View Attachment B — Rules & Legislation Committee, February 29, 2024

Racial Equity Impact Analysis:

Eliminating Lead Paint Hazards
in Oakland & Alameda County
By: Marybelle N. Tobias
Principal, Environmental / Justice Solutions
For: Darlene Flynn
Director, Oakland Department of Race and Equity
September 2021
Attachment B
Environmental / Justice Solutions
Environmental / Justice Solutions (E/J Solutions) is a diverse, multilingual consulting practice dedicated to achieving environmental justice, equity, sustainability, and meaningful community engagement. Our approach to planning and policy development is data-oriented and community-based.

Our Services
★ Gather and ground-truth quantitative and qualitative data to identify over-burdened and under-served areas and priority community needs.
★ Community outreach, engagement, and meeting facilitation to enable consensus-oriented participatory decision making.
★ Inform policy initiatives with community-supported best practices to maximize equitable outcomes, including ongoing community oversight during implementation. ★ Develop equity performance indicators and metrics for guidance and accountability during implementation.

Principal
Marybelle Nzegwu
Tobias
Senior Associates
Colin Miller
Saki Bailey
Associates
Tran Diep Lam
Aitran Doan
ej.solutions
© 2021
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Table of Contents
EXECUTIVE SUMMARY 5
Existing Racial Disparities in Oakland & Alameda County 6 Recommended Actions 7
Conclusion 10
INTRODUCTION 11
Racial Equity Assessment of Lead Paint Hazards in Oakland & Alameda County 12 Lead Paint Lawsuit & Settlement Agreement 13
Alameda County’s Proposal: Lead-Safe Alameda County: 2030 14 Lead Paint 14
Lead Poisoning 16
Lead Poisoning Prevention 20
Primary Prevention 20
Secondary Prevention 21
Racial Disparities in Oakland & Alameda County 22
Racial/Ethnic Demographics 22
Historical Legacies 23
Mapping Disparities 24
Predominant Race (with Lead Risk Percentile statewide ranking) by Census Tract 27 Life Outcomes by Race 35
Equity Gaps in Lead Poisoning Prevention Programs 38
Lead Paint Hazard Equity Indicators 41
Increased Exposure to Lead Hazards 42
High Numbers of Lead Poisoned Children and/or Low Lead Testing Rates 42 Lead Risk 47
Density of Dwellings Built before 1940 48
Most Disadvantaged / Socially Vulnerable Communities 51 CalEnviroScreen 3.0 (2018) 51
Draft CalEnviroScreen 4.0 (2021) 55
Social Vulnerability Index 60
California Healthy Places Index 63
Housing Habitability / Substandard Housing Conditions 65 Oakland Baseline Equity Indicators 65
Housing Habitability Complaints 65
Small Rental Properties and High Housing Cost Burden 66 Additional Housing Related Indicators 67
Race/Ethnicity 68
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Poverty (Low Income & Low Wealth) 68
Density of Children in Poverty 69
Youth Educational Success & Overall Level of Educational Attainment 69 Increased Sensitivity to Lead Hazards 69
Poverty 70
Extremely Elevated Blood Lead Levels 70
Density of Children in Poverty 71
Pregnant Women & Low Birthweight Infants 71
Pre-existing conditions 74
Reduced Capacity for Protective Action 74
Desired Future Outcomes: Recommendations for Racially Equitable Lead Abatement in Oakland & Alameda County 75
Establish a Robust Joint Lead Hazard Abatement Program 75 Increase Community Governance and Oversight 76
Exceed Primary Prevention Standards & Meet Priority Community Needs 77 Adopt Proactive Secondary Prevention Policies 88
CONCLUSION 90
APPENDIX A: Key Resources 91
APPENDIX B: Background on Lead Poisoning Programs 92
Federal Government 92
State of California 92
Alameda County Public Health Department- Healthy Homes Department 93 City of Oakland 94
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EXECUTIVE SUMMARY
Lead poisoning caused by lead paint remains a dire threat to public health, well-being, and life outcomes in Oakland and Alameda County. The problem is so large that the rate of lead poisoning in some Oakland zip codes is higher than in Flint, Michigan at the height of its lead in the water crisis.

Lead paint hazards disproportionately a ﬀ
ect low-income and Black, Indigenous, and Latinx
communities due to the prevalence of older, dilapidated housing, which exposes children in poverty to lead paint hazards at the greatest rates. Moreover, after lead exposure, children in poverty suﬀ
er greater harms than children from higher-income families.

Environmental Justice Solutions (E/J Solutions) prepared this Racial Equity Impact Analysis (“REIA”) on behalf of the City of Oakland's Department of Race and Equity (“DRE”) toguide the City of Oaklandin partnering with Alameda County to develop and implement an equitable lead hazard abatement program. E/J Solutions conducted an independent review of existing research and quantitative data, to isolate indicators that can be used to identify the racial demographics and geographic locations of the communities most vulnerable to lead paint hazards. In addition, relying on best practices proposed by public health departments, lead equity advocates, or implemented in other cities, this report recommends policies that prioritize at-risk communities, remedy barriers to resources, ensure lead hazards are expeditiously removed from homes in vulnerable communities, and bolster local economic resilience.

Achieving equitable outcomes will require Oakland and Alameda County to align their joint eﬀ orts
behind a geographically focused approach that ensures early and comprehensive action in the vulnerable neighborhoods experiencing high poverty, fewer resources, and greater exposure to health risks. Equity requires every program, policy, and investment to providesigniﬁ cant and sustained
support to the people hurting most.1 Through thoughtful, whole-systems thinking that dedicates the majority of available funds to removing lead hazards from housing before children are poisoned in ways that meet priority community needs, Oakland and Alameda County can eliminate racial disparities in exposure to lead paint hazards, and reduce the severity and number of new cases of lead poisoning.

I have a case of a child who came two years ago as a refugee. His blood lead level was 8 μg/dL. We were able to ﬁgure out that the lead source may have been due to the eye makeup that they had been using since birth. e doctor recommended another blood lead test and six months later when it was tested, his blood lead level went up to 72 μg/dL. It was from the house this time.

Diep Tran, Alameda County Public Health Nurse2
2 Tram Nguyen, et al., Housing Habitability and Health: Oakland’s Hidden Crisis, Alameda County Public Health & Healthy Homes, April 2018, p. 13.
1 PolicyLink.

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Existing Racial Disparities in Oakland & Alameda County Socio-economic indicators, including education, neighborhood and physical environment, employment, social support networks, and access to health care, determine our health, well-being and life outcomes.

Inequities in key indicators of well-being disproportionately burden communities of color and low-income, low-wealth communities increasing their vulnerability to environmental hazards. Scoring and ranking census tracts is one helpful way to understand varying degrees of cumulative burden and compare the most burdened and least burdened communities. This report gathers data to deﬁ ne
existing disparities and shed light on the conditions and lived experiences of the most burdened and marginalized communities within Oakland and Alameda County.

Methodology and Findings. E/J Solutions gathered data on 357 census tracts in Alameda County from various sources. We converted the results for each indicator into a scale of 0-10 then summed the scores for each indicator to create anOverall Burden Scorefor each census tract. To zero in on the most burdened communities, we isolated the top 25 most burdened census tracts overalland for each indicator. We identi ﬁ
ed the share by race/ethnicity and compared Oakland to the remainder of Alameda County. We then averaged Oakland’s share of overall burden with its share of the most burdened census tracts as a way to identify Oakland’s equitable share of available lead paint settlement funds for Alameda County:60-70%. This also corresponds to the percentage of lead hazard cases reported to Alameda County between 2015-2020 that were located in Oakland.

Limitations. For brevity of reference this report defaults to the racial/ethnic categories of: (a)Black (b) Latinx (c) Asian and (d)White, which are the predominant racial categories in Alameda County census tracts. We acknowledge that this glosses over many distinctions within these categories and signiﬁ
cantly smaller groups, such as Indigenous populations, Mixed Race, and Paciﬁ c Islander are not
well-highlighted. The overall racial burden scores highlighted above identify each census tract by its predominant demographic group, but the report also includes several demographic tables that identify all of the major racial/ethnic groups: Latinx, White, Black Asian, Paciﬁ c Islander and Other/Multiple. In
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many neighborhoods, such as4064 (Reservoir Hill/Manzanita), Oakland’s three largest racial ethnic groups are similar in size.

Shifting Demographics. Over the last two decades, signiﬁ cant racial demographic shifts have resulted
in census tracts with higher lead risk that were until recently predominantly African American, such as Gaskill (4009), North Oakland: Bushrod and Santa Fe (4006 & 4007), Temescal 1 (4011), and Longfellow (4010) neighborhoods now being predominantly White. In addition, Latinx majorities in some census tracts grew. While African American and other Black residents may not be the predominant group, Oakland still remains home to a majority of Alameda County’s Black residents and this community remains a signiﬁ
cant plurality in the most burdened neighborhoods.

Existing Equity Gaps
➔ Lack of proactive policies and programs to locate and abate lead paint hazards in at-risk housing.
➔ Insuﬃ
cient outreach, education, and blood lead testing in at-risk communities. Outreach to tenants must directly result in increased blood lead testing. ➔ Scattershot and racially inequitable implementation.
➔ Lack of coordination between overlapping jurisdictions. ➔ Disjointed and outdated data.
➔ Insuﬃ
cient program capacity.
➔ Misplaced blame due to the myth of “personal responsibility.” ➔ Mistrust resulting from poor community engagement.
➔ Inadequate protections and lack of enforcement of existing tenant protections for low-income tenants.
➔ Financial barriers to remediation for low-income homeowners and landlords. ➔ Missed opportunity to boost local economic resilience through development of a robust pipeline of RRP-certi ﬁ
ed local businesses and contractors and workforce development programs that target at-risk individuals.

Recommended Actions
The City of Oakland and County of Alameda must address the factors that drive racially disparate lead poisoning impacts through holistic and proactive lead hazard abatement programming that prioritizes permanent lead rehabilitation in at-risk communities and simultaneously addresses multiple sources of lead alongside habitability and climate resilience needs. The following recommendations assume that the City and County will devote around 60-70% of Settlement Funds to the City of Oakland, with the entity that carries out the activity managing the necessary funds.

1. Improve ongoing ability to screen for and eliminate lead hazards through proactive approaches: (a) proactive inspections of rental properties dwellings and (b) lead-safe certiﬁ
cation requirements for childcare facilities and schools.

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a. The City of Oakland willproactively inspect for all habitability issuesincluding lead paint hazards, beginning in priority census tractsand executing blanket coverage of at-risk dwellings block-by-block.
b. As inspections progress, City inspectors will carefully assess the number of temporary relocations needed and gather qualitative data about other signi ﬁ cant burdens to the
neighborhood, such as road blockages or noise.
c. The City and County will prioritize lead-safe certiﬁ cations for OUSD schools and childcare
facilities.

2. Prioritize abatement, testing, outreach, and education activities in high-risk areas and serving the populations most likely to live in high-risk dwellings. a. The City and County will utilize a geographically-phased approach in Oakland which begins in the overburdened census tracts that are most vulnerable to lead paint hazards. b. When lead paint hazards are found in homes where children reside, the City will immediately refer the case to the County for blood lead testing and other case management services.
c. The County will also receive reports of unsafe housing conditions in Oakland. The most eﬃ
cient way to share this information with the City would be for the County to have direct access to the shared Equitable Lead Hazard Abatement Program database.

3. Ensure eﬃcient
remedy of lead hazards and simultaneously address all habitability issues and all sources of lead in the places at-risk children spend time. a. The City and County will both provide lead hazard control. The Equitable Lead Hazard Abatement Program Specialist will monitor all e ﬀ
orts in Oakland to ensure identiﬁ
ed
hazards are remediated in a timely fashion.
b. The County will continue to operate its HUD-funded Lead Hazard Repair Program, but will immediately refer dwellings within Oakland that it cannot service to the City, for lead hazard control to be overseen by the Equitable Lead Hazard Abatement Program Specialist. c. The ELHAP specialist will coordinate with landowners/homeowners and schools to oﬀ er any
needed funding support for tenant relocation and lead hazard rehabilitation.

4. Ensure robust data collection; compile a database of all lead hazards identiﬁ ed within the
City of Oakland and maintain comprehensive and up-to-date public records on lead hazards and rehabilitation and remediation eﬀ
orts.
a. The City and County will enter every dwelling or other facility where habitability issues are found into a Equitable Lead Hazard Abatement Program database that is searchable and sortable by habitability issues, particularly lead.
b. ELHAP will not close a case until all habitability issues have been remedied. c. The ELHAP program will monitor and produce annual evaluations of the impacts of the program disaggregated by race/geographic proxy (census tract level preferred), which will be periodically reported to the public for transparency and community engagement.

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5. Prioritize the needs of vulnerable and overburdened tenants, landlords and homeowners. a. The City will actively enforce existing tenant protections to prevent eviction and displacement.
b. The City and County will minimizeﬁnancial
burdens by increasing the amount ofﬁnancial
support
available to low-income homeowners who may be undergoingﬁnancial hardship—
both owner-occupied dwellings and landlords providing a ﬀ ordable housing— to fund
rehabilitation and repair activities, including grants or zero-interest loans, in order to ensure that lead hazards are abated in a timely fashion.
c. The City will support low-income landlords who provide aﬀ ordable housing by making funds
available to enable them to follow through on their obligation under Oakland City Ordinance Section 8.22.800 to provide temporary relocation assistance for tenants.

6. Bolster local economic resilience.
a. ELHAP should support workforce development to increase high-road, union-wage, family-sustaining jobs creation in partnership with the Oakland Workforce Development Board and the Cypress Mandela Training Center, and oﬀ
er job-placement support post
certiﬁ
cation.
b. The City will increase Renovation, Repair, and Painting training and certi ﬁ cation
opportunities for existing small local businesses through targeted outreach to businesses registered to do business in Oakland, particularly those owned by people of color. c. The City and County will collaborate to provide wraparound services to small local businesses located in at-risk neighborhoods.

7. Increase targeted public education eﬀ
orts in vulnerable communities.
a. Focusing on at-risk areas, the County should make education about lead hazards, remediation, and lead testing more widespread and accessible through popular education and translation of lead outreach materials into additional languages. b. The City will collaborate with the County to develop and carry out eﬀ ective outreach to
hard-to-reach populations, including through partnerships with local community-based organizations that are active on the ground.
c. The County will ensure that outreach eﬀ
orts translate directly into increased blood lead
testing.

8. Ensure meaningful community participation and oversight of lead poisoning prevention eﬀ
orts.
a. The City and County will ensure equitable governance, community oversight, and transparency by building in ongoing collaboration with a ﬀ ected communities .

Well-intentioned policies may nevertheless have unintended negative consequences if the most impacted community members are not part of the process. Unintended consequences include increasedﬁnancial
hardship, unfair stigmatization, failing to identify
children / households with lead risks, and prolonged exposure to lead.

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b. Prioritize impacted community needs in all phases of policy development, treating their lived experience and input with the same level of consideration given to other highly-credible types of data and information.
c. Make lead risk data available to families, policymakers, and other stakeholders who need information about sources of exposure, such as property-speciﬁ c information on leaded
drinking water pipes and lead in the water, dust, paint, and soil at or near homes, schools, and child care facilities.
d. Increase the number of community representatives on the Joint Powers Authority Board.

9. Generate additional funding to support ongoing lead remediation systems.

Conclusion
In addition to improving quality of life and the quality of the housing stock, Oakland and Alameda County can realize multiple cascading public health, safety, environmental, social, and economic beneﬁ
ts by creating and fully funding an equitable lead hazard abatement program. Researchers have found that eradicating lead paint hazards from older homes where children from low-income families reside would provide a return of approximately $1.39 in future beneﬁ ts per dollar invested.

Dedicated funding for an equitable lead hazard abatement program would protect young children from accruing high levels of untreated lead poisoning, which can cause brain damage, anti-social, erratic, or violent behavior, and limit their future economic livelihood. Lowering exposure to lead paint hazards will increase students’ academic performance, supporting higher attendance, graduation rates, and success later in life. Furthermore, Oakland can bolster economic and community resilience by ensuring more Oakland residents are gainfully employed in rehabilitating Oakland’s housing stock and adapting to climate change, addressing lead paint hazards, alongside mold, asbestos, weatherization for energy e ﬃ
ciency, and solar and electriﬁ
cation projects. As lead poisoning,
unemployment, housing insecurity, and houselessness decrease, so too will criminalized behavior, addressing multiple root causes of insecurity and signiﬁ cantly increasing public safety forall Oakland
residents.

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1.INTRODUCTION
Across the United States there are deeply entrenched inequities drawn along racial lines. Both historically and in the present day, racial discrimination has been perpetuatedde jurethrough federally and locally sanctioned practices. These systemic policies and practices cumulatively impacthealth outcomes, lived experiences, and life expectancy. Across almost every socio-economic indicator, Black, Indigenous, Latinx and other non-White communities fare the worst, resulting in poor quality of life and shortened life expectancy.3 The racialincome and wealth gapis enormous: African Americans earn 60% of the average White income and own only 5% of the wealth, a disparity which analysts estimate cost the U.S. about $2.4 trillion in 2014.4 Nationally, in 2015,racial health disparitieswere found to “cost the [national] economy an estimated $245 billion in excess health care expenditures, illness-related lost productivity, and premature deaths.”5 Although Oakland is one of the most racially
diverse cities in the country, it has a long history of systemic racial and economic discrimination.

Within the City of Oakland and the broader context
of Alameda County, there are extreme disparities
between neighborhoods and across numerous key
determinants of well-being, including access to a
clean environment, healthy food, recreational and
open space, educational achievement, living wage
employment, and decent housing.

Exposure to lead paint and lead poisoning are
among the inequitable outcomes facing
low-income communities and Latinx, Black,
immigrant, and refugee communities in the City of
Oakland and Alameda County. Several years ago,
Oakland’s O ﬃ
ce of Planning, Building &
Neighborhood Preservation estimated that medical
services, special education, disabilities, and lost
wages due to lead poisoning, cost city residents
upwards of $150 million each year.6
Figure 1. County of Alameda Lead Outreach Poster
6 City of Oakland Oﬃ
ce of Planning, Building & Neighborhood Preservation,Proposed Program Design for Proactive Code Enforcement Operations.
5 Ibid.; John Z. Ayanian, MD, The Costs of Racial Disparities in Health Care, Harvard Business Review, October 10, 2015. 4 PolicyLink, Racial Equity Impact Assessments.
3 City of Oakland Department of Race & Equity, Oakland Equity Indicators: Measuring Change Toward Greater Equity in Oakland, 2018.

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1.1. Racial Equity Assessment of Lead Paint Hazards in Oakland & Alameda County
As systemic institutional practices have placed certain groups in harm’s way, each institution must play a part in reversing inequitable outcomes. Unless equitable considerations are infused into every aspect of policy design and implementation, even well-intended policy interventions may inadvertently exacerbate inequality, with costly results. Policymakers are now seeking out viable methodologies, programs, and policies that can remedy entrenched harms.

Oakland Municipal Code section 2.29.170 speciﬁ
es that “the City of Oakland will intentionally integrate, on a Citywide basis, the principle of ‘fair and just’ in all the City does in order toachieve equitable opportunities for all people and communities.”7 Section 2.29.170 deﬁ nes inequitable outcomes as
“diﬀ
erences in well-being that disadvantage one individual or group in favor of another” and acknowledges that the “diﬀ
erences are systematic, patterned, unfair andcan be changed. Inequities are not random; they are caused by past and current decisions, systems of power and privilege, policies and the implementation of those policies.” The Department of Race and Equity’sRacial Equity Implementation Guide provides a roadmap for City departments to follow in developing racially equitable policies.

Following DRE’s roadmap, E/J Solutions conducted an independent review of existing research and quantitative data from several public sources, including research and data shared by Alameda County Public Health Department’s Healthy Homes Department, which has been working in lead poisoning prevention for several decades. The REIA identiﬁ
es racial inequities that will be exacerbated if not
directly addressed and actions that can be taken to advance equity and meaningfully impact outcomes in the low income communities and Latinx, Black, Indigenous, immigrant, and refugee communities in Oakland and Alameda County experiencing high poverty rates and greater exposure to health risks.

1. Census tract by census tract comparison of the disparities facing a) low-income and b) non-White communities in Oakland and Alameda County that lead to increased vulnerability to lead poisoning;

2. Methodologies for prioritizing high-risk populations and neighborhoods;

3. Identiﬁ
cation of equity gaps in present-day lead poisoning prevention eﬀ orts: the agencies,
programs, and protocols related to discovery and remediation or abatement of lead paint hazards; and

4. Description of equitable program elements, including data gathering data to monitor and evaluate program implementation and ensure equity goals are met.

This REIA will guide the City of Oakland in partnering with Alameda County to ensure that joint eﬀ orts
result in equitable discovery and abatement of lead hazards and dramatically reduce present-day racial disparities in lead poisonings. The REIA’s approach and recommendations are particularly aligned with Alameda County’s “Housing Habitability and Health: Oakland’s Hidden Crisis” published in April 2018 as 7 City of Oakland Municipal Code Section 2.29.170.

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well as the lead equity recommendations developed by lead policy experts during the Equity Analysis of Lead Policies Consensus Conference held in November 2018.

Only by directing a lion’s share of any available funds toward addressing the deeply entrenched barriers that have hindered progress toward total remediation of lead hazards will vulnerable communities no longer be systematically exposed to lead hazards and receive the resources necessary to thrive.8 This equitable goal provides an opportunity for transformative approaches that shun the status quo and dismantle and reverse the policies and practices that exacerbate inequitable outcomes.

The framework is centered on actualizing the equity principle of healthy housing as acommunity asset in which local and regional governments should invest for the beneﬁ t of the greater good. The
numerous beneﬁ
ts associated with closing racial equity gaps and increasing access to healthy housing include:
➔ Eﬃ
cient and eﬀective resource allocation that reduces intransigent problems more quickly;9 ➔ Reversing legacies of discrimination;
➔ Making access to aﬀ
ordable and habitable housing a human right;
➔ Improving public health, safety and quality of life;
➔ Boosting Oakland and Alameda County’s tax base and desirability as places to live.

1.2. Lead Paint Lawsuit & Settlement Agreement
In July 2019, Santa Clara, Alameda, Los Angeles, Monterey, San Mateo, Solano, and Ventura Counties along with the City and County of San Francisco, and the Cities of Oakland and San Diego, entered into a landmark $305 million Settlement Agreement with Sherwin-Williams Co., ConAgra Grocery Products Co. and NL Industries Inc., lead paint manufacturers who knowingly sold a harmful product in accordance with “industry standards.” Alameda County and the City of Oakland are the only two parties to the Settlement Agreement with overlapping jurisdiction and shared responsibility to reduce child lead poisoning in Oakland.

Under the Lead Settlement Memorandum of Understanding, Alameda County and the City of Oakland will jointly receive 10% of the settlement abatement funds to be paid out over seven years (approximately $24 million). The abatement funds were allocated by averaging percentages of pre-1978 housing stock and pre-1951 housing stock. The funds will be “distributed to the County of Alameda to be held in a trust account in the County of Alameda treasury until the County of Alameda and the City of Oakland come to a joint agreement on the ultimate disposition of the funds.” The settlement funds may be used to address public health hazards, bodily injury, personal injuries, and property damage related to lead paint. Such eﬀ
orts may include but are not limited to developing
or enhancing “programs that abate lead from housing, particularly housing occupied by low-income individuals;” providing “services to individuals, particularly children who have been exposed to lead 9 Oakland-Berkeley-Alameda County Continuum of Care, Centering Racial Equity in Homeless System Design, January 2021, p. 3.
8 Human Impact Partners, Achieving Equity in Lead Poisoning Prevention Policy Making: Proceedings from a Consensus Conference, November 2018, p. 12.

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paint; and educating the public “about the hazards caused by lead paint, and the best means of avoiding exposure to and remediating the harms caused by lead paint, including the availability of funding for lead abatement.”

1.3. Alameda County’s Proposal: Lead-Safe Alameda County: 2030 Along with overlapping jurisdiction, the City of Oakland and Alameda County have shared responsibility to reduce child lead poisoning and can work in partnership as both have existing programs that provide lead abatement services. “The County of Alameda and the cities of Alameda, Berkeley, Emeryville, and Oakland have worked together for 27 years . . . to address the multi-faceted problems presented by lead-based paint and other lead hazards in our communities.”10 Alameda County proposes a ten-year plan for primarily ramping up existing lead poisoning prevention activities in Oakland and Alameda County, utilizing over two million annually of the settlement funds under a comprehensive, coordinated plan, MOU, and a jointly-approved spending framework. The Lead Abatement Joint Powers Authority would provide oversight and the Plan would be rati ﬁ ed
through adoption by both the Alameda County Board of Supervisors and Oakland City Council. City and County activities will “complement and support each other” and both jurisdictions can leverage existing programs and seek out additional funding to enhance services and ﬁ ll gaps.

