Improving Air Quality in Overburdened Communities Initiative

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Comment From: Anonymous Anonymous

11/11/22 @ 12:46 AM
Ecology should take a preventative, precautionary approach when it comes to air monitoring, rather than the exclusionary approach offered:

the draft air pollution and community indicators are overly narrow and restrictive, insist on the satisfaction o...↓
the department does not provide an alternative pathway to allow consideration of, or identification of, communities who wish to be considered as overburdened for the purposes of Section 3; and
despite its sound efforts so far, the department's process for seeking input is still not accessible to the most vulnerable populations and its proposal is not readily understandable to most people.
To improve the department's draft criteria, I recommend that the department ensure frontline communities can be monitored:

broaden the default pathway to identify overburdened communities by:
eliminating the multi-factor requirement that an overburdened community have both an elevated level of criteria air pollutants and exposure to a second category of pollutants;
lowering the thresholds for non-criteria pollutant exposure, and explaining how the selected thresholds correlate to health factors or desired outcomes; and
accounting for the environmental harms and cumulative health impacts experienced by vulnerable communities and at-risk populations;
create an alternative pathway to identify overburdened communities—in addition to the default pathway—one that permits a community to apply or petition for consideration due to its lived experience with pollution, or due to special or unforeseen circumstances;
expand its efforts to reach affected persons in potentially overburdened communities to incorporate hard-to-reach perspectives and input that could affect decisions about identifying an overburdened community, and its boundaries; and
build on existing community engagement efforts across programs and agencies and align its Section 3 implementation with community engagement principles and proposals from the Healthy Environment for All ("HEAL") Act.
I live in a 'sacrifice zone' in Seattle, and the toxic industrial corporations in South Seattle are not being held to accountable for their actions. As a result, our life expectancies in South Seattle are 10 years less than the rest of Seattle.
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Comment From: Luis Zepeda

11/11/22 @ 12:13 AM
I think that Ecology's definition of overburdened communities is too narrow. Perhaps having an additional method of identification through a self-nominated process could allow communities overlooked by the current criteria to be recognized?
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Comment From: Melina Rivera

11/10/22 @ 10:34 PM
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Comment From: Olivia Brey

11/10/22 @ 9:28 PM
Thank you for making this commitment to address poor air quality in communities that are most impacted. In order to truly support these communities, it is vital that Ecology improves the definition of "overburdened." Drawing on the wisdom & experienc...↓
broaden the default pathway to identify overburdened communities by:
eliminating the multi-factor requirement that an overburdened community have both an elevated level of criteria air pollutants and exposure to a second category of pollutants;
lowering the thresholds for non-criteria pollutant exposure, and explaining how the selected thresholds correlate to health factors or desired outcomes; and
accounting for the environmental harms and cumulative health impacts experienced by vulnerable communities and at-risk populations;
create an alternative pathway to identify overburdened communities—in addition to the default pathway—one that permits a community to apply or petition for consideration due to its lived experience with pollution, or due to special or unforeseen circumstances;
expand its efforts to reach affected persons in potentially overburdened communities to incorporate hard-to-reach perspectives and input that could affect decisions about identifying an overburdened community, and its boundaries; and
build on existing community engagement efforts across programs and agencies and align its Section 3 implementation with community engagement principles and proposals from the Healthy Environment for All ("HEAL") Act.
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Comment From: Duwamish River Community Coali... (Adrienne Hampton)

11/10/22 @ 9:23 PM
November 9, 2022

Erin Torrone
Department of Ecology
Air Quality Program
P.O. Box 47600
Olympia, WA 98504-7600

RE: Improving Air Quality in Overburdened Communities Initiative

Dear Ms. Torrone:
Thank you for the opportunity to comment on the Washington Depar...↓

The Duwamish River Community Coalition (DRCC) has long been community stewards for environmental and climate justice in the Duwamish Valley. The Duwamish Valley is a near-port community, one of the most polluted areas in the entire Pacific Northwest following 100 years of industrial dumping, air pollution, and release of toxic waste in the community. DRCC has worked tirelessly alongside community groups and neighbors for 20 years to clean up the water, land and air while fighting to eliminate ongoing industrial pollution that makes our communities among the least healthy in King County, WA.

