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I wanted to comment regarding the Urban Forestry grant funding
guidelines which are now slated to be used 100% to serve
disadvantaged communities (DACs) as defined by CalEnviroscreen2.  I
would first like to state that while I agree that there may be DACs
as a whole, there are also vulnerable populations as well as
pollution corridors which are not addressed by CalEnviroscreen2,
both of which would be well served by Cap and Trade (C&T) funds and
Urban Forestry (UF) initiatives.  
 
I have long been a proponent of trapping pollution at its source
and with this in mind, it seems prudent to plant trees along
freeways, where pollution is created.  In San Diego this has the
potential to reduce non-DAC created pollution that is blown inland
into DACs.  Further, I pr¬¬¬¬opose that all who use freeways are
vulnerable and that freeways are “pollution corridors” worthy of
C&T UF funding.  For example; those who use public transportation
or have older vehicles that may not have air conditioning could be
commuting from DAC communities.  In the heat of the summer, and
height of air pollution, they sit at bus stops near freeways
(whether in their designated DAC or near work) and drive on the
freeway (often during rush hour) exacerbating any air/heat/auto
pollution related health issues.  Planting dense trees along
freeways has long term pollution reduction and health improvement
potential.
 
However, I really want to bring up another issue, or two, which has
not yet been addressed.  Primarily, the fact that all persons with
allergies and asthma, young and old, and those yet to develop
allergies and asthma, are disadvantaged by climate change, air
pollution and allergenic trees and have the potential to be further
disadvantaged if trees are not selected with human health in mind. 

 
Urban Forestry is a powerful tool, with multiple benefits, a main
one being to improve public health.  However, in all of the
“Healthy” Urban Forestry presentations I have attended, none have
addressed the issue of pollen pollution and its impact on human
health, health care costs, and the economy.  Simply using Emergency
Room visits for asthma does not correctly identify those affected
or who will be affected if proper tree selections are not made. 
Allergy and asthma burdens a wide and varied population and are
frightening and costly diseases with potentially deadly outcomes
and staggering costs associated with increased health care, lost
productivity and missed work/school.  
 
Childhood asthma is steadily rising as are food/pollen related
allergies.  Pollen counts are on the rise as well and there is no
indication of slowing.  Increased CO2 and heat causes plants to
grow faster and produce more pollen at ever younger ages.  Climate
change is slated to dry the air creating additional respiratory
irritation.  Continued planting of high pollen trees will only
serve to exacerbate skyrocketing pollen counts and associated
respiratory diseases.
 
Avoidance is the only cure for allergies (and allergic asthma) yet
in my pollen studies and public encounters it has become apparent
that the public has LITTLE ABILITY to do this.  The only way for
people to avoid pollen triggers is to remove or limit them.  Urban
Foresters, Planners, Landscape Architects and Arborists are in the
unique position to do just that.  Yet, they are not schooled in the
sophisticated relationship between the urban forest and human
health.   Their focus is on the health of the trees and sometimes
the ecosystem but never on the health of humans.  I urge the ARB
and EPA to consider restrictions or limitations regarding the
planting (and perhaps removal and replacement) of known allergenic,
asthmagenic and high pollen producing plants.  Perhaps a 10%
maximum of known allergy trees (not species).  Those who suffer
with allergies and asthma caused by pollen are woefully
disadvantaged in all areas of the state, not just those defined by
CalEnviroscreen2.  Additional disadvantaged “areas” or “corridors”
could be those with high local pollen counts, an excess of
allergenic trees or high pollution sources.
 
Environmental justice for those with allergies and asthma is a
growing concern and litigation is on the horizon in other states. 
I urge the CARB and CalEPA to be on their toes with progressive
policy regarding planting campaigns and further urge you to
consider that all schools be included in the designation as DACs or
as “sensitive populations” to receive C&T funding due to the
damaging effects of both pollution and pollen on children’s
developing lungs.  Schoolyards are a prime location for large tree
banks.  Campuses and the people who use them can benefit
dramatically through Urban Forestry initiatives but only if proper
selection and human health are considered in the equation(s).  
 
