Cal/EPA Draft Cumulative Impacts Screening Tool Meeting for Local Government

As reported in the September 28 CSAC Bulletin, the California Environmental Protection Agency (Cal/EPA) has developed a method for evaluating the cumulative impacts of pollution on communities. According to the Public Review Draft the method, referred to as the California Communities Environmental Health Screening Tool (CalEnviroScreen), uses existing environmental, health and socioeconomic data to create a cumulative impacts score for communities across the state. The tool compares areas of the state against other areas, creative a relative ranking. The potential uses of the tool include guidance for grant allocations and prioritizing cleanup and abatement projects to direct resources to the communities with the greatest need. It may also be utilized to prioritize enforcement of environmental laws and inform planning decisions about sustainable economic development investments in heavily impacted communities. 

CSAC, along with other local organizations including the Regional Council of Rural Counties (RCRC) and the League of California Cities are very concerned with the potential misuse and misapplication of the tool. These concerns were expressed by all three organizations at Cal/EPA’s October 2 local government workshop. CSAC also submitted written comments to the Office of Environmental Health Hazard Assessment (OEHHA) noting the following concerns regarding other aspects of the screening tool and the process that led to its development, including the: 

• Lack of outreach to local government during the early development of the screening tool;
• Contradictory statements made in OEHHA documents, including the July 30 memo to the working group and the public review draft, concerning the intended use of the screening tool, particularly with respect to reviews under the California Environmental Quality Act (CEQA);
• Lack of specific guidance on how this tool is intended to be used by local governments in California;
• Potential use of the screening tool scores to form the basis for further regulatory requirements and controls that exceed current Federal, State and local environmental and regulatory requirements;
• Failure of the tool to distinguish between health effects due to socioeconomic factors or other social stressors and those due to chemical/pollution exposure; and,
• Potential for redlining of communities that result in a disincentive to job creation and economic expansion, contrary to the goal of this tool.

CSAC is currently in the process or organizing additional meetings/forums between county officials and Cal/EPA and OEHHA staff regarding CalEnviroScreen, including a presentation at the CSAC Agriculture and Natural Resources Policy Committee at the Annual Meeting. 

Lastly, it is our understanding that OEHHA plans to revise the current draft to reflect comments received to date, and to release the next draft by the end of November or early December. CSAC will continue to keep counties informed of the status of this process.