Residents of the Duwamish Valley are disproportionately exposed to contamination compared to wealthier communities in the City of Seattle. People who live in Georgetown and South Park have some of the highest health differences in the City of Seattle and therefore are overburdened by air pollution. Childhood asthma hospitalization rates are the highest in the City. Heart disease death rates are 1.5 times higher than the rest of Seattle and King County. Life expectancy is 13 years shorter when compared to wealthier neighborhoods and 8 years shorter when compared to the Seattle and King County average.
While we are generally supportive of the draft list of indicators for identifying overburdened communities under Section 3 of the CCA, many gaps remain in the draft indicators and community engagement process that will be critical to address and incorporate in order to eliminate health impacts in overburdened communities.


Overall, Ecology must include indicators and parameters that address additional sources of harmful air pollution, historical disparities and vulnerabilities in the face of gentrification made worse by the continued legacy of environmental racism such as redlining, displacement, and narrow policy development that still does not reflect the full experience of living in an overburdened community.

To sharpen the department's draft ceria, we recommend the department open opportunities to expand draft air pollution and community indicators in the following ways:

Identify which Washington communities are overburdened by air pollution and the significant sources of this pollution.

Center cumulative impacts while not limiting the departments scope:

Leverage emerging tools developed by federal agencies such as the Environmental Justice Index (EJI) cumulative impact tool. We generally agree with the department's proposed sources of data to identify communities through the Environmental Health Disparities Map Rank, EJScreen Demographic Index, and Tribal lands. Please note many overburdened communities are exposed to air pollution at the neighborhood level or in "hotspots" often missed or not adequately quantified due to the lack of effective air monitoring, disaggregated data, and regulatory compliance and/or enforcement.
Open the scope so that the department eliminates the multi-factor requirement that an overburdened community have both an elevated level of criteria air pollutants and exposure to a second category of pollutants.
Incorporate social science and qualitative data (community stories).
Incorporate geographic data and wind patterns into the exposure factors to reflect how air pollution is made worse by or trapped due to topography of an area such as a valley.


Provide clarity around thresholds. It is unclear why the department has selected such elevated thresholds. A community should not have to be within the worst one percent or five percent of all polluted areas for a given parameter before it is considered overburdened. Thus, assuming the highest threshold may not be the most protective measure for communities facing harms from air pollution.
Step away from either/or thinking. Communities other than those identified by the draft indicators should have the option to petition, appeal or qualify as overburdened. This would allow communities that are on the verge of being identified as "overburdened communities" under the Environmental Health Disparities Map Rank and EJScreen Demographic Index requirements to access the air monitoring resources envisioned by Section 3 of the CCA. Furthermore, the department must be clear on how the placement of air monitors and potential expanding the budget for additional air monitors is determined to anticipate an update and possible expansion of the air monitoring network in the future.
Include a wider suite of air pollution sources and indicators:

The department must include a wider suite of air pollution sources such as metals, dust, odors, and additional chemicals known as air toxics. In describing proximity to stationary sources, the department does not define "major stationary sources of air pollution." It is therefore uncertain if the department would include major sources of pollution.

For example, there are many metal recycling facilities in the Duwamish Valley. DRCC recently completed a study of airborne heavy metal concentrations through an analysis of moss samples in Georgetown and South Park. Conducted with National Forest Service scientists and led by local youth from the Duwamish Valley Youth Corps (DVYC), the analysis showed significantly higher concentrations of dangerous metals in areas near the Ardagh Glass facility.





Metals considered to be hazardous air pollutants (HAPs) have been found in glass melting feedstock or its process. In this research, lead and chromium are measured at the E. Marginal Way S. (Duwamish) monitor in quantities far above the standard or action levels.
In addition, we recommend the department specifically list mobile sources of emissions that contribute to high concentrations of PM 2.5, PM 10, NOx, SOx, ultrafine particulates and leaded fuels from aviation. Examples include:

Harmful Diesel Pollution: The Duwamish Valley is disproportionately impacted by diesel pollution because it is a high traffic transportation corridor. Three freeways border the Duwamish Valley: Interstate 5, Highway 509, and the West Seattle Bridge. During the two years that the West Seattle Bridge has been closed for repairs, an average of 100,000 vehicles per day have been rerouted through the Duwamish Valley. Numerous major trucking routes pass through Georgetown and South Park, carrying freight from the Port of Seattle, and nearby industry.

