Comment Log Display

Dear Chair Nichols and Board Members,
 
The San Bernardino Associated Governments (SANBAG) has reviewed
both the draft Interim Guidance to Agencies Administering
Greenhouse Gas Reduction Fund Monies and the draft Approaches to
Identifying Disadvantaged Communities. SANBAG understands that
there is no single methodology that would perfectly define,
identify, and address all of the disadvantaged communities in
California. However, representing a county with significant air
quality, environmental, education, and socio-economic challenges,
SANBAG strongly suggests that CalEPA and CARB use the currently
available CalEnviroScreen Tool (v.2.0) to define disadvantaged
communities (Method 1).
 
SB 535 is very clear about how the definition of disadvantaged
communities should occur:
 
(Section 39711 Health and Safety Code) These communities shall be
identified based on geographic, socioeconomic, public health, and
environmental hazard criteria, and may include, but are not limited
to, either of the following:
(a) Areas disproportionately affected by environmental pollution
and other hazards that can lead to negative public health effects,
exposure, or environmental degradation.
(b) Areas with concentrations of people that are of low income,
high unemployment, low levels of home ownership, high rent burden,
sensitive populations, or low levels of educational attainment.
 
SB 535, Section 1(g) further states that resources are to be
directed “to the state’s most impacted and disadvantaged
communities to ensure activities taken pursuant to that authority
will provide economic and health benefits to these communities as
originally planned.” It is quite clear that disadvantaged
communities should be defined as communities with the greatest
socioeconomic challenges who are also impacted by “environmental
pollution and other hazards”. The final definition must include
both elements. Therefore, out of the five proposed methods, Method
1 most closely mirrors the basic intent of the SB 535.
 
Recently, the California Transportation Commission (CTC)
encountered the identical set of issues when defining disadvantaged
communities for the Active Transportation Program. The CTC allowed
three concrete definitions (CalEnviroscreen 1.1, median household
income, and percentage of students eligible for the Free or Reduced
Price Meals Program).  The Commission also allowed a fourth
definition whereby the applicants could propose an alternative
disadvantaged community determination method. By allowing a broader
definition of the disadvantaged communities, many of the applicants
used that opportunity to define disadvantaged communities in very
creative ways. In the end, certain communities were able to qualify
as disadvantaged under the CTC guidelines, when in reality one
would have to question whether this was appropriate. This led to 86
percent of the applicants being classified as disadvantaged.  This
was clearly not the intent of the disadvantaged community criteria.
 SANBAG would strongly suggest that the definition be kept
consistent with the intent of SB 535 and be based on the extensive
work conducted in CalEPA’s development of CalEnviroScreen.
Therefore, rather than having multiple methodologies for defining
disadvantaged communities, SANBAG would recommend the use of Method
1.
 
As mentioned in the draft GGRF interim guidelines, the purpose is
“preliminary guidance on approaches that agencies can use to
maximize the benefits of investments to disadvantaged communities.”
Currently, the GGRF Expenditure Plan looks at investment plans that
will achieve the GHG reduction goals and targets while looking at
investments that facilitate feasible and cost-effective GHG
reductions. Since AB 32 is an air quality/GHG program, the air
quality, GHG, and environmental burdens of a community should be
the primary emphasis when investing on various projects. In other
words, disadvantaged communities with these environmental burdens
should be the priority of the program. The only methods that fully
analyze the environmental burdens are CalEnviroScreen Method 1 and
Method 5. However, in the interest of simplicity, SANBAG would
again recommend that Method 1 be used as the single definition.
 
SANBAG understands that improving the health of disadvantaged
communities is important and that socioeconomic factors play a
significant role in determining the health of a community. SANBAG
works very closely with the San Bernardino County Department of
Health in addressing these socioeconomic issues through
partnerships and collaboration. However, it is important to point
out that the GGRF program is not a social service program, but a
program to reduce GHG. According to the American Lung Association
2012 and 2013 State of the Air report, our county is ranked the
smoggiest in the nation. In San Bernardino County, more than
150,000 adults and children have asthma, 60,000 residents have
chronic bronchitis, 23,000 have emphysema, and 420,000 suffer from
heart disease. The state needs to recognize the true disadvantaged
communities that have the most significant environmental impacts
and make sure that these communities are not overlooked in funding
opportunities. In that regard, Method 1 best captures the essence
of the impacts. SANBAG requests that rather than utilizing a
separate methodology, the CalEnviroScreen Tool be used for its
intended purpose.

Thank you for considering comments from SANBAG