Comment - 21852 - Dr. Veronica Herrera (UCLA Dept of Urban Planning) and Daniel Coffee (UCLA Luskin Center for Innovation)

As California continues to iterate upon its environmental health screening tool, there is an acute need to incorporate elements that recognize the pervasive impacts of plastic pollution and the underlying supply chain that produces plastic goods. Plastic particles and associated chemicals have become pervasive environmental contaminants, but the effects of the plastic life cycle on Californians are not uniform. In our ongoing research report series (available at https://innovation.luskin.ucla.edu/climate/plastic-policy/), we propose a comprehensive conceptual framework for identifying these impacts, focusing on three types of exposure risk: facilities and infrastructure, food and water contamination, and consumer goods usage. CalEnviroScreen's current indicators already capture some of the risks posed to Californians by plastic. The most relevant are: 1. Air Quality (PM 2.5) includes PM 2.5 particulates that are micro/nanoplastics (MNPs), especially synthetic rubber abraded from tires. 2. Toxic Releases from Facilities covers many facilities that fall under the plastic industry umbrella. 3. Solid Waste Sites & Facilities includes many facilities (e.g., landfills) involved in end-of-life disposal of plastic waste. However, in general, CalEnviroScreen's current set of indicators fail to capture MNP exposure risk, especially through ingestion, which a growing body of research is linking to various health harms. We recommend that OEHHA explore new research and data collection--in concert with other state agencies-- that will enable the creation of an MNP contamination indicator. The most important priorities for this effort are refining existing air quality particulate data, using novel techniques to characterize MNP content; executing on directives in state law (SB 1422) to engage in comprehensive MNP testing for drinking water; and identifying strategies to quantify MNP food contamination risk (e.g., using USDA food desert designations as a proxy for ultraprocessed food reliance). Moreover, existing indicators can be improved to more accurately capture impacts on Californian communities. In general, OEHHA's reliance on a 1 km parameter for weighting of sites outside census tract boundaries is overly simplistic. Our work relies on parameters from extant peer-reviewed research to identify "heightened exposure risk zones" for plastic-related sites, and in many cases the impacts of polluting infrastructure extend well beyond 1 km. We recommend that OEHHA differentiate the parameters it uses for distance-based weighting by facility type. Regarding specific indicators, we recommend that Drinking Water be updated to include MNPs among its select contaminants when the data is available to do so, and that the SWRBC-designated pollutants underlying the Impaired Water Bodies indicator expand upon the general "Trash" category to differentiate between plastic and other types of discarded material.