Cities Index.
Environmental Justice Screening Analysis

Sunnyvale City Council
July 25, 2023

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Environmental Justice Screening Analysis
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July 25, 2023
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Environmental Justice Screening Analysis
for the
City of Sunnyvale
Prepared for:

City of Sunnyvale
456 West Olive Avenue
Sunnyvale, CA 94086
May 2020
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18010179.01
En
vironmental Justice Screening Analysis
for the
City of Sunnyvale
Prepared For:

City of Sunnyvale
456 West Olive Avenue
Sunnyvale, California 94089
Contact: Mary Jeyaprakash
Pre
pared By:

Ascent Environmental
455 Capitol Mall, Suite 300
Sacramento, CA 95814
Contact:

Dimitri Antoniou
[email protected]
May 2020
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City of Sunnyvale
Environmental Justice Screening Analysis i

TABLE OF CONTENTS
Section Page
LIST OF ABBREVIATIONS ................................ ................................ ................................ ................................ ................................ ........... II 1 INTRODUCTION ................................ ................................ ................................ ................................ ................................ ........1-3

1.1 Objectives ............................................................................................................................................................................. 1-3 2 REGULATORY BACKGROUND................................ ................................ ................................ ................................ ............... 2-5

2.1 Senate Bill 1000 ................................................................................................................................................................. 2-5

2.2 Senate Bill 535 and Assembly Bill 1550 - Disadvantaged Communities........................................................ 2-5

2.3 Assembly Bill 617 Community Air Protection Program ....................................................................................... 2-6

2.4 Senate Bill 379 Climate Adaptation and Resiliency Strategies .......................................................................... 2-6 3 THE ENVIRONMENTAL JUSTICE PLANNING PROCESS ................................ ................................ ................................ ...3-1

3.1 Stand-Alone EJ Element Vs. Integrated Policies ..................................................................................................... 3-1

3.2 Public Engagement in the Planning Process ........................................................................................................... 3-1 4 IDENTIFYING DISADVANTAGED COMMUNITIES ................................ ................................ ................................ ............ 4-1

4.1 CalEnviroScreen 3.0 .......................................................................................................................................................... 4-1

4.2 Income and Pollution Burden ...................................................................................................................................... 4-4

4.3 Ground-Truthing and Input from Public ................................................................................................................ 4-13

4.4 Future Conditions and Environmental Justice ...................................................................................................... 4-13 5 DEVELOPING GOALS AND POLICIES ................................ ................................ ................................ ................................ ...5-1

5.1 Requirements for Environmental Justice Goals and Policies .............................................................................. 5-1

5.2 Existing Goals and Policies ............................................................................................................................................ 5-2

5.3 Recommendations ........................................................................................................................................................... 5-5 6 REFERENCES ................................ ................................ ................................ ................................ ................................ ............... 6-1 Figures
Figure 4.1-1 CalEnviroScreen 3.0 Indicators...................................................................................................................................... 4-1 Figure 4.1-2 CalEnviroScreen 3.0 Scores for the City of Sunnyvale ......................................................................................... 4-3 Figure 4.2-1 AB 1550 Low-income Communities in the City of Sunnyvale ........................................................................... 4-5 Figure 4.2-2 CalEnviroScreen 3.0 Combined Pollution Burden Scores for the City of Sunnyvale ................................. 4-8 Figure 4.2-3 CalEnviroScreen 3.0 Drinking Water Contaminant Scores for the City of Sunnyvale ............................... 4-9 Figure 4.2-4 CalEnviroScreen 3.0 Cleanup Site Scores for the City of Sunnyvale ............................................................. 4-10 Figure 4.2-5 CalEnviroScreen 3.0 Groundwater Threats Scores for the City of Sunnyvale ............................................. 4-11 Figure 4.2-6 CalEnviroScreen 3.0 Hazardous Waste Scores for the City of Sunnyvale ................................................... 4-12 Figure 4.1-1 Silicon Valley 2.0 Climate Change Preparedness Decision Support Tool ................................................... 4-15 Tables
Table 5.2-1 City of Sunnyvale, Existing Environmental Justice Goals and Policies ............................................................ 5-2 Attachment 10

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LIST OF ABBREVIATIONS
°F degrees Fahrenheit
AB As
sembly Bill
ABAG Association of Bay Area Governments
CalE
nviroScreen California Communities Environmental Health Screening Tool CalEPA California Environmental Protection Agency
CARB California Air Resources Board
CEJA California Environmental Justice Alliance
City City of Sunnyvale
DAC di
sadvantaged community
EJ en
vironmental justice
GGRF G
reenhouse Gas Reduction Fund
GHG greenhouse gas
HSC H
ealth and Safety Code
MT
C Metropolitan Transportation Commission
RC
P Representative Concentration Pathway
SB Senat
e Bill
SR State Route
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City of Sunnyvale
Environmental Justice Screening Analysis 1-3
1 INTRODUCTION
Low-income residents, communities of color, indigenous peoples and tribal nations, and immigrant communities have experienced and continue to experience disproportionate environmental burdens and related health impacts in the United States. These communities face significant barriers to their overall health, livelihood, and sustainability. The environmental justice (EJ) movement arose out of a need to address the many factors that contribute to this inequity such as the lack of economic resources and political power, and a history of unjust planning and policymaking . The U.S. Environmental Protection Agency defines EJ as follows:
“Environmental justice is the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income, with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. This goal will be achieved when everyone enjoys: the same degree of protection from environmental and health hazards, and equal access to the decision- making process to have a healthy environment in which to live, learn, and work.” (EPA 2019) This definition highlights two key components of EJ: social equity must be intentionally planned for in the policy- making process and affected communities must have a seat at the table in the decision -making process.

EJ issues as they relate to land use planning are beginning to be addressed through state legislation and funding opportunities. In response to and in support of the EJ movement, Senate Bill (SB) 1000, the Planning for Healthy Communities Act, was enacted. SB 1000 mandates that cities and counties adopt an EJ element or integrate EJ goals, objectives, and policies into other elements of their General Plans to create healthier cities and counties by protecting sensitive land uses and prioritizing the needs of disadvantaged communities (DACs). SB 1000 defines a DAC as “[a]n area identified by the California Environmental Protection Agency (CalEPA) pursuant to Section 39711 of the Health and Safety Code (HSC) or an area that is a low-income area that is disproportionately affected by environmental pollution and other hazards that can lead to negative health effects, exposure, or environmental degradation.” The City of Sunnyvale (City) is in the process of updating the Air Quality and Noise sections of its General Plan (AQ and Noise Update). Concurrent with these updates, the City is integrating EJ policies and goals into the updated sections. As detailed in Section 4, “Identifying Disadvantaged Communities,” there are no DACs as defined by SB 1000 within the City. However, the City has elected to voluntarily apply EJ requirements broadly throughout the community and is following guidance developed by the California Environmental Justice Alliance (CEJA) in their SB 1000 Implementation Toolkit. The City has developed a public outreach strategy to engage residents and has conducted this Environmental Justice Screening Analysis (EJ Screening Analysis) to better understand the scope and extent of existing EJ issues in the City. This EJ Screening Analysis summarizes the regulatory background related to EJ, describes the EJ planning process, screens for potential DACs in the City, and provides recommended EJ goals and policies for the AQ and Noise Update.

