Comment - 21839 - Cade Cannedy

Hello OEHHA, My name is Cade Cannedy and I work with Climate Resilient Communities, an environmental justice organization that works primarily with frontline communities in southern San Mateo County. Specifically, I work in the Belle Haven neighborhood of Menlo Park, unincorporated North Fair Oaks, East San Bruno, and East Palo Alto. Across the board the 5.0 update seems to remove many frontline bay area communities from qualifying as DACs. The tool systematically undercounts the vulnerability of bay area communities that are undergoing rapid gentrification and displacement. Final CalEnviroscreen scores multiply pollution burden by population characteristics, and in many bay area communities populations are changing very rapidly while pollution exposure has remained relatively stable. This make communities appear less vulnerable, but that is a byproduct of richer, whiter residents replacing working class communities. Additionally, in the Bay area we are uniquely faced with extreme inequality. Census tracts are not granular enough indicators to capture vulnerability. For example, North Fair Oaks shares a census tract with Atherton, the wealthiest community in the United States, yet is composed of low income and working class residents. To prevent this, the tool should be more granular, take into account the rate of change of population characteristics and omit it from the update, or continue grandfathering census tracts in who have moved out of being considered DACs. Thank you, Cade