Comment - 21819 - Patrick Messac - Bay Area Air District Community Advisory Council representative

Thank you for the opportunity to provide feedback on the draft CalEnviroScreen 5.0 mapping tool. I appreciate the effort to increase usability and transparency. I offer the following recommendations to improve clarity, functionality, and environmental justice impact. 1. Do Not Bury Polluting Facilities in the Interface Currently, to view facility icons, a user must: Click “Pollution Burden”, Select an indicator, Expand “Pollution Burden Indicators”, Scroll to locate facility types, Select one type at a time. This multi-step process makes polluting facilities functionally buried within the tool. For community users, especially those unfamiliar with regulatory categories, this reduces accessibility and obscures accountability. Recommendation: (1) Make “Polluting Facilities” or “Sources of Pollution” a default visible layer category. (2) Elevate facility layers (e.g., Small Air Toxic Sites, Solid Waste Sites, Hazardous Waste, Cleanup Sites) so they are immediately discoverable without multiple clicks. (3) Use plain language such as “Facilities and Sites Causing Pollution” rather than technical-only labels. Observable improvement: A user opening the tool should immediately see that polluting facilities are available and easily selectable without navigating multiple nested menus. 2. Allow Multiple Facility Layers to Be Selected Simultaneously At present, only one facility type can be viewed at a time. This prevents users from seeing cumulative impacts from multiple pollution sources (e.g., Small Air Toxic Sites + Solid Waste Sites + Hazardous Waste facilities in the same census tract). This design choice unintentionally fragments pollution sources and obscures cumulative burden. Recommendation: (1) Allow users to select multiple facility types simultaneously. (2) Include a “Select All Facility Types” toggle. (3) Provide a legend that clearly distinguishes icons when multiple categories are displayed. Observable improvement: A user should be able to visually assess cumulative pollution sources in a community without toggling back and forth between categories. 3. Improve Information Displayed in Facility Pop-Ups There is a significant inconsistency in the level of detail provided across facility types. For example: Cleanup Sites often provide detailed regulatory and status information (available through hyperlink). Small Air Toxic Sites provide minimal information. Some air toxics sites appear to rely on the California Emission Inventory Development and Reporting System (CEIDARS), which does not reflect the full scope of permitting, inspection, violations, or compliance history available from regional air districts. This creates inequities in transparency. Recommendation: For each facility pop-up, include: (1) Permit status and permit number (2) Emission limits and maximum rated capacity (3) Inspection history (dates and type: routine vs. complaint-based) (4) Violations and enforcement actions (5) Reporting requirements (6) Data source attribution (clearly labeled) (7) Direct link to the regional agency database (e.g., air district facility page) Additionally, CEIDARS data should be supplemented with comprehensive regional air district data to ensure accuracy and completeness. Observable improvement: Clicking on a facility should provide meaningful accountability information, not just a name and address. 4. Clarify Data Sources and Methodology (Monitoring vs. Modeling) It is not clear to users: What portion of data is based on direct monitoring vs. modeled emissions, Whether data are self-reported, How frequently data are updated, Whether regional air district data feed directly into the system Recommendation: (1) Add a visible “Data Transparency” section for each indicator explaining: Monitoring vs. modeling basis, Reporting frequency, Responsible agency, Known data gaps Observable improvement: Users should be able to understand how reliable and current the data are without needing to leave the platform. 5. Center Polluters, Not Just Pollution CalEnviroScreen effectively shows what is happening to communities (pollution burden), but it does not always clearly show who is responsible. Environmental justice requires visibility into both exposure and sources. Recommendation: (1) Create a “Source Accountability View” that foregrounds facilities and mobile sources alongside burden metrics. (2) Integrate mobile sources (e.g., major traffic corridors, diesel routes) in a way that can be viewed alongside stationary sources. (3) Consider grouping sources under plain-language categories: Mobile (Highways, Freight Corridors), Stationary (Refineries, Industrial, Auto Body, Crematoria), Waste & Cleanup Observable improvement: The tool should make it easy to connect health burden to specific polluting sources. 6. Small Air Toxic Sites Require Particular Attention Small facilities such as auto body shops, small industrial operations, and other localized emitters often cluster in disadvantaged communities but provide the least detailed information in the tool. Given their cumulative impact, these sites should not be treated as minor or secondary. Recommendation: (1) Expand available information for Small Air Toxic Sites. (2) Ensure these facilities are included in cumulative mapping functionality. (3) Provide context about regulatory oversight and inspection frequency. Closing: CalEnviroScreen is one of the most important environmental justice tools in the country. To maintain its leadership, the platform should: - Make polluters highly visible & readily navigable - Allow cumulative source mapping - Provide comprehensive facility-level accountability data - Clearly disclose data sources and limitations Communities should not have to navigate multiple nested menus to see who is polluting their neighborhood, nor toggle one facility type at a time to understand cumulative burden. Thank you for considering these recommendations.