Comment - 21812 - Wendy Ring MD, MPH

Thanks for continuing to update CalEnviroScreen. I just finished looking at the methodology and the results for our county and wanted to provide this feedback: TRI alone does not give a full picture of air toxic emissions from major emitters. We have 2 power plants in Humboldt county. The most polluting one is a biomass plant which is a federally classified as a Major Source and emits far more criteria pollutants and air toxics than the gas fired plant. These emissions are reported under California Air Toxics Hot Spot law and are visible in CARB's own facility lookup, but they are not in TRI, which only shows toxic emissions from the less polluting natural gas fired plant. The biomass plant's emissions include dioxins, PAHs, and hexavalent chromium, to name a few. Our air district's threshold for health risk assessment for air toxics is a prioritization score of 50. The prioritization score for the biomass plant has repeatedly been over 5,000 with no health risk assessment for over 20 years. The zip code which includes the biomass plant and the valley downwind ranks 83 in CalEnvironScreen for CVD and 93 for LBW infants. This is not the first time I have looked up the biomass facility on TRI and found little or nothing reported. I'm not sure if Humboldt Sawmill Company's absence from TRI is because they're not required to report or because there is no enforcement of reporting requirements, but if TRI leaves out the county's biggest air toxics and criteria polluter, then it isn't a reliable source of data. You chose CEIDARS over TRI as the data source for small toxic emitters. I think you should do the same for major emitters. Thanks, Wendy Ring MD, MPH