California Air Resources Board

Comments re the Draft 2026 Roadmap to Reduce Air Toxics

The Roadmap in progress is an auspicious undertaking. When air pollution is discussed, PM 2.5, diesel particulates, and Black Carbon typically receive the greater part of the attention.

Notwithstanding this, the Draft Roadmap is a discursive draft. Both the Plan itself and the text of the Roadmap would benefit from editing. This reader would suggest adding a Bibliography, a glossary, and one or two further readings. A Precis (Executive Summary) at the start would also be helpful. Further editing would improve the implementation of pragmatic steps in the Toxics Roadmap.
Notes regarding specific segments of the text:

1. “Why we must act” Section I:
This is an excellent fine-grained discussion of different sorts of toxins and their sources in the context of genres of businesses and facilities in which aerosol pollutants are found. It would be strengthened by the addition of the canonical list of California TACs for reference.

2. “Why we must act” Section IV:
This section of the text does not exactly indicate that science is not keeping pace. For instance, the Agency for Toxic Substances and Disease Registry, a part of the Department of Health and Human Services’ toxicological profiles provide vast quantities of information concerning air contaminants. Apparently, as explained in Part II, there is new empirical data regarding some TACs such as ethylene oxide, and this should be explained in the text.

However, the section does demonstrate that record-keeping available to the general public is not keeping pace. Air Toxics monitoring continues, as indicated on page 18. But emissions (i.e., CEIDARs) data on point and stationary sources is terribly difficult to access.

The permitted facility files with data concerning TAC emissions for each facility are indeed available. But they are not easy to reach. For instance, permitting fact sheets for given locations are reached through the Interactive Data maps section of the BAAQMD web site. Yet for each of the sites in the Bayview Hunter's Point, the Facility Fact Sheets are at least five years old. In some cases, they are far older than that: Bayview Hunters Point Lennar Parcel A Fact Sheet, concerning AQ monitoring for Naturally Occurring Asbestos, is dated December 6, 2010. In contrast, the AQ data for criteria pollutants, gathered from BAAQMD instrumentation, is far more thorough and contemporaneous.

This researcher attempted to access data through the CARB Facility Search Tool and CARB Pollution Mapping and found that the data was both dated and extremely difficult to reach. In contrast, BAAQMD’s data was much easier to find. However, the AQMDs should not individually be the only source of emissions and permitting data.

3. “Our Path to Success” Section III
Page 28: III. The graphic depiction is confusing and does not indicate any causal relationships between the labeled sections. Perhaps a flow chart or a textual description would illustrate the issues better.

Page 33 VI. The streamlining of TAC identification as discussed on page 34 would, the reader gathers, facilitate the work of the OEHHA and the SRP. Would this process change the SRP’s meetings?

Page 37-38. It is encouraging that CARB has funds available to develop emissions control strategies for emerging TACs as mentioned. It would be very welcome if the Toxics Inventory could be developed to be robust and accessible from both the research-facing and the community-facing vantage points.