Comment Log Display

I am writing on behalf of the members of Crockett Rodeo United to
Defend the Environment/C.R.U.D.E.
(http://crockett-rodeo-united.com) to provide comments on the
California Environmental Protection Agency’s (CalEPA’s)
identification of disadvantaged communities for priority
investments of Cap-and-Trade auction proceeds and on the California
Air Resources Board’s (CARB’s) interim guidance for State agencies
to maximize benefits in disadvantaged communities, including
criteria to determine which projects benefit disadvantaged
communities as prescribed by Senate Bill 535 (SB 535; De León
2012).

C.R.U.D.E. strongly supports prioritizing funding to disadvantaged
communities. However, while supporting the goals of SB 535 and
CalEnviroScreen, we are very concerned that the current proposed
methods significantly understate the number of disadvantaged
communities in the Bay Area. Many Bay Area Communities with some of
the highest poverty rates and greatest health burdens (asthma rates
and low birth weight) are not identified. For example, current
approaches for scoring CalEnviroScreen indicators fail to
identify:

•	Portions of Richmond and Rodeo and Crockett that sit squarely in
the refinery corridor, known by locals as “Gasoline Alley”.   In
addition, the far Western border of Crockett is actually a
Superfund site, called Selby Slag.  Located along the bay at the
mouth of the Carquinez Strait.  It is currently capped and would
serve as an ideal site for a solar/wind farm that could easily
provide power all the households for both of these economically
disadvantaged communities.  If the federally designated Selby Slag
Superfund site has not been recognized by EPA as a site that should
be included in the EPA program “Re-powering America’s Land”
(http://www.epa.gov/renewableenergyland/), then every effort should
be taken by responsible agencies to correct that error.  
•	Bay View/Hunter’s Point in San Francisco,
•	Portions of West Oakland adjacent to the Port of Oakland,
•	Portions of East Palo Alto and San Jose.

In fact, CalEnviroScreen Method 1 using a 20% threshold identifies
fewer than 3% of Bay Area census tracts as disadvantaged, although
many more are truly disadvantaged.  Also, while CARB’s proposal to
map zip code areas adjacent to identified census tracts as areas
“benefitting” disadvantaged communities does expand the number of
Bay Area communities that would be eligible for funding, it still
fails to include some of the region’s most disadvantaged
communities, such as the towns of Rodeo and Crockett.   Moreover,
this expansion would only apply to projects “benefitting”
disadvantaged communities, not to projects that would directly
benefit residents “within” impacted communities.

Instead of using the one of the 5 methods currently proposed by
CalEPA to identify impacted communities, Crockett-Rodeo United to
Defend the Environment strongly favors use of the Bay Area Air
Quality Management District’s “Method 6.” This method, which still
relies on the CalEnviroscreen indicator data, ensures that
communities with top ranks in a few indicators will be better
represented. For example, of the top 10 most impoverished census
tracts in the Bay Area — where poverty rates exceed 70 percent— not
a single one is identified by CalEPA’s Method 1; utilizing Method
6, half of these census tracts are now identified.   C.R.U.D.E.
believes that using Method 6 is therefore the most consistent with
SB 535’s intent to identify disadvantaged communities with the top
scores in either pollution burdens or economic/health burdens.

Additionally, C.R.U.D.E. believes that the use of the Air
District’s Method 6 must also be accompanied by the following
changes to the CalEnviroscreen Methodology:

•	Supplement the Poverty indicator with a cost-of-living
adjustment, and/or include a Housing Affordability indicator to
take into account substantial cost-of-living differences with
respect to housing affordability, namely the share of “rent
burdened households,” which the Census Bureau defines as the
percent of households that spend over 50% of their income on rent.
•	Increase relative weights for diesel PM emissions indicators and
Traffic Density indicators or remove ½ weights from Environmental
Effects indicators.
•	Supplement the Pesticide Use indicator with urban pesticide
exposure data, or drop the Pesticide Use indicator altogether.
•	Set the threshold for determining disadvantage at the top 30%,
rather than the top 20% or 25%. This will reduce the risk of
overlooking disadvantaged communities.
C.R.U.D.E. also believes that, in order to maximize benefits to
impacted communities, State agencies should:
•	Form Regional Investment Boards with representation from
disadvantaged community members to help prioritize projects within
their communities; and 

…we thank you for your time and attention to this important issue. 
I hope you will take the comments here into consideration.