Environmental Justice - Vallejo Style

Sperry Mill site in south Vallejo
The City has released a disappointing and unreasonable facsimile of an environmental justice analysis in response to public comments regarding the private port and cement plant project proposed for south Vallejo.  Concerned citizens pointed to data showing that residents of neighborhoods near the historic Sperry Mill site already suffer high rates of respiratory illness and other health problems, and would be particularly vulnerable to the unavoidable air pollution from project operations outlined in the Environmental Impact Report.  But this new document falls well short of the analysis Vallejo residents were asking for.
At the heart of an environmental justice analysis is the concept of fairness, and the question of whether the impacts of a project are fairly distributed among population groups.  The presence of heavy industry lowers nearby residential property values, and can perpetuate a situation in which low-income and minority neighborhoods suffer most of the environmental and health impacts.  Under the heading “Project Objectives Relevant to Minority and Low-Income Populations,” the hired consultant team touts what they see as possible outcomes of the VMT/Orcem project that would offer benefits to the residents of the neighborhoods in their narrowly defined local impact zones.  A closer examination reveals that these benefits would not actually go to the people bearing the brunt of the unavoidable environmental impacts.  
 
The first of these projected beneficial outcomes purports: “To provide management and skilled labor employment opportunities for local and regional residents in the construction phases, as well as the long-term operations of commercial and industrial uses on the project site.”   How many of our local low-income and minority residents in south Vallejo are ready to step into management and skilled labor positions in heavy industry? 
 
The application for the Orcem project estimates only 20 to 30 jobs, even though the applicants are now floating much bigger numbers.  Those new inflated numbers rely on speculative estimates that include indirect jobs like truck drivers.  These aren’t the kind or number of jobs that will change the employment picture in south Vallejo.
 
The second of these ‘beneficial‘ outcomes claims: “To generate various tax revenues including property taxes and assessments, possessory interest tax, and utility user fees.” Such additional revenues allow the City of Vallejo and its school districts to provide better services to Vallejo residents.”  Funny thing, though.  More than two thirds of that money would leave town to provide better services for Solano County schools and residents of cities that are nowhere near the project location.  The applicant’s own fiscal impact study shows that Vallejo would get only 29% of those taxes and fees, while local residents would live with virtually 100% of the traffic, noise, and pollution.  Where’s the fairness in that?  
The last of the supposed benefits cited: “To provide a means for locally manufactured products to be transported and distributed increasing the viability of and the potential for attracting further manufacturing operations to Vallejo (in addition to Orcem).  Additional manufacturing operations would bring more job opportunities at all levels for Vallejo residents.”
 
What kind of further manufacturing operations would the approval of this project likely attract? Once heavy industry is re-established, with additional infrastructure like a private port and a reactivated rail line laid out in the 1860s that now cuts across the middle of town, more noisy polluting heavy industry will follow.  No-one else will want to be their neighbors.  This vision of our waterfront as the next Stockton or west Oakland is a far cry from the vision expressed by a broad sampling of City residents when their opinion was solicited for the General Plan update.  We’d be much better off in terms of jobs and the environment with light industry and businesses that generate sales tax, instead of chasing utility taxes.
Port of Stockton
The consultants struggled with the issue of air pollution, and rightly so.  The draft Environmental Impact Report explains: “If a project exceeds the identified significance thresholds, its emissions  would be considered cumulatively considerable, resulting in significant adverse air quality impacts to the region’s existing air quality conditions.”  This project would pump out more than six times the significance threshold for the nitrogen oxides that form ground level ozone, the main constituent of smog.  That’s just one of the identified significant air pollution impacts.
 
But the authors seize on the fact that our air quality management district uses regional instead of local standards for nitrogen oxides to conclude that they don’t even need to consider local impacts for this analysis.  They only felt compelled to talk about one harmful component, nitrogen dioxide, where the question of regional vs local standards gets a little murky.  In the context of an environmental justice analysis focused on fairness, the assertion that no defined local standards means no local impacts sounds absurd.  That position would seem to suggest that the impacts from nitrogen oxide emissions are unrelated to the distance from the project or prevailing wind patterns. 
 
Really?  What would a dispersion model look like for that scenario?  Will VMT/Orcem operate in a quantum state where the pollution from a point source suddenly exists everywhere in the region at once?  Of course there would be local impacts on residents, and those impacts will depend in part on the air pollution load already present in their neighborhoods and existing levels of respiratory and heart disease.  Ignoring these factors has nothing to do with fairness or justice. 
 
The really disingenuous aspect of this report is the way the authors chose to draw the lines around both the impacted neighborhoods and general population for comparison in a way that made sure their analysis would spit out the desired result.  The consultants conclude that since there isn’t a significant difference in the minority and low-income composition of the two groups that they choose to examine, there’s no environmental justice issue to address.  But the noise, pollution, and traffic impacts would extend well outside the narrow zones they use to define the impacted residents.
Likewise, their selection of the City of Vallejo as the general population to compare with these impacted neighborhoods does nothing to help assess whether the distribution of costs and benefits from the project would be unfair.  That general population for comparison should include the rest of Solano County, whose residents receive most of the economic benefits.  When the Port of Los Angeles updated their Master Plan, for example, their environmental justice analysis didn’t just look at the City of Los Angeles for comparison with a handful of local impacted neighborhoods.  They compared the neighborhoods within a mile radius of the port with all of Los Angeles County. 
The census data displayed in the VMT/Orcem analysis itself shows significant differences between the Vallejo impact zone neighborhoods and Solano County  in terms of the percentage of low-income and minority residents.  The consultants chose to ignore the data right in front of them showing that in effect south Vallejo would be used as a dumping ground by a more affluent and less diverse County population that would get most of the economic benefit.
This isn’t a question of being for or against economic development, it’s
about encouraging the kind of economic development that will enhance and promote our waterfront environment instead of degrading it.  It’s about encouraging businesses that generate sales tax and create decent paying jobs for a broad segment of the local work force, instead of a few skilled jobs and utility taxes.  Let’s leave behind the ‘take whatever we can get’ mindset and plan for what we want instead.  It’s time we put Vallejo first, and protect our most vulnerable citizens from regional politicians and crony special interests who consider our health and quality of life expendable.
Repurposed Globe Mills in Sacramento