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, Kelly Keefer 5203 66th Ave Ct WTacoma, WA 98467
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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 Sellers 3609 NW Knapp LnCamas, WA 98607
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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 Habib 555 5th Ave WKirkland, WA 98033
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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, Heather Murawski 17929 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 to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia, and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria for air pollutants. Ecology should adjust the application of the following indicators, including adding indicators so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities that meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities that meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities that meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Matthew Boguske 8500 148th Ave NERedmond, WA 98052
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Scott Bishop 1710 Giles 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, Klaudia Englund 7630 Cypress WayAnacortes, WA 98221
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Lucy Ostrander 11431 Miller Rd NEBainbridge 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, Shary B 1950 Alaskan WaySeattle, 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, LUCINDA BROUWER 16518 SE 39th StVancouver, 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, Linda Wasserman 1510 N Steele StTacoma, WA 98406
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Walter Hunner 55203 Bay Area DrElectric City, WA 99123
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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, Walter Hunner 55203 Bay Area DrElectric City, WA 99123
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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, Walter Hunner 55203 Bay Area DrElectric City, WA 99123
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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, Walter Hunner 55203 Bay Area DrElectric City, WA 99123
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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, Amy Kiba 13402 NW 54th AveVancouver, WA 98685
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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, Lauren Mendez 1230 32nd St SEAuburn, WA 98002
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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.My husband recently died as a result of a very bad lung condition in which every breath was a burden. I witnessed first hand what pollution and poor air quality does to our quality of life.Thank you for your consideration.Regards, Gloria McClintock 1411 Northview CtMount Vernon, WA 98274
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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 Brant 310 Willow 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, Carol Price 1599 NW Lassie WayPoulsbo, 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, Carolee Jones 12141 SE 21st StBellevue, WA 98005
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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 McGunagle 1727 E Olympic 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, Tamar Lowell 2241 Thomas 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, Peter Mastenbroek 12323 NE 97th StKirkland, WA 98033
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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, Victoria Urias 14001 35th 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, Judith Hance 7300 47th Ave NESeattle, WA 98115
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Emily Van Alyne 6749 Whitestone StWest Richland, WA 99353
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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, Carina Hussing 9206 26th 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, Dan Snyder 5904 53rd St Ct WUniversity Place, WA 98467
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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 DuBOIS 5020 N 18th StTacoma, WA 98406
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, rita h 4444 6th Ave SELacey, WA 98503
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Jennifer Larsen 1818 23rd 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, Linda Wright 2821 2nd AveSeattle, WA 98121
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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, Elena Rumiantseva 3807 West Lake Sammamish Pkwy NERedmond, WA 98052
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Betty Barats 1710 Donovan AveBellingham, WA 98225
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, James Feit 2906 Jackman 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, Keith Cowan 3709 SW Trenton StSeattle, WA 98126
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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, Amy Mower 7392 Mt Baker HwyMaple Falls, WA 98266
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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, Jim Roberts 629 Kirkland WayKirkland, WA 98033
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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, Darlene Baker 22016 SE 28th StSammamish, 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, Paul Ferrari 7822 189th Pl SWEdmonds, WA 98026
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Matthew White 3661 Briarwood Dr SEPort Orchard, WA 98366
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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, Felicity Devlin 2417 N Washington StTacoma, WA 98406
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, John Thompson 4953 S Spinnaker DrFreeland, WA 98249
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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, STEPHANIE BELL 21057 42nd Ave SSeatac, WA 98198
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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, Coleman Byrnes PO Box 3231Port Angeles, WA 98362
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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, Danielle Rowland 1654 153rd Ave SEBellevue, WA 98007
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Tina Brown 5526 Sugarloaf StAnacortes, WA 98221
