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Comment 109 for Public Workshops on Investment of Cap-and-Trade Auction Proceeds to Benefit Disadvantaged Communities (sb-535-guidance-ws) - 1st Workshop.


First Name: Bill
Last Name: Magavern
Email Address: bill@ccair.org
Affiliation:

Subject: APPROACHES TO IDENTIFYING DISADVANTAGED COMMUNITIES
Comment:

Matthew Rodriquez
Secretary, Cal-EPA
1001 I Street
P.O. Box 2815 
Sacramento, CA 95812-2815 

Re: APPROACHES TO IDENTIFYING DISADVANTAGED COMMUNITIES

Dear Secretary Rodriguez:

CalEnviroScreen is an important tool for advancing environmental
justice, and has been developed through a lengthy public process.
It is methodologically strong and has been vetted by environmental
justice experts for over five years.

For purposes of implementing SB 535, our goal is to assure that
funding reaches the communities most in need of programs that
reduce pollution, deliver essential services and provide jobs.

We stand behind CalEnviroScreen as a science-based tool for
measuring cumulative impacts, something our groups have long
sought. We support the use of CalEnviroScreen 2.0 to guide the
investment of AB 32 funds pursuant to SB 535.

Fundamentally, we believe it is important to target those public
investments in the communities that most need the benefits to their
health and economy. We do not expect use of CalEnviroScreen to be
perfect from the start, and we urge Cal-EPA to learn from
experience and adapt the tool according to lessons learned from
experience. We share concerns with community groups that certain
areas that we know to be highly impacted communities, such as Bay
View-Hunters Point in San Francisco, are not highlighted, but feel
confident that Cal-EPA will work to continue improving the tool in
the coming year. This is a ground]breaking effort to apply
cumulative-impacts assessment on a statewide level in a way that
has never been done before. 

Our groups have participated in virtually every opportunity for
public engagement during the development of this tool, from
attending workshops to submitting public comments. CalEnviroScreen
has also been vetted by leading academic experts in environmental
justice. The Office of Environmental Health Hazard Assessment
(OEHHA) has used a sound scientific methodology that is well
established in academic literature.

CalEnviroScreen gives decision-makers for the first time a clear,
credible scientific
methodology for the difficult task of identifying environmental
justice communities. The environmental justice movement has long
pushed for state and national agencies to develop a more
comprehensive way of looking at the range of  burdens facing
communities, rather than treating single issues in isolation.
Environmental regulations and decisions usually look at pollution
on a facility-by-facility basis, but that is not how our
communities experience pollution. Facility or media-specific
analyses make it impossible to look at how different pollutants,
such as air and water emissions, combine to become more deadly,
especially when overlaid with socioeconomic vulnerabilities. To
advance environmental justice, it is critically important that the
state have a cumulative impact screening tool such as
CalEnviroScreen.

It is also important to remember that the disadvantaged community
set-aside created by
SB535 is only one part of the Greenhouse Gas Reduction Fund
spending. Most of the $832 million in GGRF funding for 2014-2015
can be used without CalEnviroScreen targeting.

Governmental responsiveness to environmental justice issues varies
widely across the state, and thus necessitates a statewide tool to
identify disadvantaged communities. In some places, local agencies
are very unresponsive to community concerns and thus may develop
regional methodologies that do not prioritize environmental justice
concerns. Even for agencies that have already developed local tools
for identification, it is important to consider how effectively
these tools have been used to benefit environmental justice
communities.

We support making the 25% highest-scoring census tracts eligible
for SB 535 funding, as we believe that that level balances the
goals of inclusiveness and concentration of resources in the
neediest communities.

We know that Methods 1 and 5 presented by OEHHA, along with the
alternative method proposed by the Bay Area Air Quality Management
District, are under active discussion by community groups, and we
believe each of these methods has some merit. We do not believe
Methods 2, 3 and 4 meet the needs of SB 535 implementation or
utilize CalEnviroScreen to the best of its design. 
We do not have enough information on the ramifications of each to
choose one at this time. For example, it appears the Census Tract
data in the Bay Area Air Quality Management Districtfs proposed
method may differ from Census Tracts used in OEHHAfs
methodologies, as discrepancies have been identified. Our groups
seek to support policies that best serve all the environmental
justice communities in the state, rather than engaging in regional
disputes over which methodology best serves different geographic
areas. We emphasize that the overriding consideration in selecting
a methodology should be whether it identifies the highly impacted
communities throughout California.
We urge Cal-EPA to consider the needs of all those communities and
to fulfill both the letter and spirit of SB 535.

Respectfully Submitted,
Bill Magavern, Policy Director
Coalition for Clean Air

Amy Vanderwarker, Co-coordinator
California Environmental Justice Alliance

Diane Takvorian, Executive Director
Environmental Health Coalition

Vien Truong, Environmental Equity Director
The Greenlining Institute

Mari Rose Taruc, State Organizing Director
Asian Pacific Environmental Network 

Marybelle Nzegwu, Staff Attorney
Public Advocates Inc.

Attachment:

Original File Name: CalEnviroScreen comment letter final 9.15.2014.pdf

Date and Time Comment Was Submitted: 2014-09-15 16:54:06



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