1.1 OBJECTIVES
The objectives of the EJ Screening Analysis are to:
 Evaluate SB 1000 requirements with respect to the City's existing population and environmental indicators;  Determine the presence and location of potential DACs with respect to existing or future health risks and hazards by using the latest version of the California Communities Environmental Health Screening Tool (CalEnviroScreen) published by CalEPA, as well as other tools such as the Health Disadvantage Index and Cal-Adapt;  Consider how existing policies related to EJ in various sections of the General Plan address current and probable future EJ issues in the City;
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 Develop recommended goals and policies for the AQ and Noise Update that address inequities and are consistent with the goals of SB 1000; and
 Determine the best approach to highlight existing EJ-related goals and policies and integrate any new policies into the General Plan beyond those identified as part of the AQ and Noise Update.

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City of Sunnyvale
Environmental Justice Screening Analysis 2-5
2 REGULATORY BACKGROUND
This section provides an overview of key regulations and legislation in place in California relevant to DACs, EJ, and the General Plan process. Because EJ is a relatively new topic in the State’s general planning guidance, guidance and regulations regarding EJ considerations are likely to become more comprehensive in the future and should be monitored for changes and updates.

2.1 SENATE BILL 1000
SB 1000 was signed into State law in 2016 to address the statewide problem that DACs often bear a disproportionate burden of exposure to pollution and other environmental hazards. The law requires local jurisdictions with DACs, designated at the census tract level, to address EJ when they update two or more General Plan elements on or after January 1, 2018. The law requires that an EJ element be added to the General Plan or that relevant EJ goals be integrated into other required elements identifying DACs and providing policies and objectives to reduce the disproportionate health risks in DACs. Objectives and policies should promote civic engagement in the public decision-making process. The purpose is to promote policies that improve the health and overall well- being of vulnerable and at-risk communities through reductions in pollution exposure, access to healthy foods, healthy homes, improved air quality, and increased physical activity. The SB 1000 Implementation Toolkit has been developed by the CEJA to guide implementation of SB 1000 requirements and provides screening methodologies for identifying DACs.

2.2 SENATE BILL 535 AND ASSEMBLY BILL 1550 - DISADVANTAGED

COMMUNITIES
Authorized by the California Global Warming Solutions Act of 2006 (Assembly Bill [AB] 32), the cap- and-trade program is one of several strategies that California uses to reduce greenhouse gases ( GHGs) that cause climate change. The State’s portion of the cap-and-trade auction proceeds are deposited in the Greenhouse Gas Reduction Fund (GGRF) and used to further the objectives of AB 32. In 2012, the Legislature passed SB 535 (de Leon), directing that 25 percent of the proceeds from the GGRF go to projects that provide a benefit to DACs . The legislation gave CalEPA responsibility for identifying those communities. In February 2017, CalEPA released its list of DACs for the purpose of SB 535 in April 2017. To inform its decision, CalEPA used the CalEnviroScreen 3.0 results. In June 2018, to address a minor flaw in the software program algorithm, CalEPA added two census tracts (6067000800 in Sacramento and 6075012301 in San Francisco) to its Disadvantaged Communities List for Climate Investments in accordance with CalEPA’s designation report.

In 2016, the Legislature passed AB 1550 (Gomez), which now requires that 25 percent of proceeds from the fund be spent on projects located in DACs. The law requires the investment plan to allocate 1) a minimum of 25 percent of the available moneys in the fund to projects located within, and benefiting individuals living in, DACs, 2) an additional minimum of 5 percent to projects that benefit low-income households or to projects located within, and benefiting individuals living in, low-income communities located anywhere in the state, and 3) an additional minimum of 5 percent either to projects that benefit low-income households that are outside of, but within a 0.5 mile of, DACs, or to projects located within the boundaries of, and benefiting individuals living in, low -income communities that are outside of, but within a 0.5 mile of, DACs. Under AB 1550, the following definitions apply:
 “Low-income households” are those with household incomes at or below 80 percent of the statewide median income or with household incomes at or below the threshold designated as low income by the Department of Housing and Community Development’s (HCD) list of state income limits adopted pursuant to HSC Section 50093.  “Low-income communities” are census tracts with median household incomes at or below 80 percent of the statewide median income or with median household incomes at or below the threshold designated as low income by HCD’s list of state income limits adopted pursuant to HSC Section 50093.

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2.3 ASSEMBLY BILL 617 COMMUNITY AIR PROTECTION PROGRAM
AB 617 of 2017 aims to help protect air quality and public health in communities around industries subject to the State’s cap-and-trade program for GHG emissions. AB 617 imposes a new state-mandated local program to address non-vehicular sources (e.g., refineries, manufacturing facilities) of criteria air pollutants and toxic air contaminants.

The bill requires the California Air Resources Board (CARB) to identify high-pollution areas and directs air districts to focus air quality improvement efforts through the adoption of community emission reduction programs within these identified areas. Currently, air districts review individual stationary sources and impose emissions limits on emitters based on best available control technology, pollutant type, and proximity to nearby existing land uses. This bill addresses the cumulative and additive nature of air pollutant health effects by requiring community -wide air quality assessment and emission reduction planning. CARB has developed a statewide Blueprint, which outlines the process for identifying impacted communities, statewide strategies to reduce emissions of criteria air pollutants and toxic air contaminants, as well as criteria for development of community emissions reduction programs and community air monitoring plans (CARB 2018).

2.4 SENATE BILL 379 CLIMATE ADAPTATION AND RESILIENCY

STRATEGIES
SB 379 of 2015 requires cities and counties to review and update the safety elements of their General Plans to include climate adaptation and resiliency strategies. The update must include a set of goals, policies, and objectives based on a vulnerability assessment, identifying the risks that climate change poses to the local jurisdiction and the geographic areas at risk from climate change impacts. SB 379 relates closely to SB 1000 in that both involve assessing vulnerabilities of local communities and developing General Plan goals, policies, and objectives to address those vulnerabilities.

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City of Sunnyvale
Environmental Justice Screening Analysis 3-1
3 THE ENVIRONMENTAL JUSTICE PLANNING PROCESS
This section distinguishes the two options of 1) developing a stand-alone EJ Element, or 2) integrating EJ-related policies throughout the other elements of a General Plan. This section also explains how the City’s Public Outreach Strategy will inform the EJ planning process.

3.1 STAND-ALONE EJ ELEMENT VS. INTEGRATED POLICIES
SB 1000 allows a local jurisdiction to adopt either a stand-alone EJ Element or a set of EJ-related policies integrated throughout other elements of a General Plan. A stand-alone EJ element allows the public and decision-makers to see EJ policies in one place. However, more work may be needed to ensure consistency with other General Plan elements.

An integrated approach puts EJ-related polices within related General Plan elements and can better facilitate consistency between EJ-related policies and other policies in each element. Regardless of approach, EJ policies must meet internal consistency rules set forth in Government Code Section 65300.5. The City has decided to develop a set of integrated EJ-related policies throughout other sections of the General Plan.

3.2 PUBLIC ENGAGEMENT IN THE PLANNING PROCESS
As recommended in the SB 1000 Implementation Toolkit, the City has developed a public outreach strategy to engage DACs as well as the broader community. Public outreach is a critical component of the EJ planning process:
communities that are most impacted by environmental issues must have a say in the decis ions that impact their health and well-being. Engaging the community early in the planning process is essential to ensure that the AQ and Noise Update reflects the community’s needs, priorities, and vision. Community members can share their firsthand knowledge of the problems as well as their ideas for solutions, leading to more effective and equitable planning decisions.