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Lynn Rabenstein 201 N Section StBurlington, 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, Nicholas Heyer 5102 S Adams 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, John Samaras 10342 Ravenna 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, James Williams 9614 50th Pl WMukilteo, WA 98275
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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, Randall Daugherty 1405 W 6th StAberdeen, WA 98520
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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 Whitesell 816 Plymouth St 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, Penelope Johansen 715 W Broadway AveMontesano, WA 98563
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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, Patrick Hickey 1230 4th StBremerton, WA 98337
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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, Michelle Trosper 12219 NE 180th StBattle Ground, WA 98604
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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 Riordan 1925 Weaver RdSnohomish, 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, d robinson 1 River StCurlew, WA 99118
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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 Osmun 2726 NW Valley StCamas, WA 98607
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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, Cornelia Teed 1201 13th 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, mia heavyrunner 9540 SE Glendale StPort Orchard, WA 98366
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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, Delmar Fadden 5011 298th Ave SEPreston, WA 98050
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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, Cathryn Chudy 1506 E 29th StVancouver, WA 98663
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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 Church 6402 1st St Ct NETacoma, WA 98422
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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 Fortier 28129 Florence Acres RdMonroe, 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, Saab Lofton 619 3rd 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, Seth Rolland 1039 Jackson StPort Townsend, WA 98368
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Kathy Radford 55 Williams Ave SRenton, WA 98057
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Deborah Kaye 6915 Holeman AveBlaine, WA 98230
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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, Laureen France 4007 32nd 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, Denise Farrer 4309 34th 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, Jo Harvey 204 Eastgate Ave NPacific, WA 98047
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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, r wood 4326 University Way NESeattle, WA 98105
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Dennis Ledden 183 Webb 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, Joel Hencken 8811 51st St WTacoma, WA 98467
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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 Peters. 11008 NE 68th StKirkland, WA 98033
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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 Macdonald 136 3rd Ave NEdmonds, WA 98020
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, John Guros 308 10th St SMontesano, WA 98563
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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, Teresa Dix 3124 Dakota DrMount Vernon, WA 98274
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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 Shepard 85 Ocosta Third StAberdeen, WA 98520
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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, Julia Kladnik 15 5th StTonasket, WA 98855
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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 Brogan 3621 E 11th AveSpokane, WA 99202
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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, melodie martin 2339 11th 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, James Mulcare 1110 Benjamin StClarkston, WA 99403
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Kathleen Allen 5900 37th Ave SSeattle, WA 98118
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Brandie Deal 301 225th St SWBothell, WA 98021
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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, Cheryl Biale 7711 Greenridge St SWOlympia, WA 98512
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Dear Ms. Erin Torrone,Thank you for the opportunity to provide public comment on the proposed process to identify overburdened communities highly impacted by air pollution. The Climate Commitment Act’s directive to improve air quality in overburdened...↓ communities is critical to ensuring that the law functions as intended to reduce environmental health disparities. I appreciate Ecology’s ongoing commitment to incorporating public input and developing a comprehensive framework. Identifying specific communities is a necessary step to ensure the focused and strategic allocation of resources. However, the proposed process narrows eligibility in ways that may unintentionally and arbitrarily screen out vulnerable communities. The application of indicators in the proposed process also treats some similarly impacted communities very differently. I urge Ecology to refine both the approach and the process to ensure the equitable treatment of overburdened communities highly impacted by air pollution, specifically: APPROACH- Better document how and why specific indicators are being applied. At this time, the process appears too complex, and the application of the proposed indicators narrows the eligibility of communities in ways that may be inequitable and somewhat arbitrary. - Go beyond the binary approach to identifying communities that are either “overburdened” or not and better reflect the gradation of pollution impact on communities. To do this, Ecology should explore a tiered approach to account for built-in uncertainties and margins of error, in order to ensure that similarly impacted communities are treated equitably.