Caroline Farrell interviewed by Reimagine podcast producer Jess Clarke
Jess Clarke: What does CalEnviroScreen (CES) mean? What is it currently used for? What does it do?
Caroline Farrell: CalEnviroScreen is an environmental mapping tool that was developed by the state of California, specifically the Office of Environmental Health Hazard Assessment (OEHHA). It’s building off of other environmental screening tools that have been developed by different academic institutions. Basically it looks at different areas of environmental pollution, different areas of environmental exposure, and different variables of social vulnerability. It sort of maps them to create a cumulative impact tool so that you can see which areas of the state are most environmentally impacted and which socially vulnerable groups are most environmentally impacted. The way the state uses it now is often to allocate funding and resources to communities that are most impacted.
It has its roots in a lot of environmental justice advocacy from the late 90s and early 2000s, to begin to identify environmental justice communities. Because you would often hear from either decision makers or industry, “What is an EJ community?” And it was often one of those things, “Well, you would know it if you saw it.” And so in order to answer that question, environmental justice advocates pushed for creating a tool that would make it more evident to everybody what communities we’re talking about, so that we could design policy, permitting, different rule-making, as well as investments to try and redress those negative impacts.
Clarke: Do scientists use it to find out where they should be doing additional studies for health impacts if they see a high score?
Farrell: You could potentially, yeah. I think that’s one of the areas that, in looking at where there are maybe pollution hotspots and things like that. The research team of Manuel Pastor and Rachel Morello-Frosch and Jim Sadd were coming up with the environmental justice screening methodology in the, I think, mid-to-late 90s to look at these different factors. The idea behind it was, once you identified where the impacts were, then you could look at a whole host of interventions. It could be science and more additional research. It could be policy. It could be investment. But the first layer was to know where the communities are and what communities are most impacted. And then you could design a whole range of interventions.
Clarke: Does it include a scoring for the actual health of the community? Does it use mortality rates? asthma rates? Are those kind of things part of the index?
Farrell: Yeah, that’s part of the rankings, one of the levels of the ranking system. It will look at a variety of things, like what’s the pollution burden, whether you have poor drinking water, whether [your community is] home to a solid waste or hazardous waste facility. And then in terms of environmental exposures, it has asthma rates, low birth weight is another factor to consider, cardiovascular disease is another. And then for social vulnerability factors it could be English as a second language, education levels, housing burden. Things like that could also be included. So you’re looking at both the exposure and pollution levels as well as social vulnerability. That was important because people who are more socially vulnerability may not have the resources to be able to address all of the environmental exposures they have, or protect themselves from all of those exposures.
Clarke: One of the areas we’re particularly interested in is understanding how it got created. What were the coalitions that came together? What kind of groups were pushing OEHHA?
Farrell: The spark that really instigated the creation of CalEnviroScreen in the early 2010s was the passage of SB 535, which created the greenhouse gas reduction fund. Basically, in that law, it specifically required the state to develop a tool to identify the most impacted communities. That was the specific impetus to get CalEnviroScreen, or, get OEHHA involved in the creation of a statewide tool.
But I think the impetus for screening tools really began in the 1990s from the environmental movement itself, and the environmental justice movement nationwide, too, because there was pressure on US EPA to create a screening tool. And they have EJSCREEN that exists at the federal level, which at the time just basically plotted race and income. They didn’t really have a whole metrics of values that they were ranking. The other thing that was important in California was, at the time, CalEPA had created an advisory body. California passed its definition of environmental justice in 1999, where it finally defined environmental justice, and at the time, as part of that law, created an infrastructure. So there was an intergovernmental agency commission made up of all the heads of CalEPA’s agencies and departments that met on environmental justice. There was an EJ advisory committee that was created that had various representatives from EJ groups, as well as business groups. They would have meetings. I remember going to one at CARB up in Sacramento in the, maybe, early 2000s.
