Comment - 21858 - San Diego Climate Week

San Diego Climate Week (SDCW) appreciates the opportunity to comment on the draft CalEnviroScreen 5.0 tool and recognizes OEHHA’s efforts to update datasets, incorporate new indicators, and engage community-based organizations through a co-design process. CalEnviroScreen plays a critical role in shaping how environmental and climate resources are allocated across California, and its accuracy is essential to advancing environmental justice. Despite these improvements, CalEnviroScreen 5.0 continues to underrepresent the cumulative environmental burdens faced by communities such as Imperial Beach, resulting in their exclusion from disadvantaged community (DAC) designation and the funding and protections that accompany it. Imperial Beach Is Experiencing Significant Environmental and Health Burdens Not Captured by CalEnviroScreen Imperial Beach residents experience chronic exposure to pollution stemming from the Tijuana River, including repeated sewage flows, sediment contamination, and the aerosolization of pollutants that affect air quality and public health. Emerging scientific research demonstrates that pollution from contaminated waterways can meaningfully contribute to regional air pollution through mechanisms not adequately captured by traditional PM₂.₅ metrics, including the airborne transport of chemicals, pathogens, and other contaminants. CalEnviroScreen’s current reliance on limited air pollution indicators fails to reflect these complex and interrelated exposure pathways. As a result, communities impacted by river-driven air and environmental contamination are systematically undervalued in cumulative impact scores, despite well-documented health impacts such as respiratory illness, gastrointestinal disease, and other pollution-associated conditions reported by Imperial Beach residents. Gaps Risk Reinforcing Existing Inequities While CalEnviroScreen 5.0 may show relatively lower scores for drinking water or soil contamination in Imperial Beach compared to other regions, this snapshot does not reflect ongoing and cumulative risk. Repeated pollution events from the Tijuana River threaten long-term water and soil quality and create chronic exposure conditions that are not adequately captured by current datasets or scoring methods. Because CalEnviroScreen relies on available statewide data and relative rankings, communities that fall just below DAC thresholds—despite experiencing severe localized pollution—risk being excluded from environmental justice, climate, and public health funding. Analyses by academic institutions and investigative journalists have already shown that communities across California have lost access to billions of dollars in investments due to these structural limitations. Imperial Beach faces a similar risk if river-driven pollution is not incorporated into cumulative impact assessments. Recommendation: Strengthen Indicators to Reflect River-Driven and Cumulative Pollution Burdens SDCW urges OEHHA to further refine CalEnviroScreen by: Expanding air quality indicators beyond PM₂.₅ to account for nontraditional and emerging pollution pathways, including aerosolized contaminants associated with polluted waterways. Testing for hydrogen sulfide—a highly toxic, flammable, and colorless gas—began in Imperial Beach in 2024. At low concentrations, hydrogen sulfide has a distinctive “rotten egg” odor, but at higher, dangerous levels it can quickly dull the sense of smell, making it harder to detect. Recent research from San Diego State University and partner institutions shows that polluted water from the Tijuana River is releasing large amounts of hydrogen sulfide into the air, exposing nearby communities to harmful conditions. In some cases, concentrations have reached levels far above what is typical in urban areas, contributing to respiratory symptoms, nausea, and other health impacts reported by residents. Incorporating metrics or proxies that better account for chronic pollution from natural water sources, such as rivers with ongoing contamination. Ensuring that communities experiencing repeated environmental exposure events—like Imperial Beach—are not excluded from DAC designation due to methodological blind spots. CalEnviroScreen is intended to be a tool that advances equity, not one that inadvertently reinforces gaps between lived experience and technical scoring. Strengthening the tool to better reflect the realities faced by Imperial Beach and similar communities will improve its credibility, fairness, and effectiveness in guiding state investments and protecting public health. SDCW stands ready to support OEHHA in identifying data sources, research, and community knowledge that can help ensure CalEnviroScreen 5.0 more fully captures cumulative environmental burdens and fulfills its environmental justice mandate. Attached to submission: https://www.science.org/doi/10.1126/science.adv1343 https://calmatters.org/environment/2026/02/cal-enviro-screen-pollution-funding/