One of the major objectives of the City’s Public Outreach Strategy is to collaboratively identify the communities that are disproportionately affected by environmental pollution and other hazards to document and propose ways to address existing EJ issues. To do so, the City will implement a variety of outreach methods such as a newsletter, C ity website postings, mailing list, a series of community workshops, and public hearings. The EJ Screening Analysis and findings from the public engagement effort will go hand-in-hand to inform the development of this update.

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Environmental Justice Screening Analysis 4-1
4 IDENTIFYING DISADVANTAGED COMMUNITIES
This section focuses on identifying DACs using CalEnviroScreen 3.0 as a primary screening method. A secondary approach, which investigates pollution burden and income, is also applied. The findings of these methods can be supplemented by ground-truthing, which is described in Section 4.3, “Ground-Truthing and Input from Public.” Lastly, this section looks at probable future conditions and potential future EJ issues in the City due to climate change and growth. Climate change has the potential to alter or exacerbate the types of environmental effects, pollution burden, and hazards that communities face. Population growth could increase competition for scarce resources such as employment and housing alongside the worsening of local traffic and air quality conditions. Both factors are important to consider when developing long-term EJ solutions.

4.1 CALENVIROSCREEN 3.0
CalEnviroScreen is a mapping tool developed by the Office of Environmental Health Hazards Assessment (OEHHA) to help identify low-income census tracts in California that are disproportionately burdened by and vulnerable to multiple sources of pollution. CalEnviroScreen uses environmental, health, and socioeconomic information based on data sets available from state and federal government sources to produce scores for every census tract in the state.

Scores are generated using 20 statewide indicators which fall into four categories: exposures, environmental effects, sensitive populations, and socioeconomic factors. Exposures and environmental effects characterize the pollution burden that a community faces, while sensitive populations and socioeconomic factors define population characteristics. Figure 4.1-1 shows the 20 indicators, organized by the Pollution Burden and Population Characteristics categories and the four components.

Figure 4.1-1 CalEnviroScreen 3.0 Indicators
Source: OEHHA n.d.

A census tract with a high score is one that experiences higher pollution burden and/ or greater presence of sensitive populations and socioeconomic challenges than areas with low scores. CalEnviroScreen orders census tracts based on their combined pollution burden and population characteristics score, from low to high. A percentile for the overall score is then calculated from the ordered values. For example, if a census tract scores in the 50th percentile, this means it has a higher combined pollution burden score and population indicator score than 50 percent of all other census tracts in California. CalEPA has designated the top 25 percent of highest scoring tracts in CalEnviroScreen (i.e., Attachment 10

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those that fall in or above the 75th percentile) as DACs, which are targeted for investment proceeds under SB 535, the State’s cap-and-trade program. These investments are aimed at improving public health, quality of life, and economic opportunity in California’s most burdened communities while at the same time reducing pollution that contributes to climate change.

According to CalEnviroScreen 3.0, there are two census tracts within the City that are in the top 25 percent of highest scoring tracts for the state and may qualify as CalEPA-defined DACs (see Figure 4.1-2). Both census tracts extend beyond City limits, and are described below:
 Census tract 6085504602 is scored in the 80-85 percentile (i.e., this census tract has a higher overall CalEnviroScreen score than 80-85 percent of all other census tracts in the state). The tract is located at the northern end of the City adjacent to the southern tip of the San Francisco Bay and bounded by Enterprise Way to the west and the State Route (SR) 237 to the southeast. A large portion of this census tract is within the City of San Jose and includes the community of Alviso. The portion of this census tract that is within the City of Sunnyvale does not include residential uses and is composed of baylands, light industrial, office uses, restaurants, and hotels. This area is within the Moffett Park Specific Plan (MPSP), last updated in 2013, which includes zoning for industrial, office, and commercial uses. The City is currently conducting a comprehensive update to the MPSP.  Census tract 6085505202 is scored in the 75-80 percentile (i.e., this census tract has a higher overall CalEnviroScreen score than 75-80 percent of all other census tracts in the state). The tract is located primarily within the City of Santa Clara. A small portion of the tract is in the eastern part of the City, near the Lawrence Caltrain Station. This area is bounded by Kifer Road to the north, the Caltrain tracks to the south, Calabazas Creek to the west, and Uranium Drive to the east. This area is within the Lawrence Area Specific Plan (LSAP), adopt ed in 2016, which includes flexible, mixed-use zoning for residential, commercial, office, research and development, and industrial and service uses. The portion of this census tract that is within the City does not include residential uses; however, the City is currently in the process of updating the LSAP to consider allowing residential uses in this area.

These tracts are in the top 25 percent of highest scoring tracts in the state due to a combination of high pollution burden and the presence of sensitive populations and socioeconomic challenges. However, it is important to note that the sensitive populations within these tracts reside outside of the City boundaries and fall under the jurisdiction of the City of San Jose and the City of Santa Clara. SB 535 is intended to provide funding to priority populations residing in an area with high pollution exposures. There are no residential uses in the portions of these census tracts within City boundaries; therefore, they would not be considered DACs for the City under SB 535. If the City allows for residential uses in these areas in the future, it will be important to consider the effects of existing air quality issues, contaminants, and other pollution sources.

CalEnviroScreen functions as a statewide assessment; thus, the tool may need to be refined to be more relevant to local and regional contexts when identifying DACs. For example, there may be other indicators that are not included in CalEnviroScreen that are important EJ issues such as lack of access to healthy food or parks and recreational opportunities, and climate change vulnerability. On the other hand, there may be indicators in the composite CalEnviroScreen score that are not as relevant for certain regions. For example, a community may not be cons idered low-income, but given the high cost of living in the Bay Area, the community may be unable to afford quality housing, have limited mobility, and suffer some of the same disadvantages that low -incomes communities have.

Thus, there are several other ways that local governments and planners may choose to adjust CalEnviroScreen in order to better fit their local and regional context. CalEPA presents other approaches that have to conclude if they are true DACs of Sunnyvale been suggested by stakeholders in Approaches to Identifying Disadvantaged Communities such as using the top scores for pollution burden only or using the top scores for population characteristics only (CalEPA 2014). CalEnviroScreen data can also be used to generate regional rankings instead of the tool’s default statewide rankings, or a different threshold for defining what constitutes a DAC may be selected (i.e. 30 percent instead of 25 percent).

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Environmental Justice Screening Analysis 4-3
Source: data downloaded from California Office of Environmental Health Hazard Assessment in 2020 Figure 4.1-2 CalEnviroScreen 3.0 Scores for the City of Sunnyvale Attachment 10

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4.2 INCOME AND POLLUTION BURDEN
SB 1000 allows for additional identification methods of DACs by identifying areas that are both low income and disproportionately affected by environmental pollution and other hazards that can lead to negative health effects, exposure, and/or environmental degradation (CEJA 2017). These additional definitions were included in the legislation to give jurisdictions the flexibility to adapt DAC identification to their local context.