Aviation: Leaded aviation fuel, known as "avgas," is used in mainly piston-engine smaller aircraft, but remains the largest single source of lead emissions in the United States. About 80% of regional ambient lead originates from the aviation sector (Avgas). King County International Airport is a user of avgas. EPA has issued its long-awaited proposed finding that lead in aviation fuel likely "endangers public health and welfare," a measure that will trigger regulation to limit lead, but the prospects for an eventual phaseout of the fuel remain unclear amid uncertainty over the "scope, applicability, timing, and nature of any subsequent rulemakings."

Factors to identify community boundaries and expand and improve Washington's air quality monitoring network.

We remain concerned many vulnerable populations are not well accounted for or represented by existing data sets and thus the department assumes air quality monitoring is accurately and adequate representing air quality conditions.


Disaggregated data must be incorporated to reflect the full experience of communities overburdened by air pollution.

In this way, federal auditors concluded toxic pollution blindspots riddle an antiquated air monitoring network.

For instance, there are only two air toxics monitors in the City of Seattle. The Department of Ecology manages one atop Beacon Hill. This air monitor is over a mile from any industries polluting the Duwamish Valley. The Puget Sound Clean Air Agency (PSCAA) operates another air toxics monitor near the Federal Center South campus. PSCAA air monitor is over a half-mile to any significant industrial polluter and failed to record air toxics data for five of the last 10 years. In fact, environmental health researchers appealed for better localized air pollution data to assess its relationship to COVID-19 trends. To this point, we recommend the follow to the department:

Must have a concrete plan to determine where the air monitoring ultimately goes led by meaningful community engagement and interactive workshops, existing community-led research and expanding the type of monitoring conducted to include more than criteria pollutants.
Lower the thresholds for non-criteria pollutant exposure, and explain how
the selected thresholds correlate to health factors or desired outcomes to better protect communities, eliminate harm, and shape transformative air pollution regulation in Washington.
Incorporate historical data and policies that have led to a legacy of harm and environmental racism such as redlining. More so, factor in where zoning or conversion of land to industrial zoning has impacted communities.Add proximity to highways, freight corridors and superfund sites.




Develop strategies to reduce criteria air pollutants in overburdened communities.

The department must connect strategies to measurable health outcomes at the neighborhood level.

While we champion the expansion of the air monitoring network, the department must act quickly in its power to also bring real policy, regulatory and compliance solutions to eliminate harms from air pollution to increase community well-being. Because of the goals set forth in this initiative, overburdened communities will expect transformative change to result from the placement of new air monitors throughout Washington. To this point, we recommend the department:

Increase clarity on actions following the expanded air monitoring network with accountable benchmarks to address air pollutants through just policy, regulation and enforcement to eliminate air pollution in overburdened communities.
Address and incorporate areas under exploration that are acknowledged yet not added due to data limitations, such as childhood asthma.
Build on existing community engagement efforts across programs and agencies and align its Section 3 implementation with community engagement principles and proposals from the Healthy Environment for All ("HEAL") Act.

Meaningful community engagement

Meaningful community engagement remains inaccessible to overburdened communities.

While we appreciate the department's extension in the comment period as well as the listening sessions this past winter, we continue to hear from the community that language around discussing air quality remains a barrier for the common person to understand and time spent in education is far missed by the department.

The department must lead with education first before requesting dense feedback on technical terms in order to increase inclusion and belonging in decision making spaces.



This thread also joins the need for translated planning documents and educational materials prepared at the ready (not by request) as well as compensation for participation and feedback.

We understand the department faces funding limitations, yet advocate that the time spent by ecology day-to- day in this work readjust its approach to build in education of air quality and its health impacts. This work is heavy, requires time and dense synthesis especially in the lead up to a public comment opportunity. We encourage the department to balance education and planning processes in order to lower barriers and ultimately inspire justice in policy reflective of the needs in overburdened communities.

Deadly chemicals in our air and water should not be acceptable to any of us. Overburdened communities must be protected by stricter regulations on polluters and decision making that holistically heals and addresses the needs in overburdened communities. Our health and well being is dependent on healthy air, water, and soil -- this should be universally available and not dependent on race/ethnicity, income, language, or zip code. It is time for this harmful legacy to stop.