- Incorporate an adaptive management approach into the final process, including a plan to evaluate outcomes, review communities, and revise the process at regular intervals.PROCESS- Community Indicators:1. Explicitly incorporate Ecology’s existing obligation to proactively and meaningfully engage and consult with federally recognized tribes, with sufficient time and information made available.2. Environmental Health Disparities (EHD) Map and EJScreen Demographic Index: Consider using a lower rank on the EHD Map and a lower percentile on the EJScreen Demographic Index as thresholds for these indicators, in order to account for built-in uncertainties in each tool and avoid unintentionally screening out communities that may be experiencing similar levels of vulnerability and exposure to pollution. - Air Pollution Indicators:1. Ecology should build in a corrective step for the ‘Elevated Level of Criteria Air Pollution’ indicator that accounts for margins of error and gaps in existing monitoring and modeling data. For example, communities just below the PM2.5 threshold may experience similar levels of criteria air pollution as communities just over the threshold, but be treated very differently under the proposed process. Examples of places just below this threshold include Confederated Tribes of Colville Reservation lands, Spokane Tribe lands, and neighborhoods in Lacey, Olympia and Vancouver.2. The proposed application of indicators appears to undervalue several source categories of criteria air pollution. Ecology should adjust the application of the following indicators, including adding indicators, so that overburdened communities highly impacted by air pollution are not left behind:2.a. Proximity to Stationary Sources: The proposed process leaves out some communities heavily impacted by stationary sources of criteria pollutants. There are places in the 99th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include Lummi Nation lands, Swinomish Tribe lands, Samish Nation lands, the Cherry Point Industrial District region, and the Longview-Kelso area. It appears that communities in these areas are being screened out because they don’t meet the ‘Elevated Level of Criteria Pollution” indicator. However, the threshold value for this indicator is a measure of exposure to criteria pollutants. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.b. Wildfire Smoke Exposure: Tribal lands and communities highly impacted by wildfire smoke are largely left out under the proposed process. There are places at or above the 95th percentile for this category that get screened out of the draft screening map, even though they also meet the proposed Community Indicator thresholds. Examples include the city of Wenatchee, parts of the Chelan region, Spokane Tribe lands, Kalispel Tribe lands, and Confederated Tribes of the Colville Reservation lands. Similar to the ‘Proximity to Stationary Sources’ indicator, the threshold value for this indicator is a measure of exposure to PM2.5, a criteria pollutant. Communities who meet this threshold should not be screened out, or have to meet multiple criteria pollutant thresholds. 2.c. Vehicle Pollution: Vehicles are the largest source of criteria air pollution in Washington, but the proposed process may undervalue pollution from busy roadways and transportation hubs. Communities highly impacted by vehicle pollution - who also meet the Community Indicator and Elevated Level of Criteria Pollution thresholds - may get screened out by the proposed process flow.Communities highly impacted by vehicle pollution are likely included via the use of the Environmental Health Disparities Map and/or the ‘Elevated Level of Criteria Air Pollution’ indicator. However, these communities may be removed from consideration if they don’t meet a threshold for an indicator in the second tier of Air Pollution Indicators.Because there are no discrete indicators for vehicle pollution in the proposed process, it is difficult to know if any communities are being screened out for this reason. However, traffic-impacted communities who meet the thresholds for a Community Indicator and the ‘Elevated Level of Criteria Pollution’ indicator should not be at risk of being screened out. For this reason, Ecology should add one or more specific indicators for vehicle pollution.Thank you for your consideration.Regards, Jared Howe 4107 Martin Luther King Jr Way SSeattle, WA 98108
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My name is Janet Hays, My comment and hope is that City of Kenmore will be considered and chosen for current and future studies, resulting in a course correction. We could be an example instead of being unhealthy, weary and afraid. We live and breath...↓e in a topographic basin/bowl. On the bottom of the bowl is Lake Washington with an Industrial Park, which houses the Asphalt/cement plant with emmissions Monday-Friday 7AM-5PM some weekends. Within 30 feet north is the Public Burke Gilman trail used by bikers and pedestrians from Bellevue to Seattle. 10 to 20 feet north of the trail is a busy State Highway 522, sidewalks on both sides. These sidewalks put the pedestrians that traverse it at lung level with the asphalt plume(the stack is only 28 feet high). Across the highway is our City of Kenmore downtown the Library,the Post office, Kenmore Town Square, The City Hall, with zoning changing allowing an affordable living high density in the works plans directly across the 522.Highway and the stack.We are being told that the only thing comin out of the stacks is steam. We and I am speaking for my community, present public comments pictures, documents, we have walked neighborhoods we are not heard. We fought hard for both of Gerry Pollets HB's in Olympia. We need testing done for VOC's particulates and more.
Thank you, I will gladly share pictures and documents,
Janet Hays
Below is public comment to PSCAA re Cadman Asphalt facility in Kenmore
I am writing my comment as a resident of Kenmore living 700 feet from the Asphalt Plant's stack, since 2004. NE 181st is is 600 feet from the stack. The first 6 pictures were taken today the stack was assembled in August 2021. The second 6 pics are from inception until August 2021 The plant and the stack with emissions is literally under my nose.
This Asphalt Plant began as Knowle's Construction Company(plant manager Sterling Johnson), Sterling Asphalt Inc, Cemex, and is currently Cadman.