From that advisory committee, they came up with a definition for cumulative impacts, what that actually meant, as well as a list of 103 different recommendations for how CalEPA could implement environmental justice in its programs. And this was in 2003. Once the interagency EJ commission adopted this definition of cumulative impacts, they then created another advisory group to delve more into cumulative impacts, and Amy Klein was one of the researchers leading some of that work. That committee determined that there needed to be a cumulative impact tool to at least start identifying the most disadvantaged communities.
Simultaneously, one of the things that was really interesting was that while the state didn’t really work on CalEnviroScreen or cumulative impact screening tool until 2010, 2011, 2012, around there, these researchers like Manuel Pastor, Rachel Morello-Frosch, and Jim Sadd were like “well why don’t we try and develop something?”
They began working with EJ groups in the Bay Area: I think maybe Communities for a Better Environment, possibly APEN, I think the West Oakland Indicators Project. They were working with environmental justice groups on the ground in that region to help create a tool, identify what are the matrix we want to look at, what are the indicators we want to look at. They didn’t make any promises that “we’re going to find a particular result,” but “what is it that we want to look at” and then “how do we want to analyze and interpret the data that we get together?”
One of the things they did that was really interesting was, all these tools are created by publicly-available data. So it’s all the reporting data that is required for facilities to submit, whether that be through monitoring reports, whether that be through permits, however they’re required to report on this data. Because of that, it’s not always 100% accurate. One of the things that would often happen is the reporting would come from the administrative office or headquarters, like let’s say the headquarters of Chevron. Suppose it comes from the administrative office of Chevron refinery, Well where that office is located may not be where the stack is located. The pollution source may actually be closer to the community than the administrative office where the mail is received. They’re reporting from their physical mailing address, but the stack is actually maybe 1,000 feet away.
So they would do ground truthing. They would work with the community to identify where are the sensitive receptors and where are the pollution sources? So you could actually get a better sense of the proximity to pollution. Also, you don’t always have all of the sensitive receptors in a particular area that are publicly known. You may have informal childcare providers who have a small daycare in the neighborhood, but that’s not necessarily reported to the state or it’s not identified as a sensitive receptor. So what community knowledge added was this level of, who’s really being exposed and where’s the pollution really coming from?
Clarke: So a sensitive receptor isn’t a scientific instrument. It’s a group of people who have sensitivities?
Farrell: Yes, it’s not a monitoring device. It’s people. A sensitive receptor is a human being who maybe lives, works, or goes to school near where pollution is.
The ground truthing happened with the private academic research, like Manuel Pastor and Jim Sadd and Rachel Morello-Frosch and Jonathan London at UC Davis and the Center for Regional Change. OEHHA did not engage in ground truthing. They just relied on publicly available data. They weren’t necessarily working to test out the accuracy of the assumptions in their tool. But because community members had worked with researchers to develop these tools for their regions, they got used to thinking about, what are the representative factors? What are the levels that we want to look at? So there was a big debate: should we look at census tracks or census blocks or zip codes? What was the right level of analysis?
Community groups got used to working on these types of maps. So when Kevin de León was proposing SB 535 and the creation of such a tool, community groups knew it was possible. They had engaged in developing these tools with researchers for their regions. And then they were able to apply that knowledge to the public process around developing CalEnviroScreen. I believe a lot of the same groups that had worked with the researchers on their different regional tools were also submitting comments to OEHHA in 2010, 2012 when it was developing its screening tool. They proposed a lot of ideas, one of which was ground truthing. But the state at the time decided not to do that, decided against that. I don’t know if that will come up again as it updates to CalEnviroScreen 4.0, if they’ll reconsider that. But that was one of the suggestions. There was also suggestions about what factors to include, what factors not to include.
