Improving Air Quality in Overburdened Communities Initiative
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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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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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...↓e from Front and Centered, I recommend that you follow their guidance to ensure frontline communities are 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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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...↓tment of Ecology's Improving Air Quality in Overburdened Communities Initiative.
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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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...↓uld like to see toxic air pollutants included as well as ultrafine particles. Very fine particles penetrate deep in the lungs and travel into the blood stream. Criteria air pollutants don't go far enough in measuring air pollution especially when it comes to airports, refineries, and other major point polluters etc...
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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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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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...↓ 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 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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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...↓de vulnerable communities and at-risk populations;
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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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...↓t worse with the use of cell phones and other electronic wireless devices in the last 20 years. These devices transmit billions of signals everyday through the atmosphere and they create friction and friction creates heat, Has science studied this and what is their conclusion. Maybe climate change is a natural occurrence and there is nothing we can do about it. Washington state was covered with glaciers before there was pollution and the climate turned warmer and melted the glaciers, humans had nothing to do with this warm up. Taxing people will not stop climate change, it will only make it harder for them to pay bills and create more homeless people, then we will have more problem, I think the best solution to climate change would be weather modification like cloud seeding or using newer Tecnologies to control the weather. Operation Popeye was used in the Vietnan war with great succus. China used these technology's Durning the summer Olympics and it rained and washed all the pollution away If we focus all our time and money on just one thing causing climate change we might be to late. In other words look at the bigger picture and come up with other solutions if you truly want to combat climate change before it to late. Thank you for your time in this matter
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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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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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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...↓ major impact on neighborhood air quality. Most modern trucks (circa 2010 and later) have improved emission standards using urea technologies. As electric vehicle technology improves and displaces the internal combustion engine, diesel particulate and carbon monoxide pollutants levels are poised to trend downward. However, any study of transportation pollution sources potentially affecting overburdened communities in WA state conducted today would be remiss without including pollutants associated with railroad freight operations.
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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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...↓ies Map.
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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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 ...↓selections. It should be altered to be more inclusive, including more communities on the initial list. It should also include a way for those communities that may have been missed to be considered as overburdened.
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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...↓ge you to review your decision and expand your definiton of overburdened communitiess to better reflect the reality of the many communiites who are acutley suffering from pollution and climated change.
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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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...↓ign its Section 3 implementation with community engagement principles and proposals from the Healthy Environment for All ("HEAL") Act.
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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...↓ies themselves, at all stages of the process.
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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Please see the attached comments of Columbia Riverkeeper. Thank you.
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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...↓ 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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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...↓ communities behind, the Department of Ecology should err on the side of caution and include more communities on the initial list of overburdened communities.
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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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...↓ers, has allowed heavy industries to Be located near the poorer and more diverse neighborhoods. People in these neighborhoods, as identified by Tacoma Pierce County Health Department, experience significantly more health problems and deaths. We need to have better measurement of our air quality, more trees planted, phasing off of fossil fuels to transition to greener industries, preservation of any current green areas, better mass transit, protection of our water sources, etc. We need our air less polluted!!
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Elizabeth Mooney 5934 NE 201st StKenmore, WA 98028
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Caroline Bowdish 1531 N 16th AvePasco, WA 99301
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Amanda Dickinson 1322 S 18th AveYakima, WA 98902
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Amanda Dickinson 1322 S 18th AveYakima, WA 98902
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Denee Scribner 16822 N Columbine CtNine Mile Falls, WA 99026
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, James Carpenter 21123 30th Pl WLynnwood, WA 98036
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework.Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically:APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary.- Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution.- Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia, and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area.It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds.2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds.2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Sean Edmison 11820 167th Pl NERedmond, WA 98052
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Debbie Ramos 15433 SE 167th PlRenton, WA 98058
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Carole H 4807 Willamette StPort Townsend, WA 98368
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Kathy Golic 13705 460th Ct SENorth Bend, WA 98045
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, S. Jacky 2411 Lexington StSteilacoom, WA 98388
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Gay Gorden 2832 18th Ave SEOlympia, WA 98501
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Deborah Parker 55 Windward DrBellingham, WA 98229
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Faye Bartlett 3382 Southbend PlBellingham, WA 98226
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Giles Sydnor 5355 28th Ave NWSeattle, WA 98107
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Tracy Wang 5355 28th Ave NWSeattle, WA 98107
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Brian Baltin 700 Broadway ESeattle, WA 98102