I do not support the draft permit as is. The draft permit does not address the health and safety of Lake Washington, fish and wildlife, or the community, and people that drive, bike, walk, shop, stop or are just passing through Kenmore.
I have a number of concerns about the application and permit process including the the use of weather data from Paine Field being used as "similar" to the weather conditions at the asphalt plant being inappropriate.
As has been noted in meetings and likely in a number of comments, there are numerous concerns with the modeling done on the Cadman asphalt plant located in Kenmore, WA, to support the application for the plant's new or revised air permit. The purpose here is to focus on a couple of the issues of concern and the outcomes of continued operation with an increase in the permitted annual production from the plant.
When looking at the stack sampling data used in the model, the testing was done at production rates substantially less than the maximum production rate requested in the permit. The outcome of this is that pollutants which were claimed to be within regulatory defined safe limits, may well not be in real world conditions. If more accurate conditions for the worst-case scenario would have been used the modeling results may well have substantiated the need for additional data collection and review.
The weather data collected for the site is also seriously lacking due to not being collected from the area of the plant itself, or anywhere that could be considered suitably identical to the plant area conditions. Data was collected from Paine Field, over 10 miles from the plant, at considerably higher elevation than the plant, and within topography that doesn't match that of the plant vicinity. In addition, Paine field has been modified by construction to be very flat, and without any contour roughness, including tall buildings or trees over a long linear distance. This is due not only to the construction of the taxiways and runways themselves, but the required operational and safety zone conditions as required by the relevant FAA regulations and circulars, such as FAA Circular 150.
As a result, the weather data collected from Paine Field is not a realistic substitute for modelling purposes for the plant site, and deviates in ways that could underestimate the impacts from plant pollutants released to the air.
Also, there is great concern in the community that the basic conditions of the air discharge of pollutants from this facility are very much different than from most industrial air discharges. The plant is virtually at the same level as Lake Washington. The stack height is only 26 feet. The adjoining main road State Route 522 is higher than the plant, and the majority of the nearby residents live at higher elevations above the plant, including those residents closest to the plant. As a result, many residents and nearby workers are subject to the plant pollution in nearfield conditions where little dispersion has taken place. This concern is magnified when there are inversion conditions known to occur in the plant vicinity where the pollution is being trapped within the partial bowl shape of the surrounding area, with the pollution generated at the bottom of the bowl. This leads to a concern that with the variance in conditions from the area weather data was collected from as compared to the area pollutants are being released from the model as constructed could significantly underestimate the impacts of air pollution from the plant on the surround population.
At a minimum, the permit should restrict the annual production rate to be consistent with (90% to 100%) of the production rates during stack sampling for the data used in the model. Alternatively, agency review of the model should adjust the pollutant results used as inputs and adjust them to reflect the production rate as requested in the application, including determining is the resulting corrected values require additional data collection to appropriately meet regulatory requirements, both as to regulatory review and decision making, and related permit conditions.
The Puget Sound Clean Air Agency should take these steps to meet its responsibility to adequately protect air quality, including the health and wellbeing of the surrounding population.
Also, the position and elevation of the present population as compared to the plant stack height must be carefully considered, including during inversion, or air stagnation conditions known to occur in this area.
Thank you,
Jane Hays
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Thank you for providing this opportunity to comment on the Department of Ecology's process for identifying overburdened communities in Washington State that will receive additional monitoring and funding under the Climate Commitment Act (CCA).
Washing...↓ton Physicians for Social Responsibility (WPSR) is an organization of health professionals that is working to engage Washingtonians to create a healthy, just, and sustainable world. Our members include physicians from multiple specialties, registered nurses, public health professionals, and other professionals in the healthcare sector who care about stopping climate change and the health impacts that it causes.
We would like to provide comments on the current draft plan for identifying overburdened communities, including concerns regarding the identified indicators, reasoning for chosen thresholds, and suggested improvements that would make this process equitable, accessible, and inclusive of some of our most overburdened communities now and in the future.
We commend the Department of Ecology's efforts to identify multiple health burden's to overburdened communities. However, we are concerned by the exclusionary layered approach that will screen out many communities that could be at risk of increased air pollution under the CCA, with qualifying groups needing to have both a community indicator and an air pollution indicator. We recommend eliminating the multi-factor requirement for qualifying as an overburdened community, in order to allow the program to be more inclusive to vulnerable communities that may experience health harms from poor air quality. We also recommend:
lowering the threshold for inclusion under these indicators, and
considering the importance of cumulative health impacts experienced by at-risk populations.