Allergies develop after repeated exposure to allergens.  Quick and
light exposure does not cause allergy.  Repeated, heavy exposure
does.  The type of exposure one might experience with allergenic
trees at their home, workplace or school.  
 
Schools are primary places to create healthy environments using
trees that reduce outdoor air pollution, respiratory irritants and
are pollen and allergy neutral.  Children attend school during the
hours of peak pollen release (10 am- 4 pm).  Sensitizing exposure
is far more likely than at home.  Overplanting schools to
compensate for air pollution, and other factors likely to be
exacerbated by climate change seems highly logical.  Children have
developing lungs, they breathe more air per body weight than adults
and have rapid lung development between the ages of 10 -18.  They
deserve the cleanest air we can possibly provide.  I trust that the
ARB and EPA staff are familiar with the pollution/pollen
relationships shown in previous studies yet many schools are
located near busy streets for convenience.  
 
Here are two very surprising observations regarding implementation
of an allergy conscious approach to schoolyard landscaping. 
Because asthma causes more absenteeism than any other reason,
schools can increase their bottom line and average daily attendance
by reducing these absences (which cost school districts millions
annually).  Treed campuses improve mental health, which should also
make students want to be there.  Healthy trees improve air quality
and human health, reducing absences due to allergies, asthma and
other respiratory ailments.  Additionally, an allergy conscious
approach has the potential to increase standardized test scores
because standardized tests are often administered in the height of
the pollen season.  Anyone with allergies and asthma knows the
“brain fog” created by allergies.  I propose that reducing pollen
and asthma triggers has the potential to increase standardized test
scores by reducing both allergy “brain fog” and “brain drain” as
well as allergy and asthma absences and exam make-ups.  
 
We have the opportunity to plant truly healthy urban forests; not
just healthy trees.  We can provide all of the common benefits and
then some.  Reducing the pollen load will slow and hopefully
reverse the pollen and childhood asthma trend.  This will help
millions upon millions of people breathe easier while at the same
time reduce medical and other costs associated with allergies,
asthma and COPD; all diseases exacerbated by pollen exposure,
synergistic effects between pollen and pollution and the
anticipated effects of climate change.   
 
I urge the ARB and EPA to make our urban forests work for and be
healthy for all and to consider restrictions or limitations
regarding the planting (and perhaps removal and replacement) of
known allergenic, asthmagenic and high pollen producing plants. 
Perhaps a 10% maximum of known allergy trees (not species) as those
who suffer with allergies and asthma caused by pollen are woefully
disadvantaged in all areas of the state, not just those defined by
CalEnviroscreen2.  Additional disadvantaged “areas” or “corridors”
could be those with high local pollen counts, an excess of
allergenic trees or sources of high pollution, like freeways. 
 
I also urge you to consider all children as underserved, sensitive
populations when it comes to urban forestry and to designate each
schoolyard and park (to increase outdoor play and reduce obesity)
as an allowable underserved “community,” “service area” or
“sensitive population.”  The healthy foresting of places where
children learn and play has perpetual benefits that go far beyond
clean air.  
 
I realize that this is a niche area and offer my advice and
expertise to help develop appropriate plant lists and/or help to
define and implement such a progressive and needed program.  This
is not as difficult as it may initially seem.  The number of
allergy and asthma appropriate trees (healthy trees) far outweigh
their allergy causing counterparts.  
 
Let’s plant trees!      
 
Sincerely,
Rachele Melious
Aeroallergen Specialist, San Diego, CA
 
NB:  Today’s pollen issues were created in the past.  There is an
unassociated lag between tree planting and pollen
production/allergies/asthma.  New plantings will not create
noticeable pollen pollution until they have matured (approximately
7-15 years).  People, including professionals who plant and grow
these trees, have not yet made this very important health
connection.  There is also a lag in pollen release and peak asthma
symptoms.  Lag relationships make cause and effect difficult to
identify.
 
Links to two excellent resources:  
 
http://www.amazon.com/Airborne-Allergenic-America-Contemporary-Medicine/dp/0801829402
https://aaaai.execinc.com/store/product.asp?productid=132