Improving Air Quality in Overburdened Communities Initiative
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...↓
No attachments
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, jesse gillman 15811 SE 43rd PlBellevue, WA 98006
↓
No attachments
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, Teresa Dix 3124 Dakota DrMount Vernon, WA 98274
↓
No attachments
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, Ericka Berg 14035 Burke Ave NSeattle, WA 98133
↓
No attachments
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, Gena DiLabio 3124 Dakota DrMount Vernon, WA 98274
↓
No attachments
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, J K 15120 Starr Rd SEOlalla, WA 98359
↓
No attachments
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 Woolpert 185 NE Snohomish AveWhite Salmon, WA 98672
↓
No attachments
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, Martha Baskin 7719 27th Ave NWSeattle, WA 98117
↓
No attachments
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 Noel 6725 WA-291Nine Mile Falls, WA 99026
↓
No attachments
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 Falk 1010 State AveMarysville, WA 98270
↓
No attachments
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, Gregg Larson 2117 87th St Ct NWGig Harbor, WA 98332
↓
No attachments
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, Janice Schuch 1411 W Axton RdFerndale, WA 98248
↓
No attachments
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 Indigenous 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, including ports and airports. 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, Julia Buck 6037 6th Ave NWSeattle, WA 98107
↓
No attachments
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 Fitzpatrick 1501 30th AveSeattle, WA 98122
↓
No attachments
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 Stefano 22440 Vale Ct SEYelm, WA 98597
↓
No attachments
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
↓
No attachments
Washington Department of Ecology Thank you for the opportunity to comment on designating communities overburdened by air pollution. Please designate Longview-Kelso as an overburdened community and assign more regulatory continuous air monitors to the...↓ area. My complete comments, PDF 19 pp, are attached. Thank you, Diane L. DickLongview, WA
↓
No attachments
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, Richard Johnson 6 Overlake CtBellingham, WA 98229
↓
No attachments
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, Michael Garten 3420 Burke Ave NSeattle, WA 98103
↓
No attachments
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 marks 728 Caroline StPort Angeles, WA 98362
↓
No attachments
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, David Arntson 1615 208th St SEBothell, WA 98012
↓
No attachments
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, Margaret Graham 7043 23rd Ave NWSeattle, WA 98117
↓
No attachments
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, Lily Barrett 9057 E Shorewood DrMercer Island, WA 98040
↓
No attachments
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, Adam Yoshida 2505 Cliffside Ln NWGig Harbor, WA 98335
↓
No attachments
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, Klaudia Englund 7630 Cypress WayAnacortes, WA 98221
↓
No attachments
Dear Ms. Erin Torrone,As a preschool teacher, I know that good air quality is important to the development of young children.Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly i...↓mpacted 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, Mary Ferm 465 Ambrose Ln NWBainbridge Island, WA 98110
↓
No attachments
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, John Thompson 4953 S Spinnaker DrFreeland, WA 98249
↓
No attachments
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, Jennifer Valentine 313 1st AveSeattle, WA 98104
↓
No attachments
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, Asphodel Denning 108 5th Ave SSeattle, WA 98104
↓
No attachments
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, r wood 4326 University Way NESeattle, WA 98105
↓
No attachments
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, Carter McBride 46 Sunnyside DrTwisp, WA 98856
↓
No attachments
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 Lancaster 8356 16th Ave NWSeattle, WA 98117
↓
No attachments
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, Vidette Buchman 12616 40th Ave ETacoma, WA 98446
↓
No attachments
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, Lisa Ceazan 303 41st Ave NEOlympia, WA 98506
↓
No attachments
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, Felicity Devlin 2417 N Washington StTacoma, WA 98406
↓
No attachments
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 Mulcare 1110 Benjamin StClarkston, WA 99403
↓
No attachments
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
↓
No attachments
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, Victoria Urias 14001 35th Ave NESeattle, WA 98125
↓
No attachments
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, Everly-Moey Faleafine 841 Central Ave NKent, WA 98032