WPSR recognizes the efforts that Ecology has made to include the voices of community members that will most be most impacted by the definition of overburdened communities. However, there remain concerns about the lack of accessibility to this process faced by many community members. We recommend utilizing community engagement strategies from the Healthy Environment for All act to be more effectively inclusive of community members. This includes incorporating hard-to-access perspectives (due to language barriers, work schedules, etc.) through building on existing engagement efforts.
Finally, we are concerned about the potential for the definition of boundaries to exclude truly overburdened communities. Air pollution does not follow the strict boundaries of neighborhoods or cities, and we strongly recommend that the process of defining the boundaries of overburdened communities follow a gradient approach. We also recommend including a process for overburdened communities to apply for inclusion, with a special consideration provision for those with relevant lived experience
Thank you for the opportunity to provide comment and for your consideration.
Washington Physicians for Social Responsibility
Mark Vossler, MD, President
Max Savishinsky, Executive Director
Riley Lynch, Climate & Health Program Manager
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Ecology should take a preventative, precautionary approach when it comes to air monitoring, rather than the exclusionary approach offered:
the draft air pollution and community indicators are overly narrow and restrictive, insist on the satisfaction o...↓f an overly limited multi-factor test, do so without supplying adequate justification of the thresholds established, and exclude vulnerable communities and at-risk populations;
the department does not provide an alternative pathway to allow consideration of, or identification of, communities who wish to be considered as overburdened for the purposes of Section 3; and
despite its sound efforts so far, the department's process for seeking input is still not accessible to the most vulnerable populations and its proposal is not readily understandable to most people.
To improve the department's draft criteria, we recommend that the department ensure frontline communities can be monitored:
broaden the default pathway to identify overburdened communities by:
eliminating the multi-factor requirement that an overburdened community have both an elevated level of criteria air pollutants and exposure to a second category of pollutants;
lowering the thresholds for non-criteria pollutant exposure, and explaining how the selected thresholds correlate to health factors or desired outcomes; and
accounting for the environmental harms and cumulative health impacts experienced by vulnerable communities and at-risk populations;
create an alternative pathway to identify overburdened communities—in addition to the default pathway—one that permits a community to apply or petition for consideration due to its lived experience with pollution, or due to special or unforeseen circumstances;
expand its efforts to reach affected persons in potentially overburdened communities to incorporate hard-to-reach perspectives and input that could affect decisions about identifying an overburdened community, and its boundaries; and
build on existing community engagement efforts across programs and agencies and align its Section 3 implementation with community engagement principles and proposals from the Healthy Environment for All ("HEAL") Act.
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Hello,
As a concerned citizen who wants to support her neighbors, I am writing to implore you to reconsider how you think about and define the communities in question.
Ecology should take a preventative, precautionary approach when it comes to air mon...↓itoring, rather than the exclusionary approach offered because the draft air pollution and community indicators are overly narrow and restrictive, insist on the satisfaction of an overly limited multi-factor test, do so without supplying adequate justification of the thresholds established, and exclude vulnerable communities and at-risk populations.
Also, the department does not provide an alternative pathway to allow consideration of, or identification of, communities who wish to be considered as overburdened for the purposes of Section 3.
And despite its sound efforts so far, the department's process for seeking input is still not accessible to the most vulnerable populations and its proposal is not readily understandable to most people.
To improve the department's draft criteria, we recommend that the department ensure frontline communities can be monitored:
- broaden the default pathway to identify overburdened communities by:
- eliminating the multi-factor requirement that an overburdened community have both an elevated level of criteria air pollutants and exposure to a second category of pollutants;
lowering the thresholds for non-criteria pollutant exposure, and explaining how the selected thresholds correlate to health factors or desired outcomes; and
accounting for the environmental harms and cumulative health impacts experienced by vulnerable communities and at-risk populations;
- create an alternative pathway to identify overburdened communities—in addition to the default pathway—one that permits a community to apply or petition for consideration due to its lived experience with pollution, or due to special or unforeseen circumstances;
- expand its efforts to reach affected persons in potentially overburdened communities to incorporate hard-to-reach perspectives and input that could affect decisions about identifying an overburdened community, and its boundaries; and
- build on existing community engagement efforts across programs and agencies and align its Section 3 implementation with community engagement principles and proposals from the Healthy Environment for All ("HEAL") Act.
