Goal 2: Advance Environmental Justice

Build Partnerships and Community Capacity

Strategy 2.1 Community Partnership: We will develop partnerships with communities so they can directly participate in the solutions to the air quality problems that impact them.

In September 2017, a new state law, Assembly Bill 617, fundamentally changed how local air districts approach air quality planning. The law requires all major local air districts in the state to partner with state-selected communities to develop community monitoring plans and/or plans to reduce air pollution in their neighborhoods. In the Bay Area, we have partnered with communities in West Oakland, the Richmond-North Richmond-San Pablo area, East Oakland, and Bayview Hunters Point-Southeast San Francisco to identify local air pollution concerns and strategies for reducing that pollution. For the Richmond area, we also developed a community monitoring plan, in partnership with the community. This work has taught us that partnership is essential to build trust and achieve success.

Local air quality planning requires extensive community input and should align with environmental justice principles. People living in communities historically overburdened by air pollution are the experts on what is impacting their communities, their health, and quality of life. The Air District has air pollution expertise, vast amounts of air quality data, and knowledge of how various government agencies at the local, state, and federal level can help address community problems. Both government and community bring something valuable and necessary to the partnership.

More importantly, people living in communities long harmed by air and other pollution burdens have historically been excluded from meaningful participation in government decision- making. Partnering with communities is one of many steps needed to undo and correct the harm caused by past discriminatory practices.

Most of the strategies in the 2024-2029 Strategic Plan will require partnering with communities. For example, we will partner with communities to better understand their experience with air pollution and the sources that concern them, and to identify pollution reduction actions. We will work with communities to develop a new enforcement policy and to talk about compliance and enforcement efforts, air quality data needs, new funding programs, and to reimagine our existing policies and programs. Under this strategy, we will form the relationships and partnerships needed to implement the strategic plan, including with churches, schools, or other membership organizations.

We will take what we learned in West Oakland, Richmond, East Oakland, and Bayview Hunters Point and expand those partnership models to other communities impacted by air pollution. How we partner with community will be as unique as the communities are. We will work with community leaders, including community steering committee members from West Oakland, Richmond, East Oakland, and Bayview Hunters Point, to develop and define what partnership looks like from their perspective.

Partnership can take many forms, from the formation of a formal steering committee to regular Air District attendance at standing community meetings. The degree of community participation may also vary, depending on their needs. Some may want to develop formal emission reduction plans, like those adopted in West Oakland and Richmond. Others may want regular updates on how we are improving air quality in their communities, access to tools to collect their own air quality data, or to provide input on local pollution sources and the actions we can take. Under this strategy, we will meet communities where they are.

Build Partnerships and Community Capacity

Strategy 2.2 Collect Community Data: We will build community capacity to collect air pollution data and ensure the Air District better utilizes those data to reduce the pollution that harms communities most.

Community members want to understand air quality in their neighborhoods. They also want to be part of the solution in getting more information about air quality. However, community members often do not have all the tools they need to collect actionable air pollution data. These tools include not just the equipment needed to take air quality measurements, but also the resources, techniques, and/or methods to collect and interpret the data and make sure it is useful in our efforts to reduce air pollution.

In building the capacity of community members to collect and interpret air pollution data, we can also build stronger relationships and instill more trust between communities and the Air District. We can work together to better understand local air pollution.

Under this strategy, we will provide community members with air quality data collection tools, training on how to best use tools, and standard data collection procedures. We will work with communities to collect data that can help with improved enforcement, more stringent regulations, better targeted or new incentive programs, or other programs and policies to reduce pollution. Data collected could include samples of particulate matter that collects on surfaces, odor complaints, and observations of dust crossing fence lines, as well as other air monitoring data.

We are starting with communities impacted by refineries. We will help train community members in data collection procedures and record keeping. Through this and similar efforts, we will help the community collect data that will be most helpful in enforcing existing regulations and in the development of the more health- protective actions we take.

Strategy 2.3 Make Data Accessible: We will give communities the tools and data they need to access and understand air pollution data so they can be better informed of any potential air pollution problems.

