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...↓
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Ronlyn Schwartz 3648 Davie LnLangley, WA 98260
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Pamela Davies 1917 W Montgomery AveSpokane, WA 99205
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your time and consideration of these comments.Regards, Dorothy Jordan 1407 Abbot RdLynden, WA 98264
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Hannah Liu 3008 NE 141st StVancouver, WA 98686
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Daniel Aga 17303 E 3rd AveSpokane Valley, WA 99016
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Andrea Speed 1618 154th St ETacoma, WA 98445
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Dear Ms. Erin Torrone,As an environmentally motivated voter, I 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 directi...↓ve to improve air quality in overburdened communities is critical to ensuring that the law functions as intended to reduce disparities in environmental health. 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, Linda Carroll 215 W Waverly PlSpokane, WA 99205
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, james hipp 609 Rosette CtBellingham, WA 98226
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Steve Shapiro 2511 30th Ave SSeattle, WA 98144
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. 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, Caryl Gates 13215 Linden Ave NSeattle, WA 98133
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Nancy White 13311 E Forrest AveSpokane Valley, WA 99216
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Janet Hedgepath 505 NW 45th StVancouver, WA 98660
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Dan Rogers 3331 H StWashougal, WA 98671
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Dave Baine 32116 42nd Pl SWFederal Way, WA 98023
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Paul McMurray 16521 SE Auburn-Black Diamond RdAuburn, WA 98092
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, John Simanton 1909 W 9th AveSpokane, WA 99204
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. We need to take better care of what is left of our environment, for people, wildlife, marine life, and plant life.Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, priscilla martinez 35411 SE English StSnoqualmie, WA 98065
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Marian Wineman 3611 45th Ave WSeattle, WA 98199
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Sharon Anderson 1920 NW Mulholland BlvdPoulsbo, WA 98370
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Aminah Lamb-McMurray 14610 Cedar Grove Rd SEIssaquah, WA 98027
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Joyce Grajczyk 12026 SE 216th StKent, WA 98031
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Lynn DeBroeck 15932 88th St SESnohomish, WA 98290
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Kassandra Ruprecht 11812 134th Ave NWGig Harbor, WA 98329
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution.The Climate Commitment Act’s directive to improve air quality in overburdened ...↓communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently.I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Derek Benedict 709 212th Pl SWLynnwood, WA 98036
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, CRAIG SWANSON 16220 SE 28th PlBellevue, WA 98008
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Jean Pauley 414 Malden Ave ESeattle, WA 98112
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Noah Ehler 32115 NE 110th CtCarnation, WA 98014
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- 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, Virginia Davis 17721 NE 156th StWoodinville, WA 98072
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Diane Falk 1010 State AveMarysville, WA 98270
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Sara Burgess 333 34th Ave ESeattle, WA 98112
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Patricia Doran 430 E Maple StSequim, WA 98382
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Laura Huddlestone 5222 18th Ave SWSeattle, WA 98106
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, George Summers 1311 S Massachusetts StSeattle, WA 98144
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. 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, Lynne Bannerman 1513 Woodard Ct NWOlympia, WA 98502
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Richard Gordon 205 N Main AveRidgefield, WA 98642
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Jennifer England 4730 Lost Creek LnBellingham, WA 98229
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Dianna MacLeod 3513 Wildes RdClinton, WA 98236
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Lynn Lichtenberg 501 Colby AveEverett, WA 98201
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, LuAnne Swainson 2601 N Barker RdSpokane Valley, WA 99027
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, jesse gillman 15811 SE 43rd PlBellevue, WA 98006
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, William Golding 5002 Park Ave. STacoma, WA 98408
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Dianne Hurst 4753 Orcas St NELacey, WA 98516
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Jennifer Valentine 313 1st AveSeattle, WA 98104
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Phyllis Hatfield 2239 Fairview Ave ESeattle, WA 98102
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, MaryJo Fontenot 1142 E Isaacs AveWalla Walla, WA 99362
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Lorraine Johnson 13716 Lake City Way NESeattle, WA 98125
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Mike Betz 2630 Franklin StBellingham, WA 98225
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Lori Stefano 22440 Vale Ct SEYelm, WA 98597
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Gill Fahrenwald 2323 9th Ave SWOlympia, WA 98502
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Barbara Blackwood 11916 E 25th AveSpokane Valley, WA 99206
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Kari Hailey 2115 244th Ave SEIssaquah, WA 98075
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Kimberly Teraberry 532 18th Ave ESeattle, WA 98112
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Vicki Elledge 15015 223rd Ave NEWoodinville, WA 98077
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Karen Curry 103 NW Lancer LnPullman, WA 99163
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, rein attemann 316 NW 86th StSeattle, WA 98117
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Charles Ellenberger 23633 112th Ave SEKent, WA 98031
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Javier Ortiz 7326 14th Ave NWSeattle, WA 98117
