CalEnviroScreen Public Comment Letters

California Senate Bill 535 (SB 535, 2012) authorized CalEPA/Air Resources Board (ARB) to identify disadvantaged communities for the purpose of targeting a share of investment of the Greenhouse Gas Reduction Funds to disadvantaged communities.
According to SB 535 (De Leon, 2012):
These communities shall be identified based on geographic, socioeconomic, public health, and environmental hazard criteria, and may include, but are not limited to, either of the following: (a) Areas disproportionately affected by environmental pollution and other hazards that can lead to negative public health effects exposure, or environmental degradation. (b) Areas with concentrations of people that are of low income, high unemployment, low levels of homeownership, high rent burden, sensitive populations, or low levels of educational attainment. (SB 535, 2012) While public health is explicitly mentioned in part (a), research indicates that it is the conditions enumerated in part b—collectively known as the social determinants of health—that have the greatest impact on health outcomes.

The Public Health Alliance sees tremendous potential in SB 535 to help target investments to communities that are disadvantaged according to the criteria enumerated in part b, ultimately leading to improved health outcomes for all. In order to realize this potential, the Alliance has been highly engaged with the process of identifying disadvantaged communities from a social determinants perspective, and establishing guidelines for how these communities will be benefitted by Greenhouse Gas Reduction Programs.

One key strand of Alliance engagement has been around the use of the CalEnviroScreen tool which was selected by CalEPA as the tool that would be used to identify disadvantaged communities. CalEnviroScreen (CES) was initially developed as a screening methodology to identify California communities that are “disproportionately burdened by multiple sources of pollution” for internal CalEPA prioritization. The Alliance has been concerned that CES’s prioritization of pollution burden means that some highly disadvantaged communities are not being identified because their community does not have a high pollution burden score. A detailed analysis of concerns can be seen in this appendix to the Alliance’s May 2014 letter to CalEPA on identifying disadvantaged communities for the purposes of the Affordable Housing Sustainable Communities (AHSC) Program.

Below are letters submitted to by the Alliance part of the 2014-2015 development of the Greenhouse Gas Reduction Fund Program Expenditure Guidelines and program in the hope of shifting the identification of disadvantaged communities toward a social determinants point of view.

Date Topic
October 2016 Joint letter submitted with BARHII to CalEPA/OEHHA with recommendations for improvement to CalEnviroScreen 3.0.
May 2015 Joint letter submitted with BARHII to CalEPA/OEHHA with recommendations for improvements to CalEnviroScreen 2.0
September 2014 Joint letter submitted with Bay Area Health Inequities Initiative (BARHII) to CalEPA/ARB regarding August 2014 “Investments to Benefit Disadvantaged Communities” document.
May 2014 Letter to Office of Environmental Hazard Health Assessment (OEHHA) regarding the design of CalEnviroScreen 2.0

To further support the identification of disadvantaged communities from a social determinants of health perspective, the Alliance, with support from the California Endowment, has invested in the development of the California Health Disadvantage Index (HDI), which is a statewide composite index of disadvantage. The Alliance has proposed that CalEPA expand the definition of disadvantage to include a methodology like the one used to create the HDI.