Comment Log Display

Dear CalEPA and ARB Staff:

Thank you for providing an opportunity for local jurisdictions to
comment on approaches to identifying Disadvantaged Communities (DC)
pursuant to implementing SB 535.  The City of Oxnard, population
203,000, is largely surrounded by year-round agricultural
production and is home to a farmworker and blue-collar population
of low and modest incomes.  

The CalEnvironScreen v. 2.0 list of DC census tracts identifies one
five Oxnard tract above the 95 percentile screen, two tracts
between 91 and 95 percent, and two between 81 and 85 percent.  The
City supports using the CalEnvironScreen v. 2.0, Method 4, that
incorporates both pollution burden and population characteristics. 
 As an alternative, the City supports Methods 1 and 2.   

Do the proposed selection methods include recognition of EPA
Superfund sites, closed landfills, and large power generation
facilities, especially an overconcentration of these type of
historic sources of pollution in minority communities, i.e. an
historic environmental justice situation?  Oxnard has one EPA
Superfund site that needs significant funding to fully remediate
(Halaco), two once-through cooling (OTC) power plants (NRG Mandalay
and NRG Ormond Beach) that may cease operations but may not be
removed, and two closed regional landfills.   

While it is likely emissions from the two NRG power plants are
incorporated into the CalEnvironScreen methodology, it is not
likely the Halaco site, which is capped and inactive, and the two
closed landfills, both of which are capped and have ongoing methane
capture systems, and factored into the CalEnvironScreen
methodology.   Removal of the 26-acre Halaco slag pile with over
700,000 cubic yards of waste is a priority of the City, our State
Representative and Senator, and U.S. Senator Feinstein.   The Cap &
Trade funds may be a source of funding, either through the DC
set-aside or another funding category.   
In a similar manner, the two NRG OTC power plants are likely to
cease operations at the end of 2020 and, potentially, remain in
place as “gigantic beach eyesores” that could be at risk of damage
from storm events and sea-level rise.  The City, and other
jurisdictions with similar OTC coastal power plants, may need
funding assistance should the private energy companies somehow
abandon the OTC facilities in the future.

Please feel free to contact me regarding this comment letter at
(805) 385-7868, or by e-mail at chris.williamson@ci.oxnard.ca.us.