Sincerely,




Adrienne Hampton (she/her)
Climate Policy Manager
Duwamish River Community Coalition
adrienne@drcc.org
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Comment From: K. A.

11/10/22 @ 8:19 PM
Thank you for your presentation and all the work that you have put into this initiative. I am glad that efforts are underway to improve air quality in overburdened communities.

I would like the initiative to go further in measuring air pollution. I wo...↓

Studies have shown that airports are major generators of air pollution and particulates (see 1. and 2.) I would like to see ongoing regular monitoring for criteria pollutants, toxic pollutants, p 10, p 2.5 and ultrafine particles at the airport and surrounding communities to include neighborhoods to the east and west of the airport. I would like widespread community notification and involvement in planning and implementing this monitoring.

It is important that this monitoring is done because communities are affected now and will continue to be increasingly affected in the future. While cap and invest reduces emissions from other sources, it does not apply to airplane traffic. For this reason airport emissions will continue to increase and become an ever greater percentage of pollution in the future. This pollution greatly affects the health of people and the environment.

When determining which communities are overburdened by air pollution I would like to see more emphasis placed on air pollution and proximity to ongoing high volume point emissions, freeways, airports and air traffic routes. These areas have a high probability of experiencing more air pollution than other areas.

Tools such as the EJ screen and EHD screen may be helpful but I don't think they should be used to determine whether or not monitors should be placed in an area known or strongly suspected to have increased levels of air pollution. To do this would be distributing monitors in an inequitable manner which I don't think is the intention of this initiative.

1.https://www.minnpost.com/second-opinion/2014/06/airport-pollution-may-have-been-seriously-underestimated-study-suggests/

2.https://pubs.acs.org/doi/10.1021/acs.estlett.2c00322
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Comment From: Climate Solutions (Altinay Karasapan)

11/10/22 @ 7:36 PM
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Comment From: The Nature Conservancy (David Mendoza)

11/10/22 @ 7:10 PM
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Comment From: Environmental Defense Fund (Kjellen Belcher)

11/10/22 @ 7:08 PM
See attachment for Environmental Defense Fund (EDF) comments on Ecology's draft process for identifying overburdened communities highly impacted by air pollution.
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Comment From: NW Energy Coalition (Annabel Drayton)

11/10/22 @ 6:36 PM
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Comment From: Urban League of Metropolitan S... (Nirae Petty)

11/10/22 @ 6:20 PM
Hello,

Below is some feedback that we share with Front and Centered that we hope the Department of Ecology considers in its process of defining and identifying overburdened communities:

Ecology should take a preventative, precautionary approach when it...↓

the draft air pollution and community indicators are overly narrow and restrictive, insist on the satisfaction of an overly limited multi-factor test, do so without supplying adequate justification of the thresholds established, and exclude vulnerable communities and at-risk populations;
the department does not provide an alternative pathway to allow consideration of, or identification of, communities who wish to be considered as overburdened for the purposes of Section 3; and
despite its sound efforts so far, the department's process for seeking input is still not accessible to the most vulnerable populations and its proposal is not readily understandable to most people.

To improve the department's draft criteria, we recommend that the department ensure frontline communities can be monitored:

broaden the default pathway to identify overburdened communities by:
eliminating the multi-factor requirement that an overburdened community have both an elevated level of criteria air pollutants and exposure to a second category of pollutants;
lowering the thresholds for non-criteria pollutant exposure, and explaining how the selected thresholds correlate to health factors or desired outcomes; and
accounting for the environmental harms and cumulative health impacts experienced by vulnerable communities and at-risk populations;
create an alternative pathway to identify overburdened communities—in addition to the default pathway—one that permits a community to apply or petition for consideration due to its lived experience with pollution, or due to special or unforeseen circumstances;
expand its efforts to reach affected persons in potentially overburdened communities to incorporate hard-to-reach perspectives and input that could affect decisions about identifying an overburdened community, and its boundaries; and
build on existing community engagement efforts across programs and agencies and align its Section 3 implementation with community engagement principles and proposals from the Healthy Environment for All ("HEAL") Act.
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Comment From: Washington Environmental Counc... (Caitlin Krenn)