Alameda County initially proposed to spend no less than 34% of settlement funds in Oakland, with the possibility for that percentage to rise to 42% “based upon community needs assessment.” After early discussions about this REIA’s ﬁ
ndings, Alameda County now proposes to spend no less than 60% of settlement funds in Oakland.

1.4. Lead Paint
Lead (atomic symbolPb) is a naturally occurring, “soft, grayish metal with poisonous salts.”11 This toxic metal is relatively easy to ﬁnd
and extract, and especially useful for industrial purposes. It is non-biodegradable, durable yet malleable, resistant to certain levels of corrosion, and helps reduce long-term water damage.12 These properties make lead a widely-used commercial additive. Tetraethyl lead was added to gasoline in 1921 to help reduce engine knocking and wear and tear. Almost immediately, industry workers started to become extremely ill, and some lost their lives. “At Dupont's manufacturing plant in New Jersey, it was particularly bad — eight workers died between 1923 and 1925.”13 At one time or another, lead has been used in gasoline, paint, solder, water pipes, and cosmetics, as well as other products. Despite this widespread use, lead is an extremely potent toxin; exposure to lead is extremely dangerous to human health and well-being, and isparticularly harmful to young children (0-6 years old).
13 Clair Patterson And The Age Of The Earth, History of Lead Use in America, publish.illinois.edu. 12 California State Auditor, Childhood Lead Levels: Millions of Children Have Not Received Required Testing for Lead Poisoning, January 2020, p. 5; see also Traci Pedersen, “Facts About Lead,” Live Science, October 6, 2016. 11 Concept Page, “Lead,” Harvard Catalyst Proﬁ
les (“atomic number 82, atomic weight 207.19”).
10 Alameda County Community Development Agency, Healthy Homes Department, Lead-Safe Alameda County: 2030, p. 6.

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Although corporations in the lead paint industry were well aware of lead’s toxicity and its risks to public health by the early 20th century, the federal government did not ban use of leaded paint until 1978. It is possible for any home built before 1978 to have lead paint, although the older the home, the more likely it is to have several layers of decaying lead paint. Lead paint manufacturers were also aware that lead paint “powders and chalks” “soon after it is applied” and produces lead dust after a couple of years. Sales of lead paint peaked in 1922, began decreasing in the 1920s and early 1930s and by 1944, use of lead paint for residential interiors had declined to a low level.14 In addition to lead paint hazards, nearly all homes built before the 1980s also have lead solder connecting to copper pipes. Leaded gasoline was not fully banned for all on-road vehicles until 1996, and the fallout from those tailpipe emissions still contaminates outdoor soil. 15 The aviation fuel “avgas” and industrial batteries still contain lead and some cosmetics and toys have been found to contain lead.16 After the lead paint ban was enacted, there was little systemic action to remove the lead paint that remained on the interior and exterior surfaces of dwellings and other buildings. In essence, the national emergency was swept under the rug. Due to this inaction, and the fact that lead does not degrade once it is in the environment,lead paint has remained a pressing public health issue that disproportionately aﬀ
ects low-income, low-wealth communities and Latinx, Black, immigrant, 16 Ibid.
15 Nathan McClintock, Assessing Soil Lead Contamination at Multiple Scales in Oakland, California: Implications for Urban Agriculture and Environmental Justice.
14 See People v. Conagra Grocery Products Company, (2017) 17 Cal.App.5th 51.

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and refugee communities. While blood lead levels in the general U.S. population have declined steadily, there continues to be a high prevalence of low-level lead exposure among the general population, including pregnant women.17

1.5. Lead Poisoning
Lead is an extremely powerful neurotoxicant, which “can aﬀ ect almost every organ and system in the
body” and the brain (central nervous system) is the most sensitive, particularly in young children.

Humans are poisoned when theybreathe in or ingest the lead, which circulates through the blood, leading to elevated blood lead levels, and is distributed to the brain, liver, kidney, and bones. Teeth and bones store the lead where it accumulates over time. Exposure to lead presents a dire threat to public health, well-being, and children’s growth, education, development, and life outcomes.

Table 1: Terminology & Abbreviations
Lead Pb
Blood Lead Level BLL or PbB
Elevated Blood Lead Level EBLL
Micrograms per deciliter
Unit of measurement for blood lead levels
μg/dL
Although there are a number of sources of lead hazards,the main and most important method of exposure for children is ingestion of lead paint dust and chips.18 Lead paint in homes is a major contributor to blood lead levels because the lead content in lead-based paint is high, while most other sources only contain trace amounts of lead. A well-maintained surface with lead-based paint does not pose a hazard. However, as lead paint ages, it chalks, peels, or chips, creating hazardous conditions when old buildings fall into disrepair or are renovated improperly. Deteriorating lead paint, especially on surfaces that rub together, such as sliding windows, contaminates indoor dust and outdoor soil.

Lead-based paint and lead paint conaminated dust are the most widespread and hazardous sources of lead exposure for young children in the United Sates.

Center for Disease Control
Low-income communities and Latinx, Black, immigrant, and refugee communities “face disparate risk from older, poor-quality housing.” 19 Children younger than six are especially vulnerable to lead poisoning and its harmful eﬀ
ects— due to their increasing mobility (crawling, putting their hands in 19 Housing Habitability and Health: Oakland’s Hidden Crisisat p. 6. 18 David Norris, Jillian Olinger, and Mary McKay, The Weight of Lead — Part I: How Contaminated Houses Are Poisoning the Poor, ChangeLab Solutions, January 2018.
17 Motao Zhu et al., Maternal low-level lead exposure and fetal growth, Environmental Health Perspectives, vol. 118,10 (2010) (In 2003–2004, “the mean PbB among women 18–49 years of age was 1.2 μg/dL, with a 95th percentile of 2.6 μg/dL.”)
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their mouths) and early stage of development. Lead-contaminated environments can cause a young child’s blood lead concentrations to increase rapidly between the ages of six and 12 months, with the rapid rise peaking between 18 months and 36 months of age. Young children can also absorb lead more eﬃ
ciently than adults, are less likely to eliminate it through their waste once it has entered their bodies, and are more susceptible to its negative health eﬀ ects. Lead remains harmful to children over
the age of six, adults, and the elderly, and can harm the reproductive system.

Millions of women
of child-bearing age
have lead stored in
their bones due to
exposure as
children. Lead
stored in a pregnant
mother’s bones is
released during
pregnancy,
exposing the
developing fetus to
lead poisoning.

Studies have linked
slightly elevated
maternal blood lead
levels (5 -10 μg/dL)
to reproductive
problems such as
reduced fetal
growth and low birthweight, and highly elevated maternal PbB (≥ 10 μg/dL) doubles the risk of harm to the baby.20 Even lead exposure that ends well before pregnancy can lead to reduced birth weight or developmental issues.21 Lead contamination begins in the second trimester of pregnancy, increases during the third trimester “when the baby is growing rapidly and incorporates nutrients and toxins from its mother,” and continues to accumulate after birth during the baby’s ﬁ rst year.22 Lead may also
leach into breastmilk, further exposing newborns to lead poisoning even before they are able to crawl about and ingest any hazards in their environment.

The Center for Disease Control and Prevention (CDC) now deﬁ nes an elevated blood lead level as5
μg/dL and states thatno level of lead exposure is safe.23 Indeed, for young children, blood lead levels below 5 μg/dL can harm normal development patterns, and impair nervous system development, 23 Center for Disease Control and Prevention, Blood Lead Levels in Children(“This value [5 μg/dL] is based on the U.S. population of children ages 1-5 years who are in the highest 2.5 percent of children when tested for lead in their blood.”) 22 Leigh Hopper, Lead contamination found in baby teeth of children living near Exide battery plant, USC News, May 6, 2019. 21 World Health Organization, Lead Poisoning and Health (“Because lead is known to delay physical and mental development in babies, lead poisoning is a likely contributor to babies born with low birth weight”). 20 Maternal low-level lead exposure and fetal growth.

Environmental / Justice Solutions | 17

resulting in permanent brain damage, learning disabilities, speech and language deﬁ ciencies, attention
deﬁ
cit hyperactivity disorder, and aggression. Many of the health impacts are irreversible, causing lifelong debilitation, including delinquency, and antisocial behaviors. Health care providers do not treat lead poisoning “until the child’s blood lead level is above 4.5 μg/dL because the medicines also remove other good things in the body like potassium and calcium, creating a serious imbalance.”24 Table 2. Increasing Harmful Eﬀ
ects of Lead Poisoning25
BLL (μg/dL) Potential Health Impacts Services Available Below 4.5 Harm to Brain/Central Nervous System
● Reduced IQ
● Attention Deﬁ
cit Hyperactivity
Disorder (ADHD, inability to pay
attention).

The American Academy of Pediatrics has
found that “one in ﬁ
ve cases of attention
deﬁ
cit/hyperactivity disorder among U.S.
children has been attributed to lead
exposure,” limiting their prospects for
academic achievement and reducing their
productivity later in life.

Tested Children: Health care providers
will assess nutrition, consider lead
exposure risk, and provide counsel on
identiﬁ
ed risk factors.

Untested Children: High likelihood of
EBLL going undetected due to absence
of other health impacts and systematic
lack of testing.

4.5 - 9.4 Damaged Hearing
Similarly to ADHD, a child’s undiagnosed
hearing loss due to undiagnosed lead
poisoning could lead to severe disciplinary
consequences.

Tested Children: Health care providers
will retest in 1-3 months, test for iron
suﬃ
ciency, and the local prevention
program provides outreach and
education.

Untested Children: High likelihood of
EBLL going undetected due to absence
of other health impacts and systematic
lack of testing.

9.5 - 14.4 Behavioral Disorders (aggressive,
destructive or delinquent behaviors)
Tested Children: Health care providers
will retest in 1-3 months. If at this level
for two tests at least 30 days apart, the
local prevention program provides “full
case management services.”
Untested Children: High likelihood of
EBLL going undetected due to absence
of other health impacts and systematic
lack of testing.
25 Childhood Lead Levels: Millions of Children Have Not Received Required Testing for Lead Poisoningat p. 6. 24 Housing Habitability and Health: Oakland’s Hidden Crisisat p. 13.

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14.5 - 69.4 Harm to Cardiovascular System(high blood
pressure)
Harm to Immune System
Anemia
Vitamin D Deﬁ
ciency
Impaired Tooth & Bone Development
Tested Children: Full case management
services with increasing frequency of
testing. Hospitalization and chemical
treatment to reduce BLLs after BLL
reaches 44.5. Test kidney function.

Untested Children: Severe physical
impacts will likely result in medical
attention.

Above 69.5 Seizures
Comas
Death
Tested Children: Hospitalization and
chemical treatment to reduce BLLs
after BLL reaches 44.5. Test kidney
function.

Untested Children: Severe physical
impacts will likely result in medical
attention.

According to the City of Pasadena’s Public Health Department, a very small amount of lead can cause lead poisoning, “just enough lead to equal one granule of sugar each day over a period of time will raise a child’s blood lead level enough to require treatment.”26 Because of lead’s bioaccumulative nature, most cases of lead poisoning are caused by this type of chronic exposure to low-doses of lead, or slow lead poisoningas lead accumulates in the body over time.27 A child with lead poisoningmay not seem sick, but some children may have stomach problems, trouble sleeping, less energy than normal or may have problems concentrating. For children, slow lead poisoning may presentprimarily as learning and behavioral issues; in teens and young adults, it may be associated with increased school dropout rates and aggressive behavior. Thus, “despite the very real and measurable impacts of lead poisoning on children, their families, and society at large, children who are lead poisoned often exhibit few or no obvious symptoms at the time when intervention is most eﬀ ective: when the
child is young.”28
e California Sate Legislature has named childhood lead exposure as the most signiﬁcant childhood environmenal health problem in the sate.29
29 Childhood Lead Levels: Millions of Children Have Not Received Required Testing for Lead Poisoningat p. 10. 28 Toledo Lead Poisoning Prevention Coalition, Lead Poisoning Report: The Eﬀects of Lead Poisoning on African-American and Low-Income Families in Toledo, Ohio, Kirwan Institute, March 2016.
27 Traci Pedersen, Facts About Lead, Live Science, October 6, 2016. 26 City of Pasadena Public Health Department, Childhood Lead Poisoning Prevention.

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1.6. Lead Poisoning Prevention

1.6.1. Primary Prevention
The gold standard—the most direct way to prevent childhood lead poisoning— is to completely remove lead hazards from the dwellings and day care centers where young children spend signiﬁ cant
amounts of timebefore a child is exposed, referred to asprimary prevention. Primary prevention has two main prongs: (1)proactive discovery of lead based paint hazardsand (2) total abatement of lead hazards. Older, dilapidated housing occupied by low-income families carries the greatest lead risks. Much of the housing in vulnerable neighborhoods was built long before the lead paint ban, is renter-occupied, and is generally low value, making it less likely that property owners have invested in maintenance and renovations to contain or remove lead paint hazards, especially on doors and window frames where lead dust particles are most likely to originate. Residential lead hazard control is an e ﬀ
ective prevention strategy that has been found to signiﬁ cantly reduce the likelihood of
subsequent lead poisoning cases in buildings where children had been poisoned in the past.

Researchers have found that the most e ﬀ
ective existing policies for equitably achieving primary prevention of lead paint hazards includeproactive rental inspection programsand funding for lead abatement to ensure the work is completed in a timely and safe manner.30 Removing Lead Hazards
Remediation refers to the use of temporary containment measures, such as dust clearance, paint stabilization (covering exposed lead paint surfaces with non-lead paint), control of abrasion or friction points (repairs to eliminate surfaces where friction can generate lead dust particles if lead paint is present), and other measures that can eﬀ
ectively minimize lead exposure.

These interim control measures can be less costly, but have a shelf life and will have to be repeated.

The tenant or homeowner will need to perform proper and adequate maintenance to keep the threat minimized, and the City will have to inspect the property periodically, at appropriate intervals, and reapply the control measures.

Abatement refers to the permanent elimination of lead-based paint hazards, which tends to be more costly, time and labor intensive, and require tenant relocation. However, the social beneﬁ ts of
promoting total abatement likely outweigh the economic costs.

Lead Renovation, Repair and Painting Program “Unsafe and unregulated remodeling and renovation of older housing that contains lead-based paint poses signi ﬁ cant hazards that can
increase children’s blood lead levels by as much as 69 percent.”31 EPA's Lead Renovation, Repair and Painting Rule (RRP) Rule requires thatﬁrms
performing renovation, repair and painting projects that disturb lead-based paint in homes, child care facilities and pre-schools built before 1978 be certiﬁ ed
31 Health Impact Project, 10 Policies to Prevent and Respond to Childhood Lead Exposure: An assessment of the risks communities face and key federal, state, and local solutions, Pew Charitable Trust, 2018, p. 52. 30 Jill Witkowski Heaps, Stop Lead Poisoning from Harming Your Community, Earthjustice, p.2.

Environmental / Justice Solutions | 20
by EPA (or an EPA-authorized state), use certiﬁ
ed renovators who are trained by EPA-approved
training providers and follow lead-safe work practices.

Applying equity standards (prioritization of the neediest groups) to primary prevention results in the following program goals:
➔ Prioritizing the complete abatement of lead hazards from high-risk locations where vulnerable children spend time in order to minimize exposures and eliminate racial disparities in lead poisoning. This means, intentionally prioritizing abatement of lead hazards in dwellings occupied by low-income residents in theﬂatlands
of Oakland and other high-risk, highly
burdened areas in Alameda County.
➔ Making lead-safe property management and maintenance the “standard of care in Alameda County”32 by fostering the development of local knowledge of lead-safe work practices and bolstering the local economy through strategies that: (a) increase the number of small, local, BlPOC-owned businesses EPA-certi ﬁ
ed for renovation, repair, and painting (b) provide
workforce development, job placement, and wraparound support services for disadvantaged workers.

1.6.2. Secondary Prevention
Blood lead testing and follow-up services, referred to assecondary prevention, are an essential safety net that should be deployed alongside primary prevention eﬀ orts. State law mandates a targeted
approach that prioritizes testing the children (at ages 1 and 2) who are at the greatest risk of lead poisoning. Blood lead testing is not liberally accessible, however, and even children mandated by law to receive lead tests have not been tested. There needs to be more systematic blood lead testing of all children ages 0-6 years. Due to the likelihood that behavioral or learning issues may be the only external indicator of possible lead poisoning, our public health and public school system should be investigating whether children exhibiting behavior problems have potentially been exposed to lead.

It is important to note, however, thatblood lead levels may not be the most eﬀ ective methodology
for understanding lead exposure over time. Though lead exposure is typically measured through blood tests, some lead policy experts maintain that blood tests can only detect relatively recent exposures as lead does not remain in the bloodstream indeﬁ nitely, instead moving from the blood to
be stored in organs, teeth, and bones. Researchers have pointed to the much more comprehensive data on prenatal and early life exposure that can be gleaned from teeth, such as the ability to “assign time points for lead contamination,” which includes the ability to conﬁ rm in-utero lead poisoning.

The lead stored in teeth can be an important indicator of harm; higher lead in teeth means higher lead in the brain, kidney and bones.33
33 Jill E. Johnston et. al., Lead and Arsenic in Shed Deciduous Teeth of Children Living Near a Lead-Acid Battery Smelter, Environmental Science & Technology 2019 53 (10), 6000-6006. DOI: 10.1021/acs.est.9b00429; see also Lead contamination found in baby teeth of children living near Exide battery plant. 32 Lead-Safe Alameda County: 2030
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2. Racial Disparities in Oakland & Alameda County

2.1. Racial/Ethnic Demographics
Oakland is the oldest city in Alameda County,ﬁrst
incorporated as the Town of Oakland in 1852, and
reincorporated as the City of Oakland in 1854. Oakland is also remarkably one of the most diverse cities in the United States. Unfortunately, this diversity is not only inﬂux, but it has always been subject
to extreme racial disparities in lived experiences and outcomes. Between 2000 and 2015, historically Black cities and neighborhoods across the Bay Area, particularly in the ﬂatland neighborhoods in
Oakland, lost thousands of low-income Black households. The Citylost over 54,000 black residents between 1990 and 2010, a 33.6 percent decline.34 Low-income households of color were much more vulnerable than low-income White households to the impact of rapid increases in housing prices. A 30% tract-level increase in median rent paid between 2000 and 2015 was associated with a 28% decrease in low-income households of color, but there was no signiﬁ cant relationship between
rent increases and losses of low-income White households.35 Table 3. Racial/Ethnic Demographics of Oakland
Race/Ethnicity # of Residents Percentage of Population
Asian 65,902 15.5%
African American/Black 100,966 23.8%
Latinx 117,942 27%
White 150,827 35.5%
Total Population 435,637
Oakland is about one quarter of the population of Alameda County. The majority of Alameda County’s African American/Black population (57%) resides in Oakland.

Table 4. Racial/Ethnic Demographics of Alameda County (Includes Oakland) Race/Ethnicity # of Residents Percentage of Population
African American/Black 175,751 10.6%
Latinx 371,019 22.4%
Asian 499,382 30.1%
White 670,364 40.5%
Total Population 1,716,516
Source: 2019 American Community Survey 5-year estimate
35 Urban Displacement Project, Rising Housing Costs and Re-Segregation in the San Francisco Bay Area, p. 3 34 PolicyLink & City of Oakland, A Roadmap Toward Equity: Housing Solutions for Oakland, California, 2015.

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2.1.1. Historical Legacies
Many are unaware that Oakland and other Bay Area cities led the nation in developing racially exclusionary and segregationist policies that were subsequently adopted across the country. Article 34 in California’s Constitution created major roadblocks to construction of public and aﬀ ordable housing
and originated in Oakland. Berkeley’s 1916 explicitly racist zoning ordinance, which prohibited multi-family dwellings and apartments, has become a standard method for ensuring majority-White, suburban and
“desirable”
neighborhoods
that protect
community
wealth and
high property
values to the
present day.36
Map A. A
"residential
security map"
created by the
Home Owners'
Loan
Corporation
(1937)37
The federal
practices of
redlining, instituted in the 1930s, restrictive covenants in housing deeds prohibiting sale to African Americans, and excluding professions that were over 85% African American from the originalSocial Security Act allowing states to justify lower payouts for African Americans, merely continued and reinforced these local practices.

The ongoing legacy of exclusionary practices, such as redlining, is not only still visible today, it continues to cause extreme disparities in health and economic outcomes between majority White and majority non-White census tracts in Oakland and Alameda County. These disparities create signiﬁ cant
and present danger for Latinx, Black, immigrant, and refugee communities—threatening health and wellbeing, and impeding growth, education, development, and wealth. Majority White census tracts have higher incomes, more tree cover, and better quality housing, while by contrast majority 37 Erika Kelly & Brian Watt, Has Oakland's Fruitvale Neighborhood Ever Recovered From 'Redlining'?, KQED, February 9, 2018. 36 Haas Institute for a Fair and Inclusive Society, Roots, Race & Place: A History of Racially Exclusionary Housing in the San Francisco Bay Area, UC Berkeley, October 2019, p. 15.

Environmental / Justice Solutions | 23

non-White census tracts have lower incomes, lack trees and open space, and bear “the brunt of unhealthy housing issues.”38
The area known as the Fruitvale, was coded red on the HOLC map due to “odors from industries . . . the predominance of foreign inhabitants” and “inﬁ
ltration of Negroes and Orientals.” This neighborhood
still suﬀ
ers from a dearth of investment today andhas more lead poisoned children than Flint, Michigan.39 When White residents ﬂed
to the suburbs, they left the redlined neighborhood to
residents of color who were systematically denied access to credit, preventing them from becoming homeowners or entrepreneurs and severely limiting their opportunities to create generational wealth.

All of the census tracts in the Fruitvale (4062.02, 4071.01, 4071.02, and 4072) are majority Latinx today.

From 1951 to 1957 municipalities in the agricultural and grasslands area of current-day Alameda County rushed to incorporate, resulting in the rapid development of new cities -- Newark, Fremont, and Union City -- and expanding Hayward. These newly-incorporated East Alameda County cities were recipients of the ‘Whiteﬂight’
from the urban core of cities like San Francisco, Oakland, and Richmond.

For example, within 15 years of incorporation Fremont remained 97% White -- typifying the demographic patterns in East County that resulted from local racially exclusionary practices and policies, paired with Federal subsidies. 40 As UC Berkeley’s Othering and Belonging Institute has documented, “racial segregation [in Alameda County] has changed very little since 1970, and remains almost exactly at the same level.”41
Mapping Disparities
Census Tracts. The most consistent data across indicators available is at the census tract level. The U.S. Census Bureau provides a unique number to identify each tract. Census tract data oﬀ ers ﬁner
grained, more localized information than zip codes or citywide data. This report references census tracts as the primary geographic unit for comparison; where a data source uses zip codes or another geographic scale, the census tracts that fall within those boundaries are identiﬁ ed.

Unless otherwise noted, demographic data in this report is sourced from the most recent American Community Survey (ACS) data at time of writing. (Unless a source is otherwise indicated, the GIS maps used in this report were generated by E/J Solutions). 41 Othering and Belonging Institute, Racial Segregation in the San Francisco Bay Area, Part 3: Measuring Segregation, UC Berkeley, May 2019.
40 Haas Institute for a Fair and Inclusive Society, Roots, Race & Place: A History of Racially Exclusionary Housing in the San Francisco Bay Area, UC Berkeley, October 2019, p. 58.
39 M.B. Pell and Joshua Schneyer, The thousands of U.S. locales where lead poisoning is worse than in Flint, Reuters, December 19, 2016.
38 Steve King et al., Building an Indicator Base for Healthy Housing Issues in Oakland, Urban Strategies Council, Alameda County Healthy Homes Alliance, November 2013.

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Map B. United States 2020 Census Census Tract Reference Map Oakland Neighborhood Names. Although census tracts each have a unique number identiﬁ er,
without constantly referencing a map, it can be diﬃ
cult to get a grasp on the locations the numbers
refer to or to use them in discussion. To aid ease of reference, Urban Strategies Council developed a map that provides a corresponding neighborhood name to each census tract in the City of Oakland, reproduced below. This report will identify census tracts in Oakland by: (a) number, (b) neighborhood name, (c) district, and (d) zip code. (Some of the neighborhood names used by Urban Strategies Council cover more than one census tract, in which case we have added a 1, 2, or 3 to the name to distinguish the diﬀ
erent tracts.)
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Map C. Census Tracts and Neighborhood Names, Urban Strategies Council Cities and Census Designated Places within Alameda County. Due to its focus on Oakland and other constraints, the report does not supplement the census tract numbers of geographic areas in Alameda County outside of Oakland with neighborhood names.