4.2.1 Income
Poverty is a key social determinant of health. Numerous studies have found that low -income populations are more likely than wealthier populations to experience adverse health outcomes when exposed to environmental pollution (CalEPA and OEHHA 2017). SB 1000 defines low-income areas as: 1) an area with household incomes at or below 80 percent of the statewide median income or 2) an area with household incomes at or below the threshold designated as low-income by HCD’s annually updated list of state income limits.

CARB has created a map that identifies low-income communities across California by statewide median income and by HCD State Income Limits. As shown in Figure 4.2-1, the entirety of census tracts 6085509000 and 6085504802 are located within the City and meet the definition of a low-income area:
 Census tract 6085509000 is in the northern portion of the City and is bounded by US 101 to the north, East Maude Avenue to the south, North Mathilda Avenue to the west, and North Fair Oaks Avenue to the east. This neighborhood is known as SNAIL, and is identified as one of the City’s neighborhood associations. Thirty-five percent of people in this census tract are living below twice the federal poverty level, which is higher than 52 percent of the census tracts in California.
 Census tract 6085504802 is in the northern portion of the City and is bounded by SR 237 to the north, US 101 to the south, Calabazas Creek to the East, and Lawrence Expressway/Lawrence Station Road to the west. A portion of the Lakewood Village neighborhood association is located within this tract, south of the Adobe Wells Mobile Home Park. Twenty-two percent of people in this census tract are living below twice the federal poverty level, which is higher than 31 percent of the census tracts in California.

As shown in Figure 4.2-1, portions of census tracts 6085504602 and 6085505202 are located within the City and meet SB 1000’s definition of a low-income area. However, as described in Section 4.1, “CalEnviroScreen 3.0,” there are no residential uses in the portions of these census tracts within City boundaries. T herefore, they would not be considered low-income areas for the City of Sunnyvale.

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Source: data downloaded from California Air Resources Board in 2020 Figure 4.2-1 AB 1550 Low-income Communities in the City of Sunnyvale Attachment 10

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4.2.2 Pollution Burden
Unlike identifying low-income areas, SB 1000 does not specify a clear method or threshold for identifying areas “disproportionately affected by environmental pollution and other hazards.” The SB 1000 Implementation Toolkit suggests several supplementary methods and tools for analyzing pollution burden, including the Environmental Justice Screening Method developed at the University of Southern Cal ifornia, the Regional Opportunity Index developed by the University of California Davis, and the Bay Area Air Quality Management District’s (BAAQMD’s) Community Air Risk Evaluation (CARE) program. BAAQMD initiated the CARE program to identify areas with high concentrations of air pollution and populations most vulnerable to air pollution’s health impact, based on detailed emissions inventories and air dispersion modeling. The City was not identified as one of the areas with elevated pollution levels (BAAQMD 2018).

CalEnviroScreen 3.0 also includes a detailed breakdown of the 12 pollution burden indicators and the combined Pollution Burden score, which represents the potential exposures to pollutants and the adverse environmental conditions caused by pollution. As shown in Figure 4.2-2, several census tracts - adjacent to SR 237, SR 101, and the Central Expressway have high combined Pollution Burden scores in the 60 to 70 percentiles. Census tracts 6085505202 and 6085504602 experience the highest pollution burden in the City, with a score of 88. Specific pollution indicators that are of greatest concern to the City are discussed below:
 Fine Particulate Matter (PM2.5): PM2.5 is very small airborne particle pollution (less than 2.5 micrometers), which can include a mixture of particles such as organic chemicals, dust, soot and metals. Because of their small size, PM

2.5 can travel deep into the lungs and cause health problems such as heart and lung disease. The PM 2.5 pe
rcentile for most census tracts is the City is 53, meaning the summed concentration is higher than 53 percent of the census tracts in California.
 Diesel Particulate Matter (DPM): Exhaust from vehicles and equipment with diesel engines contains a mixture of gases and solid particles, many of which are harmful to health. According to the California Almanac of Emissions and Air Quality (CARB 2013), most of the estimated health risks from toxic air contaminants (TACs) can be attributed to relatively few compounds, the most important being DPM. Generally, the D PM percentile for census tracts in the City ranges from 53 and 78, meaning the summed concentration is higher than 53 to 78 percent of the census tracts in California.
 Drinking Water: Both natural and human sources can contaminate drinking water. Natural sources can be found in rocks and soil or come from fires. Human sources include factories, sewage, and runoff from farms. As shown in Figure 4.2-3, several census tracts clustered in the western portion of the City are scored in the 50 to 60 percentiles for drinking water contamination, meaning average contaminant concentrations are higher than 50 to 60 percent of the census tracts in California. A higher score indicates greater concentrations of water contaminants or water quality violations. Contaminants of concern include hexavalent chromium, dibromochloropropane, lead, nitrate, perchlorate, trihalomethanes, uranium, and radium.  Traffic Density: Traffic density is measured by vehicle-kilometers per hour compared to the size of the census tract. Census tracts in the northern portion of the City near SR 237 and SR 101, and in the southern portion of the City near the Central Expressway are within the 80 to 100 percentiles for traffic density, meaning traffic is more dense than 80 to 100 percent of the census tracts in California.  Cleanups: Cleanup sites are places that are contaminated with hazardous chemicals and require clean up by the property owners or government. Chemicals at cleanup sites can move through the air or groundwater. People living near these sites have a greater potential to be exposed to chemicals from the sites than people living further away. As shown in Figure 4.2-4, numerous cleanup sites exist within the City and are generally clustered in the northern half of the City. There are three sites within the City that are on the U.S. Environmental Protection Agency’s National Priorities List (“Superfund sites”): the Westinghouse Electric Corporation (CAD001864081), TRW Microwave Inc. (CAD009159088), and the National Semiconductor Corporation (CAD041472986). Census tracts in the northern portion of the City are scored in the 90 to 100 percentiles, meaning the number and type of cleanup sites is higher than 90 to 100 percent of the census tracts in California.

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 Groundwater Threats: Hazardous materials stored on land or underground may leak and contaminate soil and groundwater. Common soil and groundwater pollutants include gasoline and diesel fuels at gas stations, as well as solvents, heavy metals and pesticides. As shown in Figure 4.2-5, groundwater threats are most prevalent in the central portion of the city. Census tracts in this area have scores in the 90 to 100 percentiles meaning the number and type of groundwater threats is higher than 90 to 100 percent of the census tracts in California.  Hazardous Waste: As shown in Figure 4.2-6, hazardous waste-generating facilities are generally located in the northeastern quadrant of the City. Census tracts in this area have scores in the 90 to 100 percentiles, meaning the number and type of hazardous waste sites is higher than 90 to 100 percent of the census tracts in California.

