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Another Fair Housing Act expert has raised questions over the validity of a disparate impact study completed for Palmer College of Chiropractic's prospective planned institutional district plan.

At the request of the Davenport Civil Rights Commission, Jack Cann, an attorney with the Housing Justice Council in St. Paul, Minnesota, reviewed the analysis of Mosaic Community Planning and found its conclusion of no disparate impact to be flawed.

Disparate impact is when policies appear to be neutral, but in reality impact a protected group disproportionately.

"There are several problems with the analysis and the conclusion that there is no disparate impact," Cann wrote. "The argument that there is no disparate impact is clearly flawed and I don't believe the analysis includes sufficient data to permit a conclusion."

Palmer was asked to rezone more than 38 acres into a planned institutional district, or PID, after it revealed preliminary plans last year to invest more than $50 million in campus improvements over the next 10 years.

Over the past several years, Palmer has acquired a number of properties, many of which are historic, near its campus. But some fell into disrepair and led to blight in the neighborhood. The college was granted the ability to demolish 11 of the historic properties with the caveat of a PID being approved.

But before the Plan and Zoning Commission could vote to recommend the PID, the Civil Rights Commission raised concerns about the plan violating the Fair Housing Act.

With the vote tabled indefinitely, the city paid Mosaic $11,680 in October to complete a disparate impact analysis.

Last month, Calvin Bradford, a Fair Housing Expert whose work was quoted in the study, also called the analysis flawed.

In Cann's letter to Civil Rights Director Latrice Lacey, he wrote that there was "no actual analysis of the non-student population to be displaced by school expansion."

Cann also said "the assumption in the analysis is based on the overall racial makeup of the whole PID area" which is "clearly a mistake."

"That could hardly be the case if, as the Mosaic Analysis concludes, the proportion of the minority residents in the non-student population to be displaced is roughly the same as for the city as a whole," Cann wrote.

Additionally, Cann wrote that the analysis does not address how affordable housing is or the needs of minorities versus whites for affordable units.

The final point in the letter was that the U.S. Supreme Court had rejected a viewpoint similar to Mosaic's criticism of the analysis of impediments, which called "affordable housing investments in both impacted and non-impacted areas, as 'dissonant with contemporary fair housing interpretation.'"

Lacey wrote in an email to the Quad-City Times that the Civil Rights Commission will discuss the Mosaic analysis and the input received from Bradford and Cann at its Feb. 13 meeting.

"I would imagine that the information provided through the Mosaic report and subsequent analyses of that report will give the Commission insight to have a meaningful discussion on the issues previously presented and the project itself," Lacey wrote. "I would have to wait until the Commission meets and discusses it to know what steps it would like to take, or if it would like to take any action at all."