11/10/22 @ 6:17 PM
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Comment From: Martha Baskin

11/10/22 @ 6:08 PM
The draft air pollution and community indicators, as written,are overly narrow and restrictive, insist on the satisfaction of an overly limited multi-factor test, do so without supplying adequate justification of the thresholds established, and exclu...↓

To improve the department's draft criteria, I respectfully recommend the following:
1) broaden the default pathway to identify overburdened communities by eliminating the multi-factor requirement that an overburdened community have both an elevated level of criteria air pollutants and exposure to a second category of pollutants;

2) lower the thresholds for non-criteria pollutant exposure, and explaining how the selected thresholds correlate to health factors or desired outcomes; and,
3) account for the environmental harms and cumulative health impacts experienced by vulnerable communities and at-risk populations by creating an alternative pathway to identify overburdened communities—in addition to the default pathway—one that permits a community to apply or petition for consideration due to its lived experience with pollution, or due to special or unforeseen circumstances;

Respectfully,
Martha Baskin
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Comment From: Front and Centered (Deric Gruen)

11/10/22 @ 5:28 PM
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Comment From: Association of Washington Busi... (Peter Godlewski)

11/10/22 @ 5:08 PM
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Comment From: Alexander Mihal

11/10/22 @ 3:38 PM
this is a closed mined approach, we are spending billions of dollars on something that may or may not work. Has science looked at other possibilities for climate change, instead of focusing on pollution as the only cause. It seems like things got alo...↓
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Comment From: Alliance for Community Engagem... (Heidi Cody)

11/10/22 @ 2:58 PM
Alliance for Community Engagement (ACE) SWWA is submitting a PDF comment letter via the upload link. Thank you for you work, and for speaking with ACE.
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Comment From: Brittney Bollay

11/10/22 @ 2:51 PM
Please broaden the default pathway to identify overburdened communities by:
-eliminating the multi-factor requirement that an overburdened community have both an elevated level of criteria air pollutants and exposure to a second category of pollutants...↓
-lowering the thresholds for non-criteria pollutant exposure, and explaining how the selected thresholds correlate to health factors or desired outcomes; and
-accounting for the environmental harms and cumulative health impacts experienced by vulnerable communities and at-risk populations
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Comment From: Mike Elliott

11/10/22 @ 2:40 PM
Dear Dept. of Ecology:

It is very important that air quality in overburdened communities and neighborhoods be improved. For neighborhoods in close proximity to major transportation routes, carbon monoxide and diesel particulates may very likely have a...↓

Generally, railroad freight container train operations are considered "cleaner" than highway truck container operations, if for no other reason than container shipments by rail REMOVE A SIGNIFICANT NUMBER OF TRUCKS FROM THE HIGHWAYS. Albeit there are caveats to consider. First and foremost, the Class I railroad carriers must maintain an ADEQUATE A PROFESSIONAL WORKFORCE IN SIZE, TRAINING, AND EXPERIENCE to operate container trains safely and efficiently. Second, the railroad must have ADEQUATE LOCOMOTIVE POWER available to run container trains. Third, locomotive power must be MODERN, LOW-EMISSION equipment (In the past, leased power operated in WA state was NOT modern, low emission equipment). With these points in mind, let's consider what the Class I railroads have done over the past five years with special emphasis on the past two years.

Approximately five or six years ago, the Class I railroads decided to adopt one of the most irresponsible "business" models in the history of modern railroading. That model is known as: Precision Scheduled Railroading. The ill conceived scheme to boost profits was hatched by the late modern-day Robber Barron Hunter Harrison who, at the time, was CEO on the CSX railroad. Not to be outdone by a colleague, the other Class I railroad CEOs soon jumped on the "profits above all else" bandwagon adopting some iteration of PSR. For a more complete explanation of PSR and related historical background, please read the attached white paper entitled, "How America's Supply Chain Got Railroaded," by Yale law student Matthew Jinoo Buck.

