Public Participation letter to the Bay Area Air Quality Management District 11/1/10

November 1, 2010


To:       Bay Area Air Quality Management District

            Board of Directors


From:   Bay Area Environmental Health Collaborative


Re:       Public Participation


Dear Board Members of BAAQMD:


Finally, the Bay Area Air Quality Management District is beginning to respond to years of efforts and recommendations by the Bay Area Environmental Health Collaborative (BAEHC) to BAAQMD to improve public outreach and engagement in affected communities. Attached for your reference is a Summary of Recommendations for improved public participation that BAEHC has submitted to BAAQMD over the past two years.


In response to specific proposals by BAEHC, staff drafted a report on the District’s services to Limited English Proficient (LEP) populations including recommendations for improvements, which was presented to the Public Outreach Committee last week.  At a recent meeting with BAEHC members, APCO Jack Broadbent committed the District to developing and implementing a Public Engagement Policy and Public Engagement Plan to guide how the District will engage Bay Area community residents in the future. While BAEHC is encouraged that the District has finally agreed to take specific steps to improve public outreach and engagement, we further request that the Board:


  • Ensure that the Public Engagement Policy and Plan move forward in a very timely manner with opportunities for meaningful involvement of affected community residents and advocates, including BAEHC, throughout the process;
  • Push staff to include BAEHC’s specific recommendations – including language assistance for LEP populations, expanded opportunities for public participation in regulatory proceedings, and improved website accessibility – into the Policy and Plan;
  • Hold staff accountable by requesting regular reports to the Public Outreach Committee and Board on the District’s progress on development and implementation of the Policy and Plan;
  • Take the lead on developing a meaningful Public Engagement Policy which commits the District to effectively improving outreach and engagement and dedicating the necessary resources to do so;
  • Ensure that the Policy and Plan are developed in partnership with affected community residents and incorporate community concerns and needs, with a goal of advancing Environmental Justice.


We believe the District’s Public Engagement Policy should be developed and adopted by the Board as soon as possible.  The District proposes to hire a consultant to develop the Public Engagement Plan. While BAEHC has concerns about working with a consultant after our experience with the language assistance report, we are hopeful that this process will value community input and result in an effective plan.  BAAQMD staff also proposed a Public Engagement Working Group to assist in developing the Policy and Plan. BAEHC is willing to participate, as long as the objective of the Working Group will in fact be expanded public participation, and the process will not delay implementation of the Policy, Plan or our recommendations. We will be involved as long as progress is being made and if the majority of the group is comprised of community representatives and advocates.


Staff has also agreed to implement some of our recommendations as short-term measures in the interim, such as:

1)      Multilingual voicemail box

2)      Translation of key documents

3)      Notice of language assistance for public meetings

4)      Translation of select information on website

5)      Translation of vital documents on website

6)      Double speaking time for LEP speakers at proceedings

7)      Tele-interpreters available for all phone calls                 


We further request that the Board press staff to improve the availability of public information on the District’s website. Although BAEHC proposed specific recommendations nearly two years ago – including model examples such as the searchable facility database used by SCAQMD – none of our recommendations have been implemented, despite assurances that the District was making progress in this area.  BAEHC was led to believe that updates to other District systems would enable similar improvements to the website.  However we recently learned that there are no such plans to improve the website, for example, by making it easier for residents to identify facilities in their communities or be informed about District proceedings.  Easy access to public records and information is vital to improving public participation. We are frustrated not only that none of our recommendations are being implemented, but also because staff has not been clear on this issue. We ask you to direct staff and dedicate the necessary resources to making critical website improvements.


Finally, we believe that community residents have been left out of past BAAQMD outreach efforts. In our meeting with Jack Broadbent and other staff on October 13th, we discussed the need for a cultural and structural shift within BAAQMD, so that the word “public” includes community residents. BAEHC can help guide this process in order to improve outreach to Bay Area communities. We would like to discuss this new effort with you and will follow up to coordinate a meeting with select Board members.


Thank you for your time and interest.




Rosina Roibal

Bay Area Environmental Health Collaborative





Bay Area Clean Air Task Force
Bayview Hunter’s Point Environmental Health and Environmental Assessment Task Force
Breathe California
Chinese Progressive Association
Ditching Dirty Diesel
Environmental Law and Justice Clinic, Golden Gate University School of Law
Communities for a Better Environment
Greenaction for Health and Environmental Justice
Healthy San Leandro Collaborative
People Organizing to Demand Environmental and Economic Rights
Regional Asthma Management and Prevention Initiative
West County Toxics Coalition
Asian Pacific Environmental Network
Hayward Citizens Against Pollution
Global Community Monitor
Science and Environmental Health Network
West Berkeley Alliance for Clean Air and Safe Jobs