One of the big issues: all of the methodologies that were developed in collaboration with researchers included race as one of the factors. And CalEnviroScreen does not include race. They include a lot of proxies for race, but there was a sense that if we include race, it would prompt legal challenges. But it’s like, race is the factor that most predicts whether you’re environmentally impacted. So to not include it is to ignore lots and lots of research, and instead you’re creating proxies for race. Why not just use race? It just doesn’t make sense.
Clarke: Is that a political sensitivity of the administration? Because of anti-affirmative action laws?
Farrell: I think it was just an over-sensitivity and a broadening of the anti-affirmative action rules in the state. And that was under the Brown administration. With a new administration, I don’t know if there would be the same sensitivities, but that was true under the Brown administration.
Clarke: You were mentioning that there was a very early tool that the federal EPA had, which was just race and, what were the two?
Farrell: Yeah, race and income. Those were the two factors. And then over the years since CalEnviroScreen, I think over the last maybe 10 to 15 years, that tool has become more robust and added more variables to the federal tool. But the federal tool has fewer environmental variables because, again, they’re limited to what are the things that are commonly reported throughout the country. What are the environmental impacts that are reported throughout the country? We have more reporting requirements in California than maybe other places. So they plot fewer environmental variables. But it’s become a much better tool than initially when it first started.
Clarke: Is there a utility in public policy prescriptions that comes from having a more refined understanding of the sub-factors? What does all that complexity generate on the upside in terms of creating better social services or better pollution control or better impact management or dealing with the housing, or what other issues that are identified in the scoring process?
Farrell: I think if you’re just trying to give out money through the tool, I don’t think you need as many factors, but the value of having a variety of different factors is you can start looking at what are the other policy interventions that could help in this particular case. If this particular community is impacted mainly by water, you may start looking at what are some policy solutions or project solutions or local government, state government, federal government solutions to that particular water problem? Or if you’re seeing that there are all these communities, like in port communities, that are suffering from the same issues, what can we do about ports? What’s the policy around ports that would reduce this for everybody? Similarly, if you’re seeing all the communities in the San Joaquin Valley are dealing with impacts from dairies, what’s the rulemaking we can do around dairies that would reduce these impacts?
You can begin to see that there are common policy threads that could impact many different communities. Or if you see that this one community is impacted by all of these things, then maybe that’s a different strategy. You can begin to understand how pollution impacts different communities in the same way, or how it impacts communities differently depending on where they are or what level of social vulnerability they have. The other thing is you can begin to see how agencies can work together better because everything is so siloed. You can begin to see how communities are experiencing these things on the ground. They’re dealing with all of these impacts, so maybe instead of dealing with them one at a time, looking at things more comprehensively.
Clarke: Given that time period that’s passed, what are some of the successes and lessons learned from the California experience?
Farrell: I think it should be really important to be really clear about what the purpose of the tool is from the get-go. When you look back at the CalEPA 100 or so recommendations, it was really clear that the environmental justice community wanted to have these tools to identify EJ communities to begin to have more information to better target regulation, better target permitting, and better target investment and grant funding. So it was all three purposes.
I think what happened in California is, once the mandate for developing a statewide tool was in 535, it became very tied to funding, and we lost track of the other [purposes]: it’s an opportunity to create better permitting requirements or it’s an opportunity to actually reduce pollution through direct regulation or rulemaking. And it all became about funding. That misses the point and also makes the tool vulnerable because if you’re in a highly impacted region and you’re getting preference for certain funding, that makes other groups and other communities that may have a better quality of environment or be less socially vulnerable, feel like, “Well wait a minute. What about us?” It becomes like a battle for pork as opposed to, no, we’re actually trying to improve communities that have been systemically neglected or systemically burdened by pollution for decades.
