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Comment 69 for Public Workshops on Investment of Cap-and-Trade Auction Proceeds to Benefit Disadvantaged Communities (sb-535-guidance-ws) - 1st Workshop.
First Name: Tracy
Last Name: Delaney
Email Address: tdelaney@phi.org
Affiliation: Public Health Alliance of Southern CA
Subject: Public Health Departments Disadvantaged Communities Comment Letter
Comment:
(Please refer to the formatted PDF of this letter and its attachment submitted via the web). Dear Secretary Rodriguez and Chairman Nichols: This letter is being sent on behalf of two regional alliances of Public Health Department representatives from across the State of California, actively advancing chronic disease prevention and health equity through a health in all policies approach. We welcome the opportunity to comment on the recent documents released by the CalEPA/ARB regarding the identification of disadvantaged communities for the purpose of prioritizing investment of the Greenhouse Gas Reduction Funds per SB 535. We understand that the implementation of this legislation is progressing under rapid timelines and appreciate the Air Resources Board’s commitment to nonetheless provide thoughtful deliberation to address public feedback. As public health professionals engaged in efforts to reduce the stark disparities in health that exist across California, an important focus of our work is identifying and improving conditions in health disadvantaged communities. Evidence suggests that social factors, which include income, unemployment, education and rent burden, are the most significant drivers of health and wellbeing (US Burden of Disease Collaborators. The state of US health, 1990-2010: burden of diseases, injuries, and risk factors. JAMA. 2013 Aug 14; 310(6):591-608.) We are concerned that neither Method 1 (overall CalEnviroScreen (CES) score) nor the other alternate methods presented in the recently released methodology report, “Approaches to Identifying Disadvantaged Communities”, adequately identify populations that are highly disadvantaged based on these social factors, collectively referred to as the social determinants of health. The importance of employing a methodology that adequately identifies and weights disadvantage based on the social determinants of health is further elevated given the importance community stakeholders place on income, unemployment, education and rent burden in defining the common needs of disadvantaged communities. In Table 3 “Common Needs of Disadvantaged Communities (As Identified by Community Advocates)” of the August 22, 2014 document “Investments to Benefit Disadvantaged Communities,” the bulk of the needs given are economic—improved jobs to increase family income, better workforce preparation, reduced housing and energy costs and improved transportation access. The needs that are not economic are couched in economic terms—health harms like asthma and obesity are “suffered disproportionately by low-income residents/ communities.” Stakeholders understand what the scientific evidence clearly demonstrates; that social determinants are the largest contributor to health and quality of life. The Public Health Alliance of Southern California, with technical assistance from the California Department of Public Health (CDPH), has conducted an analysis to determine whether communities identified as disadvantaged based on a high (top 15%) overall CES score are also the most disadvantaged (top 15%) in terms of poverty. Our analysis suggests that only 56.5% of these most impoverished (top 15%) census tracts would be identified as disadvantaged based on their top 15% overall CES Score (please see analysis (a) Poverty in the attachment below, “Poverty, Population Characteristics and CES 2.0”). Further, only 52.5% of census tracts identified as disadvantaged based on the overall CES score fell into the top 15% of census tracts based on poverty level. Both of these results suggest deficiencies in how the tool is being used to identify socioeconomic vulnerability and, hence, public health disadvantage. A second analysis (see Attachment below, analysis (b) “Population Characteristics”) also suggests a relatively poor statistical correlation between pollution-burden and population characteristics, as currently measured, among census tracts in CES 2.0. Only 61.8% of the census tracts with a top 15% population characteristic score are also in the top 15% in terms of their overall CalEnviroScreen Score. This poor statistical correlation can be seen visually in Figure 2 of "Approaches to Identifying Disadvantaged Communities” report where the scatterplot diagram for method 1, overall CalEnviroScreen Score does not show a linear clustering (i.e., pollution burden scores tracking equally with population characteristic scores) but rather a diffuse cloud, with many communities that score high on one criteria but not on another. The fundamental approach utilized in CalEnviroScreen (CES), to incorporate both pollution burden and social determinant criteria into a single score through multiplication, creates a number of methodological concerns. First, the multipliers don’t always reflect identified biologic or risk interactions between pollution and population characteristic factors. Additionally, the assignment of weights such that an equal 10 point scale is given to both the pollution burden and population characteristics means that the primary (social) determinants of health are undervalued based on their proportional contribution to health outcomes, and that pollution burden is disproportionately over-weighted. Finally, the population characteristic score includes health outcomes strongly associated with environmental exposures while omitting critical chronic disease health outcomes that contribute to the majority of healthcare expenditures (Galea S, Tracy M, Hoggatt KJ, DiMaggio C, Karpati A. Estimated deaths attributable to social factors in the United States. Am J Public Health. 2011;101:1456-1465.) This analysis is not meant to suggest that pollution burden should be discarded as a measure of disadvantage. Instead, it suggests that pollution burden and population characteristic data are independent and should be weighted according to their share of attributable mortality and morbidity in the United States. Our two Alliances are currently developing an evidence-based method for identifying health disadvantaged communities. This is a deliberate process undergoing scientific review, and as such is not expected to be completed prior to ARB’s September decision point. Given that, we understand that our index will not be considered as a qualifying option in this first year’s criteria. However, we want to ensure that in future years, an evidence-based health disadvantage metric is included into the methodology for defining disadvantaged communities. In the development of future year’s disadvantaged community identification methodology and allocation protocols, we would suggest the formation of a working group that includes representatives from public health and low-income communities to provide input on the implementation of SB 535, ranging from continued refinement in the identification of disadvantaged communities, to SB 535 guidance document updates, and the evaluation of the effectiveness of awarded projects in addressing disadvantage. This will provide critical input needed to both effectively achieve greenhouse gas targets and maximize benefits to disadvantaged communities. For the purposes of this year’s allocation only, we ask CalEPA/ ARB to consider the use of a one-time temporary measure that weights the current CES indicators based on the relative magnitudes of their demonstrated impacts on health and well-being as reflected in the research literature. Thank you for your consideration of our comments. There is a tremendous opportunity to effectively address climate change and to create transformative change in disadvantaged communities across California. We welcome the opportunity to partner with CalEPA/ARB now and in the future to ensure that we meet or exceed greenhouse gas targets while optimizing the greatest evidence-based co-benefits for disadvantaged communities. Sincerely, Susan Harrington M.S., R.D. Director, County of Riverside Department of Public Health Co-Chair, Public Health Alliance of Southern California Cheryl Barrit, M.P.I.A . Preventive Health Bureau Manager Long Beach Department of Health and Human Services Co-Chair, Public Health Alliance of Southern California Tracy Delaney, Ph.D., R.D. Executive Director, Public Health Alliance of Southern California Chuck McKenty, Ph.D. Alameda County Department of Public Heatlh Co-Chair of BARHII Michael Stacey, MD Solano County Public Health Department Co-Chair of BARHII Sandi Galvez, MSW BARHII Executive Director
Attachment: www.arb.ca.gov/lists/com-attach/74-sb-535-guidance-ws-UzIHcwZlVVlQNVMy.pdf
Original File Name: ARB CalEPA DAC Methodology Comment Letter Alliance BARHII 9.15.14 + Analysis.pdf
Date and Time Comment Was Submitted: 2014-09-15 14:11:47
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