↓
No attachments
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, Norman Baker 3789 Lost Mountain RdSequim, WA 98382
↓
No attachments
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, MLou christ Dayton Ave NSeattle, WA 98103
↓
No attachments
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, Carol Smith 3018 Coolidge DrBellingham, WA 98225
↓
No attachments
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, Margaret Woll 208 Highland DrBellingham, WA 98225
↓
No attachments
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.Regards, Nancy Jacobs 12203 NE 37th StBellevue, WA 98005
↓
No attachments
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, Cherie Warner 645 SW Mies StPullman, WA 99163
↓
No attachments
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. The Environmental Justice Task Force did the hard work of identifying at risk communities across the state and made it part of the WA Health Disparities Map: https://fortress.wa.gov/doh/wtnibl/WTNIBL/. I encourage the Department of Ecology to as much as possible, not narrow its definition of impacted communities to reduce scale, but think very broadly in terms of on-going impacts today and historical impacts. Living near highly traveled roads (I-5) and trucking corridors, industries, in wildfire and smoke storm areas which are now expanding, please think broadly and into the future on defining highly impacted. The identification cannot be static, as we continue to develop in response to increasing population, warehouse pressures that pair with increasing freight transportation needs, and growing into the WUI increasing wildfire and smoke risks. Consider the science of the impacts of climate change changing our atmosphere and wind flow patterns causing bad air to settle over regions. Who is impacted most by those conditions when we also institute backyard burn bans?Thank you for your consideration.Regards, Elly Claus-McGahan 4301 N Frace AveTacoma, WA 98407
↓
No attachments
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, Keith Cowan 3709 SW Trenton StSeattle, WA 98126
↓
No attachments
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, Brandie Deal 301 225th St SWBothell, WA 98021
↓
No attachments
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 Ryan 18923 Olympic View DrEdmonds, WA 98020
↓
No attachments
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, Emily Van Alyne 6749 Whitestone StWest Richland, WA 99353
↓
No attachments
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 Blackwood 11916 E 25th AveSpokane Valley, WA 99206
↓
No attachments
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, Sherri Dysart 191 W Loertscher RdShelton, WA 98584
↓
No attachments
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.Seems reasonable and appropriate.Thank you for your consideration.Regards, Greg Willett 14304 92nd Ave NWGig Harbor, WA 98329
↓
No attachments
Dear Ms. Erin Torrone,As the mother of two growing daughters, in a family who cares deeply about the environment and community, we appreciate the opportunity to provide public comment on the proposed process to identify overburdened communities highl...↓y 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, Kylie Loynd 2525 Minor Ave ESeattle, WA 98102
↓
No attachments
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, Heather Murawski 17929 W Spring Lake Dr SERenton, WA 98058
↓
No attachments
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, Noah Ehler 32115 NE 110th CtCarnation, WA 98014
↓
No attachments
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, Randall Daugherty 1405 W 6th StAberdeen, WA 98520
↓
No attachments
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 Bartlett 617 Oppelt RdChehalis, WA 98532
↓
No attachments
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 Hagen-Lukens 4200 SW Atlantic StSeattle, WA 98116
↓
No attachments
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, shawn bell 1511 38th StAnacortes, WA 98221
↓
No attachments
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, Nancy Quackenbush 56 Grove StEastsound, WA 98245
↓
No attachments
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 Berg 7008 Kickerville RdFerndale, WA 98248
↓
No attachments
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, Charles Ellenberger 23633 112th Ave SEKent, WA 98031
↓
No attachments
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, Irene Bensinger 43708 161st Ave EEatonville, WA 98328
↓
No attachments
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, Alfred Ferraris 1340 Corona StPort Townsend, WA 98368
↓
No attachments
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, Betty Barats 1710 Donovan AveBellingham, WA 98225
↓
No attachments
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, Scott Bishop 1710 Giles Ave NWOlympia, WA 98502
↓
No attachments
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, Carolyn Linscott 2508 19th Ave SSeattle, WA 98144
↓
No attachments
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, Sara Burgess 333 34th Ave ESeattle, WA 98112