So, how are the railroads, PSR, and improving air quality in overburdened WA state communities connected? The issues are connected because, in the Class I railroad's quest for another piece of gold to count, they forced thousands of container loads off trains and onto many, many more highway trucks - some less-efficient, higher polluting trucks. Literally, all of these trucks use the roads and highways adjacent to many of the overburdened communities. Further, urea needed for diesel truck emission systems was made to be in short supply due, in large part, to the railroad industries inability to transport urea product to end users due to lack of adequate workforce and locomotive power requirements.

Finally, I draw your attention to Surface Transportation Board hearing, Docket# EP-770, held March 26th & 27th, 2022 in Washington D.C. The topic of Docket# EP-770 was, "Urgent Issues in Freight Rail Service. Written stakeholder comments may be found under the docket number on the STB website here: https://www.stb.gov/. I encourage WA ST Dept. of Ecology to review all stakeholder comments associated with EP-770 and to watch all eighteen (18) hours of stakeholder testimony (see YouTube https://www.youtube.com/watch?v=Q0rk5tnrFqA). The written and oral testimony provided during the two days of stakeholder hearings provide substantial insights as to railroad industry actions that intentional forced copious truck traffic onto highways (that should have been on rail), thus increasing truck traffic pollution and, consequently, negatively impacting air quality in overburdened neighborhoods of WA state.

Thank you for this opportunity to provide comments on Improving Air Quality in Overburdened Communities Initiatives. Mike Elliott
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Comment From: Millie Magner

11/10/22 @ 2:21 PM
The Dept of Ecology must address the environmental inequities in determining what populations and regions are overly burdened by poor air quality. We know and have data from Washington Department of Health's "Washington Environmental Health Disparit...↓

DOE must monitor air quality with an environmental justice lens. The HEAL Act focus is the tool that must be used to capture vulnerabilities.

Do not leave communities behind that have historically been ignored.
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Comment From: Patricia Harris

11/10/22 @ 2:04 PM
The Department of Ecology in its Improving Air Quality in Overburdened Communities Initiative needs to reconsider its method of defining overburden communities. The currently proposed method is not inclusive enough and seems to lack evidence for its ...↓
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Comment From: Joseph B Szwaja Szwaja

11/10/22 @ 1:49 PM
Dear Dept of Ecology,

After reviewing the data, is appears to me that your thresholds for who is overburdened are too narrow and must be reshaped to truly support frontline communities that indeed bear the brunt of pollution in our state.

I strongly ur...↓

Thank you so much for your consideration and for all of the wonderful work you do on behalf of our state.

Joseph Brian Szwaja
Retired Public School Teacher
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Comment From: Ruth Sawyer

11/10/22 @ 1:33 PM
It doesn't make sense for Ecology to come up with it's own criteria when we already have the HEAL Act definition of "overburdened communities."

I recommend that Ecology build on existing community engagement efforts across programs and agencies and al...↓
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Comment From: Yonit Yogev

11/10/22 @ 1:16 PM
To the Dept of Ecology,
Regarding the implementation of the Climate Commitment Act, and specifically regarding Improving Air Quality in Overburdened Communities, I sincerely hope the department plans to collaborate fully with the folks in the communit...↓
The currently proposed method's list of how to define an overburdened community is currently narrow and exclusive.
Additionally, to be sure no communities that should be included are left out, it is important for DOE to include more rather than fewer communities on the list of those who are overburdened. So many of these communities have been historically marginalized.
DOE should also work on creating a pathway for overburdened communities to get on the list if they aren't on it initially.
Hopefully we're all finally learning the lessons from failed experiments of the past, that if communities aren't fully at the table, attempts to 'fix' things won't work. The communities themselves must be 100% involved from start to finish. That will ensure success. Thank you.
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Comment From: Columbia Riverkeeper (Daniel Serres)

11/10/22 @ 12:51 PM
Please see the attached comments of Columbia Riverkeeper. Thank you.
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Comment From: Esther Min

11/10/22 @ 10:44 AM
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Comment From: Coleen Anderson

