation-AFFHT0007-August-2024.pdf

3. University of Richmond, Digital Scholarship Lab. Mapping Inequality: Redlining in New Deal America.
Historical redlining maps for comparison with modern zoning and neighborhood conditions.
https://dsl.richmond.edu/panorama/redlining/

4. National Zoning Atlas. National Zoning Atlas Project.
Mapping and comparison of zoning restrictions, including single-family and multifamily housing regulations.
https://www.zoningatlas.org/

5. Monkkonen, P., et al. (2024). Do Land Use Plans Affirmatively Further Fair Housing? Journal of the American Planning Association, 90(2), 247–260.
Fair Housing Land Use Score (FHLUS), housing opportunity, and segregation.
https://pmc.ncbi.nlm.nih.gov/articles/PMC11750077/

6. Urban Displacement Project, University of California, Berkeley. Gentrification and Displacement Mapping Research.
Displacement risk, neighborhood change, and housing vulnerability.
https://www.urbandisplacement.org/maps/

7. California Department of Housing and Community Development. Affirmatively Furthering Fair Housing Data Viewer.
Segregation, housing opportunity, displacement risk, and fair housing enforcement.
https://www.hcd.ca.gov/affh/data-viewer

8. U.S. Environmental Protection Agency (2024). EJScreen Technical Documentation, Version 2.3.
Methods for measuring pollution exposure, environmental disparities, and cumulative burdens. Historical documentation; the public EJScreen tool was discontinued in 2025.
https://www.epa.gov/system/files/documents/2024-07/ejscreen-tech-doc-version-2-3.pdf