There are many sources of air pollution data available to the public, especially in communities known to have high levels of pollution and near large sources of air pollution. Data sources include the Air District’s own air monitoring stations, refinery fenceline air monitors, community monitors, and low-cost air pollution sensor networks such as PurpleAir. Other data sources include the Air District’s facility-level emission estimates, permit information, and compliance histories. With so much data available, there come challenges. When there are questions about community air quality, it can be difficult for community members to know which data source to use, or why there may be conflicting or different data in the same community. Also, seeing air pollution data without appropriate context can be confusing, as community members may not know how to interpret the data. They may not know if the number they are seeing is considered high or low, or how it compares to health standards, or if it is an unusually high number that points to an air quality problem.

In addition to publicly available air quality data, community members want more access to our data on permitting, emissions, and enforcement activities. Much of this data is either inaccessible or difficult to find.

Under this strategy, we will work to better understand community data needs and how to make air quality data more available, accessible, and understandable. We will prepare an inventory of available data, including monitoring, permitting, enforcement, and complaint data. We will work with community members to better describe this data. Additionally, different communities have different data needs, so we will do our best to customize our approach to meet the specific needs of individual communities.

Strategy 2.4 Community Health Data: We will provide communities with better health information, so they know the potential health implications of air pollution and are better able to participate in decision-making.

Decades of discrimination, disinvestment, and the consequences of federal government redlining, and local land use policies have all contributed to dramatic differences in people’s health outcomes in communities of color, compared to the Bay Area as a whole. These communities are often located near major industrial facilities, highways, busy roadways, and ports, with higher levels of exposure to air pollution. People living in communities impacted by local pollution want to better understand the health conditions in their neighborhood, and how health conditions are impacted by air pollution.

Existing health data is challenging to use, especially if it is used to understand and reduce environmental injustice. Most health data is available at a zip code, city, or county level, which can mask differences between different neighborhoods or parts of a neighborhood. For example, a neighborhood block may have severe health issues that are unseen in the data if averaged with wealthier residents who live farther from major air pollution sources.

Additionally, available health data comes with complex definitions for each health condition. These definitions often change, making it nearly impossible to track health trends, or changes, over time.

We currently work with public health departments and community health centers to provide health data to communities. Such data includes asthma rates, cardiovascular and respiratory disease, cancer rates, and emergency room visits. Under this strategy, we will expand our efforts to collect, analyze and provide health data to communities. We will use Health Impact Assessment methodologies using multiple data sources and consider input from community members and others, to determine the potential effects of a proposed policy, program, or project on community health. Moving forward, we will work with health care providers to gain access to better data and with community members to collect neighborhood, block-by-block level data using survey techniques. We will also work to consider how to best share health data with our various community partners, ensuring it meets their needs.

Strategy 2.5 Air Quality Complaints: We will improve the complaint process to ensure it is effective and transparent.

With limited air monitors and air quality inspectors to cover the entire Bay Area and its hundreds of thousands of possible sources of air pollution, members of the public are often the first to become aware of air pollution problems or incidents in their neighborhood. Odors, smoke, dust, and particulates from a variety of commercial, manufacturing, and industrial operations, portable equipment, cars and trucks, and residential activities can all generate air pollution. Sometimes, this pollution is visible or can be smelled, alerting people to a potential problem.

Members of the public are part of the solution in alerting us to potential air quality violations. Alerts come to us in the form of air quality complaints. The Air District’s complaint process serves an important role in early identification of air quality issues, but it relies on effective participation by the public. The complaint process is only as strong as community members who know about it and use it effectively. Improving our responsiveness and transparency is also important to foster a robust complaint system that reduces local air pollution.

However, community members have expressed frustrations with our complaint system. They feel that at times we do not arrive in time to document the issue, especially if the problem occurs late at night or on a weekend. They also become frustrated when the Air District cannot track down the source of the problem or does not follow up on what happened with the complaint, whether it was addressed and how. In addition, we have heard from community members that they would like our air monitors to be better able to identify potential air quality problems, and to have those problems followed up or confirmed through inspections.

Under this strategy, we will explore new ways to provide complaint information to the public. We will also improve the transparency of complaint outcomes and follow up with community members on what the problem was and how it was resolved, using plain, non-technical language. We will ensure responsiveness, including during nights, weekends, and holidays.