Clarke: There’s a way in which the cap-and-trade philosophy out of which the 535 funds sprang, it’s just that. Well we’re going to collect all the money over here, and then we’re going to pour it back onto the communities that got impacted instead of shutting down that plant in the first place or stopping that toxic emissions before the product was distributed all across the state. How has CalEnviroScreen worked or enabled people to do some good work in terms of either specific impacted communities that you’re familiar with or ways in which it changed the political conversation and advanced the ability of environmental justice groups and communities to really be in the political process—either as a direct solution to a specific impacted community or, looking at the California legislature or the public agencies that deal with the issues that we’re talking about. Where has CES played a role as one of the tools?
Farrell: I think it’s been not just positive, but it’s been important in some of the work around SB 1000 implementation and the creation of general plans at the local level, at city and county levels. Some counties don’t fully embrace CalEnviroScreen because it is a statewide tool that compares communities to others in the state rather than in a particular local jurisdiction. But there’s been discussion about how the tool could be adapted to include regional or local indicators, depending on the scale of government you’re looking at.
I think it has been really helpful in showing, particularly in communities that are quite impacted compared to other communities at the state level, that local jurisdictions need to be paying attention to these communities in their general plans and in their planning and permitting processes. So I think that’s been useful, and it has prompted a conversation about how jurisdictions are planning for highly-impacted communities and disadvantaged communities within their jurisdictions. A lot of that is still in process, so it’s unclear how it is actually going to shake out at the end of the day, but I think it’s been important for those reasons.
I think it’s been important in shifting some of how local government plans some community development projects through, [projects] like the Transformative Climate Communities. It has shifted so that you need to demonstrate real community support for investments. You need to look at how are you actually collaborating with existing community groups in highly disproportionately impacted areas of the state in a way that doesn’t just lead to displacement and gentrification. It’s prompting a closer look and maybe recalibrating some of the planning processes.
It’s shifting also, like in Kern County, because the state is looking more at how it is investing in disadvantaged communities. It has shifted a little bit how local jurisdictions are working with community groups to identify projects for state funding. For a long time in Kern County, the county would create a list of projects that it would then seek grant funding for from the state, or bond funding or whatever funding might be available. And rarely did it have any relationship to what was actually needed in the community or actually wanted by community residents. But with CalEnviroScreen and then a shift in state priorities to start funding more in disadvantaged communities and using the tool to identify those communities, it shifted things so now local jurisdictions like Kern County are actually partnering with community groups to identify projects, and then working with communities to develop the applications and to advocate with state funding boards to get resources.
So it’s shifting some of those relationships at the local level, which could lead to more transformative change beyond just what CalEnviroScreen brings. I think mapping in general is becoming more and more prevalent in advocacy to demonstrate and to tell the story of why the 2500-foot setback is needed between communities and oil and gas drilling, why it’s needed around pesticides and pesticide spraying. I think mapping is becoming increasingly a tool that both regulators and community members are used to working with.
Clarke: That’s good. So just wrapping up what’s your vision, in terms of next steps on an advocacy level, either as a state priority (re CES 4.00) or the federal level?
Farrell: Yeah. As there are these different opportunities at the state level to update CalEnviroScreen and at the federal level to develop a tool, I think it’s really important to make sure that these efforts are grounded in the actual ways to reduce pollution in low income communities and communities of color, on the ground. Part of the value of having the tool is you can begin to show where there are disproportionate impacts in Black, indigenous, and people of color communities. But the next phase is really about how do we address that and stop it from happening.
Funding isn’t the only way of doing that. It’s about developing strategies for emission reductions. That can start by developing some cumulative impact policies that address multiple things at the same time rather than just addressing air in one policy, water in another policy, solid waste in another policy. But how are you tackling all of these things at the same time? Maybe the tool can take us to the next iteration of that discussion.
Clarke: All right. We have been joined by Caroline Farrell, Executive Director of the Center on Race, Poverty, & the Environment, the grandparent of Race, Poverty, & the Environment Journal. I really want to thank you for joining us this afternoon for this segment. Thanks, Caroline.
Farrell: Thank you. I appreciate it.
Interview with Caroline Farrell recorded on 2/08/21