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Source: data downloaded from California Office of Environmental Health Hazard Assessment in 2020 Figure 4.2-2 CalEnviroScreen 3.0 Combined Pollution Burden Scores for the City of Sunnyvale Attachment 10

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Source: data downloaded from California Office of Environmental Health Hazard Assessment in 2020 Figure 4.2-3 CalEnviroScreen 3.0 Drinking Water Contaminant Scores for the City of Sunnyvale Attachment 10

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Source: data downloaded from California Office of Environmental Health Hazard Assessment in 2020 Figure 4.2-4 CalEnviroScreen 3.0 Cleanup Site Scores for the City of Sunnyval e Attachment 10

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Source: data downloaded from California Office of Environmental Health Hazard Assessment in 2020 Figure 4.2-5 CalEnviroScreen 3.0 Groundwater Threats Scores for the City of Sunnyvale Attachment 10

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Source: data downloaded from California Office of Environmental Health Hazard Assessment in 2020 Figure 4.2-6 CalEnviroScreen 3.0 Hazardous Waste Scores for the City of Sunnyvale Attachment 10

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4.3 GROUND-TRUTHING AND INPUT FROM PUBLIC
The SB 1000 Implementation Toolkit recommends that local governments complement DAC identification with a method known as “ground-truthing.” Ground-truthing is defined as “a community fact-finding process where residents supplement technical information with local knowledge to better inform policy and project decisions” (CEJA 2017). Given the broad scale of analysis, state and federal data may occasionally be inaccurate at the local level, such as distance data that have margins of error as high as a quarter mile.

A community-based survey of existing conditions will help the City better understand issues that government datasets do not capture. Ground-truthing also helps in identifying transient or extremely small DACs, such as migrant workers or homeless populations. As described in the City’s Public Outreach Strategy, the City will conduct two community workshops to identify DACs and priority issues.

4.4 FUTURE CONDITIONS AND ENVIRONMENTAL JUSTICE
While CalEnviroScreen captures current pollution burden and population characteristics, it is also important to consider how climate change and future conditions may affect the City’s disadvantaged populations. Projecting future EJ issues is difficult due to the variety of factors involved. However, based on what is understood about existing EJ issues in the City, educated assumptions can be made about how these conditions may change or remain the same in the future.

4.4.1 Climate Change
Cal-Adapt was used to predict the effect of climate change on future environmental condi tions in the City. Cal-Adapt is a climate change scenario planning tool developed by the California Energy Commission that downscales global climate model data to local and regional resolution under two emissions scenarios. The Representative Concentration Pathway (RCP) 8.5 scenario represents a business-as-usual future scenario in which emissions rise steadily through 2099. The RCP 4.5 scenario represents a future in which global emissions peak by 2040 and decrease substantially through 2099.

The City experienced an observed historical annual average maximum temperature of 69.2 degrees Fahrenheit (°F) between 1961 and 1990. Under the RCP 4.5 scenario, the City’s annual average maximum temperature is projected to increase to 72.6°F by 2050 and increase to 73.8°F by 2099. Under the RCP 8.5 scenario, the City’s annual average maximum temperature is projected to increase to 73.4°F by 2050 and increase to 76.5°F by 2099 (Cal-Adapt 2019). In addition to an overall increase in temperature, the frequency and duration of heat wave events in the City are also projected to increase by 2099 (Cal-Adapt 2019). Similarly, the frequency and duration of extreme precipitation events is also projected to increase between 1961 and 1990, the City experienced an average of 11 observed historical extreme precipitation events per year. Under the RCP 4.5 scenario, the annual average number of extreme precipitation events is projected to increase to 13 events by both 2050 and 2099. Under the RCP 8.5 scenario, the annual average number of extreme precipitation events is projected to increase to 13 events by 2050 and 16 events by 2099 (Cal-Adapt 2019).

Santa Clara County’s Silicon Valley 2.0 Project supports the county with climate risk assessment, adaptation, and resilience planning. The project produced a web-based Climate Change Preparedness Decision Support Tool which allows users to run customized queries using regionally specific data to model future climate change vulnerabilities.

As shown in Figure 4.4-1 below, all areas of the City would be affected by an increase in extreme heat events, and there are several parcels in the City that are at risk for sea-level rise and flooding.

Climate change exacerbates existing public health issues and poses special challenges to DACs. Increased temperatures and frequency and intensity of extreme heat events in the City would worsen existing air quality issues.

As noted in the California Department of Public Health’s Climate and Health Profile Report of Santa Clara County, increased heat intensifies the photochemical reactions that produce smog and ground level ozone and PM

2.5, which
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contribute to and exacerbate respiratory disease in children and adults (CDHP 2017). Increased temperatures can also alter the spread and prevalence of disease vectors such as mosquitos.

Sea-level rise would both directly and indirectly affect the City: direct impacts include the inundation of areas in the northern part of the City, such as the Sunnyvale Baylands Park, the City’s Water Pollution Control Plant, the Sunnyvale Materials Recovery and Transfer Station, and parts of the Lockheed Martin property. Indirect impacts consist of the disruption of regional transportation infrastructure, which would affect transit and mobility in the City.

As shown in Figure 4.4-1, increased frequency and duration of extreme precipitation events may cause flooding in the northern and central portions of the City. These are some of the same areas that bear high pollution burden and are affected by traffic, hazardous materials, and are considered low-income areas as described in Section 4.2, “Income and Pollution Burden.”
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4.4.2 Population and Housing
The Metropolitan Transportation Commission (MTC) and the Association of Bay Area Governments (ABAG) produced Plan Bay Area 2040, the region’s transportation and land use roadmap for future growth. MTC and ABAG forecast that between 2010 and 2040, the Bay Area population is expected to grow by 2.1 million people, from 7.2 million to

9.6 million (MTC and ABAG 2017a). The City is forecasted to experience a 53 percent increase in population by 2040, from an estimated population of 145,255 in 2010 to 222,210 people in 2040 (MTC and ABAG 2017 b). Population growth will exacerbate existing EJ issues such as air pollution, traffic density and volume, and lack of affordable housing. If the percentage of household income devoted to housing costs continues to rise in the future, this issue will disproportionally impact disadvantaged populations.

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5 DEVELOPING GOALS AND POLICIES

5.1 REQUIREMENTS FOR ENVIRONMENTAL JUSTICE GOALS AND

POLICIES
Per Government Code Section 65302(h), the EJ Element or integrated EJ policies must identify objectives and policies to reduce the unique or compounded health risks in DACs. A “unique or compounded health risk” is a risk that by itself, may not be harmful to health. However, when considered in the context of other health risks to a community, these risks are cumulatively harmful. For instance, DACs are often exposed to multiple health risks such as air pollution while concurrently living in poor housing conditions and experiencing other socioeconomic stressors.

Unique or compounded health risks can be addressed by means that include but are not limited to:
 Reducing pollution exposure, including improving air quality . Many diseases such as asthma, birth defects, cancer, and heart disease can be linked to exposure to toxic substances in the environment. DACs experience a disproportionate share of exposure to environmental toxins, and their related health impacts. Thus, this section focuses on policies to prevent and mitigate exposure to hazardous materials and air pollution, remove and restrict toxic pollutants, and protect sensitive populations within and around DACs. Special consideration is given to land use compatibility and the siting of sensitive receptors and facilities that emit, handle, store, or dispose of hazardous materials.
 Promoting public facilities. Under SB 1000, “public facilities” include, but are not limited to, public improvements, public services, and community amenities, as defined in subdivision (d) of Government Code Section 66000. This section focuses on policies to that ensure DACs equitable access to public facilities such as parks, libraries, public transit, roads and trails, and health-care facilities.
 Promoting food access. Health conditions related to diet are on the rise. Multi-pronged approaches are needed to support healthy food consumption and address food insecurity: availability, affordability, access, and community education are essential. This section focuses on policies and programs to promote access to and utilization of healthy foods, such as zoning and streamlining project approvals for grocery stores, promoting community gardening, and encouraging local food production.  Promoting safe and sanitary homes. Housing location, quality, affordability, and stability have an impact on health. This section focuses on policies to ensure healthy and safe housing, such as addressing the presence of asbestos and lead; and policies to increase access to housing, affordable housing, and prevent the displacement of low-income and vulnerable residents and families.
 Promoting physical activity. Physical inactivity is one of the key contributors to chronic disease in California.