Alameda
Albany
Ashland CDP
Berkeley
Castro Valley CDP
Cherryland CDP
Dublin
Emeryville
Fairview CDP
Fremont
Hayward
Livermore
Newark
Oakland
Piedmont
Pleasanton
San Leandro
San Lorenzo CDP
Sunol CDP
Union City
Other Alameda County
Environmental / Justice Solutions | 26

2.1.2. Predominant Race (with Lead Risk Percentile statewide ranking) by Census Tract
Data disaggregated by race is fundamental to racial equity impact assessments. Too often, however, the racial categorizations consistently available are concurrently extremely broad and extremely limiting. For example, the category of Asian covers people from numerous nationalities/ethnicities and it is often diﬃ
cult to disaggregate the subcategories from the umbrella category, which masks the equity gaps experienced by some groups. Similarly, there is no category on the census that adequately represents Middle Eastern or North African identities. Nevertheless, the disparities between White and non-White census tracts are stark.

The maps of Oakland and Alameda County below color-code census tracts by the racial/ethnic group with greatest numbers; darker shades indicate higher concentrations of the predominant racial group.

The tables below the maps list the census tracts according to their predominant racial/ethnic group alongside their statewide percentile rank for Lead Risk, as calculated by the California Environmental Protection Agency’s Oﬃ
ce of Environmental Health Hazard Assessment. On the tables, census tracts in the top 5% of Lead Risk statewide (95+) are coded in the darkest red; census tracts between the top 15% - 6% (85-94) are in the next darkest shade; the lightest shade of red marks the census tracts in the top 25% - 14% (75-84). Below the 75th percentile is unshaded.

Map D. GIS map of Predominant
Racial/Ethnic Group by Census
Tract: Oakland
Key
Environmental / Justice Solutions | 27

Table 5. Oakland: Predominantly Latinx Census Tracts
CT Neighborhood Lead
Pctl
CT Neighborhood Lead
Pctl
4059.01 Lower San Antonio 1 92.83 4086 Bancroft/Havenscourt 2 99.85 4061 Jingletown/Kennedy Tract 81.14 4087 Bancroft/Havenscourt 1 98.49 4062.01 Reservoir Hill/Meadow Brook 97.24 4088 Havenscourt/Coliseum 98.99 4062.02 Fruitvale/Hawthorne 96.13 4089 Fitchburg/Hegenberger 93.49 4063 San Antonio/Sausal Creek 93.83 4090 Oakland Airport 97.88 4065 Peralta/Hacienda 93.88 4091 Brockﬁ
eld Village 99.43
4070 Lower Laurel/Allendale 89.26 4092 Sobrante Park 90.56 4071.01 Harrington/Fruitvale 90.71 4093 North Stonehurst 97.71 4071.02 Jeﬀ
erson/Fruitvale 95.34 4094 Elmhurst Park 97.58
4072 Fruitvale 97.02 4095 Woodland/Tassafaronga 98.33
4073 Lockwood/Coliseum 95.43 4096 Webster 97.28
4074 Fremont 99.53 4097 Castlemont 92.68
4075 Seminary 99.37 4103 Cox/Elmhurst 94.86
4085 Arroyo Viejo 96.76 4104 Durant Manor 86.79
Table 6. Oakland: Predominantly African American/Black Census Tracts CT Neighborhood Lead
Pctl
CT Neighborhood Lead
Pctl
4014 Hoover/Foster 88.57 4077 Maxwell Park 80.86
4015 Clawson/Dogtown 74.57 4082 Millsmont 85.51
4016 McClymonds 93.45 4083 Eastmont Hills 86.93
4018 Prescott 95.08 4084 Eastmont 98.55
4022 Prescott/Mandela Peralta 92.58 4098 Golf Links 86.87 4024 Bunche/Oak Center 84.15 4099 Sequoyah 52.31
4025 Acorn 92.62 4100 Chabot Park 50.66
4027 Bunche/MLK Jr 71.85 4101 Foothill Square/Toler Heights 79.88 4028 Uptown/Downtown 71.55 4102 Las Palmas 93.74
4036 Adams Point 1 56.68 4105 Defremery/Oak Center 97.2 4076 Fairfax/Lower Maxwell Park 92.91
Environmental / Justice Solutions | 28
Table 7. Oakland: Predominantly Asian Census Tracts
CT Neighborhood Lead
Pctl
CT Neighborhood Lead
Pctl
4026 Jack London Gateway 53.91 4055 Ivy Hill 88.78
4029 Downtown 71.01 4057 Upper San Antonio/Highland Park 89.67 4030 Chinatown 35.51 4058 San Antonio/Highland Terrace 92.86 4031 Downtown/Old Oakland 12.09 4033 Chinatown/Laney 31.18 4059.02 Lower San Antonio 2 92.83 4060 Oakland Estuary 68.78 4053.02 Eastlake 63.97 4054.01 Eastlake Clinton 1 88.29 4054.02 Eastlake Clinton 2 93.04 4066.02 Lower Dimond School 88.52 Table 8. Oakland: Predominantly White Census Tracts
CT Neighborhood Lead
Pctl
CT Neighborhood Lead
Pctl
4001 Panoramic Hill 7.49 4042 Upper Piedmont Ave 43.14
4002 Rockridge 68.71 4043 Upper Rockridge 43.33
4003 Shafter/Rockridge 63.81 4044 Glen Highlands 22.72
4004 Upper Telegraph/Fairview Park 68.54 4045.01 Montclair 1 60.87 4005 Bushrod/N. Oakland 65.61 4045.02 Montclair 2 42.07 4006 Bushrod/Children's Hospital 79.75 4046 Piedmont Pines 41.76 4007 Santa Fe/N. Oakland 79.46 4047 Oakmore 2 58.52
4008 Paradise Park/Golden Gate 72.47 4048 Oakmore 1 86.24 4009 Gaskill 81.39 4049 Glenview 74.79
4010 Longfellow 83.87 4050 Trestle Glen 65.31
4011 Temescal 1 76.45 4051 Crocker Highland 66.39
4012 Temescal 2 61.47 4052 Cleveland Heights 2 77.02
4013 Pill Hill 36.41 4053.01 Cleveland Heights 1 60.21
4017 Port of Oakland 61.96 4056 Bella Vista 65.22
4034 Lake Merritt 44.49 4064 Reservoir Hill/Manzanita 88.77 4035.01 Oakland/Harrison 1 46.25 4066.01 Laurel/Upper Peralta Creek 91.52 4035.02 Oakland/Harrison 2 42.2 4067 Lincoln Highlands 57.93 4037.01 Adams Point 3 46.8 4068 Redwood Heights 3 74.01 4037.02 Adams Point 2 42.83 4069 Redwood Heights 1 82.52 4038 Lakeshore 57.17 4077 Maxwell Park 80.86
4039 Grand Lake 48.99 4078 Mills College 68
4040 Piedmont Ave 3 42.41 4079 Redwood Heights 2 80.27
4041.01 Piedmont Ave 2 55.03 4080 Woodminster 32.73
4041.02 Piedmont Ave 1 55.55 4081 Caballo Hills 15.53
Environmental / Justice Solutions | 29
The signiﬁ
cant demographic shifts that have taken place over the last two decades are visible in a comparison of the two maps of Alameda County below. Several predominantly White census tracts with higher than 75% Lead Risk percentiles were until recently predominantly African American / Black, such as Gaskill (4009), North Oakland: Bushrod and Santa Fe (4006 & 4007), Temescal 1 (4011), and Longfellow (4010) neighborhoods. A table highlighting some of these demographic shifts is below in Table 32 (p.72).

Maps E & F. Predominant Racial/Ethnic Group by Census Tract: Alameda County Environmental / Justice Solutions | 30

Table 9. Alameda County: Predominantly Latinx Census Tracts CT City/CDP Lead Pctl CT City/CDP Lead Pctl
4323 San Leandro 70.78 4366.02 Hayward 61.39
4324 San Leandro 85.74 4367 Hayward 57.32
4326 San Leandro 69.02 4368 Hayward 90.49
4331.03 San Leandro 68.3 4369 Hayward 92.9
4331.04 San Leandro 57.99 4370 Hayward 65.14
4338 San Leandro 86.99 4373 Hayward 94.42
4339 Ashland 80.02 4374 Hayward 92.7
4340 Ashland 91.56 4375 Hayward 87.99
4351.02 Hayward 21.4 4376 Hayward 79.73
4351.04 Hayward 45.12 4377.01 Hayward 76.04
4352 Hayward 49.86 4377.02 Hayward 74.46
4353 Hayward 62.31 4378 Hayward 62.3
4355 Cherryland 84.22 4379 Hayward 88.39
4356.01 Cherryland 91.66 4381 Hayward 83.2
4356.02 Cherryland 88.01 4382.01 Hayward 89.23
4357 San Lorenzo 86.53 4402 Union City 83.57
4358 San Lorenzo 82.17 4430.01 Fremont 59.12
4359 San Lorenzo 83.96 4443.02 Newark 64.09
4360 San Lorenzo 84.44 4444 Newark 75.38
4361 San Lorenzo 76.79 4445 Newark 57.12
4362 Hayward 78.4 4514.04 Livermore 81.93
4365 Hayward 73.73 4366.01 Hayward 90.37
Table 10. Alameda County: Predominantly White Census Tracts CT City/CDP Lead Pctl CT City/CDP Lead Pctl
4201 Albany 67.55 4305 San Leandro 76.07
4204 Berkeley 44.34 4306 Castro Valley 52.36
4205 Albany 78.35 4307 Castro Valley 75.76
4206 Albany 65.19 4308 Castro Valley 85.81
4211 Berkeley 60.92 4309 Castro Valley 74.74
4212 Berkeley 67.69 4310 Castro Valley 82
4213 Berkeley 65.42 4311 Castro Valley 80.48
4214 Berkeley 65.36 4312 Castro Valley 54.69
4215 Berkeley 57.91 4321 San Leandro 83.5
4216 Berkeley 60.76 4322 San Leandro 81.25
4217 Berkeley 68.97 4327 San Leandro 61.53
Environmental / Justice Solutions | 31
4218 Berkeley 65.41 4364.01 Hayward 72.91
4219 Berkeley 74.69 4364.02 Hayward 27.63
4220 Berkeley 62.6 4401 Union City 15.11
4221 Berkeley 68.82 4411 Fremont 34.62
4222 Berkeley 61.43 4412 Fremont 42.15
4223 Berkeley 66.94 4426.02 Fremont 73.49
4224 Berkeley 40.26 4441 Newark 35.31
4225 Berkeley 64.39 4443.01 Newark 43
4227 Berkeley 52.26 4502 Dublin 7.27
4230 Berkeley 59.29 4503 Dublin 15.1
4231 Berkeley 66.78 4504 Dublin 31.53
4232 Berkeley 71.07 4505.01 Dublin 14.82
4233 Berkeley 76.99 4505.02 Castro Valley 2.72
4234 Berkeley 78.91 4506.01 Pleasanton 12.49
4235 Berkeley 78.13 4506.02 Pleasanton 8.8
4236.01 Berkeley 72.77 4506.03 Pleasanton 22.38
4236.02 Berkeley 48.82 4506.04 Pleasanton 25.05
4237 Berkeley 73.91 4506.05 Pleasanton 10.11
4238 Berkeley 62.49 4506.06 Pleasanton 6.65
4239.01 Berkeley 64.59 4506.07 Pleasanton 24.52
4239.02 Berkeley 63.05 4507.01 Livermore 2.9
4240.01 Berkeley 81.02 4507.41 Pleasanton 22.35
4251.01 Emeryville 28.4 4507.42 Pleasanton 9.5
4251.03 Emeryville 10.31 4507.44 Pleasanton 10.4
4251.04 Emeryville 46.33 4507.46 Pleasanton 14.56
4261 Piedmont 60.96 4511.01 Livermore 8.03
4262 Piedmont 76.4 4511.02 Livermore 3.55
4271 Alameda 69.1 4512.01 Livermore 23.99
4272 Alameda 72.43 4512.02 Livermore 11.22
4277 Alameda 64.73 4513 Livermore 18.31
4278 Alameda 77.27 4514.01 Livermore 23.5
4279 Alameda 76.64 4514.03 Livermore 43.9
4280 Alameda 61.38 4515.01 Livermore 26.8
4281 Alameda 65.73 4515.03 Livermore 58.97
4282 Alameda 56.96 4515.04 Livermore 6.42
4284 Alameda 74.95 4515.05 Livermore 4
4285 Alameda 50.69 4515.06 Livermore 35.98
4286 Alameda 21.43 4516.01 Livermore 15.31
4301.02 Castro Valley 13.6 4516.02 Livermore 31.85
4302 Castro Valley 36.52 4517.01 Livermore 39.4
4303 Castro Valley 47.89 4517.03 Livermore 24.92
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4304 Castro Valley 51.96 4517.04 Livermore 21.5
Table 11. Alameda County: Predominantly Asian Census Tracts CT City/CDP Lead Pctl CT City/CDP Lead Pctl
4202 Albany 75.02 4415.01 Union City 1.59
4203 Albany 53.37 4415.03 Newark 4.14
4226 Berkeley NA 4415.21 Fremont 2.42
4228 Berkeley 55.58 4415.22 Fremont 12.71
4229 Berkeley 22.77 4415.23 Fremont 9.99
4251.02 Emeryville 5.83 4415.24 Fremont 2.83
4273 Alameda 58.12 4416.01 Fremont 35.17
4276 Alameda 71.74 4416.02 Fremont 72.06
4283.01 Alameda 21.02 4417 Fremont 37.68
4283.02 Alameda 5.35 4418 Fremont 26
4287 Alameda 15.8 4419.21 Fremont 15.98
4301.01 Castro Valley 11.2 4419.23 Fremont 31.9
4325.01 San Leandro 86.35 4419.24 Fremont 22.69
4325.02 San Leandro 78.03 4419.25 Fremont 3.7
4328 San Leandro 43.34 4419.26 Fremont 39.1
4330 San Leandro 86.73 4419.27 Fremont 11.48
4331.02 San Leandro 72.36 4420 Fremont 7.4
4332 San Leandro 83.62 4421 Fremont 14.14
4333 San Leandro 90.64 4422 Fremont 40.94
4334 San Leandro 18.45 4423.01 Fremont 66.92
4335 San Leandro 81.68 4423.02 Fremont 28.31
4336 San Leandro 76.49 4424 Fremont 55.5
4351.03 Castro Valley 2.57 4425 Fremont 67.35
4371.01 Union City 30.17 4426.01 Fremont 32.74
4371.02 Hayward 60.43 4427 Fremont 33.06
4372 Hayward 54.97 4428 Fremont 36.36
4380 Hayward 82.09 4429 Fremont 21.38
4382.03 Hayward 36.78 4430.02 Fremont 51.95
4382.04 Hayward 41.27 4431.02 Fremont 5.3
4383 Hayward 94.6 4431.03 Fremont 6.02
4384 Hayward 42.01 4431.04 Fremont 20.75
4403.01 Union City 36.09 4431.05 Fremont 1.42
4403.04 Union City 38.53 4432 Fremont 2.15
4403.05 Union City 24.67 4433.01 Fremont 8.61
4403.06 Union City 56.11 4433.21 Fremont 3.21
4403.07 Union City 16.47 4433.22 Fremont 20.16
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4403.08 Union City 22.73 4442 Newark 39.81
4403.31 Union City 43.97 4446.01 Newark 23.12
4403.32 Union City 5.2 4446.02 Newark 9.52
4403.33 Union City 9.39 4501.01 Dublin 0.38
4403.34 Union City 36.13 4501.02 Dublin 0.13
4403.35 Union City 10.26 4507.43 Pleasanton 7.53
4403.36 Union City 48.84 4507.45 Pleasanton 0.43
4413.01 Fremont 4.23 4507.5 Dublin 0.67
4413.02 Fremont 26.38 4507.51 Pleasanton 0.77
4414.01 Fremont 22.4 4507.52 Pleasanton 0.96
4414.02 Fremont 19.25
Table 12. Alameda County: Predominantly African American/Black Census Tracts CT City/CDP Lead Pctl CT City/CDP Lead Pctl
4354 Hayward 66.04 4240.02 Berkeley 75.36
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2.1.3. Life Outcomes by Race
The United States Census has published an Opportunity Atlas that tracks the outcomes of 20 million Americans from childhood (born between 1978-1983) to age 35. The results demonstrate that, where you are born, your race, and your parent’s income have an outsized impact on your life outcomes— “the roots of a person’s aﬄuence
or poverty today can be traced back to the neighborhood where they grew up.”
The maps below depict ‘Household Income at Age 35,’ for children born to parents of all income levels between 1978-1983. At 35, children born in census tracts coded dark red had household incomes below $29,000, while children born in census tracts coded dark blue had household incomes above $61,000. In Oakland, the red areas on the map track the redlined areas on the 1937 HOLC map above.

They also correspond to the census tracts that are majority Latinx and majority Black.

Maps G & H. ‘Household
Income at Age 35’ in Oakland
and Alameda County, U.S.

Census Opportunity Atlas.

Taken as a whole, no other
location in Alameda
County had income
outcomes as poor as
Oakland.

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The census tracts with the lowest Household Income outcomes for Whites, turned out to have the lowest household incomes overall. This demonstrates aneed to explicitly target low-income Whites in these census tracts.

Table 13. Oakland: Lowest Household Income at age 35
Race All Parent
Incomes
Census Tracts Low Parent
Income
Census Tracts
White $15,000 4102 (Las Palmas) $9,600 4064 (Reservoir Hill / Manzanita)
Latinx $18,000 4013 (Pill Hill)
4035.01
(Oakland/Harrison1)
$13,000 -
$14,000
4035.01
(Oakland/Harrison 1)
4013 (Pill Hill)
Black $18,000 4089 (Fitchburg /
Hegenberger)
4054.01 (Eastlake
Clinton 1)
$15,000 4054.02 (Eastlake
Clinton 2)
Asian $28,000 4073
(Lockwood/Coliseum)
$31,000 4073
(Lockwood / Coliseum)
Table 14. Alameda County: Lowest Household Income at age 35 Race All Parent
Incomes
Census Tracts Low Parent
Income
Census Tracts
White $31,000 4377.02 (Tennyson,
Hayward)
$8,300 4379 (Garin, Hayward)
Latinx $25,000 4235 (South Berkeley) $14,000 4507.42 (Pleasanton) Black $17,000 4442 (Newark)
4280 (Alameda)
$2,200
$11,000
$13,000
$14,000
$16,000
4384 (Glen Eden
Hayward)
4361 (San Lorenzo)
4331.02 (San Leandro)
4312 (Castro Valley)
4403.06 (Union City)
4412 (Niles, Fremont)
4429 (Blackow, Fremont)
4507.43 (Pleasanton)
Asian $44,000 4366.01 (Jackson
Triangle, Hayward)
$14,000 4304 (Castro Valley)
Diﬀ
erences in life expectancy by race. Life expectancy, the average number of years a person can expect to live, serves as an indicator of overall community health. The low-income communities and Latinx, Black, immigrant, and refugee communities in Oakland’sﬂatlands face signiﬁ
cantly worse life
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outcomes than other communities in Alameda County, with life expectancies that are nearly 17-28 years lower than the census tracts with the highest life expectancy.

Table 15. Lowest and Highest Life Expectancy in Alameda County Census Tract Life Expectancy
(Years)
Neighborhood City Predominant
Racial/Ethnic Group
4025 67.7 Acorn Oakland Black
4084 71.2 Eastmont Oakland Black
4092 71.5 Sobrante Park Oakland Latinx
4075 72.2 Seminary Oakland Latinx
4085 72.5 Arroyo Viejo Oakland Latinx
4090 73 Oakland Airport Oakland Latinx
4105 73 Defremery / Oak Center Oakland Black
4089 73.1 Fitchburg / Hegenberger Oakland Latinx
4095 73.3 Woodland / Tassafaronga Oakland Latinx
4064 73.4 Reservoir Hill / Manzanita Oakland White
4415.24 90 Fremont Asian
4415.23 90.1 Fremont Asian
4031 90.6 Downtown / Old Oakland Oakland Asian
4415.03 92.4 Newark Asian
4225 94.6 Berkeley White
4228 95.6 Berkeley Asian
Map I. Life Expectancy by Census Tract, Alameda County Public Health Department Environmental / Justice Solutions | 37

2.2. Equity Gaps in Lead Poisoning Prevention Programs
The City of Oakland, County of Alameda, and State of California all need to increase primary prevention eﬀ
orts aimed atpreventing future cases of lead poisoning, especially in the geographic areas where children are at greatest risk.42 California currently relies primarily onsecondary prevention requiring health, educational and environmental interventions for children only after they are lead poisoned. (For a brief background on key federal, state, and local programs, see Appendix B.) We need to promote methods that control lead hazards before they result in poisoning and protect the families that can’t reach out for support. Furthermore, theﬁnite amounts of funding available are best spent
serving the most vulnerable populations and areas. The following equity gaps in present-day approaches to lead poisoning prevention cause unintended negative consequences for people of color and low-income communities who bear a disproportionate burden of lead exposure, exacerbating existing racial inequities, such as the school-to-prison pipeline.

1. Lack of proactive policies and programs to locate and abate lead paint hazards in at-risk housing. The State of California requires health departments to take action to address residential lead paint hazards onlyafter a blood test shows that a child has an elevated blood lead level, “literally using the blood of children to identify the houses that poison them.”43 Lead policy experts have called this approach misguided, especially as it is ineﬀ ective in signiﬁ
cantly reducing
the number of children who continue to be lead-poisoned and falls short of locating all of the residential properties with lead hazards because far fewer children are tested than required by law. Moreover, there are no laws requiring universal lead testing, so the need for testing likely exceeds the amount of testing required by law.

Alameda County’s Public Health Department has pioneered a health equity framework, publishing the groundbreaking “Life and Death from Unnatural Causes: Health and Social Inequity in Alameda County” in 2008, which takes an in-depth look at health inequities and underlying social inequities in Alameda County based on local data. The “Community Assessment, Planning and Education (CAPE) unit of the Alameda County Public Health Department has also developed a predictive model using statistical methods to incorporate multiple known risk factors for elevated BLL in children at the census tract level throughout the County.”44 It is not clear how this tool has been used to ensure services are delivered proactively within Alameda County.

2. Insuﬃ
cient outreach, education, and blood lead testing in at-risk communities.Outreach to low-income homeowners, landlords, and tenants must directly support increased blood lead testing, e.g., through establishment of new testing sites in at-risk communities. Many people are unaware of the hazards of lead paint and how to avoid or prevent them, and would beneﬁ t from
44 Housing Habitability and Health: Oakland’s Hidden Crisisat p. 10. 43 The Weight of Lead — Part I: How Contaminated Houses Are Poisoning the Poor. 42 California State Auditor, Childhood Lead Levels: Millions of Children Have Not Received Required Testing for Lead Poisoning, January 2020, p. 2.

Environmental / Justice Solutions | 38
an accessible and engaging popular education curriculum or materials helping them to understand the dangers of lead poisoning.

3. Scattershot and racially inequitable implementation. The County and City must do more to prioritize lead poisoning prevention eﬀ
orts in the communities that experience elevated risk of childhood lead exposure and are more socially vulnerable, such as the census tracts where high rates of children tested have elevated blood lead levels, weaker infrastructure to support good health, and greater exposure to additional health risks.

4. Lack of coordination between overlapping jurisdictions. “The current system su ﬀ ers from
misalignment and lack of coordination with diﬀ
erent public agencies in diﬀ
erent jurisdictions ...
all addressing pieces of the problem” and no single agency has been able to eﬃ ciently respond to
the problem at hand.45 This “patchwork of laws, regulations, andﬁnancing frameworks, along
with a siloed programmatic approach, leads to piecemeal strategies and a climate of competition across sources of lead and the settings in which it can be found (e.g., water and paint, schools and homes), communities, and advocates. The fragmentation reduces the e ﬀ ectiveness of
programs, dissipates resources, and continues to place communities at risk.”46

5. Disjointed and outdated data. “The disjointedness of data collection and analysis for the system also limits our ability to understand the problem and to more eﬀ ectively work together to design
and implement solutions to address the problem. No single source of data exists to assess the habitability conditions and related health impacts of all rental housing units at the local level.

