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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: email@example.com
Subject: APPROACHES TO IDENTIFYING DISADVANTAGED COMMUNITIES
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 Districtfs proposed method may differ from Census Tracts used in OEHHAfs 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.
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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