11/10/22 @ 10:23 AM
Ecology should take a preventative, precautionary approach when it comes to air monitoring, rather than the exclusionary approach offered:
* the draft air pollution and community indicators are overly narrow and restrictive, insist on the satisfaction...↓
* the department does not provide an alternative pathway to allow consideration of, or identification of, communities who wish to be considered as overburdened for the purposes of Section 3; and
* despite its sound efforts so far, the department's process for seeking input is still not accessible to the most vulnerable populations and its proposal is not readily understandable to most people.
To improve the department's draft criteria, we recommend that the department ensure frontline communities can be monitored:
* broaden the default pathway to identify overburdened communities by:
* eliminating the multi-factor requirement that an overburdened community have both an elevated level of criteria air pollutants and exposure to a second category of pollutants;
* lowering the thresholds for non-criteria pollutant exposure, and explaining how the selected thresholds correlate to health factors or desired outcomes; and
* accounting for the environmental harms and cumulative health impacts experienced by vulnerable communities and at-risk populations;
* create an alternative pathway to identify overburdened communities—in addition to the default pathway—one that permits a community to apply or petition for consideration due to its lived experience with pollution, or due to special or unforeseen circumstances;
* expand its efforts to reach affected persons in potentially overburdened communities to incorporate hard-to-reach perspectives and input that could affect decisions about identifying an overburdened community, and its boundaries; and
* build on existing community engagement efforts across programs and agencies and align its Section 3 implementation with community engagement principles and proposals from the Healthy Environment for All ("HEAL") Act.
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Comment From: Sept Gernez

11/10/22 @ 10:07 AM
The currently proposed method provides too narrow and too exclusive of a list when defining overburdened communities, and there is a lack of evidence and justification for the specific framework chosen. In order to not leave historically marginalized...↓
Please develop a pathway to get on the list of overburdened communities, for those who may be left behind from the proposed approach.
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Comment From: Janeen Provazek

11/10/22 @ 1:35 AM
Tacoma, WA has been identified as an overburdened community with significant air pollution due to our heavy industries. Some areas are worse than others. For example, anywhere near our Port and also in South Tacoma. Of course, our city, like many oth...↓
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Comment From: Elizabeth Mooney

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Caroline Bowdish

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Amanda Dickinson

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Amanda Dickinson

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Denee Scribner

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: James Carpenter

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Sean Edmison

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Debbie Ramos

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Carole H

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Kathy Golic

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: S Jacky

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Gay Gorden

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Deborah Parker

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Faye Bartlett

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Giles Sydnor

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Tracy Wang

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Brian Baltin

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Kathleen Allen

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Judith Cohen

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: rita h

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Alana Khayat

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: James Krieger

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Robert Brown

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Sarah Campbell

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Andrea Gruszecki

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Katherine Nelson

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Thomas Hughes

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Hannah Liu

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Morgan Brownlee

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Margie Bone

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Ken Zirinsky

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Kathryn Lambros

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Nicholas Jurus

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Bill Justis

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: William Sneiderwine

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Lanie Cox

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: R Olson

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment.. The Climate Commitment Act’s directive to improve air quality in overburdened communities is critical to ensuring that the law functions as intended to reduce environment...↓
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Comment From: Lori Erbs

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Diane Shisk

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Derek Benedict

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,It probably isn't shocking to you to know that a great majority of fossil "fool" plants are built near neighborhoods of poor people and minorities.So I thank you for the opportunity to provide public comment on the proposed proc...↓
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Comment From: Constance Voget

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: LP Singh

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Lori Erbs

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Barbara Scavezze

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Lynn Carpenter

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Kristin Blalack

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Ted Matts

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Dan Rogers

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Lucinda Wingard

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Jack Laskowski

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: priscilla martinez

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Jean Schwinberg

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Jean Pauley

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Tina Brown

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Joyce Grajczyk

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Barbara Menne

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Lucy JOHNSON

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Laura Marx

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: James Little

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,I appreciate the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened ...↓
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Comment From: Tika Bordelon

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Gayle Leberg

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Brel Froebe

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Mellor Teams

11/10/22 @ 1:00 AM
Settings (Gear Icon) > Notifications. © 2019 Microsoft Corporation, One Microsoft Way, Redmond WA 98052-7329Read our privacy policy
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Comment From: Anne Nequette

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Steven Shapiro

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Sandra Aseltine

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Barry Chapman

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. I appreciate Ecology’s ongoing commitment to incorporating public input and d...↓
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Comment From: Shirley Leung

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Andrea Faste

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Christi Sutphin

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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Comment From: Sharon Parshall

11/10/22 @ 1:00 AM
Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓
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