Comment Submissions - Draft CalEnviroScreen 4.0

Hello, I am a public health professional, but the views here are my own (and not my employer’s). I would respectfully ask you to consider including tobacco retailers as a form of data in CalEnviroScreen 4.0 (akin to how you include hazardous waste facilities). Since it became undeniable in the 1960s that tobacco causes cancer, middle and upper class Americans — that is, those with resources — increasingly overcame the addiction and passed local laws that discouraged initiation. The tobacco industry in turn doubled down on marketing towards groups perceived as marginal: the working class, African Americans, LGBTQ, rural residents, etc. Their target populations are almost always geographically concentrated, and those communities are disproportionately burdened with tobacco retailers. Tobacco retailers are not a neutral presence. Their very existence exacerbates tobacco addiction. Since the Master Settlement Agreement over twenty years ago, tobacco advertising has been concentrated at retailers (as opposed to, say, billboards). This makes each retailer an intense point of advertisements, as they’re often in windows, on gas pumps and behind the cash register (the “power wall”). Such advertisements normalize the presence of tobacco and, among people trying to quit, induce cravings. Further, the closer it is a tobacco retailer, the harder it is to quit because there are more opportunities to relapse. The harms from tobacco are catastrophic, rivalling or surpassing forms of pollution traditionally considered environmental problems. The 2014 Surgeon General report on smoking estimated that approximately 480,000 Americans die annually from smoking-related disease, of whom roughly 40,000 were people who did not themselves smoke but were exposed to secondhand smoke. Including tobacco retailers in the CalEnviroScreen has a specific practical benefit. Senate Bill 1000 (2016) requires that local jurisdictions use it to identify ‘disadvantaged communities’ for the purposes of deciding whether the jurisdiction needs to include an environmental justice element in its general plan. The Governor’s Office of Planning and Research general plan guidance repeatedly uses tobacco as an example of a harm in its discussion of environmental justice elements, but planners do not have a readily available tool to comparatively evaluate concentrations of tobacco retailers. Finally, this is a relatively straightforward ask to fulfill. Tobacco retailers are required to get a State license, and the California Department of Tax and Fee Administration has the addresses of the physical location of stores. Thank you for your consideration.