Instead, it is necessary to approximate these using various geographic levels of data from the US census, American Housing Survey, City code enforcement cases and data from multiple public agencies.”47

6. Insuﬃ
cient program capacity . For several decades, the Alameda County Healthy Homes Department has conducted outreach, remediated homes, and secured treatment for lead poisoned children and slow progress is being made. The County rehabilitated 189 units at 93 locations between January 2015 - April 2020, which were placed on its Lead-Safe Housing Registry. The data appears to indicate that around 30-60% of the lead unsafe housing discovered in Oakland and Alameda County between January 2015 – April 2020 was fully remediated.48 The City of Oakland needs to provide signiﬁ
cant assistance by taking concerted citywide action toﬁnd and
rehabilitate lead paint hazards. Funding has also been extremely limited for the City’s Lead Safe Housing Program, which applies only to owner-occupied dwellings. The program has remediated 824 dwellings since 1999, six- seven units each year in 2015-2016, but only 1-2 dwellings per year since 2018.49
49 Data provided by the City of Oakland’s Lead Safe Housing Program: Lead-based Paint Project Completions from 1999 to 2020.
48 Data provided by Alameda County Healthy Homes Department: Number of Reported Lead Hazards and Number of Units certiﬁ
ed Lead-Safe.
47 Housing Habitability and Health: Oakland’s Hidden Crisisat p. 10. 46 Achieving Equity in Lead Poisoning Prevention Policy Making: Proceedings from a Consensus Conferenceat p. 5. 45 Id. at p. 6.

Environmental / Justice Solutions | 39

7. Misplaced blame due to the myth of “personal responsibility.” Low income families and families of color are often either implicitly or explicitly blamed for exposing their children to lead hazards as a result of “assumptions about their housekeeping, parenting, or choices about where they live.”

8. Mistrust resulting from poor community engagement. There has been little public inclusion in lead hazard prevention policy making, which can leave community members feeling “undervalued, tokenized, misrepresented, and expendable.”50

9. Inadequate enforcement of tenant protections for low-income tenants. Oakland’s Just Cause for Eviction Ordinance prohibits arbitrary discrimination by landlords and prevents termination of a tenancy without just cause for eviction. Yet, many low-income tenants still do not report habitability concerns. Unreported hazards can create “repeat oﬀ ender” units that expose current
and future tenants to lead. Conversely, expenditures for costly repairs and upgrades can lead to displacement when small property owners are pressured to recover the costs by raising the rent.

10. Barriers to remediation for low-income homeowners and landlords. Low-income homeowners and mom-and-pop landlords may have ﬁnancial
diﬃ
culty complying with independent
environmental testing and rehabilitation requirements. They may also experience barriers in accessing government funding or be unable to qualify for additional loans. “Communities that are already struggling ﬁnancially
are further impacted when they are required to bear the cost of implementing lead prevention policies. If they are ﬁnancially unable to remediate exposure,
people continue to experience health impacts.”51 There may be a vital need to supplement HUD’s Lead-based Paint Hazard Control and Lead Hazard Reduction Demonstration grants to make suﬃ
cient funding available.

11. Missed opportunity to boost local economy through development of a robust pipeline of RRP-certiﬁed
local businesses and contractors.More needs to be done to lift up the need for environmental lead testing and rehabilitation of lead paint hazards. Right now, the market for lead rehabilitation contractors is not as signiﬁ
cant as it should be. As such, even if training is
oﬀ
ered for free, existing small contractors may not be able to develop additional services or spare their personnel for suﬃ
cient time to procure additional training.

The homes in vulnerable communities have multiple severe habitability issues, including asbestos and mold. Project managers and landownersneed and are likely to seek outcontractors that are certiﬁ
ed to handle multiple issues that will improve habitability, indoor air quality and energy a ﬀ
ordability, from asbestos and mold to energy eﬃ
ciency, energy conservation,
electriﬁ
cation and rooftop solar installation. Local, small, disadvantaged business enterprises and workforce development need to have the opportunity to gain the skills and certiﬁ cations to
perform all of these types of jobs, with a unique focus on their own neighborhoods. 51 Ibid.
50 Achieving Equity in Lead Poisoning Prevention Policy Making: Proceedings from a Consensus Conference at p. 5.

Environmental / Justice Solutions | 40

2.3. Lead Paint Hazard Equity Indicators
To prioritize the populations with the greatest need for resources, lead policy experts point to the need to focus on “screening homes rather than children as a more preventative approach.”52 The City and County can use available data to identify the neighborhoods and even blocks or streets that are vulnerable to lead hazards and stage local interventions that channel resources to under-resourced areas. Researchers have found that targeting lead paint hazard control interventions “only to more at-risk populations ” —older housing occupied by low-income residents— oﬀ ers the greatest
per-dollar beneﬁ
ts, including a greater return and higher net beneﬁ
ts.”53 The Health Impact Project
found that eradicating lead paint hazards from older homes of children from low-income families nationwide would provide $3.5 billion in future beneﬁ
ts, or approximately $1.39 per dollar invested,
and protect more than 311,000 children nationwide.54
This section identiﬁ
es neighborhood-scale, racially disaggregated indicators related to vulnerability to lead hazards in order to pinpoint areas and demographic groups experiencing high degrees of burden across multiple indicators. Many of these indicators were identiﬁ ed in a report by the Urban Strategies
Council, commissioned by the Alameda County Healthy Homes Alliance. The indicators re ﬂ ect
demographic, socio-economic, and health characteristics that determine a person or community’s exposure and sensitivity to lead hazards as well as their capacity to protect themselves from the hazards in their environment.The equity indicators selected are not intended to be deﬁ nitive or
exhaustive, but rather exemplary of the cumulative burdensthat increase vulnerability to lead hazards. Indicators such as those highlighted here are a snapshot of the diﬀ erent factors that cause
people of color to be over-represented in the population that is most vulnerable to lead poisoning. ➔ Heightened risk of exposure to lead hazards. These populations are more likely to live or work in high-risk dwellings/buildings, primarily low-income residents of dwellings built before 1978. Lead exposure patterns perpetuate the disparities that low-income households and Latinx, Black, immigrant, and refugee communities face.
◆ The older the building, the higher the likelihood of ﬁ nding lead paint.
◆ Young children have the most risk of exposure, due to the likelihood that they will play on the ﬂ
oor or in the dirt and either breathe in or ingest contaminated dust. ◆ Children from BIPOC families, refugees, and children who were adopted from outside the U.S. are at higher risk of exposure.
◆ People who work with lead or even in lead abatement, may expose their families to lead from the workplace.
◆ Low-income households have a higher prevalence of lead hazards (29%) than 54 Id. at p. 2.
53 10 Policies to Prevent and Respond to Childhood Lead Exposure: An assessment of the risks communities face and key federal, state, and local solutions at p. 44-45.
52 Achieving Equity in Lead Poisoning Prevention Policy Making: Proceedings from a Consensus Conferenceat p. 30-31 (“[P]articipants recommended creating a new metric for identifying priority communities that combines elevated blood lead levels (BLLs), social vulnerability index, and other variables, such as age of housing stock.”).

Environmental / Justice Solutions | 41
higher-income households (18%).
◆ Black households had higher prevalence (28%) than White households (20%). ◆ Households receiving government housing assistance had half as many hazards (12%) compared to unassisted housing (22%).
➔ Heightened sensitivity to lead hazards. These populations have biological factors that make them more sensitive to the negative impacts of lead exposure. This includes children, pregnant women, low birthweight babies, and people with pre-existing conditions (comorbidities) including heart disease and asthma.
➔ Reduced capacity for remediation/abatement (protective action) . Socio-economic factors inhibit people’s ability to take action to protect themselves from harms presented by lead paint.

This includes lack of awareness of lead exposure, lack ofﬁnancial resources to rehabilitate known
harms, and inability to receive proper and timely medical care, including for pre-existing conditions.

2.3.1. Increased Exposure to Lead Hazards

2.3.1.1. High Numbers of Lead Poisoned Children and/or Low Lead Testing Rates
Why it Matters. Census tracts where high numbers of lead poisoned children have been observed or where a low percentage of children have been tested are likely to have high rates of lead exposure.

State and federal mandates require all children enrolled in Medi-Cal to receive mandatory lead testing, enabling the state to provide data on the number of enrolled children who have missed their required tests. As Medi-Cal provides health coverage for those with limited means, it is a good proxy for identiﬁ
cation of children living in poverty. Children enrolled in Medi-Cal should receive theirﬁrst test at
age one (12 month) and a second test at age two (24 months). Sadly, large percentages of children are missing their tests and furthermore not all children living in poverty are enrolled in Medi-Cal.

Although there seems to be a downward trend in elevated BLLs overall, there is signiﬁ cant
variability between counties in the rates of elevated BLLs. Because not all young children receive blood lead tests, it is not clear whether the overall decline or geographic variability is due to actual variability in the prevalence of elevated BLLs, or to variability in the extent to which the highest at-risk children in the county are being identiﬁ ed and tested.55
Because of the dire shortage of testing, BLL data cannot be the sole criterion for identifying areas with high-risk of lead exposure. Another reason not to rely solely on Observed EBLL data is that it has the capacity to be limited or even misleading. Lead equity experts state that —“the half-life of lead in the blood is 28 days. If blood samples are not taken within this window after exposure, elevated BLLs may be missed.”56 Without BLL testing becoming more liberally available, right now the timing of the lead test needs to be fortuitously precise. Nonetheless, identifying the census tracts with high rates of children with EBLLs provides a useful focus on areas where lead paint issues are likely widespread. 56 Achieving Lead Equity in Policymaking: Proceedings from a Consensus Conferencep. 31 (November 2018). 55 California Department of Public Health, California’s Progress in Preventing and Managing Childhood Lead Exposure(June 2020).

Environmental / Justice Solutions | 42
Conversely, the areas
with low rates of blood
testing should also be
focused on. Where large
numbers of low-income
children have not been
tested, the true extent of
the existing problem is
not known. Furthermore,
the data show a slightly
negative correlation
between the areas with
high numbers of children
of children with EBLLs
and the rate of missed
tests. That is to say, testing rates were slightly higher in the census tracts where more lead-poisoned children were found and slightly lower in the census tracts where fewer lead-poisoned children were found.

Equity Findings. Sixty-two percent of the 1,751 lead poisoned children in Alameda County recorded between 2000 and 2010, lived in the City of Oakland.57 The most recent CDPH data from 2013-2018 shows 1,589 lead poisoned children in Alameda County, of which 53% were found in Oakland. 57 Data provided by County of Alameda, CA Dept. of Public Health, RASSCLE database, 2011.

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Map J. Alameda County CAPE,
percentage of Lead Poisoned Children
by zip code (2012 data).

High Numbers of Children with Observed Lead Poisoning.In roughly one-third of Alameda County census tracts, one or fewer tested children had lead poisoning. By contrast, in each of the top ten census tracts in Alameda County, over 20 tested children were lead poisoned. ● African Americans and Latinos are overrepresented statistically in lead poisonings.58 ● The 15 census tracts where the most lead poisoned children were found are primarily in San Antonio, Fruitvale, and East Oakland, which are predominantly Latinx, Black and Asian, and have a conﬂ
uence of low household incomes, older rental properties, substandard housing conditions, concentrations of older housing, and a high percentage of low-income families with children under the age of six.59, 60
● The next most impacted city is Fremont, then Hayward.

Table 16. Census Tracts with Highest Number of Lead Poisoned Children & Percentage of Tests Missed by Children in Medi-Cal
Top 25 Census
Tracts in
Alameda County
# of Lead
Poisoned
children
under 6 ZIP City
# of
Required
Tests
# of
Missed
Tests
% of
Tests
Missed
1 4062.01 44 94601 Oakland 595 288 48%
2 4088 31 94621 Oakland 969 528 54%
3 4076 27 94601 Oakland 562 321 57%
4 4072 24 94601 Oakland 877 375 43%
5 4087 24 94605 Oakland 914 528 58%
60 Neighborhood Knowledge for Change: West Oakland Environmental Indicators Project, Paciﬁ c Institute for Studies in
Development, Environment and Security, p. 54 (2002).
59 City of Oakland Oﬃ
ce of Planning, Building & Neighborhood Preservation, Proposed Program Design for Proactive Code Enforcement Operations, see n.19.
58 Housing Habitability and Health: Oakland’s Hidden Crisisat p. 9 (“These numbers reﬂ ect the national landscape: 28% of
African American households and 29% of poorer households face housing related lead exposure risks compared with 20% of Whites and 18% of wealthier households.”)
Environmental / Justice Solutions | 44

6 4075 23 94621 Oakland 738 383 52%
7 4096 23 94621 Oakland 841 478 57%
8 4419.27 22 94538 Fremont 99 67 68%
9 4070 21 94619 Oakland 591 330 56%
10 4071.02 21 94601 Oakland 480 250 52%
11 4086 18 94605 Oakland 1439 977 68%
12 4419.23 18 94538 Fremont 361 217 60%
13 4014 16 94608 Oakland 368 221 60%
14 4054.01 16 94606 Oakland 420 192 46%
15 4103 16 94603 Oakland 567 310 55%
Source: California State Auditor, CDPH data FY 2013-14 through 2017-18 Table 17. Demographics of the Census Tracts with the Most Lead Poisoned Children CT Neighborhood/City
# of Lead
Poisoned
children White Black Asian Latinx PI Other
1 4062.01 Reservoir Hill / Meadow
Brook / D5 Oakland 44 7% 16% 23% 44% 3% 7%
2 4088 Havenscourt/Coliseum 31 5.1% 34% 3.4% 52.8% 4.1% 0.5% 3 4076 Fairfax/Lower Maxwell Park 27 10% 41% 11% 31% 0% 7% 4 4072 Fruitvale D5/D4 24 7% 8% 15% 68% 0% 2%
5 4087 Bancroft/Havenscourt 1 24 5% 41% 2% 49% 0% 3%
6 4075 Seminary 23 6% 32% 5% 52% 0% 5%
7 4096 Webster 23 2% 27% 4% 64% 1% 2%
8 4419.27 Fremont 22 12.5% 2.6% 68.2% 11.8% 0% 4.8%
9 4070 Lower Laurel/Allendale 21 11% 16% 36% 33% 0% 5%
10 4071.02 Jeﬀ
erson/Fruitvale 21 15% 16% 16% 46% 3% 4%
11 4086 Bancroft/Havenscourt 2 18 4% 32% 2% 58% 0% 5%
12 4419.23 Fremont 18 21.5% 0% 66.4% 8.4% 0% 3.1%
13 4014 Hoover/Foster 16 23.9% 32.9% 12.7% 19.9% 0% 8.5% 14 4054.01 Eastlake Clinton 1 16 17.4% 23.2% 36.5% 17.4% 0% 5.6% 15 4103 Cox/Elmhurst 16 2.1% 22.2% 1.9% 69.1% 2.4% 1.8% Source: American Community Survey 2017 5-year estimate
Low Lead T esting Rates. The data shows high numbers of children who should have been tested but were not. Across Alameda County, the percentage of children enrolled in Medi-Cal who missed their Environmental / Justice Solutions | 45
mandatory testing ranges between 37% - 81% per census tract. Because census tracts with high percentages of missed tests can have lower overall numbers of children on Medi-Cal, the table below is organized according to the raw number of missed tests to identify the areas with the largest number of children on Medi-Cal as well as the percentage of missed tests. Census tracts with higher rates of missed tests but lower numbers of required tests experience less burden overall and include4502 Dublin, where 8 lead poisoned children were found, 4419.25 Fremont, which had 10 cases,4281 Alameda, 6 cases; and 4004 Oakland (Upper Telegraph/Fairview Park), 7 cases.

Table 18. Census Tracts with the Highest Number of Missed Lead Tests for Children in Medi-Cal CT City Oakland Neighborhood # EBLL
# Required
Tests
# Tests
Missed
% Tests
Missed
4086 Bancroft/Havenscourt 2 18 1,439 977 68%
4087 Bancroft/Havenscourt 1 24 914 528 54%
4088 Havenscourt/Coliseum 31 969 528 58%
4085 Arroyo Viejo 15 942 521 55%
4368 Hayward 5 763 516 68%
4339 Ashland 8 909 498 55%
4097 Castlemont 13 838 497 59%
4096 Webster 23 841 478 57%
4369 Hayward 4 815 462 57%
4366.01 Hayward 11 765 427 56%
4093 North Stonehurst 12 786 415 53%
4028 Uptown/Downtown 3 563 406 72%
4094 Elmhurst Park 13 768 385 50%
4514.04 Livermore 7 623 385 62%
4075 Seminary 23 738 383 52%
4072 Fruitvale 24 877 375 43%
4332 San Leandro 3 573 366 64%
4095 Woodland/Tassafaronga 11 647 363 56%
4363 Hayward 12 671 346 52%
4338 San Leandro 8 607 344 57%
4062.02 Fruitvale/Hawthorne 10 812 339 42%
4326 San Leandro 7 560 337 60%
4070 Lower Laurel/Allendale 21 591 330 56%
4402 Union City 6 658 324 49%
4076 Fairfax/Lower Maxwell Park 27 562 321 48%
4377.02 Hayward 4 665 321 57%
4364.01 Hayward 10 480 318 66%
4103 Cox/Elmhurst 16 567 310 54%
4365 Hayward 6 483 308 64%
4340 Ashland 9 494 307 62%
Source: California State Auditor
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2.3.1.2. Lead Risk
Why it Matters. CalEPA’s Draft CalEnviroScreen 4.0 includes an indicator that assesses the percentage of homes with higher likelihood of lead hazards along with the percentage of households that areboth low-income and have children. Children younger than 6 years of age, with rapidly developing brains, are most at risk of lead poisoning. Oakland has one of the highest concentrations of young children, with approximately 30,659 children under 6 years of age. OEHHA calculates the percentage of homes with likelihood of lead hazards using the construction period for each housing unit in the census tract.

Figure 2. Lead
Risk Formula
Draft CES 4.0
Report
Map K. Lead
Risk in
Alameda
County, Draft
CES 4.0
Findings. There are 116 census tracts in Alameda County that have lead risks above the 75th percentile statewide.
➔ The 22 most burdened tracts are all located in Oakland, with the following two (#23 and 24) are located in Hayward. The 25th census tract is also in Oakland. ➔ All of the 22 census tracts with the greatest lead risk are in the top 5% of census tracts statewide. 14 of the 22 tracts also have cumulative burdens above the 75th percentile statewide.
➔ All 22 of the census tracts with the most lead risk have more than 5 children with observed elevated BLLs.
➔ Important to note that census tracts4419.23 and 4419.27 in Fremont, which both have high Environmental / Justice Solutions | 47

numbers of observed EBLLs, did not rise to the top of CalEPA’s lead risk indicator. This result underscores the need to: (a) use more than one indicator to identify at-risk areas and (b) investigate all areas that score high on key indicators, rather than relying on a composite score, which can mask the impact of the individual indicators that drive the score.

Table 19. Census Tracts with Greatest Lead Risk to Low-Income Families with Children (Draft CES 4.0)
Census
Tract
ZIP
Code Neighborhood City
Lead Risk
Percentile
Observed
EBLLs
Draft CES

4.0 Percentile
4086 94605 Bancroft/Havenscourt 2 Oakland 99.85 18 65.16 4074 94601 Fremont Oakland 99.53 14 77.52
4091 94603 Brockﬁ
eld Village Oakland 99.43 5 95.83
4075 94621 Seminary Oakland 99.37 23 82.37
4088 94621 Havenscourt/Coliseum Oakland 98.99 31 97.48
4084 94605 Eastmont Oakland 98.55 13 57.12
4087 94605 Bancroft/Havenscourt 1 Oakland 98.49 24 65.80 4095 94621 Woodland/Tassafaronga Oakland 98.33 11 90.98 4090 94621 Oakland Airport Oakland 97.88 11 97.26
4093 94603 North Stonehurst Oakland 97.71 12 69.50
4094 94603 Elmhurst Park Oakland 97.58 13 89.63
4096 94621 Webster Oakland 97.28 23 63.75
4059.01 94606 Lower San Antonio 1 Oakland 97.25 15 77.73 4062.01 94601 Reservoir Hill/Meadow
Brook Oakland 97.24 44 83.24
4105 94607 Defremery/Oak Center Oakland 97.2 6 90.33
4072 94601 Fruitvale Oakland 97.02 24 83.54
4085 94621 Arroyo Viejo Oakland 96.76 15 63.76
4062.02 94601 Fruitvale/Hawthorne Oakland 96.13 10 79.18 4073 94601 Lockwood/Coliseum Oakland 95.43 12 97.96
4071.02 94601 Jeﬀ
erson/Fruitvale Oakland 95.34 21 64.07
4018 94607 Prescott Oakland 95.08 6 84.84
4103 94603 Cox/Elmhurst Oakland 94.86 16 57.82

2.3.1.3. Density of Older Homes Dwelling Built before 1940 Lead paint may be found in any property built before 1978. The likelihood that lead paint hazards are present, however, increases dramatically the older the dwelling unit. Nationally, more than half of homes built prior to 1978, roughly 76% of homes built before 1960, and 87% of homes built before 1940 are estimated to still contain lead paint. Lead paint was most heavily used in pre-1940s housing and the paint used during that period contained the highest percentages of lead content, as Environmental / Justice Solutions | 48
much as 50 percent of a substance called “white lead carbonate” that is highly absorbable.61 The density of pre-1940s housing stock plays a signiﬁ
cant role in boostingtotal lead levels; higher
densities of older, deteriorating housing contribute to greater levels of soil contamination.62 The percentage of housing units constructed in 1940 or earlier is a useful indicator for targeting the areas that are likely to have the greatest concentrations of lead-based paint hazards.

Figure 3. U.S. EPA, “Protect
Your Family from Sources of
Lead.”
OEHHA developed California-speciﬁ
c ratios for the Draft CalEnviroScreen 4.0 Lead score, based on its review of County parcel records on the age, condition, and assessed value of residential structures and lead paint hazard studies of West Coast housing. Homes built after 1998 deﬁ nitively do not contain
lead paint. Whereas, roughly four percent of homes built between 1978 and 1998, 22% of homes built between 1960-1977, 69% of homes built between 1940-59, and 71% of homes built before 1940 are likely to contain lead paint.

The American Community Survey 2015-2019 ﬁve-year
estimate identiﬁ
es roughly 608,000 housing
units in Alameda County(margin of error 481). Of these, about170,000 housing units are located in Oakland. The same data estimates roughly 65,057 housing units built before 1940 in Oakland with a margin of error of 11,775. As the number of pre-1940 units has not increased since before 1940 outside of the County Assessor’s data, the most accurate tally ahead of the 2020 Census is from the 2010 Census, which places the number of housing units in Oakland builtbefore 1940 at 55,339. Of Oakland’s pre-1978 housing stock,nearly 40% were built in 1939 or earlier. Between 71-87% of these housing units are likely contaminated by lead, although low-income families and renters face the greatest hazards. Berkeley follows Oakland with 22,853 pre-1940 housing units, and the City of Alameda is next with 10,566 units. West Oakland is the oldest part of the City and the historical nexus of industry, warehousing, and transportation. The Lower Bottoms and South Prescott neighborhoods are among the oldest neighborhoods. Around “37% of the housing stock in West Oakland was built before 1940,” with many of the houses in this area dating from the 1870s to 1910s. 63 Other 63 Nathan McClintock, Assessing Soil Lead Contamination at Multiple Scales in Oakland, California: Implications for Urban Agriculture and Environmental Justice, Urban Studies and Planning Faculty Publications and Presentations, p.15 62 Nathan McClintock, Assessing Soil Lead Contamination at Multiple Scales in Oakland, California: Implications for Urban Agriculture and Environmental Justice, Urban Studies and Planning Faculty Publications and Presentations (November 2012, p. 15
61 See People v. Conagra Grocery Products Company, (2017) 17 Cal.App.5th 51.

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neighborhoods in Oakland with high concentrations of older housing include: East Oakland, Oakport, and Harbor Bay Parkway.

The map below is color coded to identify the predominant age of housing units in each census tract in Alameda County. Census tracts where the largest plurality of housing units were constructed after 1979 did not receive a color. The census tracts with the darkest red coloring have the highest percentage of pre-1939 housing units.