Access and proximity to safe places for physical activity are significant predictors of physical activity levels. This section focuses on policies to promote spaces for physical activity and ensure access, connectivity, and equitable distribution of physical activity opportunities such as pedestrian-friendly and bicycle-friendly streetscapes (OPR 2017).

In addition to reducing unique or compounded health risks in DACs, the EJ Element or integrated EJ policies must also identify objectives and policies to promote civil engagement in the public decision- making process and ones that prioritize improvements and programs that address the needs of DACs. Examples include policies that promote equitable and inclusive community engagement in local planning processes and policies to identify and reverse systemic funding inequities to ensure that DACs are the primary beneficiaries of investments and that projects and programs do not increase toxic exposures, reduce affordable housing stock, or displace residents and/or local businesses. Additionally, the SB 1000 Toolkit suggests two other objectives: equitable development and design and reducing climate vulnerability (CEJA 2017).

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5.2 EXISTING GOALS AND POLICIES
The City’s General Plan, Climate Action Playbook, and City Council Policy Manual contain goals and policies that address EJ issues, reduce unique or compounded health risks, promote civil engagement in the decision- making process, and prioritize the needs of underserved communities. These goals and policies along with the specific EJ requirements they address, are listed in Table 5.2-1.

Table 5.2-1 City of Sunnyvale, Existing Environmental Justice Goals and Policies Source Goal, Policy, or Strategy Environmental Justice Issue Addressed
General Plan,
Chapter 2,
Community
Vision (CV)
Goal CV-1: Achieve a community in which citizens and businesses are informed about local issues and City programs and services are actively involved in shaping the quality of life and participate in local community and government activities.  Policy CV-1.1 Assure that all community members have reasonable access to City information, services and programs within budgeted resources.  Policy CV-1.2 Provide accurate and thorough information in a timely manner to ensure that community members have an opportunity to respond effectively.  Policy CV-1.3 Encourage community involvement in the development and implementation of city and community activities, programs an d services.

Promote civil engagement
General Plan,
Chapter 3, Land
Use and
Transportation
(LT)
 Policy LT-2.3: Accelerate the planting of large canopy trees to increase tree coverage in Sunnyvale in order to add to the scenic beauty and walkability of the community; provide environmental benefits such as air quality improvements, wildlife habitat, and reduction of heat islands; and enhance the health, safety, and welfare of residents.

Reduce pollution exposure,
improve air quality.

Promote physical activity.

General Plan,
Chapter 3, LT
 Policy LT-3.2: Refine land use patterns and the transportation network so they work together to protect sensitive uses and provide convenient transportation options throughout the planning area.

Reduce pollution exposure,
improve air quality.

General Plan,
Chapter 3, LT
 Policy LT-7.5: Consider the impacts of all land use decisions on housing affordability and on the housing needs of special needs groups within Sunnyvale.

Promote safe and sanitary
homes.

Prioritize needs of
disadvantaged communities.

General Plan,
Chapter 3, LT
Goal LT-8: Create a city development pattern and improve the city’s infrastructure in order to maximize healthy choices for all ages, including physical activity, use of the outdoors, and access to fresh food.
 Policy LT-8.1 Promote community gardens and urban farms.  Policy LT-8.2 Increase the number and frequency of farmers markets.  Policy LT-8.3 Enable the availability of fresh food in the community.  Policy LT-8.4 Promote compact, mixed-use, and transit-oriented development in appropriate neighborhoods to provide opportunities for walking and biking as an alternative to auto trips.
 Policy LT-8.5 Promote walking and bicycling through street design.

Promote public facilities.

Promote food access.

Promote physical activity.

General Plan,
Chapter 3, LT
Goal LT-9: The City strives to provide and maintain adequate and balanced open space and recreation facilities for the benefit of maintaining a healthy communi ty based on community needs and the ability of the city to finance, construct, maintain, and operate these facilities now and in the future.
 Policy LT-9.1 Ensure that the planned availability of open space in both the city and the region is adequate.
 Policy LT-9.2 Follow management and preventive maintenance strategies to extend the usable life of open spaces and recreation facilities, such as planning for and implementing Reduce pollution exposure,
improve air quality.

Promote public facilities.

Promote food access.

Promote physical activity.

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“non-use times” for open space and facilities in order to assure adequate maintenance and regeneration time.
 Policy LT-9.5 Maintain existing park and open space tree inventory through the replacement of trees with an equal or greater number of trees when trees are removed due to disease, park development or other reasons.
 Policy LT-9.6 Maintain park and open space tree inventory on a system wide basis rather than a site-by-site basis with an understanding that there is no single optimum number of trees for a particular site.
 Policy LT-9.7 Maintain a working fruit orchard throughout the larg est portion of Orchard Heritage Park for as long as practical.
 PolicyLT-9.8 Conduct a cost/benefit analysis to determine whether the general community would be well-served during non-school hours by capital improvements to school-owned open space and/or recreational facilities. The cost/benefit analysis should take into account ongoing maintenance costs and responsibilities. When it is determined that the community would be well served by the capital improvement, the City will consider funding a share of the costs of those improvements proportionate to the City’s use.
 Policy LT-9.9 Support the acquisition or joint use through agreements with partners of suitable sites to enhance Sunnyvale’s open spaces and recreation facilities based on community need and through such strategies as development of easements and right -of- ways for open space use, conversion of sites to open space from developed use of land, and land banking.
 Policy LT-9.11 Facilitate and encourage pedestrian traffic in public recreational open spaces and utilize the Santa Clara Valley Transportation Authority’s Pedestrian Technical Design guidelines whenever appropriate and feasible.
 Policy LT-9.12 Support the acquisition of existing open space within the City limits as long as financially feasible.
 Policy LT-9.14 Mitigate as feasible the open space need in areas identi fied as underserved through the acquisition of new parkland and/or the addition of amenities in order to bring sites in line with Design and Development Guidelines.  Policy LT-9.15 In applying the Park Dedication requirements for new development, place a priority on acquiring land over in-lieu payment, particularly when the development is in areas identified as underserved and/or when the land is of sufficient size or can be combined with other land dedication to form larger Mini Parks or Neighborhood Parks.  Policy LT-9.16 Place a priority on ensuring that each site has the minimum resources identified in the Design Guidelines for its park classification before adding new amenities over and above the minimum required resources for the park classification.  Policy LT-9.18 Improve accessibility to parks and open space by removing barriers.

General Plan,
Chapter 3, LT
 Policy LT-11.4: Participate in regional efforts to respond to transportation and housing problems caused by economic growth to improve the quality of life and create a better environment for businesses to flourish.

Reduce pollution exposure,
improve air quality.

Promote safe and sanitary
homes.

General Plan,
Chapter 3, LT
 Policy LT-11.5: Encourage businesses to emphasize resource efficiency and environmental responsibility and to minimize pollution and waste in their daily operations.

Reduce pollution exposure,
improve air quality.

