Comment Log Display
Below is the comment you selected to display.
Comment 113 for Public Workshops on Investment of Cap-and-Trade Auction Proceeds to Benefit Disadvantaged Communities (sb-535-guidance-ws) - 1st Workshop.
First Name: Robert
Last Name: Garcia
Email Address: rgarcia@cityprojectca.org
Affiliation:
Subject: Re: Include Race, Color, National Origin, and Green Access in CES 2.0 and SB 535 Guidance
Comment:
Dear Assistant Secretary Mataka: We support guidance and an improved CalEnviroScreen (CES) tool that properly considers race, color, and national origin, as well as green access, in order to identify underserved communities and to distribute cap and trade greenhouse gas reduction funds under SB 535. We recommend the following steps to improve CES for the reasons discussed below. (1) Reinstate race, color, and national origin data as an indicator in the CES score. (2) Include green access as an indicator in addition to pollution burdens and population characteristics in CES. (3) Guidance documents on the distribution of greenhouse gas reduction funds under SB 535 should incorporate race, color, and national origin, as well as green access. (4) Guidance documents, CES, and other public documents should refer to “underserved communities,” rather than “disadvantaged communities.” “[W]hen society’s rewards – including the right to breathe clean air[,] live far away from toxic wastes[, and live near parks and green space] – are systematically distributed by race, it is better to know than to remain dangerously ignorant,” as USC Prof. Manuel Pastor has written. Good social research needs data on race and ethnicity. There is no sound social science or technical reason to exclude such data. Federal law requires collecting, analyzing, and publishing data based on race, color, or national origin where, as here, there is evidence of racial and ethnic disparities regarding pollution burdens, vulnerability, and green access. No law prohibits it. Claims that Prop 209 or other state laws prohibit or constrain agencies from collecting, analyzing, and publishing such data to include in the CES or to distribute greenhouse gas reduction funds are false, prejudicial, and discriminatory. The Environmental Justice Screening Method (EJSM) developed by the USC Program on Environmental and Regional Equity (PERE) includes race and ethnicity. CES should too. CalEPA should supplement statewide ranking of census tracts with regional scoring and ranking of census tracts, strengthen its hazard proximity analysis, and include EJSM’s land-use methodology and climate change indicators in CES. See California Environmental Justice Alliance (CEJA)’s June 2, 2014 letter to the Office of Environmental Health Hazard Assessment (OEHHA). As CEJA states, “[t]he impacts of climate change will be a critical issue for communities to contend with in the coming years, and we know that low-income communities and communities of color will be hit first and worst and have least resources to adjust to climatic changes. CalEnviroScreen’s assessment of where the most vulnerable communities are located could greatly enhance the statewide conversation on where climate adaptation efforts and investments should be focused, and we recommend CalEPA to begin to consider the development of an indicator on climate change in the next year.” The City Project joins in (1) the September 15, 2014, letter from the SB535 Coalition to the Air Resources Board (ARB) re Comments on Draft Interim Guidance on Investments to Benefit Disadvantaged Communities; and (2) the September 15, 2014, letter from Los Angeles-based environmental justice groups to ARB re greenhouse gas reduction funds and SB 535 standards, to the extent those letters are not inconsistent with the position described below. We write separately here on the need to explicitly address equity and disparities based on race, color, or national origin, and compliance in the planning and implementation process with federal and state civil rights and environmental justice laws and principles.
Attachment: www.arb.ca.gov/lists/com-attach/118-sb-535-guidance-ws-BWZdOgZrUGZSJAVk.pdf
Original File Name: CalEPA public comments 20140915.pdf
Date and Time Comment Was Submitted: 2014-09-15 16:55:25
If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.