Map L. Predominant Age of Housing Units in Alameda County The following table lists the census tracts with a social vulnerability index over .8 as measured by the CDC Social Vulnerability Index where housing units were primarily constructed in 1949 or before and the estimated number of housing units constructed in 1939 or before (pre-1940). For additional context, the census tracts in Oakland with the most pre-1940s housing units—4010 (Longfellow) and 4003 (Shafter/Rockridge)— have over 1650 pre-1940s housing units. These census tracts also had 13 and 9 lead poisoned children, respectively.
(November 2012) (With respect to soil lead contamination, there is a “hot spot” in the southwest corner of West Oakland and a “cold spot” along Union and 10th Streets where Acorn public housing built in 1996 replaced the soil.) Environmental / Justice Solutions | 50

Table 20. Predominant Age of Housing, Number of Pre-1940 Housing Units, Predominant Race/Ethnicity, Number of Lead Poisoned Children & Social Vulnerability Index CT Year
Built
#
pre-1940
Oakland Neighborhood
/ City / CDP
# EBLL Race/Ethnicity SVI
4059.01 pre-1940 608 Lower San Antonio 1 15 Latinx 1
4075 pre-1940 640 Seminary 23 Latinx 1
4062.02 pre-1940 1235 Fruitvale/Hawthorne 10 Latinx 0.99 4072 pre-1940 408 Fruitvale 24 Latinx 0.99
4089 pre-1940 299 Fitchburg/Hegenberger 11 Latinx 0.99
4030 pre-1940 479 Chinatown 7 Asian 0.98
4063 pre-1940 691 San Antonio/Sausal Creek 13 Latinx 0.96 4065 pre-1940 840 Peralta/Hacienda 12 Latinx 0.96
4074 pre-1940 695 Fremont 14 Latinx 0.94
4071.02 pre-1940 773 Jeﬀ
erson/Fruitvale 21 Latinx 0.93
4087 pre-1940 1236 Bancroft/Havenscourt 1 24 Latinx 0.91 4097 pre-1940 444 Castlemont 13 Latinx 0.91
4340 1940-49 166 Ashland CDP 9 Latinx 0.89
4105 pre-1940 344 Defremery/Oak Center 6 Black 0.89
4070 pre-1940 1168 Lower Laurel/Allendale 21 Latinx 0.88 4090 1940-49 124 Oakland Airport 11 Latinx 0.87
4059.02 pre-1940 462 Lower San Antonio 2 7 Asian 0.86
4060 pre-1940 642 Oakland Estuary 3 Asian 0.86
4061 pre-1940 548 Jingletown/Kennedy Tract 15 Latinx 0.84 4073 pre-1940 427 Lockwood/Coliseum 12 Latinx 0.84
4096 pre-1940 412 Webster 23 Latinx 0.84
4054.01 pre-1940 627 Eastlake Clinton 1 16 Asian 0.81
4029 pre-1940 469 Downtown 0 Asian 0.79
4054.02 pre-1940 529 Eastlake Clinton 2 15 Asian 0.79

2.3.1.4. Most Disadvantaged / Socially Vulnerable Communities CalEnviroScreen 3.0 (2018)
The California Environmental Protection Agency’s Oﬃ
ce of Environmental Health Hazard Assessment
developed the California Communities Environmental Health Screening Tool or CalEnviroScreen to “help identify communities disportionately burdened by multiple sources of pollution and with population characteristics that make them more sensitive to pollution.”64 CalEnviroScreen 3.0 (“CES 3.0”) generates a numerical score for each census tract based on 20 indicatorsand each census tract is then ranked 64 California Oﬃ
ce of Environmental Health Hazard Assessment,CalEnviroScreen 3.0. For an in-depth discussion of this tool and its use in policymaking, see CalEnviroScreen: A Critical Tool for Achieving Environmental Justice in California.

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against every other census tract in the state. Census tracts scores are generally referenced by their statewide percentile rank (0-100), e.g., all census tracts in the top 25% or above the 75th percentile. CES

3.0 will likely be phased out soon as CalEPA has released Draft CES 4.0 earlier this year (see section immediately below for CES 4.0), but provides an excellent reference for comparisons and to view trends.

Why it Matters. The CalEnviroScreen tool combines pollution data and data on socioeconomic indicators to understand the combined impact of multiple stressors on one community. The impacts of environmental hazards, such as poor air or water quality, combine with socioeconomic limitations, such as lack of access to health care or linguistic isolation, resulting in greater levels of devastation. The cumulative impact of high burdens across multiple indicators is social debilitation; the areas and communities facing the worst impacts are the areas with the greatest overall need for assistance in combating exposure to lead hazards and lead poisoning.

Racial Equity Findings. As identiﬁ
ed by CES 3.0:
➔ Within Alameda County, disadvantaged communities above the 75th percentile statewide are disportionately located in the City of Oakland.
➔ Latinx communities in East Oakland are disproportionately represented in the most disadvantaged census tracts in Alameda County.
➔ African Americans are the next largest plurality in the most disadvantaged census tracts in Oakland, representing more than their per capita share of the general population. Together, Latinx and African American residents are around 90% of the population in the four most burdened census tracts in Alameda County/Oakland.

CES 3.0 identiﬁ
es 38 “disadvantaged” census tracts in Alameda County according to their statewide ranking. Oakland contains thetop 15most cumulatively burdened census tracts in Alameda County. Of the remaining 23 tracts, 13 are in Oakland. The 16th most burdened census tract is located in San Leandro. A full list of the census tracts with cumulative burdens among the top 25% in California is included in the CES 4.0 section below.

CES 3.0 DACs in Alameda County Percentage
Oakland 28 74%
San Leandro 3 8%
Hayward 2 5%
Union City 2 5%
Berkeley 1 3%
Newark 1 3%
Emeryville 1 3%
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Map M. GIS Map
showing the
boundaries of Oakland
overlaying CES 3.0
scores.

Map N. GIS map with boundaries of Alameda County shaded in light purple overlaying CES 3.0 percentiles.

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Table 21. Fifteen Most Cumulatively Burdened Census Tracts in Alameda County (2018) #
Census
Tract
No. Neighborhood
ZIP
Code City
CES 3.0
Percentile
CES 3.0
Percentile Range
1 4090 Oakland Airport 94621 Oakland 96.91 Top 5%
2 4091 Brockﬁ
eld Village 94603 Oakland 96.38 Top 5%
3 4088 Havenscourt/Coliseum 94621 Oakland 96.22 Top 5%
4 4092 Sobrante Park 94603 Oakland 93.48 Top 10%
5 4073 Lockwood/Coliseum 94601 Oakland 91.16 Top 10%
6 4095 Woodland/Tassafaronga 94621 Oakland 90.3 Top 10% 7 4060 Oakland Estuary 94606 Oakland 89.13 Top 15%
8 4022 Prescott/Mandela Peralta 94607 Oakland 88.32 Top 15% 9 4094 Elmhurst Park 94603 Oakland 88.02 Top 15%
10 4089 Fitchburg/Hegenberger 94621 Oakland 86.68 Top 15% 11 4018 Prescott 94607 Oakland 86.25 Top 15%
12 4061 Jingletown/Kennedy Tract 94601 Oakland 85.81 Top 15% 13 4014 Hoover/Foster 94608 Oakland 85.40 Top 15%
14 4030 Chinatown 94607 Oakland 84.99 Top 20%
15 4017 Port of Oakland 94607 Oakland 84.56 Top 20%
Source: CalEnviroScreen 3.0
Demographics. The race/ethnicities of residents of the 15 most cumulatively burdened census tracts are below. The majority demographic group is bolded and shaded in the darker color and the lighter color marks the second largest racial/ethnic group. The demographic data in CES 3.0 is based on the 2010 census, making it the most accurate snapshot available of that time, and is provided below to illuminate any demographic shifts between 2010 and 2019 data (the most recent 5 year estimates available).

Table 22. Race/Ethnicity of 15 Most Burdened Census Tracts in Alameda County CT No.

Oakland
District
CES 3.0
Percentile White Black Asian Latinx Native Other
4090 7 96.91 1.7 43.3 4.3 48.8 .1 1.8
4091 7 96.38 1.6 41 3.7 51.8 .1 1.8
4088 6/7 96.22 2.1 41.4 7.8 45.9 .2 2.7
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4092 7 93.48 1.7 40.1 6.4 49.5 .4 1.9
4073 5/6 91.16 13.2 12.7 9.2 63.1 .1 1.8
4095 7 90.3 2.3 24.4 3.6 67.8 .4 1.6
4060 2 89.13 16.7 12.1 46.8 21.3 .3 2.8
4022 3 88.32 16.3 36.4 11.4 30.2 .3 5.4
4094 7 88.02 2.3 23.4 5.7 67.1 .1 1.4
4089 7 86.68 2 31.9 4.2 59.4 .4 2.1
4018 3 86.25 15 57.4 3.3 19.3 .3 4.6
4061 5 85.81 16.3 10.5 12.6 57.7 .7 2.2
4014 3 85.40 15.2 48.4 10 21.1 .6 4.6
4030 2 84.99 4.2 4.4 88.3 1.3 .1 1.6
4017 3 84.56 25.9 33.1 10.3 25.6 .4 4.6
Source: CalEnviroScreen 3.0
Draft CalEnviroScreen 4.0 (2021)
OEHHA released a Draft CalEnviroScreen 4.0 in February 2021. The update allowed a comparison of the previous dataset with the latest data.

Why it matters. In addition to updates based on new data, CalEnviroScreen includes one new indicator, which has great signi ﬁ
cance to this report: Lead. The indicator measures the risk of exposure to lead-based paint hazards for children in poverty. With this addition, the total number of indicators included in the cumulative score moves to 21. This enables a comparison between the highly burdened census tracts in CES 3.0 and Draft CES 4.0, where changes in ranking can likely be attributed to the level of lead paint burdens.

Findings. Remarkably, after the addition of the newest indicator on lead risk to low-income families with children, the total number of census tracts in Alameda County that rank in the top 25% statewide remains 38. However, Alameda County’s 15 most burdened census tracts are more burdened overall. An additional census tract moves into the topﬁve percent most burdened statewide. The
number of tracts among the 10% most burdened statewide doubled from three to six. In addition, all of the top 15 are now ranked above the 85th percentile (top 15%) statewide. Conditions have worsened in Oakland and San Leandro, compared to Alameda County overall. Before, the top 15 census tracts were located in Oakland, now a census tract from San Leandro moves into the top 15.

DRAFT CES 4.0 DACs in Alameda County Percentage
Oakland 32 84%
San Leandro 3 8%
Union City 1 2.6%
Berkeley 1 2.6%
Alameda 1 2.6%
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Maps O & P. Draft CES 4.0 results for Oakland and Alameda County. Source:OEHHA.

Environmental / Justice Solutions | 56

Table 23. Fifteen Most Cumulatively Burdened Census Tracts in Alameda County (Draft CES 4.0) #
Census
Tract
No.

Zip
Code City Neighborhood
CES 4.0
Percentile
Draft CES 4.0
Percentile
Range
1 4073 94601 Oakland Lockwood/Coliseum 97.96 Top 5%
2 4088 94621 Oakland Havenscourt/Coliseum 97.48 Top 5%
3 4090 94621 Oakland Oakland Airport 97.26 Top 5%
4 4091 94603 Oakland Brockﬁ
eld Village 95.83 Top 5%
5 4030 94607 Oakland Chinatown 92.75 Top 10%
6 4022 94607 Oakland Prescott/Mandela Peralta 92.72 Top 10% 7 4061 94601 Oakland Jingletown/Kennedy Tract 92.60 Top 10% 8 4095 94621 Oakland Woodland/Tassafaronga 90.98 Top 10% 9 4060 94606 Oakland Oakland Estuary 90.39 Top 10%
10 4105 94607 Oakland Defremery/Oak Center 90.33 Top 10% 11 4324 94577 San Leandro 89.82 Top 15%
12 4025 94607 Oakland Acorn 89.80 Top 15%
13 4094 94603 Oakland Elmhurst Park 89.63 Top 15%
14 4089 94621 Oakland Fitchburg/Hegenberger 89.24 Top 15% 15 4033 94607 Oakland Chinatown/Laney 87.35 Top 15%
Source: DRAFT CalEnviroScreen 4.0
Demographics. TheLatinx population comprises well over 50% of the top four census tracts - the only census tracts in Alameda County that have cumulative burdens among the top 5% statewide. The Asian population in census tract 4030 is the most concentrated of any demographic group in Oakland.

Table 24. Race/Ethnicity of 15Most Burdened Census Tracts in Alameda County65 CT No. City
CES 4.0
Percentile White Black Asian Latinx Native
Paciﬁc
Islander Other
4073 Oakland 97.96 15.8 7.9 13.9 58.4 0.1 0.4 3.5
4088 Oakland 97.48 5.1 34.0 3.4 52.8 0.1 4.1 0.5
4090 Oakland 97.26 1.9 32.3 4.0 52.7 0.0 2.5 6.5
4091 Oakland 95.83 1.5 33.9 3.4 55.1 0.3 0.0 5.8
65 DRAFT CalEnviroScreen 4.0; 2018 American Community Survey.

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4030 Oakland 92.75 5.7 3.9 81.6 3 1.1 3.2 1.5
4022 Oakland 92.72 26.6 27.9 19.1 21.7 0.9 0.0 3.7
4061 Oakland 92.60 13.6 10.0 16.2 57.9 0.0 0.5 1.8
4095 Oakland 90.98 4.6 27.5 0.7 63.3 0.1 1.9 1.9
4060 Oakland 90.39 18.2 14.9 44.2 19.6 0.0 0.2 2.9
4105 Oakland 90.33 8.3 63.3 14.7 10.4 0.3 0.7 2.2
4324 San Leandro 89.82 19.1 5.6 32.3 39.6 0.0 1.1 2.3
4025 Oakland 89.80 8.8 64.2 10.5 10.7 0.0 0.0 5.8
4094 Oakland 89.63 4.3 17.1 8.2 68.8 0.0 0.3 1.3
4089 Oakland 89.24 3.6 28.7 4.4 59.3 0.0 1.1 3.0
4033 Oakland 87.35 23.3 7.6 50.8 9.3 2.5 0.0 6.4
Table 25. Race/Ethnicity of 15Least Burdened Census Tracts in Alameda County CT No. City
CES 4.0
Percentile White Black Asian Latinx Native
Paciﬁc
Islander Other
4261 Oakland 0.25 75.4 1.3 17.6 1.2 0.2 0.0 4.3
4216 Berkeley 0.29 72.9 3.2 14.0 4.7 0.0 0.6 4.7
4301.02 Castro Valley 0.35 56.7 3.5 18.4 11.0 0.0 0.7 9.7 4211 Berkeley 0.88 76.5 1.4 11.6 6.5 0.0 0.3 3.7
4206 Albany 1.21 67.2 0.3 15.2 11.1 0.0 0.5 5.7
4213 Berkeley 1.26 80.6 1.3 8.8 1.8 0.0 0.2 7.3
4215 Berkeley 1.40 77.2 3.5 11.2 4.9 0.0 0.3 2.9
4364.02 Hayward 1.45 51.0 20.1 9.7 14.3 0.0 0.0 5.0
4043 Oakland 1.64 63.8 2.8 13.4 12.1 0.0 0.0 7.9
4212 Berkeley 1.82 73.9 1.2 11.9 4.5 0.1 0.0 8.4
4511.02 Livermore 2.11 77.5 0.3 9.4 8.5 0.4 0.0 3.9
4046 Oakland 2.16 68.7 4.7 14.6 3.9 0.1 2.2 5.7
4047 Oakland 2.17 72.9 6.4 9.6 8.4 0.0 0.3 2.4
4432 Fremont 2.33 18.5 0.0 73.6 1.3 0.3 1.2 5.0
4506.04 Pleasanton 2.35 59.9 0.5 25.3 10.0 0.4 0.0 4.0
Table 26 lists the census tracts ranked above the 75th percentile statewide according to both CES 3.0 and CES 4.0, in order of their rank on CES 4.0. The neighborhood names of census tracts that appear in the top 25% on both maps are listed in red.

Table 26. Comparison of Disadvantaged Communities in CES 3.0 and Draft CES 4.0 (Ordered by Rank on Draft CES 4.0)
Census
Tract
Zip
Code City Neighborhood
CES 3.0
Percentile
Draft CES 4.0
Percentile
4073 94601 Oakland Lockwood/Coliseum 91.16 97.96
4088 94621 Oakland Havenscourt/Coliseum 96.22 97.48
4090 94621 Oakland Oakland Airport 96.91 97.26
4091 94603 Oakland Brockﬁeld Village 96.38 95.83
4030 94607 Oakland Chinatown 84.99 92.75
4022 94607 Oakland Prescott/Mandela Peralta 88.32 92.72 Environmental / Justice Solutions | 58
4061 94601 Oakland Jingletown/Kennedy Tract 85.81 92.60 4095 94621 Oakland Woodland/Tassafaronga 90.30 90.98
4060 94606 Oakland Oakland Estuary 89.13 90.39
4105 94607 Oakland Defremery/Oak Center 81.17 90.33
4324 94577 San Leandro 83.60 89.82
4025 94607 Oakland Acorn 81.55 89.80
4094 94603 Oakland Elmhurst Park 88.02 89.63
4089 94621 Oakland Fitchburg/Hegenberger 86.68 89.24
4033 94607 Oakland Chinatown/Laney 82.13 87.35
4092 94603 Oakland Sobrante Park 93.48 86.71
4325.01 94577 San Leandro 81.16 85.91
4017 94607 Oakland Port of Oakland 84.56 85.75
4018 94607 Oakland Prescott 86.25 84.84
4014 94608 Oakland Hoover/Foster 85.40 84.15
4016 94607 Oakland McClymonds 77.84 83.78
4072 94601 Oakland Fruitvale 78.46 83.54
4062.01 94601 Oakland Reservoir Hill/Meadow Brook 75.48 83.24 4013 94609 Oakland Pill Hill 71.28 83.00
4075 94621 Oakland Seminary 72.62 82.37
4287 94501 Alameda 74.85 81.98
4015 94608 Oakland Clawson/Dogtown 82.39 80.98
4232 94710 Berkeley 70.21 80.00
4010 94608 Oakland Longfellow 78.52 79.53
4028 94612 Oakland Uptown/Downtown 73.45 79.36
4062.02 94601 Oakland Fruitvale/Hawthorne 70.98 79.18
4026 94607 Oakland Jack London Gateway 68.50 79.02
4009 94608 Oakland Gaskill 66.74 78.84
4371.01 94587 Union City 78.82 78.66
4059.02 94606 Oakland Lower San Antonio 2 67.46 78.11
4059.01 94606 Oakland Lower San Antonio 1 68.28 77.73
4332 94578 San Leandro 82.67 77.62
4074 94601 Oakland Fremont 76.93 77.52
4027 94612 Oakland Bunche/MLK Jr 76.39 73.87
4031 94607 Oakland Downtown/Old Oakland 66.89 73.29
4008 94608 Oakland Paradise Park/Golden Gate 67.05 72.57 4220 94710 Berkeley 75.94 71.61
4362 94541 Hayward 71.03 71.22
4381 94544 Hayward 73.51 69.84
4093 94603 Oakland North Stonehurst 82.60 69.50
4054.01 94606 Oakland Eastlake Clinton 1 75.56 69.43
4024 94607 Oakland Bunche/Oak Center 79.87 68.13
4007 94608 Oakland Santa Fe/N. Oakland 69.81 67.98
4372 94545 Hayward 75.02 67.81
4369 94541 Hayward 70.08 66.70
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4382.03 94544 Hayward 80.45 66.41
4326 94577 San Leandro 70.64 64.33
4053.02 94606 Oakland Eastlake 65.78 64.20
4403.01 94587 Union City 75.55 62.48
4446.01 94560 Newark 78.74 62.47
4251.04 94608 Emeryville 77.39 59.17
Social Vulnerability Index
The Center for Disease Control’sSocial Vulnerability Indexlooks at the relative vulnerability of every U.S. census tract with a measurement of15 social factors, including poverty, lack of vehicle access, and limited English proﬁ
ciency, grouped into four major themes: socioeconomic; housing composition and disability; minority status and language, housing and transportation. The range of scores is from 0 (lowest vulnerability) to 1 (highest vulnerability). Census tracts are scored but not ranked -- multiple tracts receive the same score.

Why it Matters.This score does not take pollution burden into account, but focuses on socio-economic factors including additional important vulnerability indicators not included in CalEnviroScreen, such as access to a vehicle, single-parent households, and people with disabilities. There is a strong correlation between this Social Vulnerability Indexand Draft CalEnviroScreen 4.0’sLead Riskindicator, meaning that of all the indicators studied, these two were most likely to rank census tracts in Alameda County similarly. Again, this highlights the need to overcome multiple factors that contribute to social vulnerability and meet priority needs holistically, in order to achieve equitable outcomes.

Figure 4. Center for Disease
Control Social Vulnerability
Index Documentation
Environmental / Justice Solutions | 60

Map Q.

GIS map
of CDC SVI
scores for
Alameda
County
Listed below are the scores for the 25 most socially vulnerable census tracts in Oakland and Alameda County that scored above .75 (the darker shade of blue on the map above. Within Oakland, there are 14 highly vulnerable census tracts with scores at 0.9 or above.

Racial Equity Finding. Latinx communities in East Oakland are disproportionately represented in the highly vulnerable census tracts.

Table 27. Most Socially Vulnerable Census Tracts
#
Census
Tract No. Neighborhood
ZIP
Code City SVI Score
Lead
Percentile
1 4059.01 Lower San Antonio 1 94606 Oakland 1 97.25
2 4075 Seminary 94621 Oakland 1 99.37
3 4062.02 Fruitvale/Hawthorne 94601 Oakland 0.99 96.13
4 4072 Fruitvale 94601 Oakland 0.99 97.02
5 4089 Fitchburg/Hegenberger 94621 Oakland 0.99 93.49
6 4030 Chinatown 94607 Oakland 0.98 35.51
7 4339 94578 Ashland 0.97 80.02
8 4063 San Antonio/Sausal Creek 94601 Oakland 0.96 93.83 9 4065 Peralta/Hacienda 94601 Oakland 0.96 93.88
10 4086 Bancroft/Havenscourt 2 94605 Oakland 0.96 99.85 Environmental / Justice Solutions | 61

11 4093 North Stonehurst 94603 Oakland 0.96 97.71
12 4095 Woodland/Tassafaronga 94621 Oakland 0.96 98.33
13 4088 Havenscourt/Coliseum 94621 Oakland 0.95 98.99
14 4062.01
Reservoir Hill/Meadow
Brook 94601 Oakland 0.94 97.24
15 4074 Fremont 94601 Oakland 0.94 99.53
16 4071.02 Jeﬀ
erson/Fruitvale 94601 Oakland 0.93 95.34
17 4087 Bancroft/Havenscourt 1 94605 Oakland 0.91 98.49 18 4097 Castlemont 94605 Oakland 0.91 92.68
19 4105 Defremery/Oak Center 94607 Oakland 0.89 97.2
20 4340 94578 Ashland 0.89 91.56
21 4070 Lower Laurel/Allendale 94619 Oakland 0.88 89.26 22 4090 Oakland Airport 94621 Oakland 0.87 97.88
23 4059.02 Lower San Antonio 2 94606 Oakland 0.86 92.83 24 4060 Oakland Estuary 94606 Oakland 0.86 68.78
25 4362 94541 Hayward 0.86 78.4
Table 28. Predominant Race/Ethnicity of Most Socially Vulnerable Census Tracts #
Census
Tract
No. SVI Score Oakland Neighborhood City Race/Ethnicity
1 4059.01 1 Lower San Antonio 1 Latinx
2 4075 1 Seminary Latinx
3 4062.02 0.99 Fruitvale/Hawthorne Latinx
4 4072 0.99 Fruitvale Latinx
5 4089 0.99 Fitchburg/Hegenberger Latinx
6 4030 0.98 Chinatown Asian
7 4339 0.97 Ashland Latinx
8 4063 0.96 San Antonio/Sausal Creek Latinx
9 4065 0.96 Peralta/Hacienda Latinx
10 4086 0.96 Bancroft/Havenscourt 2 Latinx
11 4093 0.96 North Stonehurst Latinx
12 4095 0.96 Woodland/Tassafaronga Latinx
13 4088 0.95 Havenscourt/Coliseum Latinx
14 4062.01 0.94 Reservoir Hill/Meadow Brook Latinx
15 4074 0.94 Fremont District Latinx
Source: American Community Survey 2019 5-year estimate
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California Healthy Places Index
The California Healthy Places Index (HPI) was developed by the Public Health Alliance of Southern California and provides overall scores along with more detailed data on speciﬁ c policy action areas that
shape public health. Census tracts are given a percentile rank based on the percentage of census tracts that have less healthy conditions. (A tract with a percentile score of 20.3 has healthier conditions than

20.3% of other California census tracts.)
Why it Matters. This tool combines a unique set of topics and indicators. The topics span economic outcomes, education, transportation, social, neighborhood, environment, housing and healthcare access. Indicators include homeownership, housing habitability, access to healthcare, park access, supermarket access, tree canopy, voting, and preschool enrollment.

Racial Equity Finding. Latinx and Black communities in East Oakland are disproportionately represented in the unhealthiest census tracts.

Map R. Healthy Places Index, Alameda County
On the map above, the census tracts that are shaded in dark blue have the least healthy conditions (percentile score 0-25) and the census tracts in dark green have the healthiest conditions (percentile score 75-100). The table below provides a list of all of the census tracts in Alameda County that received a percentile rank of 25 or below.