General Plan,
Chapter 3, LT
 Policy LT-14.10: Encourage multiple uses of public and quasi-public facilities (e.g., religious institutions, schools, social organizations, day care), such as community events, after - school programs, and festivals.

Promote public facilities.

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Source Goal, Policy, or Strategy Environmental Justice Issue Addressed
General Plan,
Chapter 3, LT
 Policy LT-14.11: Maintain and promote conveniently located public and quasi -public uses and services that enhance neighborhood cohesiveness and provide social and recreational opportunities.

Promote public facilities.

General Plan,
Chapter 3, LT
 Policy LT-14.12: Recognize childcare and places of assembly as essential services and land uses that support the diverse needs of the community. Avoid locating these sensitive uses near hazardous materials, noise, dust, etc.

Reduce pollution exposure,
improve air quality.

Promote public facilities.

General Plan,
Chapter 3, LT
 Policy LT-14.17: Give due consideration to the location and operation of government uses in order to provide benefit to the greater community
Promote public facilities.

General Plan,
Chapter 3, LT
 Policy LT-14.8: Ensure that development projects provide appropriate improvements or resources to meet the city’s future infrastructure and facility needs and provide development incentives that result in community benefits and enhance the quality of life for residents and workers.

Prioritize needs of
disadvantaged communities.

General Plan,
Chapter 4,
Community
Character (CC)
Goal CC-12: The City strives to maximize access to all of its services, facilities and amenities.  Policy CC-12.3 Provide recreation and enrichment programs, services, facilities and amenities to underserved areas and/or populations of the City. Underserved areas and/or populations could be due to factors such as: geography, gender, economics or ethnicity.

Promote public facilities.

Prioritize needs of
disadvantaged communities.

General Plan,
Chapter 5,
Housing (HE)
Goal HE-1 Assist in the provision of adequate housing to meet the diverse needs of Sunnyvale’s households of all income levels.

Goal HE-2 Maintain and enhance the conditions and affordability of existing housing in Sunnyvale.

Goal HE-3 Minimizes the impact of governmental constraints on the maintenance, improvement and development of housing.

Goal HE-4 Provide adequate sites for the development of new housing through appropriate land use and zoning to address the diverse needs of Sunnyvale’s residents and workforce.

Goal HE-5 Promote equal housing opportunities for all residents, including Sunnyvale’s special needs populations, so that residents can reside in the housing of their choice.

Goal HE-6 Maintain sustainable neighborhoods with quality housing, infrastructure and open space that fosters neighborhood character and the health of residents.

Promote safe and sanitary
homes.

General Plan,
Chapter 6, Safety
and Noise (SN)
Goal SN-1: Ensure that natural and human-caused hazards are recognized and considered in decisions affecting the community, and that land uses reflect acceptable levels of risk based on identified hazards and occupancy.
 Policy SN-1.1 Evaluate and consider existing and potential hazards in developing land use policies. Make land use decisions based on an awareness of the hazards and potential hazards for the specific parcel of land.
 Policy SN-1.5 Promote a living and working environment safe from exposure to hazardous materials.
 Policy SN-1.6 Operate a response system that will provide effective control and investigation of hazardous materials emergencies.

Reduce pollution exposure,
improve air quality.

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Source Goal, Policy, or Strategy Environmental Justice Issue Addressed
General Plan,
Chapter 7,
Environmental
Management
(EM)
Goal EM-11: Improve Sunnyvale’s air quality and reduce the exposure of its citizens to air pollutants.
 Policy EM-11.1 The City should actively participate in regional air quality planning.  Policy EM-11.2 Utilize land use strategies to reduce air quality impact , including opportunities for citizens to live and work in close proximity.  Policy EM-11.3 Require all new development to utilize site planning to protect citizens from unnecessary exposure to air pollutants.
 Policy EM-11.4 Apply the Indirect Source Rule to new development with significant air quality impacts. Indirect Source review would cover commerci al and residential projects as well as other land uses that produce or attract motor vehicle traffic.  Policy EM-11.5 Reduce automobile emissions through traffic and transportation improvements.
 Policy EM-11.6 Contribute to a reduction in Regional Vehicle Miles Traveled.  Policy EM-11.7 Reduce emissions from City of Sunnyvale fleet vehicles.  Policy EM-11.8 Assist employers in meeting requirements of Transportation Demand Management (TDM) plans for existing and future large employers and participate in the development of TDM plans for employment centers in Sunnyvale.

Reduce pollution exposure,
improve air quality.

General Plan,
Chapter 7, EM
Goal EM-12: Ensure that municipal solid waste is collected and transported in a safe and healthy manner.

Reduce pollution exposure,
improve air quality.

General Plan,
Chapter 7, EM
Goal EM-13: Encourage residents to maintain clean neighborhoods by preventing unsightly accumulations of discarded materials and illegal dumping of municipal solid waste.  Policy EM-13.1 Provide periodic opportunities for residents to dispose of refuse at discounted or no charge.

Reduce pollution exposure,
improve air quality.

Climate Action
Playbook
Strategy 1: Promoting Clean Electricity
Strategy 2: Decarbonizing Buildings
Strategy 3: Decarbonizing Transportation and Sustainable Land Uses Strategy 4: Managing Resources Sustainably
Reduce climate vulnerability.

Reduce pollution exposure,
improve air quality.

Climate Action
Playbook
Strategy 5: Empowering Our Community:
 Play 5.1 Enhance community awareness and engagement
 Play 5.2 Track and share data and tools
Promote civil engagement.

Climate Action
Playbook
Strategy 6: Adapting to a Changing Climate:
 Play 6.1 Assess climate vulnerabilities for Sunnyvale  Play 6.2 Protect shoreline area from sea level rise and coastal flooding  Play 6.3 Strengthen community resiliency
Reduce climate vulnerability.

City Council
Policy Manual
 Policy 1.1.18: Public Outreach for Pending Land Use and Development Proposals Promote civil engagement.

5.3 RECOMMENDATIONS
As shown in Table 5.2-1, the City has implemented many goals and policies that address pollution exposure, public services, public health, housing, civic engagement, and climate change at a broad, citywide level . The City has also implemented several policies that are specifically aimed at addressing EJ. However, there are still opportunities to further address issues of pollution burden and equity in the City. The recommended polic y considerations below generally fall under two categories: policies that are tailored to and prioritize the needs of underserved communities, and policies that address EJ in a more specific and concrete way.

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5.3.1 Reduce Pollution Exposure
Existing policies that reduce pollution exposure and improve air quality focus on creating an efficient transportation network, encouraging alternative transportation methods, increasing urban tree cover and open space, reducing waste generation, and proper siting of both sensitive land uses and pollution- generating sources. The City should consider the following recommendations:
 When siting new receptors near existing sources, provide clear siting distances, by source, that trigger a site- specific assessment to determine what reduction measures are applicable  When siting new receptors near existing sources in areas where risk may exceed BAAQMD recommended levels, provide recommendations for appropriate reduction measures  When locating new sources, provide site-specific evaluation and the consideration of the best available technology to reduce pollution (e.g., electrification)
 Consider the use of vegetative barriers between major sources and new sensitive receptors. Policies should provide specific criteria for when this is applicable.
 Adopt strategies that increase the dispersion of traffic emissions such as requiring new development to include vegetative barriers, solid barriers, or by incorporating design elements to promote air flow and pollutant dispersion along street corridors (i.e., varying the form and height of buildings along street corridors, buffer spaces along high-volume roadways).
 Prioritize implementation of transportation improvements and urban tree cover projects, and parks and recreation projects in low-income and high pollution burden bearing communities, which are identified in Section 4, “Identifying Disadvantaged Communities.”
 Coordinate with state and county agencies to prioritize hazardous site cleanup and remediation activities in low - income and high pollution burden bearing communities.
 Encourage the phasing out of non-conforming land uses from residential communities, especially for communities that are low-income and/or bear a high pollution burden.

