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Comment 35 for Public Workshops on Investment of Cap-and-Trade Auction Proceeds to Benefit Disadvantaged Communities (sb-535-guidance-ws) - 1st Workshop.
First Name: Judy
Last Name: Farris
Email Address: judyfarris.uucod@verizon.net
Affiliation: Green Sanctuary UU Church of the Desert
Subject: CalEPA Identification of Disadvantaged Communities and CalEnviroScreen
Comment:
I attended the 9/10/14 Public Workshop in Mecca re: the investment of cap-and-trade auction funds. I was impressed with CalEnviroScreen 2.0 and the work that has gone into gathering data on a wide variety of indicators in every census tract and then compiling it into scores to readily allow comparison. But during the meeting, the data gap for a number of indicators for the Coachella Valley became apparent. An example is emergency department visits for asthma. The eastern part of our valley has no emergency departments - nor any hospitals or urgent care. Other indicators may have data gaps due to insufficient air monitoring - we are a major freight corridor, both truck and rail, are subject to seasonal heavy winds, and have the Salton Sea and all its many environmental problems at our eastern end. In addition, there are many parcels of tribal sovereign land not subject to the same statutes, reporting, etc. as surrounding properties. It is likely that other areas of the state have data gaps, for these or different indicators, due to sparse population in unincorporated rural communities. If these gaps could be filled, their CES scores would no doubt be higher. For this reason, I urge you to select the top 25% of disadvantaged communities for receipt of cap-and-trade funded projects to help insure that those in need, and deserving, of reduction in the health issues caused by greenhouse gas emissions will not inadvertently be left out due to inadvertently lower scores. As to the five methods for using the score components to identify the communities, I think pollution burden only, and population characteristics only, undermine the great effort that has gone into CES to provide a balanced assessment of environmental risk and should not be used. (I do not have sufficient knowledge of statistics to weigh in on the other three methods.)
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Date and Time Comment Was Submitted: 2014-09-12 16:45:26
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