The efforts we undertake in this strategy will be supported by our efforts in Strategy 4.8 Air Quality Incidents, where we will enhance our air pollution incident response program, in collaboration with community partners, to better respond to and communicate about air quality incidents.

Strategy 2.6 Talk with Communities: We will meet with communities about air pollution problems in their neighborhoods, their concerns, how we are addressing them, and what more they need from us, so we are more responsive to communities.

Communities with a long history of being exposed to pollution, understandably, do not always trust government agencies. They have little trust that they are being protected from pollution, including air pollution, and they want more transparency and information on what we are doing to protect them. Communities want to know how we are holding industries, businesses, and others accountable for polluting their communities. They also want more air pollution data from air monitoring and to be informed about any legal actions we have taken against those who violate air quality regulations.

Communities also want to tell us about their experience with air pollution and violations in their neighborhoods. Such information could increase our capacity to enforce air quality regulations. Although we meet with some community groups to share information about our enforcement activities, we do not have a formal, structured program. Under this strategy, we will develop a structured program to meet regularly with community members to talk about air pollution in their neighborhoods, including compliance and enforcement activities, recent incidents or other air pollution violations, our enforcement response, the extent of public harm, and legal actions we may take. We will also share information about air monitoring activities and data in their neighborhoods.

Identify Disparities

Strategy 2.7 Understand Local Air Pollution: We will work with communities overburdened by air pollution to develop a more complete understanding of air pollution in their neighborhoods.

In Strategy 1.1 Change Approach to Air Quality, we describe how we will change our approach to reducing air pollution, where we will continue efforts to both attain national and state air quality standards and to ensure that we reduce inequities in local air pollution exposure. Under this strategy, we will build partnerships with community members to incorporate their knowledge and experience into our understanding of local air pollution. Community knowledge is crucial for a complete and accurate understanding of local air pollution, especially which sources of air pollution are most affecting people’s health and quality of life.

The Air District’s air quality monitoring network was historically designed to assess regional air quality. This is done through a limited number of monitoring locations in the region that collect and measure air quality data. As a result, there are gaps in data about local air quality in communities that don’t have a large, traditional air monitoring station. In addition, our historical approach to understanding air pollution focuses on those sources that are large enough to impact air pollution regionally. We therefore do not always have a good understanding of sources that can have air pollution impacts at the local or neighborhood level.

A more local understanding of air pollution impacts will help communities know more about what they are breathing and, where possible, what actions they can take to reduce their exposure to air pollution. A better understanding of sources of air pollution that impact communities will also help the Air District develop more effective strategies to reduce those sources’ impacts.

Under this strategy, we will build relationships and partnerships with communities to understand their experience and knowledge of local air pollution. We will talk with communities about what air pollution they are experiencing and where it might come from. We will use their experience and knowledge to inform where we do additional air monitoring, including mobile monitoring and short term monitoring studies. We will run air pollution data, including emissions and monitoring data, through computer modeling programs to get a more complete picture of air pollution within specific neighborhoods.

We will also partner with communities to identify their additional air monitoring needs, and report back on the air pollution data we collect.

Reduce Disparities

Strategy 2.8 Community-Directed Funds: We will manage funds to benefit communities in partnership with those communities, including money that the Air District collects in penalties from air pollution violations that affect communities.

If a specific industry or business violates an Air District regulation, we take enforcement action and often assess a financial penalty. These financial penalties can be substantial for significant air quality violations. The money we collect through penalties has historically been used to help pay for the Air District’s enforcement program. This means that penalty funds have not necessarily directly reduced air quality impacts in the location where the violation occurred.

In May 2024, the Air District adopted a new policy that will direct a portion of the money generated through penalties back into communities where the violation occurred. Additionally, in 2021, the Air District created a “Community Benefit Fund” of $3 million for projects that will directly benefit communities. These funding sources are an opportunity. And as described in Strategy 1.4 Reimagine Funding, communities want to decide how such funding is used. They want to participate in the decisions on the types of air quality projects we fund and to ensure projects directly benefit them.

Under this strategy, we will establish a team within the Air District to administer the portion of penalty funds distributed to affected communities and the broader region, in consultation with the communities and region. For the Community Benefit Fund, we will develop a community-led process, in collaboration with the Community Advisory Council and local community based organizations, where communities participate in decisions on how to spend that money.