5.3.2 Promote Public Facilities
The City has developed a strong suite of policies that promote fair access to, availability, and use of public facilities, with an emphasis on the needs of underserved communities. Given the projected population growth in the City and anticipated climate vulnerabilities, the City should consider the following recommendations:
 To meet future demand, prioritize new public facilities (e.g., transit routes, infrastructure improvements, schools, parks and recreation, emergency services) in areas that are also able to serve the needs of underserved communities.
 Increase the resilience of flood control infrastructure to protect communities from existing flood impacts and project climate vulnerabilities.

5.3.3 Promote Food Access
Existing policies that promote access to healthy food focus on increasing the availability of health y food through working orchards, community gardens, and farmer’s markets. One important aspect of community food security is access to culturally appropriate foods.
 Given the City’s diverse population who speak English as a second language, it is recommended that the City considers policies to support existing ethnic markets and facilitate the establishment of new ethnic markets within walkable distances to low-income communities.

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 Create programs or informational campaigns regarding healthy eating habits and food choices, and the availability of food assistance programs.

5.3.4 Promote Safe and Sanitary Homes
The City’s Housing Element contains policies that address housing conditions, affordability, and land use compatibility issues. Goals and policies aim to improve affordability, availability of affordable units, funding mechanisms and homebuyer assistance for low- and moderate-income households, and rental assistance. A variety of programs are in place to encourage and support property owners in maintaining housing stock in good condition. The Housing Element also contains policies to address the needs of specific populations, such as seniors, persons with disabilities, and minorities. There are no further recommendations for goals or policies in this category.

5.3.5 Promote Physical Activity
Existing policies that promote physical activity involve enhancing walkability; access and availability of parks, open space, and recreational facilities; and active transportation. Additional policies that the City should consider include:
 Prioritizing the development of recreational facilities, parks, and improvements to pedestrian and bicycle infrastructure in low-income and high pollution burden bearing communities.  Application of “universal design principles” in the design and review of development and redevelopment projects so that new development is accessible to all people. Universal design is the design of buildings or environments to make them accessible to all people, regardless of age, disability or other factors. Examples of universal design are curb cuts, kneeling buses, smooth surfaces for easy wheelchair travel, and accessible pedestrian signals.

5.3.6 Promote Civic Engagement in the Public Decision-Making Process
Existing policies that promote civil engagement focus on providing transparent information and data, ensuring equal access to information, and encouraging community involvement in decision- making. There is much that the City does to eliminate cultural and language barriers for participation: multi-lingual noticing and information sharing, providing translation services if needed, and designing outreach processes with the needs of specific communities in mind. The City also proactively seeks to create diverse boards, commissions, advisory committees, and task forces, which helps shift decision-making power to those who may be most affected. There are no further recommendations for goals or policies in this category.

5.3.7 Prioritize Improvements and Programs that Address the Needs of Disadvantaged Communities
The City has implemented several policies that are specifically aimed at addressing the needs of underserved communities: Policy LT-7.5 prioritizes the housing needs of special needs groups in the City, Policy LT-14.8 requires development projects to provide adequate community benefits, and Policy CC -12.3 focuses on ensuring that underserved communities have access to City programs, services, facilities, and amenities. Additionally, many of the policies described in Table 5.2-1 would result in communitywide benefits, which would improve conditions for underserved communities as well. An integral component of EJ planning is to proactively prioritize projects and investments that directly benefit DACs. The following policy is recommended :
 As the City invests in and supports improvements in underserved communities, it is also important to ensure that future improvements do not produce negative impacts such as loss of affordable housing or the displacement of residents and local legacy businesses.

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6 REFERENCES
BAAQMD. See Bay Area Air Quality Management District. Revised 2013 CARE Communities Map. Available:
https://www.baaqmd.gov/~/media/files/planning-and-research/care-program/revised-2013-care- communities-pdf.pdf?la=en. Accessed May 13, 2020.

Bay Area Air Quality Management District. 2018.

Cal-Adapt. 2019. Cal-Adapt Climate Tools. Available: https://cal-adapt.org/tools/ CalEPA. See California Environmental Protection Agency.

CalEPA and OEHHA. See California Environmental Protection Agency and the Office of Environmental Health Haza rd Assessment.

California Air Resources Board. 2018. Community Air Protection Blueprint. Available: https://ww2.arb.ca.gov/our- work/programs/community-air-protection-program/community-air-protection-blueprint. Accessed January 7, 2020.
———. 201 3. The California Almanac of Emissions and Air Quality—2013 Edition. Available:
http://ww3.arb.ca.gov/aqd/almanac/almanac13/almanac13.htm. Accessed November 6, 2019.

California Department of Public Health. 2017. Climate and Health Profile Report, Santa Clara County. Available:
https://www.cdph.ca.gov/Programs/OHE/pages/climatehealthprofilereports.aspx . Accessed January 7, 2020.

California Environmental Justice Alliance. 2017. SB 1000 Implementation Toolkit, Planning for Healthy Communities.

California Environmental Protection Agency. 2014. Approaches to Identifying Disadvantaged Communities .

California Environmental Protection Agency and the Office of Environmental Health Hazard Assessment. 2017. Update to the California Environmental Health Screening Tool: CalEnviroScreen 3.0.

CARB. See California Air Resources Board.

CDHP. See California Department of Public Health.

CEJA. See California Environmental Justice Alliance.

EPA. See U.S. Environmental Protection Agency.

Governor’s Office of Planning and Research. 2017. State of California General Plan Guidelines. Available:
http://opr.ca.gov/planning/general-plan/guidelines.html. Accessed January 7, 2020.

Metropolitan Transportation Commission and Association and Bay Area Governments. 2017a. Plan Bay Area 2040.

Adopted July 26, 2017.
———. 2017b. Projections 2040 by Jurisdiction (Curated). Available: http://projections.planbayarea.org/. Accessed January 7, 2020.

MTC and ABAG. See Metropolitan Transportation Commission and Association and Bay Area Governments.

OEHHA. See Office of Environmental Health Hazard Assessment.

Office of Environmental Health Hazard Assessment. n.d. CalEnviroScreen 3.0 Factsheet. Available:
https://oehha.ca.gov/media/downloads/calenviroscreen/fact-sheet/ces30factsheetfinal.pdf. Accessed January 7, 2020.

OPR. See Governor’s Office of Planning and Research.

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Santa Clara County. n.d. Silicon Valley 2.0, Climate Change Preparedness Decision Support Tool. Available:
http://siliconvalleytwopointzero.org/home. Accessed January 7, 2020.

U.S. Environmental Protection Agency. 2019. Environmental Justice. Available:
https://www.epa.gov/environmentaljustice. Accessed December 10, 2019.

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