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Mary Ferm 465 Ambrose Ln NWBainbridge Island, WA 98110
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, William Sneiderwine 14901 SE Sunpark DrVancouver, WA 98683
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Susan Vossler 12945 64th Ave NEKirkland, WA 98034
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Lloyd Johnston 13421 26th Ave NESeattle, WA 98125
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Bob Schuessler 4249 S Kenny StSeattle, WA 98118
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Abigail Houghton 4305 S Webster StSeattle, WA 98118
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Candice Cassato 6417 54th Ave NWOlympia, WA 98502
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Rebecca Brown 2224 E South Riverton AveSpokane, WA 99207
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, J. Woodworth 27011 E Eastland DrNewman Lake, WA 99025
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Alfred Ferraris 1340 Corona StPort Townsend, WA 98368
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, David Arntson 1615 208th St SEBothell, WA 98012
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Dear Ms. Erin Torrone,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 commitme...↓nt to incorporating public input and developing comprehensive framework. Identifying specific communities is necessary to ensure focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. Application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both approach and process to ensure 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 application of proposed indicators narrows eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond 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 tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate adaptive management approach into the final process, including 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 lower rank on EHD Map and lower percentile on 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 include corrective step for ‘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 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. Proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust 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: 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 proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet ‘Elevated Level of Criteria Pollution” indicator. However, threshold value for this indicator is 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 proposed process. There are places at or above 95th percentile for this category that get screened out of draft screening map, even though they also meet proposed Community Indicator thresholds. Examples include city of Wenatchee, parts of Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to ‘Proximity to Stationary Sources’ indicator, threshold value for this indicator is measure of exposure to PM2.5, 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 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 proposed process flow.Communities highly impacted by vehicle pollution are likely included via use of 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 threshold for an indicator in 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 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, Den Wichar 711 W 25th StVancouver, WA 98660
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Brenda Michaels 1240 W Sims WayPort Townsend, WA 98368
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Richard Johnson 6 Overlake CtBellingham, WA 98229
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Keith Brumwell 13249 1st Ave SWBurien, WA 98146
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Rebecca Rose 20119 113th St SESnohomish, WA 98290
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Tina Ethridge 1308 Seneca StSeattle, WA 98101
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is SPECIFICALLY DESIGNED TO REPAIR SOCIALLY INEXCUSABLE PAST RACE, POOR, and ETHNIC ABUSE-BIASED, AND PURE GREED-BASED POLITICALLY CORRUPT FRAUD and is critical to ensuring that the CURRENT 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, Patrick Conn 22018 126th Ct SEKent, WA 98031
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Edward Kaeufer 8432 Catalina DrBlaine, WA 98230
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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
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Marilee Henry 14042 97th Ave NEKirkland, WA 98034
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Julie Goebel 1900 Alabama StBellingham, WA 98229
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Abbie Abramovich 1616 Madrona DrSeattle, WA 98122
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, deb kalahan 4845 NE 5th StRenton, WA 98059
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Liz Nedeff 18332 W Spring Lake Dr SERenton, WA 98058
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Daniel Henling 1412 NW 61st StSeattle, WA 98107
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Michael Saunders 1311 8th Ave SWOlympia, WA 98502
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Debbie Spear 20928 133rd St SEMonroe, WA 98272
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, J K 15120 Starr Rd SEOlalla, WA 98359
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Perry Bryant 1400 Hubbell PlSeattle, WA 98101
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Millie Magner 4228 28th Pl WSeattle, WA 98199
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Judith Cohen 1608 E Republican StSeattle, WA 98112
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Norman Baker 3789 Lost Mountain RdSequim, WA 98382
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Ruth King 6945 Mill Ct SEOlympia, WA 98503
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Fay Payton 814 SE 12th StCollege Place, WA 99324
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Erik LaRue 17598 Maiben RdBurlington, WA 98233
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Nance Nicholls 208 Main StDavenport, WA 99122
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Jane Leavitt 3002 Cascadia Ave SSeattle, WA 98144
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. 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, Marquam Krantz 5698 NE Wild Cherry LnBainbridge Island, WA 98110
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Grace Padelford 11807 100th Ave NEKirkland, WA 98034
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, JOHN LAMBERT 4440 McKinley AveCarnation, WA 98014
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Michael Garten 3420 Burke Ave NSeattle, WA 98103
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