Comment Log Display

I am writing on behalf of the Bay Area Environmental Collaborative
(BAEHC), a broad partnership among diverse organizations working to
protect public health in communities most heavily impacted by air
pollution in the San Francisco Bay Area region. BAEHC’s mission is
to ensure better health for residents through measures to reduce
air cumulative pollution, particularly in heavily burdened areas
and for those especially vulnerable to the impacts of exposure.  

BAEHC strongly supports prioritizing state funds to benefit
communities most impacted or “disadvantaged” by the adverse effects
of air pollution. We strongly support the development and
implementation of the CalEnviroScreen, which could be an effective
tool to evaluate cumulative impacts and identify such communities.
We have vital concerns, however, about the statewide application
and scoring of a tool that fails to identify as “disadvantaged”
areas known to be the among the poorest and most burdened by air
pollution in the densely populated Bay Area region. 

While BAEHC does not support the “cap and trade” approach to
pollution reduction, it is critical that revenue generated under
the state program actually benefit communities suffering the
greatest pollution impacts, as envisioned under the law. SB535
requires 25% of funds to benefit “disadvantaged” communities and at
least 10% to be directly invested within these communities. Certain
Bay Area communities have already been identified as among the most
affected in the region, with some of the greatest health impacts in
the state, yet are omitted by the current proposal. The application
of the CalEnviroScreen tool on a statewide basis with the proposed
scoring method is therefore flawed and insufficient to determine
which “disadvantaged” communities should benefit under SB535. With
hundreds of millions of investment dollars at stake, it is vital
that CalEPA/CARB make a proper determination, as envisioned under
the law, to benefit the most heavily burdened communities –
including parts of West Oakland and Richmond, and Bayview Hunters
Point in San Francisco, which suffer some of the greatest health
impacts and are among the poorest areas in our urban region.
 
According to the BAAQMD, the proposed CalEnviroScreen scoring
method identifies less than 3% of Bay Area census tracts in the top
20% statewide, despite serious health burdens that rank in the top
20% statewide, such as asthma and low birth weight infants (two
health indicators used in the CalEnviroScreen). Even with a 25%
threshold, the proposed scoring method would only identify 5% of
census tracts in the region as “disadvantaged.” The tool as applied
fails to designate areas with some of the worst pollution health
impacts in the state as “disadvantaged,” underrepresenting the Bay
Area region by omitting communities that should certainly benefit
from funds under SB535. 

BAEHC supports recommendations to improve application of the
CalEnviroScreen to ensure that the most impacted areas in the
hardest hit regions will benefit from investments of revenue
generated under state programs. We strongly support use of regional
rankings rather than statewide rankings, taking into account
localized impacts in each of the most burdened regions, to
determine which communities are “disadvantaged” and should benefit
under SB535. Similarly, a population based approach would more
equitably allocate funds than an across the board statewide
approach.  

The proposed scoring method also fails to consider the relative
importance of indicators (with limited exception for environmental
effects, weighted at half value). Weighting certain indicators such
as health impacts and other social determinants affecting
vulnerability including poverty would more accurately identify
communities that are “disadvantaged” by pollution, such as those
omitted by the proposed method even though they rank among the
poorest and most exposed in the Bay Area region. 

The poverty indicator also fails to take into account the rising
cost of living in the Bay Area region, including housing costs,
security and other socioeconomic factors that should be included in
this important indicator. Ignoring regional differences in cost of
living inequitably substantially biases low-income populations that
may be more vulnerable to pollution impacts. 

In addition, certain exposure indicators should be weighted to
incorporate their relative significance. The local impact from
exposure to diesel-PM is direct and far greater than exposure to
ozone, for instance. Prioritizing exposure to more harmful
pollutants would be more accurate and would highlight Bay Area
communities currently omitted, despite that they are among the
worst in the state. 

Finally, the thresholds under consideration should be broadened to
ensure that the most impacted communities in the most populated and
burdened regions will benefit. While we strongly support regional
rankings rather than a statewide approach, a 30% threshold should
be used with a statewide approach, rather than proposed thresholds
of up to just 25%. 

BAEHC looks forward to broad application of the CalEnviroScreen
tool to help achieve Environmental Justice in the Bay Area region
and across California. With the above recommendations, we believe
this could be a vital tool for communities and agencies to better
understand and address cumulative pollution impacts, and in this
instance, provide guidance for determining how to prioritize state
funds to benefit the most impacted or “disadvantaged” communities.
Thank you for this opportunity to provide input. 


Best regards,
 
Amy S. Cohen
On behalf of the Bay Area Environmental Health Collaborative