Thank you,
Mandy (Amanda) Lozano
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I applaud your dedication for doing good work. But you are outsiders assessing the needs from your perspective which results in leaving people off of your list of overburdened communities. You are not getting access to the most vulnerable population...↓s. When you do talk there is a communications gap so your proposal is not readily understandable to most people. Instead use community engagement principles and proposals from the Healthy Environment for All ("HEAL") Act to work with insider community engagement efforts. Based on their perspective, residents of overburdened communities must be given the opportunity to apply or petition for consideration due to their lived experience with pollution, or due to special or unforeseen circumstances. It is be better to be safe than sorry so err on the side of caution and include more communities on the initial list of overburdened communities. I feel you are excluding vulnerable communities and at-risk populations by using community indicators that are overly narrow and restrictive due to an overly limited multi-factor test. I support the many other recommendations Front and Centered has presented to you. Please widen your scope to identify all the vulnerable populations in overburdened communities so they can enjoy improved air quality. Thank you for your work.
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Thank you for this opportunity to get assistance in our cause.
We would like to request Kenmore, Washington's shoreline be provided air quality monitoring due to having heavy industry (asphalt from grandfathered facility) and associated highway traffi...↓c in a downtown area near parks, Burke Gilman Trail, commercial buildings, residences that include vulnerable populations.
We have been fighting for environmental justice for over a decade.
Please visit our website at perkinkenmore.org
Please call me for more information. We are presently working with academics and civic leaders, but we need the data that air monitoring would provide to effectively make the changes necessary to protect the health of residents of North Lake Washington and those who use the area for recreational purposes.
Thank you very much for considering our request.
Sincerely,
Elizabeth Mooney
President of People for an Environmentally Responsible Kenmore
perkinkenmore.org
425-877-3602
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I'm writing in support of including a more inclusive list of overburdened communities and erring on the side of caution moving forward, as impacts are likely to increase and clarify in future. Any decisions should be founded in scientific and evidenc...↓e based justification when solidifying the framework, with clear steps, a non-burdensome vetting process that doesn't overload already burdened and struggling communities with the lift, and which takes steps to seek out those communities usually left out and marginalized by previous systems or efforts. Thank you for your time and consideration, and thank you for your work and effort on air quality and climate actions.
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the draft air pollution and community indicators are overly narrow and restrictive, insist on the satisfaction of an overly limited multi-factor test, do so without supplying adequate justification of the thresholds established, and exclude vulnerabl...↓e communities and at-risk populations;
the department does not provide an alternative pathway to allow consideration of, or identification of, communities who wish to be considered as overburdened for the purposes of Section 3; and
despite its sound efforts so far, the department's process for seeking input is still not accessible to the most vulnerable populations and its proposal is not readily understandable to most people.
To improve the department's draft criteria, we recommend that the department ensure frontline communities can be monitored:
broaden the default pathway to identify overburdened communities by:
eliminating the multi-factor requirement that an overburdened community have both an elevated level of criteria air pollutants and exposure to a second category of pollutants;
lowering the thresholds for non-criteria pollutant exposure, and explaining how the selected thresholds correlate to health factors or desired outcomes; and
accounting for the environmental harms and cumulative health impacts experienced by vulnerable communities and at-risk populations;
create an alternative pathway to identify overburdened communities—in addition to the default pathway—one that permits a community to apply or petition for consideration due to its lived experience with pollution, or due to special or unforeseen circumstances;
expand its efforts to reach affected persons in potentially overburdened communities to incorporate hard-to-reach perspectives and input that could affect decisions about identifying an overburdened community, and its boundaries; and
build on existing community engagement efforts across programs and agencies and align its Section 3 implementation with community engagement principles and proposals from the Healthy Environment for All ("HEAL") Act.
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I am writing to ask that you improve the department's draft criteria, and recommend that the department eliminate the multi-factor requirement that an overburdened community have both an elevated level of criteria air pollutants and exposure to a sec...↓ond category of pollutants. I also ask that you expand the the currently proposed method of defining overburdened communities. There are many more suggestions which have been presented to you by the Front and Centered organization. I wholeheartedly support their recommendations as you develop how to identify, include, and improve marginalized community air quality.
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