↓
No attachments
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, Karen Huff 506 Karr AveHoquiam, WA 98550
↓
No attachments
Dear Ms. Erin Torrone,I strongly support this improved effort using the CCA to improve air quality. My neighborhood is impacted greatly by transportation pollution and it is located in the heart of Seattle. The addition of more and more private aircr...↓aft flying over my district (Fremont) is alarming. General aviation aircraft still use AVGAS which is loaded with lead! Many sight-seeing helicopters now fly over my house at low altitude, as just one source of danger, yet the FAA and the Department of Ecology are of no help. I can't even get air monitoring to be installed in the area. The additional burden of private low flying aircraft - added to commercial planes in a landing pattern overhead, a major transportation corridor only four blocks away (SR99) and commuter air activity landing and taking off from Lake Union - these all contribute to the dirty air we breathe. Yet I cannot get any air monitoring in my district! This is only going to get worse as autonomous air-taxis, delivery drones, and other aircraft add to the density of pollution drifting down on Seattle neighborhoods. But no one seems to care. Maybe the Climate Commitment Act will give citizens an improved tool to seek help and cause action to be taken. Therefore, I strongly support the implementation of this act!++++++++++++++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, Paul Fellows 4220 Dayton Ave NSeattle, WA 98103
↓
No attachments
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, George Norris 358 W Hemlock StSequim, WA 98382
↓
No attachments
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, Kassandra Ruprecht 11812 134th Ave NWGig Harbor, WA 98329
↓
No attachments
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 Kaye 6915 Holeman AveBlaine, WA 98230
↓
No attachments
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 Snyder 5904 53rd St Ct WUniversity Place, WA 98467
↓
No attachments
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, Tom Harding 3308 E 11th AveSpokane, WA 99202
↓
No attachments
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, Erik LaRue 17598 Maiben RdBurlington, WA 98233
↓
No attachments
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, Cornelia Teed 1201 13th StBellingham, WA 98225
↓
No attachments
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, John Macdonald 136 3rd Ave NEdmonds, WA 98020
↓
No attachments
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, Karen Fortier 28129 Florence Acres RdMonroe, WA 98272
↓
No attachments
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, Marjorie Millner 1107 NW 137th StVancouver, WA 98685
↓
No attachments
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, MaryJo Wilkins 315 W 50th AveKennewick, WA 99337
↓
No attachments
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 Bates 6821 44th Ave NESeattle, WA 98115
↓
No attachments
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, Gill Fahrenwald 2323 9th Ave SWOlympia, WA 98502
↓
No attachments
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, Amy Mower 7392 Mt Baker HwyMaple Falls, WA 98266
↓
No attachments
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 STARBUCK 1126 Grand AveSeattle, WA 98122
↓
No attachments
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, Jane Leavitt 3002 Cascadia Ave SSeattle, WA 98144
↓
No attachments
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 Feit 2906 Jackman StPort Townsend, WA 98368
↓
No attachments
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, Glenn Phillips 1711 23rd Ave SSeattle, WA 98144
↓
No attachments
Dear Ms. Erin Torrone,Thank you for the opportunity to make a 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
↓
No attachments
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, STEPHANIE BELL 21057 42nd Ave SSeatac, WA 98198
↓
No attachments
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, Yvonne Brandon 5415 159th Pl NERedmond, WA 98052
↓
No attachments
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, Kristen Severns 777 SW 19th CtOak Harbor, WA 98277
↓
No attachments
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, Gloria McClintock 1411 Northview CtMount Vernon, WA 98274
↓
No attachments
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, David Breed 7510 Happy Hollow RdStanwood, WA 98292
↓
No attachments
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, Cathy Erntson 3129 La Linda Ct SEPort Orchard, WA 98366
↓
No attachments
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, Jared Howe 4107 Martin Luther King Jr Way SSeattle, WA 98108
↓
No attachments
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, Joanna Grist 5206 Palatine Ave NSeattle, WA 98103
↓
No attachments
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, lisa mccrummen 537 N 83rd StSeattle, WA 98103
↓
No attachments
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, Daniel Henling 1412 NW 61st StSeattle, WA 98107
↓
No attachments
[
Previous Page
/
Next Page
]