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Kathleen Allen 5900 37th Ave SSeattle, WA 98118
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Judith Cohen 1608 E Republican StSeattle, WA 98112
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, rita h 4444 6th Ave SELacey, WA 98503
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Alana Khayat 4108 46th Ave SWSeattle, WA 98116
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, James Krieger 1614 24th AveSeattle, WA 98122
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Robert Brown 1443 Edwards AveFircrest, WA 98466
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Sarah Campbell 4120 50th Ave NESeattle, WA 98105
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Andrea Gruszecki 19805 Sunnyside Dr NShoreline, WA 98133
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Katherine Nelson 9445 S 232nd StKent, WA 98031
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Thomas Hughes 915 N M StTacoma, WA 98403
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Hannah Liu 3008 NE 141st StVancouver, WA 98686
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Morgan Brownlee 6200 Soundview DrGig Harbor, WA 98335
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Margie Bone 120 NE 53rd StSeattle, WA 98105
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Ken Zirinsky 3612 N 33rd StTacoma, WA 98407
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Kathryn Lambros 8339 25th Ave NWSeattle, WA 98117
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Nicholas Jurus 9412 SW Gorsuch RdVashon, WA 98070
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Bill Justis 6345 Cedar Flats Rd SWOlympia, WA 98512
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, William Sneiderwine 14901 SE Sunpark DrVancouver, WA 98683
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Lanie Cox 13625 S Sherman RdSpokane, WA 99224
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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...↓al health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. I support efforts that would:- Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.Thank you for your consideration.Regards, R.Court Olson 15817 SE 26th StBellevue, WA 98008
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Lori Erbs 5310 Marda LnAcme, WA 98220
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Diane Shisk 19428 Aurora Ave NShoreline, WA 98133
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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...↓ess to identify overburdened communities highly impacted by air pollution.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 environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Derek Benedict 709 212th Pl SWLynnwood, WA 98036
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Constance Voget 1615 N 41st StSeattle, WA 98103
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, LP Singh 11111 address confidentialSeattle, WA 98125
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Lori Erbs 5310 Marda LnAcme, WA 98220
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Barbara Scavezze 13268 NE 182nd StWoodinville, WA 98072
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Lynn Carpenter 120 3rd Ave SEdmonds, WA 98020
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Kristin Blalack 1018 Central St NEOlympia, WA 98506
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Having a degree in Environmental Toxicology, I understand what Ecology is attempt to put together, and I commend its efforts. Some major gaps exist.Identifying specific communities is important to make sure the focused and strategic allocation of resources. However, the proposed process limits eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities that may be inequitable and somewhat arbitrary. It needs to better document how and why specific indicators are being applied. It seems too complex as explained now and needs to be understood by communities and people who want to get involved in the process as it goes. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution. It should go beyond identifying communities that are either “overburdened” or not and should reflect the gradation of pollution impact on communities, like a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably. The proposed process seems to leave out some communities heavily impacted by stationary sources of criteria pollutants, like near refineries, paper mills, and cement factories.Make sure thresholds are low enough to incorporate uncertainties into the model's indexes, as well as corrective steps to account for margins of error and gaps in existing monitoring and modeling data.Ecology should adjust the application of the indicators so that overburdened communities highly impacted by air pollution are better shown their vulnerabilities and total pollution impact. It appears that certain communities are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. Also, the proposed process may undervalue pollution from busy roadways and transportation hubs. Because there seems to be no indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. Ecology should add one or more specific indicators for vehicle pollution.The process should also include a plan to evaluate outcomes, review communities, and revise the process at regular intervals.Thank you for taking input on this initial step through this very important process. It is indeed live or death decision making and responsible governance to consider its citizens fears, knowledge, and understanding.Regards, Ted Matts 3035 Barrell Springs RdBow, WA 98232
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Dan Rogers 3331 H StWashougal, WA 98671
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Lucinda Wingard 3604 121st St Ct NWGig Harbor, WA 98332
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Jack Laskowski 8410 Holly LnEdmonds, WA 98026
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. We need to take better care of what is left of our environment, for people, wildlife, marine life, and people.Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, priscilla martinez 35411 SE English StSnoqualmie, WA 98065
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Jean Schwinberg 6341 5th Ave NESeattle, WA 98115
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Jean Pauley 414 Malden Ave ESeattle, WA 98112
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Tina Brown 5526 Sugarloaf StAnacortes, WA 98221
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Joyce Grajczyk 12026 SE 216th StKent, WA 98031
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Barbara Menne 1415 N Anderson StTacoma, WA 98406
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Lucy JOHNSON 2933 Fairmount Ave SWSeattle, WA 98116
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Laura Marx 1903 10th Ave WSeattle, WA 98119
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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 ...↓communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: Thank you for your consideration.Regards, James Little 5208 Latona Ave NESeattle, WA 98105
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Tika Bordelon 1400 Hubbell PlSeattle, WA 98101
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Gayle Leberg 18019 Baldwin RdBothell, WA 98012
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Brel Froebe 2915 Cedarwood AveBellingham, WA 98225
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Anne Nequette 1715 NW 59th StSeattle, WA 98107
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Steven Shapiro 2511 30th Ave SSeattle, WA 98144
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Sandra Aseltine 2790 Tracyton Beach Rd NWBremerton, WA 98310
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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...↓eveloping a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities affected by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Barry Chapman 2922 W Dean AveSpokane, WA 99201
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Shirley Leung 14020 32nd Ave NESeattle, WA 98125
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Andrea Faste 7713 11th Ave NWSeattle, WA 98117
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Christi Sutphin 807 N B StEllensburg, WA 98926
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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...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Sharon Parshall 4348 336th Pl SEFall City, WA 98024
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