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Table 29. Unhealthiest Places in Alameda County
#
Census
Tract Oakland Neighborhood or City
ZIP
Code HPI Score
Predominant
Race/Ethnicity
1 4070 Lower Laurel/Allendale 94619 24.8 Latinx
2 4101 Foothill Square/Toler Heights 94605 24.7 Black
3 4071 Fruitvale 94601 23.1 Latinx
4 4074 Fremont District 94601 22.5 Latinx
5 4072 Fruitvale 94601 22.1 Latinx
6 4339 Ashland 94578 22.1 Latinx
7 4087 Bancroft/Havenscourt 1 94605 21.5 Latinx
8 4093 North Stonehurst 94603 20.3 Latinx
9 4096 Webster 94621 19.2 Latinx
10 4356.01 Cherryland 94541 18.1 Latinx
11 4094 Elmhurst Park 94603 16.6 Latinx
12 4103 Cox/Elmhurst 94603 15.3 Latinx
13 4227 Berkeley 94704 14.7 Latinx
14 4028 Uptown/Downtown 94612 13 White
15 4059.01 Lower San Antonio 1 94606 13.8 Latinx
16 4059.02 Lower San Antonio 2 94606 13.7 Asian
17 4014 Hoover/Foster 94608 13.6 Black
18 4028 Uptown/Downtown 94612 13 Black
19 4075 Seminary 94621 11.1 Latinx
20 4062.02 Fruitvale/Hawthorne 94601 10.6 Black
21 4018 Prescott 94607 10.6 Latinx
22 4105 Defremery/Oak Center 94607 8.9 Black
23 4062.01 Reservoir Hill/Meadow Brook 94601 7.8 Latinx 24 4025 Acorn 94607 6.4 Black
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25 4086 Bancroft/Havenscourt 2 94605 6.3 Latinx
26 4088 Havenscourt/Coliseum 94621 5.6 Latinx

2.3.1.5. Housing Habitability / Substandard Housing Conditions Why it matters. Disparities in lead poisoning outcomes are directly connected to the disproportionate amount of substandard housing in low-income communities. Older, lower-value residential properties are most at risk of harboring lead paint hazards.66 Poor quality housing, and lack of repair increases the likelihood of degraded lead paint and rental properties with unresolved lead hazards have the potential to harm multiple families. A substantial amount of Oakland's housing stock needs some level of repair, from deferred maintenance to substantial rehabilitation.67 Although Oakland’s municipal code upholds “the right to occupancy of safe decent housing,” the public health and welfare of Oakland residents largely depends on each property owner’swillingness or ability to invest in their property. Some landlords take advantage of residents they know won't be able to ﬁ
ght back, a practice called “predatory habitability.”68 Moreover, habitability complaints received by the City more thank lifely reﬂ ect only a fraction of the
true housing issues faced by vulnerable tenants or homeowners — seniors, low- and moderate- income households, persons on ﬁxed
incomes, undocumented tenants, and tenants of color. Many residents are unaware of the available City services, do not know how to access them, or simply avoid contact with the City. Vulnerable tenants face additional risks and are more likely not to report hazardous conditions in order to keep their rents from rising, avoid eviction, and prevent retaliation of any kind. Undocumented tenants face the additional fear of detention or deportation causing them to avoid interaction with government programs.

Oakland Baseline Equity Indicators
Housing Habitability Complaints
The Housing Habitability Complaints Equity Indicator tracks housing habitability complaints as a percent of total housing units by zip code. To understand existing racial disparities, the percentage of housing units that haveﬁled
habitability complaints in predominantly non-White zip codes is compared to rates in predominantly White and racially and ethnically mixed zip codes. Housing units in predominantly non-White zip codes were 2.03 times more likely to report housing habitability complaints than housing units in predominantly White zip codes.

Findings. Oakland’s oldest, poorest neighborhoods with the highest proportion of renters are likely to 68 Angela Johnston & Melissa Ortega-Welch, Lead and the Bay Area Housing Crisis, KALW, December 13, 2018. 67 City of Oakland Oﬃ
ce of Planning Building & Neighborhood Preservation,Proposed Program Design for Proactive Code Enforcement Operations, (“The National Center for Healthy Housing’s 2009 study of health-related housing problems in the nation’s largest Metropolitan Statistical Areas, rated the City of Oakland the 39th least healthy central city out of forty-four (44) jurisdictions surveyed, with nearly 60% of housing units showing one or more health-related problems.

Oakland’s housing stock also ranks among the oldest and most heavily rental of the cities surveyed.”) 66 The Weight of Lead — Part I: How Contaminated Houses Are Poisoning the Poor.

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suﬀ
er the most from substandard housing conditions. These include Latinx, Black, immigrant, and refugee communities, families with children, low-income renters, undocumented residents, residents receiving public assistance and elderly renters.
➔ Oakland City Council found that “code violations such as inadequate plumbing and heating, leaky roofs, mold, vermin infestations and improper disposal of garbage among many other violations . . . are disproportionately found in neighborhoods in theﬂatlands of East and West
Oakland,”69 including Longfellow (4010); Hoover/Foster (4014); San Antonio (4057, 4058 4059.01, 4059.02, 4063); Fruitvale (4062.02, 4071.01, 4071.02, 4072); Lower Maxwell Park (4076); and Havenscourt (4086, 4087, 4088).70
➔ Neighborhoods in East Oakland tend to have the highest total number of habitability complaints, whereas Downtown and Chinatown have higher rates of complaints per 100 properties. The diﬀ
erence between the highest total number of complaints and the highest rates of complaints indicates a high likelihood that there are additional habitability issues in East Oakland that go unreported.

2.3.1.6. Small Rental Properties and High Housing Cost Burden Why it Matters. Oakland’s Code Enforcement data indicates that the highest rates of habitability issues in Oakland are found in low-income rental housing properties with ﬁve (5) or fewer units.

Buildings with 2-5 units were more likely to report the presence of numerous habitability issues, increasing the likelihood of deteriorating lead paint. Smaller multi-unit buildings are more likely to be owned by mom-and-pop proprietors who may not have deep pockets. Data from the 2012 U.S. Rental Housing Finance Survey shows that owners of smaller properties are less likely to generate suﬃ cient
operating income to cover their mortgage payments and their properties have much longer expected pay-oﬀ
timeframes.

The extremely
high housing
cost burden
increases rates
of
houselessness
among the
working poor and increases the likelihood that housing aﬀ ordable to the lowest income tenants will be
overcrowded or substandard. Using data from the Alameda County Assessor’s Oﬃ ce, in 2013 Urban
Strategies Council identiﬁ
ed the distribution of housing types across Oakland, providing numbers for the top 25 neighborhoods by residential type.71
71 Building an Indicator Base for Healthy Housing Issues in Oaklandat p. 27. 70 Building an Indicator Base for Healthy Housing Issues in Oakland. 69 Oakland City Council Resolution, Establishing a Proactive Rental Inspection (PRI) Program to Address Housing Habitability Violations Without Displacing Vulnerable Tenants and Directing the City Administrator to Return to Council with a Plan and Appropriate Legislation to Begin Implementing a PRI Program, June 16, 2016.

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2019 ACS data shows approximately 95,402 rental units in Oakland, of which, single family dwellings account for 27% (23,564), duplexes 9% (8,682), and 3-4 units buildings 16% (15,741). ACS data lumps properties with 5-9 units together, making it diﬃ
cult to estimate how many additional 5-units there
are. Nationally and in Oakland, two-four unit properties are the most common type of multi-family property. For example, Longfellow has 348 two-four unit dwellings, and 388 multi-family properties of any size.

Table 30. 2-4 Unit Dwellings, Percentage Children & Housing Cost Burden Percentile (Draft CES 4.0) Neighborhood
Census
Tract
# 2-4 unit
Dwellings
% Children
under 10 Race/Ethnicity
Housing
Burden
1 Longfellow 4010 348 8.8 White 36%
Asian 34% 91.59
2 Hoover/Foster 4014 309 3.9 Black 33%
White 24%

97.89 3
Santa Fe/North Oakland 4007 299 7.2 White 40%
Black 28%

80.09 4
Temescal 4011 262 7.2 White 53%
Asian 21%

56.13 5
Shafter/Rockridge 4003 234 11.6 White 69%
Asian 11%

7.73 6
Fairfax/Lower Maxwell Park 4076 232 18.2 Black 42%
Latinx 31%

56.13 7
North Stonehurst 4093 227 16.3 Latinx 63%
Black 27%

83.75 8
Lower Laurel/Allendale 4070 226 11.4 Latinx 32%
Asian 27%

92.82 9
Peralta/Hacienda 4065 224 12.3 Latinx 49%
Asian 20%

87.84 10 San Antonio/Highland
Terrace
4058 216 10.2 Asian 44%
Latinx 21%

89.29 2.3.1.7. Additional Housing Related Indicators
➔ Low-income Owner-Occupied Housing
➔ [Density of Single-Family Homes Per Square Mile (by Census Tract) ➔ Density of Multi-Family Housing Properties Per Square Mile (by Census Tract) ➔ Percent Owner-Occupancy by Census Tract, 2010
➔ Percent Renter-Occupancy by Census Tract, 2010
➔ Tracts with at Least Two-Thirds Owner or Renter Occupancy ➔ Percent of Renter Households with Children Under Age 18 ➔ Code Enforcement Complaints for Work Without a Permit Environmental / Justice Solutions | 67

2.3.1.8. Race/Ethnicity
Why it Matters. Minority and low-income populations are concentrated in areas identiﬁ ed as
high-risk for lead poisoning. Any child can be aﬀ
ected by lead, but exposure is unequal across
populations and race and ethnicity are particularly strongly associated with children’s risk. 72 The demographic data on lead risk by predominant race/ethnicity of each census tract is included above (Section 2.1.2.). The results show that Latinx populations in Oakland are most predominant in the highest risk areas in Alameda County, followed by African American/Black and Asian populations. In fact, four of the ﬁve
census tracts where the most lead poisoned children were found are predominantly Latinx, and the other is
predominantly African American/Black
(Section 2.4.1.1.).

E/J Solutions gathered data on 357 census
tracts in Alameda County from various
sources. We converted the results for each
indicator into a scale of 0-10, then simply
added up each indicator to create an
Overall Burden Score for each census
tract. To zero in on the most burdened
communities, we isolated the top 25 most
burdened census tracts overall and for
each indicator. We identiﬁ
ed the share by
race/ethnicity and compared Oakland to
the remainder of Alameda County.

According to Alameda County, “28% of the African American population and 25% of the Latinx population are represented among children found to have elevated blood lead levels, rates which reﬂ
ect the national landscape where “28% of African American households and 29% of poorer households face housing related lead exposure risks compared with 20% of Whites and 18% of wealthier households.”73

2.3.1.9. Poverty (Low Income & Low Wealth)
Poverty increases both exposure and sensitivity to health hazards. As the Opportunity Atlas shows, the ﬂatlands
of Oakland have the highest concentration of poverty in Alameda County: median household income is $52,962 and unemployment is nearly 11%. In Alameda County, there are 37 census tracts above the 75th percentile statewide for unemployment, 25 of which are in Oakland. Sixty-one percent of all children in Oakland are on Medi Cal and 40% receive Cal-Fresh. The census tract or block where children enrolled in Medi-Cal and other public assistance programs reside can be a useful indicator. 73 Housing Habitability and Health: Oakland’s Hidden Crisisat p. 9. 72 10 Policies to Prevent and Respond to Childhood Lead Exposure: An assessment of the risks communities face and key federal, state, and local solutions at p. 9.

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2.3.1.10. Youth Educational Success & Overall Level of Educational Attainment
Why it Matters. Many of the health impacts of lead poisoning primarily manifest as attitudinal and behavioral impacts that severely hinder academic achievement. “Lead-poisoned children are more likely to struggle in school, drop out, get into trouble with the law, underperform in the workplace, and earn less throughout their lives, independent of other social and economic factors.”74 Even at very low levels, lead exposure aﬀ
ects the brain’s ability to control impulses and process information, with studies showing that lead poisoning has an adverse impact on IQ. Furthermore, low levels of lead exposure may have the worst impact on IQ: “An increase in blood lead from less than 1 to 10 µg/dL is associated with a loss of 6 IQ points, compared with only 2 points lost from a rise from 10 µg/dL to

20.36.”
Proactive lead inspections in census tracts that demonstrate low educational outcomes may reach communities with low blood lead level testing rates and/or widespread lead poisoning.

Database: Oakland Equity Indicators. While the report does not include census tract-level data on education outcome indicators, it identiﬁ
es the diﬀering issues each population struggles with.
● Enrollment in OUSD
● Drop-out rate
● Graduation Rate
● Expulsions/Suspensions
● Preparedness to attend UC/CSU
● Education percentile

2.3.2. Increased Sensitivity to Lead Hazards
Sensitive populations are more susceptible to the harmful impacts of pollution in their environments.

This includes individuals with impaired physiological or psychological conditions, or lower protective biological mechanisms due to genetic factors. “The fetus, children, pregnant and elderly are particularly susceptible to some of the toxic eﬀ
ects of lead;” lead exposure in infancy results in higher levels of impairment than exposures of the same duration at equivalent doses during adolescence.75 While children aged zero to six are the most susceptible to the harmful impacts of lead paint hazards, children over six and non-pregnant adults may also experience heightened sensitivity, due to illness or other factors.

2.3.2.1. Poverty
Why it Matters. Poverty is the most important non-biological factor that increases sensitivity to harmful impacts of exposure. A recent study published in the journalNature Medicine found stronger that children in lower-income families had greater negative impacts from living in high-lead-risk 75 Norm Healey, Lead toxicity, vulnerable subpopulations and emergency preparedness2009 Jun; 134(3-4):143-51. doi:

10.1093/rpd/ncp068. Epub 2009 Apr 26.
74 10 Policies to Prevent and Respond to Childhood Lead Exposure: An assessment of the risks communities face and key federal, state, and local solutions.

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census tracts than children from higher-income families. Children of lower-income families who live in neighborhoods with a high-risk of lead exposure scored signiﬁ cantly lower on cognitive tests and
had smaller brains.76 Children living in poverty tend to live in older, substandard rental housing, with less access to healthy nutritious food. For young children with diets low in iron and calcium there is an increase in the uptake and absorption of lead. In neighborhoods like Fruitvale, which also has a dearth of grocery stores, “many of the low-income children who live there have diets that are deﬁ cient in iron
and calcium, increasing their risk of lead absorption.”77 As lead reduces executive function and behavioral control, the constraints and discomforts of poverty compound these impacts, often resulting in outbursts that are then criminalized.

Case Study: Brandon
Excerpt from The thousands of U.S. locales where lead poisoning is worse than in Flint78 Across the street is the old rental house where, as a baby, Brandon was exposed to peeling lead paint. Health records show thatbefore age 2, his levels reached nearly 10 times the current CDC threshold. He was hospitalized and received chelation treatment. The drugs remove heavy metals from the body and help prevent further damage, but once a child is exposed, the impact can be irreversible.

Brandon, who is easily excited, was at turns cheerful and mournful during an interview. He never ﬁnished
high school and hasn’t held a job. He has cognitive impairment, Attention Deﬁ cit
Hyperactivity Disorder and outbursts of anger. He was recently arrested after a dispute with a convenience store clerk over soda pop, and is now on probation. “Ever since I caught the lead, I’ve been messed up in the head. I can’t control my anger or feelings,” Brandon said. “I could have been better than I am.”

2.3.2.2. Extremely Elevated Blood Lead Levels
Why it Matters. Reducing disparities requires an intentional focus on the communities that have been the most harmed. To the extent that location data is available, the City and County should prioritize comprehensive lead hazard screening in the census tracts where blood lead testing has revealed abnormally high blood lead levels. 2018 data from the California Department of Public Health shows that 362 childrenin Alameda County had EBLLs greater than or equal to 4.5 μg/dL, whereas 97.78% of children have BLLs below 4.5 μg/dL.79 Sixty two childrenhad EBLLs greater than or equal to 9.5, which amounted to 0.38% of children screened.
79 California Department of Public Health, Blood Lead Level Maps and Data, Table 1 and 2 (2018). 78 M.B. Pell and Joshua Schneyer, The thousands of U.S. locales where lead poisoning is worse than in Flint, Reuters, Dec. 19, 2016.
77 Rachel Swan, Parents in Oakland's Fruitvale area confront lead-paint plague, SF Chronicle, January 25, 2017. 76 Environmental Working Group, Bill Requires California to Test Millions of Children for Lead Exposure,” (“Association of lead-exposure risk and family income with childhood brain outcomes”) Environmental / Justice Solutions | 70
Table 31. Percentage of Lead Poisoned Children with EBLL Above and Below 4.5 μg/dL #
BLL <

4.5 μg/dL
%
BLL
< 4.5
μg/dL
#
BLL ≥

4.5 μg/dL
%
BLL ≥

4.5 μg/dL
#
BLL ≥ 9.5
μg/dL
% BLL ≥

9.5 μg/dL
#
Children
< 6
screened
#
Children
< 6 in
Medi-Cal
#
Children
< 6
Alameda
County
15,945 97.78% 362 2.22% 62 0.38% 16,307 32,969 107,004

2.3.2.3. Pregnant Women, Low Birthweight Infants & Density of Children in Poverty
Why it Matters. Pregnant mothers and children with pre-existing conditions (comorbidities) are among the populations most susceptible to harmful impacts of lead paint. Low birthweight babies born weighing less than 5 pounds, 8 ouncesare among the most sensitive. Low birthweight babies face increased risk of infant mortality and a host of short- and long-term complications such as trouble breathing, bleeding in the brain, heart problems, intestinal disorders and retinopathy. These factors can result in extreme sensitivity to the harmful impacts of lead based paint.

In addition, low-level maternal blood lead levels can cause low birthweight. Lead contamination begins in the second trimester of pregnancy, increases during the third trimester “when the baby is growing rapidly and incorporates nutrients and toxins from its mother,” and continues to accumulate after birth during the baby’sﬁrst
year.80 The decrease in birth weight per each microgram increase in maternal PbB is signiﬁ
cant, including at lower concentrations, and action is necessary to address the high prevalence of low-level PbB among pregnant women.81 Lead may also leach into breastmilk, further exposing newborns to lead poisoning even before they are able to crawl about and ingest any hazards in their environment. Yet, experts point to the lack of standards concerning lead exposure for pregnant women and their unborn babies, despite proof of the risks to a developing fetus.

Nationally, African Americans face the greatest risk of low birth weight; Black mothers have a prevalence of low birth weight that is two times higher than White mothers. ◆ 1 in 7 African American babies (about 13 percent)
◆ 1 in 12 Asian babies (about 8 percent)
◆ 1 in 13 American Indian/Alaska Native babies (about 7 percent) ◆ 1 in 14 Hispanic babies (about 7 percent)
◆ 1 in 14 White babies (about 7 percent)
Racial Equity Findings. Need to target census tracts with high rates of low birthweight infants, high poverty and high cumulative disadvantage. The table below shows census tracts with: (a) high rates of low birth weight babies (Draft CES 4.0 top 5% statewide) (b) high numbers of children under 10; and (c) 81 Maternal low-level lead exposure and fetal growth.
80 Lead contamination found in baby teeth of children living near Exide battery plant.

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high levels of cumulative disadvantage/social vulnerability (CES 3.0, Draft CES 4.0 & SVI). Census tracts with greater than 13-14% children under 10 (bolded) are above average.

Table 32. Prevalence of Low Birth Weight Infants & Children Under 10 in Burdened Communities CT Zip
Code
Neighborhood
or City
LBW
Pctl DAC Pctl SVI %Children
under 10
Largest
Racial/Ethnic
Group
Next
Largest
Group
4027 94612 Bunche/MLK Jr 99.86 76.39 CES 3.0

73.87 CES 4.0
.56 14% 2010
6% 2018
Black
56% 2010
42% 2018
Latinx
16%
2010-2018
4025 94607 Acorn 99.55 81.55 CES 3.0

89.80 CES 4.0
.85 20% 2010
22% 2018
Black
64% 2010
67% 2018
Latinx
11% 2010

4.5% 2018
4015 94608 Clawson/Dogtown 99.31 82.39 CES 3.0

80.98 CES 4.0
.51 9% 2010
4% 2018
Black
53% 2010
37% 2018
White
20% 2010
40% 2018
4088 94621 Havenscourt
/Coliseum

98.65 96.22 CES 3.0

97.48 CES 4.0
.95 19% 2010
21% 2018
Latinx
46% 2010
53% 2018
Black
41% 2010
34% 2018
4090 94621 Oakland Airport 97.55 96.91 CES 3.0

97.26 CES 4.0
.87 17% 2010
16% 2018
Latinx
49% 2010
53% 2018
Black
43% 2010
32% 2018
4092 94603 Sobrante Park 96.91 93.48 CES 3.0

86.71 CES 4.0
.68 17% 2010
12% 2018
Latinx
50% 2010
55% 2018
Black
40% 2010
32% 2018
4382.03 94544 Hayward 96.39 80.45 CES 3.0

66.41 CES 4.0
.63 10% 2010

6.9% 2018
Asian
45% 2010
54% 2018
Latinx
25% 2010
22% 2018
4009 94608 Gaskill 96.02 66.74 CES 3.0

78.84 CES 4.0
.29 11% 2010
11% 2018
Black
44% 2010
30% 2018
White
31% 2010
42% 2018
4105 94607 Defremery/Oak
Center

95.88 81.17 CES 3.0

90.33 CES 4.0
.89 16% 2010
18% 2018
Black
62% 2010
63% 2018
Asian
17% 2010
15% 2018
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4018 94607 Prescott 95.62 86.25 CES 3.0

84.84 CES 4.0
.51 15% 2010
14% 2018
Black
57% 2010
37% 2018
Latinx
19% 2010
20% 2018
White
15% 2010
33% 2018

2.3.2.4. Pre-existing conditions
Pre-existing conditions, including cardiovascular disease and asthma, exacerbate the impacts of lead poisoning. Census tract-level data about these pre-existing Cardiovascular disease and asthma can be found in CalEnviroScreen and has been included in the assessment of each census tract's overall degree of burden/vulnerability.

Exposure to lead can also contribute to the development of these health conditions, which then increase sensitivity to other factors, such as COVID-19. “The Institute for Health Metrics and Evaluation (“IHME”) estimated that in 2017, lead exposure accounted for 1.06 million deaths and 24.4 million years of healthy life lost … worldwide due to long-term eﬀ
ects on health. The highest burden was in low- and
middle-income countries. IHME also estimated that in 2016, lead exposure accounted for 63.2% of the global burden of idiopathic developmental intellectual disability, 10.3% of the global burden of hypertensive heart disease, 5.6% of the global burden of the ischaemic heart disease and 6.2% of the global burden of stroke.”82

2.3.3. Reduced Capacity for Protective Action
Lack of public awareness and poverty can increase exposure to lead, poverty can increase sensitivity to lead, and both incapacitate the ability to take protective actions. Unsafe renovations of older housing are a signiﬁ
cant source of exposures to lead paint hazards. As many members of the public are unaware of the dangers posed by lead paint, middle and higher-income owners of older housing can unwittingly expose themselves and their children. This may be particularly relevant for the census tracts in West Oakland that have seen an inﬂ
ux of White residents. Other barriers include lack of health care, limited English proﬁ
ciency and immigration status.
82 World Health Organization Fact Sheets, Lead Poisoning and health, August 23, 2019.

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3. Desired Future Outcomes: Recommendations for
Racially Equitable Lead Abatement in Oakland &
Alameda County
Strategies for meeting the gold standard —primary prevention— aim to remove lead hazards before a child’s blood lead levels become elevated. The CDC states, “the most important step … is to prevent lead exposure before it occurs.”83 Yet, as far too many children are already being exposed, the next best step is to curtail and eliminate lead exposure in the most impacted and vulnerable places as quickly as possible. Accomplishing these goals equitably demands adiligent and proactive approach that ensures lead hazards are comprehensively abated in the communities facing the greatest risks and vulnerabilities.

The recommendations detailed below prioritize strategies for proactively and eﬃ ciently eliminating
lead hazards from communities facing high levels of cumulative burden, reducing racial disparities in lead poisoning, meeting priority community needs in order to increase community resilience, and increasing access to resources. The recommendations are based on best practices shown to successfully drive down rates of lead poisoning. Successful strategies include proactive rental inspection programs and funding for rehabilitation. Across the country, the communities with the best outcomes with respect to lead paint threats have approached the “lead poisoning issue holistically, looking at primary prevention policies, ﬁnancing,
transparency, enforcement, outreach, testing,
remediation/abatement, early intervention support for lead-poisoned children, cultural competency, community buy-in, workforce development and tenant protections together.”84 Communities with the best outcomes approach the lead poisoning issue holistically, looking at primary prevention policies, ﬁnancing, transparency, enforcemen, outreach, testing, remediation, early intervention support for lead-poisoned children, cultural competency, community buy-in, workforce development and tenant protections together.

