County finds Colorado's Environmental Justice Screening Tool Deficient
Published on May 17, 2023
Weld County evaluated Colorado EnviroScreen and found the tool has significant deficiencies. Colorado EnviroScreen is an Environmental Justice (EJ) screening tool created by Colorado State University for Colorado Department of Public Health and Environment (CDPHE). The tool depicts the locations of Disproportionately Impacted Communities (DIC) based on the current definition in the Colorado’s Environmental Justice Act. As described on CDPHE’s website, these communities can directly benefit from money and resources. These communities could also be prioritized for enforcement and compliance initiatives and receive additional opportunities to participate in rulemaking and air permitting decisions.
Based on Weld County’s findings, Colorado EnviroScreen should not be used as a screening tool until its many significant deficiencies are corrected. The tool relies on outdated information, uses incorrect methods and documentation is unclear. EnviroScreen has a total of 35 datasets, 23 of which are of questionable quality. Examples of questionable data include air toxics, ozone, drinking water regulations and climate risks. In addition, the use of a “distance-weighted” approach produces inaccurate results which results in higher (i.e., worse scores) for rural areas and lower (i.e., better scores) for urban areas. This means that urban communities tend to have lower EnviroScreen scores, which provides a false impression that environmental burdens in those communities are lower than they might be in reality. The full list of deficiencies and limitations are documented in an 80-page report with a tabular summary of questionable data, maps of results, and recommendations. The report is available on Weld County’s website at https://www.weld.gov/Government/Departments/Commissioners/Climate-Conversation (under the “Air” section; March 2023 “A Review of Colorado EnviroScreen”).
The current tool could adversely impact communities that it intends to help. Users of the tool, including CDPHE, should not rely on this tool to formulate plans, distribute grants or implement regulations. Weld County has made these points clear in a current rulemaking in which the Air Pollution Control Division (APCD) is proposing to use EnviroScreen to make substantial decisions for permitting actions in DIC. Weld County has expressed concern with the reliance on the current version of EnviroScreen and its lack of a scientific peer-review process.
Before EnviroScreen is used for any purpose it should be subjected to an independent scientific review, particularly because the use of this tool has been proposed for regulatory purposes with significant social, financial, and legal implications. Given the questionable quality of data and methodologies used in EnviroScreen, any decisions made using this tool could be the wrong decisions.
As Environmental Justice rulemaking continues in Colorado, the Board is fully engaged with CDPHE and the APCD to ensure our most vulnerable populations are treated fairly and any rule proposing the use of EnviroScreen for decision-making be delayed until the tool is properly reviewed and corrected.