Strategy 2.9 Address Legal Barriers: We will strive to change laws that prevent the Air District from advancing environmental justice.

Most actions the Air District can take to reduce pollution are authorized, and restricted, by state and federal laws. The sources we can regulate, how we issue and enforce permits, the penalties we can collect, and even how we operate our incentive programs are all bound by law. Some of these laws can act as barriers to advancing environmental justice. For example, state law sets limits on penalties we can collect for air quality violations of our permits and regulations. As described in Strategy 2.8 Community-Directed Funds, the community can benefit from these penalty funds. Limits on penalties mean less deterrence and accountability for facilities and less funding for communities to reduce the impacts of air pollution.

Under this strategy, we commit to working toward changing state law limiting the amount of money in penalties we can collect for violations of our air pollution regulations and permits. We will work with the state legislature on other ideas for changes to laws that can benefit overburdened communities and to do the advocacy necessary to get ideas into law. We will also bring our state and federal representatives into the conversation on the local health impacts of air pollution. We will share our story of how the Air District and communities are partnering together to improve local air quality. Building legislators’ knowledge about air pollution’s health impacts may help lawmakers champion the legal changes we need. For example, we need more money for grant programs that reduce air pollution in communities. Communities also need more direct funding to partner with the Air District in reducing air pollution and to help us bring down other barriers to overcoming environmental injustices.

Strategy 2.10 Civil Rights Laws: We will advance and prioritize compliance with civil rights laws, including the federal Civil Rights Act of 1964 and related California laws.

Title VI of the Civil Rights Act of 1964 prohibits recipients of federal financial assistance from discriminating based on race, color, religion, sex, national origin, or disability. California Government Code section 11135 contains similar prohibitions against discrimination under state law. The Air District is responsible for ensuring that its actions and practices are not discriminatory.

Public participation practices that are inclusive and nondiscriminatory, access to programs for people with limited English proficiency, and access for people with disabilities are part of complying with civil rights laws. In addition, permitting, rulemaking, enforcement, and other actions taken by the Air District must not have a discriminatory effect, meaning that the actions cannot have an inequitable impact on members of a group identified by race, color, or national origin.

Under this strategy, we will review how we issue permits to ensure we are following civil rights laws and regulations. In 2022, the United States Environmental Protection Agency published guidance to help state and local governments comply with civil rights laws as they carry out their permitting programs. This interim guidance may be a starting point in examining whether additional steps need to be taken in reviewing permit decisions for civil rights compliance, as part of Strategy 4.3 Consistent Permits.

We will also implement the Air District's Plan for Language Services to Limited English Proficient Populations to ensure compliance with civil rights laws. This plan details our commitment to provide meaningful access to important Air District services and programs to persons with limited English proficiency, including providing information in multiple languages and upon request, to best meet community needs to engage with and participate in Air District programs.

Strategy 2.11 Cumulative Health Impacts: We will develop our understanding of the cumulative effects of air pollution and other stressors, and use this information to focus regulatory efforts in areas experiencing the most serious air pollution and related cumulative impacts.

The Air District is researching ways to better understand and more effectively address cumulative impacts in communities overburdened by air pollution and other chronic environmental, income, health, housing, job security, and other stressors. Cumulative impacts occur when private businesses or governments make individual decisions that when added together, can cause impacts that accumulate over time to negatively affect people's health, well-being, and quality of life.

Certain communities and populations are at greater risk from air pollution and other environmental pollution because of things like neighborhood characteristics, education, and income, that are well-known contributors to greater health problems than average. Cumulative exposure to pollution and other chronic stressors affect lower-income communities of color more so than whiter, wealthier communities.

Under this strategy, the Air District will develop a better understanding of where cumulative impacts exist and how they should be considered in both our and local government decision-making. We will develop and share methods for understanding which communities and community members are most heavily impacted by cumulative environmental burdens and chronic stressors and why. We will use this information as we consider cumulative impacts in our programs, including permitting, regulations and compliance.

We will also provide tools and guidance to local governments to incorporate a more complete understanding of cumulative impacts as they make decisions affecting their communities, including plan and policy recommendations and guidance for siting, designing, and permitting land use projects.