Stop Lead Poisoning from Harming Your Community

3.1. Establish a Robust Joint Lead Hazard Abatement Program The City and County must work collaboratively to increase their capacity toﬁnd lead paint hazards in
the City of Oakland and eliminate lead in homes, schools, and childcare facilities, with adequate implementation funding, full transparency, and accountability. The City of Oakland will need to play a much larger role in addressing the lead paint hazards in its housing stock, but it need not do so in a vacuum. Working cooperatively will support both jurisdictions in capitalizing on the City’s unique ability to deploy proactive approaches to detect lead hazards without utilizing lead settlement funding. 84 Stop Lead Poisoning from Harming Your Community at p. 5 83 Center for Disease Control, Blood Lead Levels in Children.

Environmental / Justice Solutions | 74
Likewise, the Alameda County Public Health Department and the Healthy Homes Department have much expertise and useful data to share. A joint program will ensure joint knowledge of and response to buildings where lead is found and homes where children with EBLLs have been found. The City and County should no longer keep their eﬀ
orts siloed, which hampers the ability to keep real-time records and monitor program impacts. A joint and comprehensive program that addresses the lead hazard disparities in Oakland would make the most e ﬃ
cient use of the City and County’s overlapping
jurisdiction in the City of Oakland without duplicating eﬀ orts.

For sake of reference, this REIA refers to the proposed partnership between the City of Oakland and the County of Alameda as the Equitable Lead Hazard Abatement Program (“ELHAP”).

3.2. Increase Community Governance and Oversight
A key attribute of lead poisoning prevention programs is that they aﬀ ect many stakeholders, “putting
burdens on them, providing beneﬁ
ts to them, or changing how they do their jobs.”85 As such, lead policies need broad community education and buy-in, alongside meaningful stakeholder input and oversight. Direct input from impacted community members is absolutely necessary. Unless policy makers consistently gather qualitative data and value lived experience on equal footing with other forms of data, blind spots can lead to harmful unintended consequences.

Community leadership is essential to ensuring equitable outcomes, as evidenced by the fact that PUEBLO (People United for a Better Life in Oakland), a member-driven, base-building community non-proﬁ
t organization dedicated to leadership development and advocating for the needs of low-income Oaklanders, advocated for the creation of and helped found the Alameda County Lead Poisoning Prevention Program in 1990.

Alameda County’s Lead Poisoning Prevention Program is governed by a Joint Exercise of Powers Agreement forming a Joint Powers Authority (“JPA”). The JPA’s Board of Directors is composed of a representative from each city in the County Service Area, a member of the Alameda County Board of Supervisors, and a Community Representative. Gwen Hardy, a co-founder of PUEBLO, is the current Community Representative. The JPA could provide even more robust community oversight by expanding the number of Community Representatives. Ideally, there would be no less than one Community Representative from each city and the unincorporated areas in the County Service Area (ﬁ
ve or more community representatives). Additional community representatives could include: (a) parents of lead-poisoned children; (b) single-parent families; (c) low-income tenants, tenant advocates and base-building organizations; (d) low-income landlords and low-income homeowners; (e) medical professionals and care providers; (f) teachers and school administrators.

The ELHAP should continually be informed by input from hyperlocal community stakeholders in impacted communities. This can be achieved through focus groups, online or paper surveys, and door-to-door canvassing and ground-truthing conducted in partnership with local community-based organizations.
85 Stop Lead Poisoning from Harming Your Community.

Environmental / Justice Solutions | 75

3.3. Exceed Primary Prevention Standards & Meet Priority Community Needs

3.3.1. Raise funding to enable signiﬁ
cant investment in lead abatement and maintain a robust system for monitoring lead abatement eﬀ
orts, including staﬃng
and technological support. The
Equitable Lead Hazard Abatement Program should implement the highest policy standard for lead hazard remediation/abatement and lead poisoning prevention. The overarching program structure need not be too extensive as it is intended primarily to monitor and coordinate the City and County’s eﬀ
orts. A nimble system will enable most of the funds toﬂow to the neediest Oakland residents. As
envisioned, the program would require at least one dedicated Program Specialist, administrative support, and IT support to maintain a state of the art system for collecting and monitoring program data. Lead paint settlement funds now available to the City and County should be leveraged to generate additional program funding sources. This can include use of a fee that is cost recovering but not passed through to tenants nor an undue burden on landlords or homeowners. In addition to money from the city’s budget, public-private partnerships and bringing in money from the philanthropic community and other sources are both important to fund a robust lead program.

Table 33. Proposed Staﬃ
ng for Joint Lead Hazard Abatement
Position FTE Role and Area of Focus
Lead Hazard Abatement Program Specialist 1.0 Monitor all program eﬀ orts, oversee
funding for relocation/rehabilitation
grants or loans, and periodically evaluate
progress toward reducing disparities.

Administrative Assistant 1.0 Program support and database maintenance.

IT Support .5 Develop and deploy technological
solutions, including in-ﬁ
eld tablets for
contemporaneous data entry.

3.3.2. Increase the City and County’s capacity to proactively inspect for (and eliminate) lead hazards across all types of housing stock, including rental property, owner-occupied dwellings, and multi-family units. The City and County will need to directly address and neutralize the myriad factors that contribute to racially disparate outcomes in lead poisoning/exposure to lead hazards. One of the key elements of the current system that leads to disparate outcomes is its overreliance on tenants or homeowners taking action to alert authorities to the presence of lead in their environment, either through a habitability complaint, rent adjustment petition, unsafe renovation, or an elevated blood lead test.

One of the things that troubles me about this issue is, why are we using the children in our community to be ... lead poisoning detectives? Why aren’t we getting ahead of the ... curve? Larry Brooks, Director - Alameda County Healthy Homes Department Environmental / Justice Solutions | 76
Oakland is poised to implement aproactive rental inspection program(PRIP) that will proactively send Code Enforcement inspectors to rental properties without need for a tenant complaint. City inspectors can inspect properties for lead while performing inspections for housing habitability and code compliance, creating an additional economic e ﬃ
ciency because Oakland will not be using
settlement funds to staﬀits
PRIP program.Lead settlement funds should primarilyﬂow
to tenants
and landlords to ensure hazards are eliminated as quickly as possible.

An alternative approach would be for the City to either directly hireor ask landlords/homeowners to hire cost-eﬀ
ective third-party contractors to inspect for and rehabilitate lead only. A proactive model of this approach is currently being implemented by the cities of Rochester, New York andToledo, Ohio (see case study below). While both methods have pros and cons, it appears ideal for the City to inspect for, document, and ensure rehabilitation of all housing habitability issues at once.

Case Study: City of Toledo, Ohio
The Toledo City Council unanimously passed a new
Residential Rental Properties and Lead Safety Compliance Ordinance (the Toledo Lead Ordinance) on October 20,
2020. The Ordinance is based on an analysis of risk
assessments conducted in Toledo by the Health
Department, which showed that the majority of
childhood lead poisoning in Toledo occurs in rental
properties with four units or less.

The Toledo Lead Ordinance requires owners of 1-4 unit
properties built before 1978 to:
➔ Register with the County Auditor;
➔ Have their units inspected and remediated by a
Local Lead Inspector; and
➔ Obtain a Lead-Safe Certiﬁ
cate from the
Toledo-Lucas County Health Department before
they can rent out their property.

Lead-safe certiﬁ
cates are available for 5 years, or 20
years in the case of full abatement. Family child-care
homes (e.g. in-home daycares) also need a lead-safe
certiﬁ
cate, but are not required to register with the
Auditor.86
Compliance with the requirements is being phased in, with rental properties located in census tracts that “pose the greatest danger of lead exposure to children” required to register ﬁ rst. The ordinance
includes ten phases, in descending order of risk, in a ﬁ ve year compliance period. Each phase
contains eleven census tracts.
86 City of Toledo, Lead Ordinance, Section 1760.14.

Environmental / Justice Solutions | 77

Toledo also promotes the use of licensed Local Lead Inspectors, Clearance Technicians, and Lead Risk Assessors who have registered with the Toledo-Lucas County Health Department, maintaining an updated list of actively registered Local Lead Inspectors who wish to market their services to owners.87
The Toledo-Lucas County Health Department will issue the lead-safe certiﬁ cates. The City of Toledo’s
Department of Neighborhoods will coordinate the program and wraparound services with the Lead Safe Coordinator. Toledo’s Code Enforcement Department will begin enforcing the lead law in the most at-risk census tracts once the ﬁ
rst compliance date for phase one elapses.

3.3.3. Prioritize vulnerable communities for early action.To address the highest needsﬁrst, utilize
a straightforward prioritization methodology that leads to early and comprehensive lead abatement, outreach, and testing activities in vulnerable census tracts. For example, the City of Toledo’sResidential Rental Properties and Lead Safety Compliance Ordinance(known as the Toledo Lead Ordinance) used an analysis of all reported cases of lead poisoned children over the pastﬁve years in combination with
additional census tract and residential parcel information, to develop aﬁve year compliance phase-in
schedule for compliance which begins with rental properties located in census tracts that “have been determined to pose the greatest danger of lead exposure to children.” 88 Figure 5. City of Toledo, Ohio Lead Ordinance Compliance dates by groups of census tracts.

The Oakland Department of Transportation used a similar prioritization scheme for its 2019 paving plan. Funding for road repairs was allocated by taking into account both the condition of the road and 88 City of Toledo, Lead Safety Ordinance.
87 City of Toledo, Lead Safe Toledo.

Environmental / Justice Solutions | 78

the proportion of residents in the neighborhood who are in underserved communities. Relevant to transportation access issues, “communities were identiﬁ ed by including people of color, low-income
households, people with disabilities, households with a severe rent burden, people with limited English proﬁ
ciency, and youth/seniors.”89
Prioritization Methodology

1. Select a holistic set of indicators that demonstrate cumulative burdens and community vulnerability to lead paint hazards. Using an indicator that represents each vulnerability category (exposure, sensitivity, protective capacity) is a useful guideline.

2. Choose an appropriate threshold for initial focus, such as the 25 most burdened census tracts for each indicator, or census tracts above a certain percentile. The number of census tracts chosen should be based on programmatic ability to prioritize and reach theﬁrst tier of census
tracts within theﬁrst
phase of program eﬀ
orts. Divide the remaining tracts into tiers of roughly 20-30 census tracts, or as corresponds to programmatic capacity/need.

3. Isolate the census tracts that demonstrate high cumulative burdens across multiple indicators by ranking census tracts according to the number of indicators where they have high degrees of burden or according to the level of burden experienced in each of the indicators, e.g., above the 90th percentile when ranked against all census tracts in Alameda County.

It is important toinvestigate community needs in the census tracts with high burdens in any of the vulnerability indicators, rather than only relying on a composite score to direct focus. The degree of overall burden, however, is still a relevant indicator.

4. Comprehensively deploy holistic and proactive program eﬀ orts in priority neighborhoods. Work
from block to block to address lead hazards on a community-wide basis rather than only in the homes where complaints have been received. Increase outreach for lead testing and recruitment for workforce development and lead certiﬁ
cation through partnerships with
community-based organizations that hire community residents, such as the East Oakland Black Cultural Zone's Neighborhood Ambassadors.

Findings. The previous section of this REIA includes data from several lead hazard vulnerability indicators to identify highly burdened census tracts. To conduct an equity assessment and highlight the areas with high cumulative burdens across multiple indicators, E/J Solutions calculated an overall burden for each census tract. We converted all of the gathered data into a scale of 0-10, then added the value of all of the negative indicators and subtracted the sum of the positive indicators. (For positive indicators, higher numbers represent positive outcomes, such as for life expectancy, whereas for negative indicators, higher ranking scores indicate negative outcomes.) Although we highlight only 89 City of Oakland Department of Transportation, OakDOT Kicks Oﬀ Three-Year, $100 Million, Equity-Focused Paving Plan, August 22, 2019.

Environmental / Justice Solutions | 79
the top 10-25 census tracts in the body of this report, all of the data we collected has been shared with the City and County.

Table 34. 25 Census Tracts with Greatest Vulnerability
Census
Tract
Nearby
City
Predomin
ant Race/
Ethnicity
Overall
Burden
Score
Census
Tract
Nearby City Predomina
nt Race/
Ethnicity
Overall
Burden
Score
4073 Oakland Latinx 215.4 4324 San Leandro Latinx 176.0 4090 Oakland Latinx 201.2 4092 Oakland Latinx 175.7
4088 Oakland Latinx 200.8 4075 Oakland Latinx 174.7
4030 Oakland Asian 193.1 4016 Oakland Black 173.4
4061 Oakland Latinx 191.7 4025 Oakland Black 172.9
4022 Oakland Black 189.2 4014 Oakland Black 172.0
4089 Oakland Latinx 188.3 4094 Oakland Latinx 171.5
4091 Oakland Latinx 184.3 4062.01 Oakland Latinx 170.3
4105 Oakland Black 182.0 4072 Oakland Latinx 169.8
4095 Oakland Latinx 181.2 4015 Oakland Black 169.3
4060 Oakland Asian 179.7 4287 Alameda Asian 167.3
4017 Oakland White 178.7 4059.01 Oakland Latinx 165.2
4018 Oakland Black 177.3
Table 35. 25 Census Tracts with Least Vulnerability
Census
Tract
Nearby City Predomi
nant
Race/
Ethnicity
Overall
Burden
Score
Census
Tract
Nearby City Predomina
nt Race/
Ethnicity
Overall
Burden
Score
4301.02 Castro Valley White 24.4 4517.01 Livermore White 38.5 4511.02 Livermore White 25.1 4043 Oakland White 39.0
4044 Oakland White 27.5 4515.05 Livermore White 39.9
4506.04 Pleasanton White 29.7 4047 Oakland White 40.1
4517.03 Livermore White 30.4 4506.05 Pleasanton White 40.5 4364.02 Hayward White 31.0 4212 Berkeley White 40.9
4045.02 Oakland White 31.3 4420 Fremont Asian 41.5
4080 Oakland White 32.3 4211 Berkeley White 43.4
4046 Oakland White 32.5 4304 Castro Valley White 43.6
4506.06 Pleasanton White 32.6 4517.04 Livermore White 43.9 4045.01 Oakland White 33.0 4238 Berkeley White 44.1
4215 Berkeley White 34.1 4505.02 Castro Valley White 44.7 4432 Fremont Asian 34.3
Environmental / Justice Solutions | 80
Map Q. Alameda County map of
cumulative risk by zip code using:
(a) Density; (b) Poverty; (c) %
African American; (d) % Hispanic;
(e) Pre-1950 Housing; (f)
Population <21 Years; and (g)
High School Educational
Attainment indicators.

A simple comparison of indicators is also an eﬀ
ective methodology. Census tracts in East Oakland rise
to the top of the three vulnerability indicators in Table 24 below: Draft CES 4.0 Lead Percentile, Number of Children with EBLLs and Draft CES 4.0 Percentile. Two of the three indicators include metrics for poverty, pre-existing conditions, and age of housing units.

Using both methodologies, census tract4088 (Havenscourt/Coliseum)rises to the top. It is ranked in the top 5% of CES 4.0 and Lead; 31 children were found to have lead poisoning between 2014-2017; in addition, life expectancy is 73 years, and it scores 0.96 (out of 1) on the CDC Vulnerability index. Given its showing across multiple indicators, this census tract should be targeted within theﬁrst phase of
proactive inspections, outreach, and testing e ﬀ
orts. A census tract with high lead risk and high
cumulative burdens but low Observed EBLL, such as 4091 (Brookﬁ eld Village) should similarly be
included in early phases of proactive inspections and should receive targeted lead testing eﬀ orts in
coordination with community members and community based groups.

Table 36. Top 5 Census tracts by Lead Pctl, with Observed EBLL, and Cumulative Impact Pctl Census
Tract ZIP Neighborhood City Lead Pctl Observed
EBLL
Draft CES 4.0
Percentile
4086 94605 Bancroft/Havenscourt 2 Oakland 99.85 18 65.16 4074 94601 Fremont Oakland 99.53 14 77.52
4091 94603 Brookﬁ
eld Village Oakland 99.43 5 95.83
4075 94621 Seminary Oakland 99.37 23 82.37
4088 94621 Havenscourt/Coliseum Oakland 98.99 31 97.48

3.3.4. Build and maintain a central database to monitor lead abatement eﬀ orts and use active
case monitoring to ensure identiﬁ
ed hazards are remediated in a timely fashion.Systematize methods for collecting comprehensive data about lead hazard abatement in Oakland, regardless of Environmental / Justice Solutions | 81

whether the property was identiﬁ
ed by the City or County. All lead hazards found in Oakland by either the City or County should result in a case opened and closed by the Equitable Lead Hazard Abatement Program. The ELHAP, in addition to maintaining up-to-date records on where lead hazards are found, should meticulously track rehabilitation and remediation eﬀ orts. A case should be closed only once
lead hazards and other habitability issues have been removed.

Oakland currently maintains records for Property Maintenance, Building Maintenance, and Zoning activity, which include inspectors’ reports or reports provided by private companies or residents with the Notice of Violation. It also contains some data which tracks the lead cases referred to the County.

However, no City database captures the details of habitability complaints in a standardized way that enables sorting by the speciﬁ
c contaminants or habitability issues associated with each complaint. To determine whether a case contains lead hazards and whether or not they have been resolved requires a review of the database on a case-by-case basis. The City is in the process of determining how to update/adapt its Accela database to generate detailed, standardized reports about lead complaints.

3.3.5. Facilitate remediation ofall habitability issues and improve climate resilience. If City staﬀ perform
the inspections for the presence of lead paint hazards in vulnerable communities, inspectors will undoubtedly discover multiple habitability issues, such as asbestos, mold, or lack of smoke or carbon monoxide detectors. Eﬀ
orts should be made to rehabilitate all the issues identiﬁ ed at the same
time, particularly because many are typically found on the same surfaces as lead hazards, such as windows. The City also has capacity to assist homeowners and tenants by repairing minor issues, such as providing screens for windows free of cost. The lead program specialist should maintain accurate records of any additional habitability issues present at a site where lead hazards are found, and should not mark a case as fully complete (e.g., issue a Certiﬁ cate of Clearance) until all habitability issues are
remediated. The process of inspection, environmental investigation, and remediation/abatement can be invasive and burdensome to families, and may not seem worthwhile if additional indoor environmental hazards remain.

Another synergistic element to consider is the way this rehabilitation work intersects with climate change mitigation and adaptation eﬀ
orts that are currently needed. For instance, energy eﬃ ciency
retroﬁ
ts like weatherization, and electriﬁ
cation that can require major construction, can take place at the same time that lead and other habitability issues are addressed. As high heat days and the number and intensity of wildﬁ
re smoke pollution compounded by ozone continues to increase with worsening climate disruption, weatherization and passive airﬁltration to improve indoor air quality and health will
be increasingly important. The City of Oakland’s 2030 Equitable Climate Action Plan (ECAP) has set forth ambitious goals of weatherizing and ultimately electrifying 100% of Oakland’s existing building stock by 2040, without displacement or adverse impacts on low-income communities of color. Pairing targeted and preventative lead hazard abatement with these additional retro ﬁ ts is a means of stacking
functions and prioritizing the most-impacted communities to beneﬁ t from improved indoor air quality,
thermal comfort, and habitability as well as energy aﬀ
ordability and climate resilience.

The Cypress Mandela Training Center in Oakland has developed programs where trainees can receive training for multiple certiﬁ
cations during either a 16-week or 8-week program. The 16-week program Environmental / Justice Solutions | 82
covers carpentry, electrical, plumbing, cement masonry, ironwork, energy eﬃ ciency, and solar. The
8-week Environmental program includes certi ﬁ
cations for asbestos, waste sites, mold, lead, and
infectious disease. Their vision is for contractors and businesses from overburdened communities to service the neighborhoods where they live. Cypress Mandela’s partner, Revalue.io has built a GIS map platform that connects local contractors with projects requiring lead, mold, and asbestos abatement or remediation, energy eﬃ
ciency and rooftop solar installation and that identiﬁ
es the cost savings from
day one of utilizing a Green Lease or Pay As You Save on-billﬁnancing method to pay for holistic and
comprehensive renovations using the anticipated energy bill savings from energy e ﬃ ciency
improvements.

3.3.6. Prioritize full abatement of lead hazards, whenever feasible. Home inspections that discover lead paint hazards, especially in homes where sensitive populations reside, should result in the total abatement (complete elimination) of the lead paint hazards whenever possible. The cities of Rochester, NY and Toledo, OH allow use of interim controls and do not require dwellings to be lead-free before being certiﬁ
ed lead-safe.90 While interim controls may require lower up-front costs, they will need to be actively maintained, especially on high friction areas, and require periodic repetition and follow-up inspections. Shifting lead elimination e ﬀ
orts to permanent solutions is important to protect
low-income communities that may lack the resources to maintain interim controls, which can expose them to recurring and new environmental hazards.

Ideally, the City and County will also need to embrace systemic solutions that address “multiple lead exposure pathways [such as lead solder and lead service lines] through simultaneous infrastructure upgrades” and avoid “piecemeal remediation” of lead hazards.91 This is important to equity because “addressing one hazard and not others may leave residents with a false sense of safety, as risk for lead exposure could remain due to unaddressed sources of lead. Permanent removal of housing components painted with lead-based paint, such as trim, windows, and doors, as well as replacement of lead service lines and renovation of plumbing systems, reduces the need for ongoing maintenance or management of lead, which is often less likely to be performed in low-income homes and communities.”92 Strategies like window replacement have important co-bene ﬁ ts that go beyond
removal of the lead hazard, including improved energy eﬃ ciency, comfort and health, and reduced
energy costs.

Lead poisoning of children in OUSD schools with older plumbing systems is one key priority issue that should be addressed expeditiously.

3.3.7. Monitor and ensure timely follow-up inspections. Where total abatement is not feasible, use of temporary containment measures, such as an XRF gun or prior encapsulation, will require a follow-up inspection. Ensure that the follow-up inspections are tied to the length of time that the remediation will last and carefully educate landlords, tenants and homeowners about the maintenance 92 Id. at p. 16, 29.
91 Achieving Equity in Lead Poisoning Prevention Policy Making: Proceedings from a Consensus Conferenceat p. 28. 90 City of Rochester, Lead Paint: Get Prepared; City of Toledo,Lead Safe Toledo: For Owners.

Environmental / Justice Solutions | 83
requirements. The Equitable Lead Hazard Abatement Program Specialist will need to retain an open case with a ﬂag
to indicate that no further action is needed at this time, but inspectors will need to return periodically. “If the ﬁ
x lasts two years, inspect every two years.”

3.3.8. Strive for comprehensive reduction of lead hazards in priority areas. Work toward inspecting and rehabilitating as many buildings as possibleand testing as many children as possible within priority communities.

3.3.9. Enhance enforcement of tenant protections and provide funding to low-income landlords and homeowners to ensure eﬀ
ective and timely remediation of lead hazards without permanent displacement. Some renters experience conﬂ
icts with landlords over lead paint hazards. The need to pay temporary relocation assistance may cause some mom-and-pop landlords to resist needed renovations. Low-income owner-occupiers may also need assistance to aﬀ ord the cost of alternative
temporary lodging arrangements.

In some cases, temporary displacement caused by residential remediation can lead to permanent displacement when a landlord fails to allow a tenant to move back in once repairs are completed as required by the City’s tenant protection laws. TheHousing Equity Roadmap adopted by Oakland City Council on September 30, 2015, directs the city to couple its proactive rental inspection program with tenant protections to “anticipate, avoid and, at least, mitigate the unintended consequence of displacing tenants,” due to building condemnation or a requirement for large scale construction to cure code violations. Tenant protections should include:

1. Providing temporary relocation assistance to low-income landlords to oﬀ set the cost of
complying with Oakland’s temporary relocation ordinance.

2. Increasing enforcement of the Residential Rent Adjustment Program, Just Cause for Eviction Ordinance, Tenant Protection Ordinance and other tenant protection lawsto prevent unlawful evictions or rent increases. Under City Ordinance 8.22.080, when a tenant returns to a unit after vacating for repairs, the owner must petition the Rent Adjustment Board to impose any rent increases, aside from allowable CPI (consumer price index, a measure of inﬂ
ation) and Banking adjustments, above the lawful rent on the date the tenant vacated the unit for repairs.

3. Additional ELHAP-based protections could provide helpful support. These could include:
developing a fast-tracked way for displaced tenants to petition for relief; restricting Landlords from petitioning the Rent Adjustment Board to increase the rent for at least one calendar year after repairs are completed; extending the amount of time a tenant has to ﬁle a petition
contesting a rent increase from 90-120 days to one year; and/or exempting tenants from paying rent to noncompliant landlords.

