Comment - 21844 - Southern California Association of Governments

SCAG utilizes the CalEnviroScreen tool in many different work areas, such as the Sustainable Communities Program. SCAG staff appreciates the opportunity to provide input on the Draft CalEnviroScreen 5.0 update and have the following comments: SCAG commends OEHHA on the robust engagement effort with the co-design process and appreciates the inclusion of environmental justice organizations representing interests from across the state. CalEnviroScreen still needs a more thorough analysis of environmental health outcomes for indigenous communities in California. In August 2025, Brookings Metro and SCAG co-published the “Good Data, Stronger Tribes: Overcoming Native American Data Challenges in Southern California” (https://www.brookings.edu/articles/good-data-stronger-tribes/) report that assesses data challenges for Tribes and Native Americans in the SCAG region and nationally. The report explains how combining Tribal boundaries with census data can give users a false sense of precision and uses CalEnviroScreen as an example of a public data dashboard that does this. SCAG suggests reviewing this report and noting any data limitations, especially in any analysis of race/ethnicity of CalEnviroScreen 5.0 scores. SCAG appreciates that OEHHA documented the intent for a more robust model update and the inclusion of climate change indicators in future iterations of CalEnviroScreen. Staff recommends reviewing the “Mitigating allocative tradeoffs and harms in an environmental justice data tool” article from February 2024 (https://doi.org/10.1038/s42256-024-00793-y) to strengthen the reliability of the tool.