4. Identify strategies to prevent repeat-oﬀ
ender units such as requiring landlords to acquire a
lead-free or lead-safe certiﬁ
cation before re-renting a unit.

Environmental / Justice Solutions | 84
Small property owners carry the signi ﬁ
cant ﬁnancial
burden of lead removal, which can prevent
rehabilitation and repair from happening in a timely manner. Remedying substandard conditions can be costly. Some historic properties may restrict certain modiﬁ cations or require signiﬁ
cant structural
changes, making such remediations even costlier. Furthermore, the previous reliance on a complaint-based system for identifying housing habitability issues, means that many substandard properties with signiﬁ
cant issues have gone under the radar, becoming costlier to remedy over time.

Some lead advocates have argued against “full abatement and removal of all lead hazards in a community with low housing values because landlords could not aﬀ ord those ﬁxes.”93
Yet, communities with low housing values are most in need of full abatement. Funding for abatement will mitigate some of these unintended harms. ELHAP should provide assistance to low-income landlords/homeowners to ensure all needed rehabilitation and repair takes place expeditiously.

Incentives, such as matching grants can be used to encourage early compliance to improve the health and well-being of tenants.94 Both low-income “mom-and-pop” landlords providing aﬀ ordable housing
and low-income homeowners should receive adequate ﬁnancial support to make the repairs as
expeditiously as possible, such as through a zero-interest loan or grant fund, e.g., supplementing HUD’s Lead Hazard Repair Grant and Match used by the Healthy Homes Department.

3.3.10. Increase training, certiﬁ
cation, and wraparound services to increase opportunities for small local businesses. There is opportunity to utilize third party contractors for either lead inspections or lead repair and rehabilitation in order to boost the local economy and build community resilience. The County of Alameda is an EPA-approved RRP training provider, but the need for certiﬁ ed
contractors vastly outweighs the current system’s capacity to provide them.

The City will need to build a robust pipeline of local certi ﬁ ed and cost-eﬀ
ective Oakland-based
contractors. Creating pathways to connect local contractors with projects, funding, and clients enables the City to lift up contractors who are based in the census tracts with the highest need. The current list of rehabilitation contractors on the City’s website contains relatively few Oakland-based lead certiﬁ ed
or EPA lead-certiﬁ
ed contractors and would beneﬁ
t from a reorganization that better highlights lead
risk and rehabilitation contractors.95 The City and County can support Alameda County’s local economy and community resilience by actively referring landlords/homeowners to local contractors on lead abatement and other rehabilitation projects. The City may also consider removing or limiting existing exemptions for local hire requirements. As mentioned earlier, Revalue.io is working with Cypress Mandela to become an important resource for connecting emerging small, local and disadvantaged contractors to energy eﬃ
ciency and other renovation and repair projects.

Through its business registry, Oakland can conduct outreach to existing small, local, and disadvantaged renovation and construction contractors to get them RRP certi ﬁ ed through enrollment in free
trainings, e.g., EPA’s RRP 1-day safety certiﬁ
cation provided by the County, and other certiﬁ
cation
programs, such as those oﬀ
ered by the Cypress Mandela Training Center. The City will also need to 95 City of Oakland, List of Rehabilitation Contractors. 94 City of Toledo, Lead Safe Toledo: Early Bird Matching Grant. 93 Earthjustice, Better Lead Policy: Proactive Rental Inspection.

Environmental / Justice Solutions | 85
address the fact that, even if free, some small disadvantaged business enterprises may need funding support to cover potential revenue losses incurred by removing personnel from their job functions.

Oakland can also work to providefull-circle training and wraparound support. A good model for some of the wraparound support needed is Alameda County’s Contractor Technical Assistance Program (CTAP) in partnership with Merriwether & Williams Insurance Systems, which works to increase equitable access to contracting opportunities by “assisting local small, minority, women and veteran contractors to meet County requirements and qualify for bonding or increase their bonding capacity for Alameda County construction and other projects requiring bonding.”96

3.3.11. Support targeted workforce development to increase opportunities for members of at-risk communities. The City and County can increase focused outreach to disadvantaged individuals for training and workforce development. The Oakland Workforce Development Board (OWDB) has proposed a Lead Abatement Workforce Training Program, which would “provide oversight of the training and development of a skilled workforce to provide lead abatement services.” The program will:
(a) outreach and recruitment to provide career services for jobseekers to receive paid lead abatement training, supportive services and job placement. (b) partner with Career Technical Education (CTE) programs to provide jobseekers with industry-recognized training certiﬁ cations and (c) partner with
construction contractors and labor unions for job placement.

The OWDB will lead the coordination of eﬀ
orts, help develop training programs, and gather workforce development partners. In addition, the Cypress Mandela Training Center oﬀ ers two training programs,
one comprehensive 16-week training that includes soft skills, and an 8-week environmental training that includes lead abatement. The Equitable Lead Hazard Abatement Program should increase awareness of and funding for these programs with targeted outreach in priority census tracts, such as areas with high unemployment, poverty, and low educational attainment. The Alameda County Healthy Homes Department provides the RRP training that is part of the Cypress Mandela training. Additional funding could help scale up Cypress Mandela's programs; no one funding source covers all of the multiple certiﬁ
cation trainings they provide.

3.3.12. Make public education about lead hazards, remediation/abatement and lead testing more widespread and accessible, especially in at-risk areas through targeted outreach and education. The County, with City support, should conduct proactive outreach in priority neighborhoods where proactive inspections will occur. Deploy strategies that ensure hard-to-reach tenants and other residents understand: (a) the dangers of lead; (b) the urgent need for remediation/abatement and temporary relocations, e.g., Rehabilitate your dwelling so that you and your children can be healthy and thrive; (c) the dangers posed byunsafe renovations; (d) available funding and other aﬀ
ordable options for rehabilitation; and locations where they can receive blood lead testing. Key strategies to improve outreach to African American, Black, Latinx, Indigenous, immigrant, refugee and other “hard-to-reach” communities include door-to-door canvassing, coordinating with OUSD, a community-trusted source, to share information with parents; and partnering with local CBOs that have deep relationships with local communities, e.g., American Indian 96 Merriwether & Williams Insurance Services, Alameda County Technical Assistance Program.

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Child Resource Center and membership organizations like East Bay Housing Organization. The community should also have access to the data about where lead hazards are found and how the City and County are spending lead program funds.

3.3.13. Combat unfair blame and stigma placed on low-income families of color . Increase messaging around how lead poisoning is not due to any family’s actions, but the result of systemic practices.

3.3.14. Monitor, evaluate on a quarterly basis whether the program is meeting equity goals, and make programmatic changes as needed. Review program data to understand who is receiving program bene ﬁ
ts. Key equity components include, tracking the number of inspections and rehabilitations in priority census tracts. Priority demographics and areas should be targetedﬁrst and early
reports should demonstrate that the majority of outreach, rehabilitation and blood lead testing was performed in these areas and for these demographics. At program outset, key goals should also include increasing immigrant and refugee access to services (risk of higher levels of exposure and reduced capacity for protective action). The ELHAP should produce annual reports tracking these results, particularly highlighting the number of households and children that are better oﬀ . If annual
reports do not demonstrate equitable outcomes, the City and County should course-correct by working with stakeholders in priority demographic groups to review program policies and procedures and identify the barriers that disservice that group.

3.4. Adopt Proactive Secondary Prevention Policies
The City and County should coordinate to target priority populations and augment outreach eﬀ orts to
include (a) veri ﬁ
ed pathways to testing; (b) certiﬁ
cation or remediation assistance to ensure
engagements lead to abatement of lead hazards; and (c) early-intervention to protect children from lead poisoning.

3.4.1. Proactive Lead Testing. Aim for early and universal blood lead testing to enable early intervention. The County must develop new programs and tools to increase screening to ensure every child is tested as early as possible. Possible strategies include:
➔ Ensure that all children in Priority Census Tracts receive blood lead tests at ages 1 and 2.

Children aged 3-6 should be tested if they have not previously been tested. ◆ The City and County can partner with schools and daycare centers to require and provide lead testing before children enter preschool and kindergarten. ◆ Mandatory testing can also be triggered for school children of any age by risk factors that might be able to catch lead problems before BLLs get too high. ◆ Set up temporary and/or permanent locations where parents in at-risk neighborhoods can get lead testing for their children. Testing sites could be set up at areaschools using criteria for prioritizing the establishment of new testing sites, for instance a testing site could be triggered by reaching a certain volume of education/behavioral reports,such as suspensions or expulsions.Due to the likelihood that behavioral or learning issues Environmental / Justice Solutions | 87
may be the only external indicator of possible lead poisoning, our public health system should be involved in investigating whether children exhibiting behavior problems have potentially been exposed to lead and should make blood lead level testing liberally available.
➔ Ensuring that children of any age living in homes where the City ﬁ nds lead receives lead testing.
➔ Providing lead testing for pregnant women, or even earlier, as they enter child-bearing age, may be needed to decrease lead exposure to their future oﬀ spring.
➔ For identiﬁ
ed sensitive populations, such as low birthweight infants, inspect their homes for lead hazards and administer lead tests as proactive measures.

3.4.2. Bolster Public Education and Targeted Outreach. Target priority census tracts, including (a) census tracts with high numbers of lead-poisoned children or (b) where high percentages of children on Medi-Cal have not received testing. Periodically collect quantitative and qualitative data to track public awareness of lead issues.

3.4.3. Create Strong Community Partnerships. To the greatest extent feasible, partner with local community based organizations, especially those who work directly with community members and/or have a base of community membership, to continually engage the community. Informed residents can help spread information in “hard to reach” communities.

3.4.4. Academic Interventions. Consider ways to provide “targeted evidence-based academic and behavioral interventions” to children with a history of lead exposure.97 The County can work to elevate “practices and pedagogies that can help children with elevated blood lead levels avoid or overcome cognitive and behavioral challenges.”98 Oﬀ
ering support to lead poisoned children could increase their lifetime family income and likelihood of graduating from high school and college and decrease their potential to enter the school-to-prison pipeline. Evidence shows that interventions during both early and middle childhood are most eﬀ
ective at increasing mean family income at age 40.99
99 Id. at p. 77.
98 Id. at p. 68.
97 10 Policies to Prevent and Respond to Childhood Lead Exposure: An assessment of the risks communities face and key federal, state, and local solutions at p. 2.

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4. CONCLUSION
In addition to improving quality of life and the quality of the housing stock, Oakland and Alameda County can realize multiple cascading public health, safety, environmental, social, and economic beneﬁ
ts by creating and fully funding an equitable lead hazard abatement program. Researchers have found that eradicating lead paint hazards from older homes where children from low-income families reside would provide a return of approximately $1.39 in future beneﬁ ts per dollar invested.

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APPENDIX A: Key Resources
Datasets

1. Oﬃ
ce of Environmental Health Hazard Assessment, California Environmental Protection Agency: CalEnviroScreen 3.0 Report & Map, 2018

2. Oﬃ
ce of Environmental Health Hazard Assessment, California Environmental Protection Agency: Draft CalEnviroScreen 4.0 Report & Map, 2021

3. Public Health Alliance of Southern California: California Healthy Places Index

4. Center for Disease Control: Social Vulnerability Index, 2018

5. California Department of Public Health, California State Auditor, Lead poisoned children in Alameda County - EBLL data FY 2013-14 through 2017-18

6. Alameda County Public Health Indicators - Life Expectancy Reports
Lead

1. Tram Nguyen et al., Housing Habitability and Health: Oakland’s Hidden Crisis, Alameda County Public Health & Alameda County Healthy Homes Department, April 2018.

2. Health Impact Project, 10 Policies to Prevent and Respond to Childhood Lead Exposure: An assessment of the risks communities face and key federal, state, and local solutions, Pew Charitable Trust, 2018.

3. Human Impact Partners, Achieving Lead Equity in Policymaking: Proceedings from a Consensus Conference, November 2018.

4. California State Auditor, Childhood Lead Levels: Millions of Children in Medi-Cal Have Not Received Required Testing for Lead Poisoning, January 2020.

5. California Department of Public Health, California’s Progress in Preventing and Managing Childhood Lead Exposure, 2020.

6. Nathan McClintock, Assessing Soil Lead Contamination at Multiple Scales in Oakland, California:

Implications for Urban Agriculture and Environmental Justice, 2012.

Equity

7. Othering & Belonging Institute, Racial Segregation in the San Francisco Bay Area, Part 2, 2019

8. UC Berkeley & California Housing Partnership, Urban Displacement Project, Rising Housing Costs & Resegregation in the Bay Area, 2015

9. Oakland-Berkeley-Alameda County Continuum of Care, Centering Racial Equity in Homeless System Design, January 2021.

10. Urban Strategies Council,Building an Indicator Base for Oakland, February 2014.

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APPENDIX B: Background on Lead Poisoning Programs
Federal Government
The primary federal law concerning lead paint hazards in housing is the Residential Lead-Based Paint Hazard Reduction Act, also called Title X, to re ﬂ
ect the section of the Housing and Community
Development Act of 1992 in which it was enacted. Key features of the act include:
● Authorizing the HUD lead hazard control grant program, which is the federal government’s primary means of assisting homeowners with control eﬀ
orts. The program makes up less than 0.3
percent of the department’s budget.
● Creating a certiﬁ
cation system for individuals and businesses performing lead control activities. ● Requiring either interim controls or lead abatement for federally owned and assisted housing, such as public and military housing.
● Establishing the federal lead disclosure rule, which requires property owners to reveal any known lead paint hazards to prospective buyers or tenants before a property is sold or rented. ● Deﬁ
ning existing lead-based paint in housing as containing 5,000 ppm of lead or 1 mg/cm2. ● Requiring EPA to publish standards for lead in dust and bare soil at residential properties.

State of California
California’s Health and Human Services Agency includes the Departments ofPublic Health (CDPH) and Health Care Services (DHCS). In the late 1980s, California enacted a series of legislative mandates to reduce lead exposure. Together CDPH and DHCS are tasked with carrying out various preventative approaches to addressing lead hazards in children. DHCS oversees the provision of lead tests to children in Medi-Cal and CDPH runs the Childhood Lead Poisoning Prevention (CLPP) Program. The purpose of CLPP is to both; (a) identify and care for children with elevated blood lead levels (EBLLs) and (b) reduce exposure to lead hazards in the environments where children “live, learn, and play.”100 (CDPH also has an Occupational Lead Poisoning Prevention Program.) In practice, when lead tests identify children with lead poisoning, CDPH ensures the delivery of appropriate case management services to those children and requires local lead poisoning prevention programs to monitor abatement eﬀ
orts in their homes.101 CDPH provides funding to local agencies, such as the Alameda County Healthy Homes Department, to enable: (1) increased testing of at-risk children; (2) follow-up services —nursing case management— for lead poisoned children; and (3) elimination of lead hazards in the environment.

In January 2020, the California State Auditor found that, despite the mandates of state law, CDPH’s “current eﬀ
orts do not appear to align with preventing future instances of lead poisoning in those 101 Childhood Lead Levels: Millions of Children Have Not Received Required Testing for Lead Poisoningat p. 11. 100 California Department of Public Health, California’s Progress in Preventing and Managing Childhood Lead Exposure, p. 3 (“In order to protect California’s children, we must not only identify and treat children with elevated BLLs but also remove lead from the environments in which they live, learn, and play.”) Environmental / Justice Solutions | 91
geographic areas in which children are at the greatest risk“102 because the programs can only remove lead hazards from the homes of lead poisoned children. This approach only “prevents future poisoning in those speciﬁ
c homes” and is only triggered once harm has already occurred. The Auditor also found that:
● CDPH has not met legislative requirements to update the factors health care providers use to determine if children are at risk of lead exposure.
● CDPH’s eﬀ
orts for reducing lead exposure in high-risk areas rely onoutreach alone, even though it cannot demonstrate the eﬀ
ectiveness of the outreach.103 Although CDPH claims that the local prevention programs are reducing lead exposure through education and outreach, it could not demonstrate the eﬀ
ectiveness of this outreach. The Auditorﬁnds
that using limited funds for
proactive abatement is likely much more cost e ﬀ
ective at reducing lead hazards and
increasing lead testing than simply increasing education and outreach eﬀ orts.

In response, CDPH states that it is prioritizing increased testing for at-risk populations and increasing its partnerships with schools and other stakeholders to promote awareness of the issue. DHCS response to the California State Auditor’s report states, “DHCS agrees with the recommendations and has prepared corrective action plans to implement them.”104 Alameda County Public Health Department- Healthy Homes Department People United For A Better Life In Oakland (P.U.E.B.L.O.) advocated for the establishment of a comprehensive county-wide lead poisoning prevention program with housing, health and environmental staﬀ
all under one roof. In response, the Alameda County Board of Supervisors established the County Service Area Lead Abatement District, composed of the Cities of Oakland, Berkeley, Alameda, and Emeryville, in 1991. The Lead Abatement District is governed by a Joint Powers Authority Board, which includes one community representative alongside elected oﬃ cials
from each city, and the County of Alameda. In 1992, Alameda County established a multi-disciplinary agency to take focus on “the health and housing needs of children at risk of lead poisoning.” The Alameda County Lead Abatement Program became the Lead Poisoning Prevention Program the following year, ﬁ
nally becoming the Alameda County Healthy Homes Department (HHD) in 2013. 104 California Health and Human Services Agency, Letter dated November 25, 2019 from Mark A Ghaly, MD, MPH, Secretary to Elaine M. Howle, California State Auditor. (In response to the Auditor’s ﬁ nding that DHCS’ failure to ensure
timely lead testing of Children in Medi-Cal places them at risk for permanent health problems, the agency agreed that it should develop a new “performance standard for lead testing of one- and two- year olds” and “impose sanctions or provide incentive payments as appropriate to improve performance.” For the recommendation addressing the need for families to know about the lead testing services their children are entitled to receive. DHCS will send an annual notiﬁ
cation to parents and include a reminder to any parents ”who have not used preventive services over the course of a year.” The ﬁ
nal recommendation concerned the need for DHCS to increase lead testing rates by amending its contracts with Medi-Cal managed care plans to require monthly identiﬁ cation of all children who have not received a
required test and reminders sent to the responsible health care providers of the requirement to test those children.

DHCS plans to do so and impose corrective action plans for non-compliance.) 103 Ibid.
102 Childhood Lead Levels: Millions of Children Have Not Received Required Testing for Lead Poisoningat p. 2 .

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HHD provides services to prevent lead poisoning and to promote health and safety in the home. It does this primarily through (1) Public Outreach & Trainingand (2) Healthy Housing Assessments and Interventions. Since inception, HHD has received funding from the State of California’s Childhood Lead Poisoning Prevention Branch, which funds nursing case management services for lead poisoned children. Based on the mandate provided by state funding, the County conducts environmental investigations into possible lead hazards in the homes of children who have tested with EBLLs.

HHD also receives grants from the U.S. Department of Housing and Urban Development’s Oﬃ ce of
Lead Hazard Control and Healthy Homes, which distributes federal funds for lead abatement through two grant programs: the Lead-based Paint Hazard Control and the Lead Hazard Reduction Demonstration grant programs. Alameda County has received 11 Lead Hazard Control Grants, which were used to treat over 3,000 units, with approximately 65% of the treated units located in Oakland.

In 2011, Alameda County used funding from a Lead Paint Settlement to fund the Healthy Child Initiative, a 30-month initiative to increase lead screening through targeted outreach to medical providers and the broader community Alameda County-wide. Since 2014, the Healthy Homes Department has been able to provide full lead hazard home repair and rehabilitation services.

Program Limitations. “36% of the applications for HUD lead hazard control grants operated by ACPHD drop out of the process. Typical reasons for dropping out include lack of interest, or ineligibility due to:
income limits, no children under age 6, post 1978 building, or living outside the program area.”105 City of Oakland
Oakland has relied on code violation complaints and Rent Adjustment Program petitions, which can include health and safety violations, to force landlords to repair run-down homes. However, between 1996 and 2018, fewer than 600 health and safety RAP petitions were ﬁ led, according to city data,
representing little more than half a percent of all rental properties in the past two decades. In 2010, an Alameda County Grand Jury found widespread fault with Oakland’s Building Services Division, prompting an overhaul of the City’s inspection processes.106 Speciﬁ cally, the Grand Jury recommended
that City inspectors give clear, consistent, and easy-to-understand messages to property owners about code violations, with clear communication and a fair appeals process--in contrast to their assessment of what had been happening to that point.107
These recommendations spurred advocacy groups to help deﬁ ne the City’s reform program. In 2012,
the City, County, and several non-proﬁ
t groups began to meet as the Place Matters Working Group.108 The group worked to support a health housing pilot program and a Proactive Rental Inspection (PRI) program. The following year, the City accepted a $75,000 grant from the Kresge Foundation (via the 108 See for example, the Place Matters Policy Platform. 107 Id. at 80.
106 Alameda County Grand Jury Final Report, 2010-11, p. 63. 105 Claudia Cappio, Assistant City Administrator,Informational Report on a Proactive Rental Inspection Pilot Program, March 23, 2017, p. 10.

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County) to support the Healthy Housing Pilot Program.109 The ongoing foreclosure crisis had exacerbated already severe public health issues in many rental units, as maintenance issues were often deferred or ignored as ownership of properties changed hands. The Pilot Program was a collaboration between the City of Oakland, the Alameda County Healthy Homes Department, the Alameda County Public Health Department, and other partners.

In October 2015, Oakland announced the Safe Housing Inspection Program (SHIP), a collaboration between the Oakland Fire Department and the Oakland Department of Planning and Building.110 This program empowered the City to initiate inspections of suspected unhealthy conditions, taking the onus from tenants to report violations and potentially risk losing their housing. The Fire Department could also refer houses for inspection based on information they gathered during routine ﬁ re inspections.

The Program began with inspections in Oakland’s San Antonio/East Lake neighborhood.

Other possible programs that could oversee the lead rehabilitation work, under Housing and Community Development: (this existing program is for taking grants for lead) - Home Maintenance and Improvement Program (HMIP)
- Emergency Home Repair Program
- Access Improvement Program (grants for access improvements on rental and owner occupied properties)
- Minor Home Repair Program
- Lead Safe Homes Programs
- West Oakland Homeownership rehab program to correct Health and Safety violations - Neighborhood housing Rehabilitation program to correct - A ﬀ
ordable Housing Health and Safety Rehabilitation Program (This program provides loans to owners of existing multifamily aﬀ
ordable rental housing to prevent or address health and safety conditions.

In 2016, the City Council furthered these goals by formally adopting a Proactive Rental Inspection (PRI) program to address housing habitability violations without displacing tenants.111 The details of the program were hammered out over the following year. In those deliberations, the Healthy Homes Department found that Oakland had an aging housing stock which put vulnerable families at risk, that 30% of Oakland’s housing needed repair, and that 61% of Oakland’s housing was built prior to 1978, when the use of lead paint was prominent.112 The City allocated $500,000 in FY 2017-18, and $100,000 the following year towards the new PRI program. The City’s FY 2019-21 budget allocated over $500,000 112 Larry Brooks, Healthy Housing and Reducing Lead Poisoning in Oakland, Presentation, Alameda County Healthy Homes Department.
111 City of Oakland Agenda Report, Establish PRI Program to Improve Unhealthy Housing Without Displacement, June 30, 2016
110 City of Oakland, Mayor Libby Schaaf Announces Safe Housing Inspection Program to Combat Housing Crisis, October 20, 2015.
109 City of Oakland Agenda Report, Foreclosure Prevention/Mitigation Grants From: Department Of Housing And Community Development, October 17, 2013.

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to the PRI program . The details and requirements of the PRI program, in terms of inspections, health treatment protocols, and the requirements of building contractors, continue to be reﬁ ned by the City.

City of Oakland - Lead-Safe Homes Program (LSHP)
The Lead-Safe Homes Program provides free risk assessment for lead hazards, painting services to qualiﬁ
ed owner-occupied low- and moderate-income households. This program has not been well-funded in recent years, resulting in the program averaging one to two project completions in recent years. To be eligible:
● The property must be (a) residential, (b) with 1 to 4 units, and (c) located within one of seven Community Development Districts;
● At least one property owner must live in the unit to be painted and all owners on record must apply;
● Household income cannot exceed 50% of the area median income, unless the residence is home to children under age 6, then household income may not exceed 80% of the area median income; AND
● The household must meet ONE of the following (prioritization) criteria:
○ The head of household is at least 62 years of age OR
○ The resident has a physical disability that prevents him/her from doing the painting OR ○ A child under 6 resides or visits frequently OR
○ An expectant mother resides at the property.

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Rules & Legislation CommitteeFebruary 29, 2024

Rules & Legislation Committee
February 29, 2024