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This supplementary legal document describes recommendations for storm- and waste-water management improvements for the Formosa petrochemical plant in Calhoun County, Texas. The text is a fairly standard drainage assessment. The author describes non-trivial discharge of pollutants out of the plant’s outfalls, which drain into local waters, and the inability of the plant’s systems to prevent flooding from even small storms. For some context on this, it is pretty standard to design a stormwater system to be able to drain the 100-year storm (that is, the storm with a 1% or less chance of occurring in any given year). Formosa’s Texas plant demonstrated the inability to convey even the 2-year storm.

Emphases are mine:

“Problem areas were identified based on the results from the outfall drainage studies provided by Formosa. Thus, all the results in the OPCC rely on those studies, uncertainities associated with those studies, and the assumptions made for those studies, some of which may or may not be appropriate as I pointed out in Supplement #2 [Page 4]” (3)

“The proposed improvements assume that the conveyance capacity of the problem areas is increased 100%, which would be able to handle twice as much flow that it currently does. The results from the Drainage Study are not conclusive as to what storm event Formosa’s system currently is capable of conveying. The report does mention that the system is not capable of conveying the 2-year storm, and “sometimes” not even the 1-year storm event.” (3)

“A 45% contingency is applied to the OPCC due to the uncertainties associated with underground utilities, likelihood of existence of low road crossings and need to replace those, groundwater impacts, other unknowns, and additional costs associated with engineering, etc. 45% is reasonable and in line with industry practices in my experience, especially given the large amount of unknown information available.” (4) 

“My opinion from my July 9, 2018 report that “there have been and are still pellets and/or plastic materials discharges above trace amounts through Outfall 001” is further supported by the deposition testimony of Lisa Vitale, as representative for Freese & Nichols, Inc, that she and her colleagues have seen floating white pellets or small plastic pieces in Lavaca Bay and in the area near outfall 001 as part of her work on the receiving water monitoring program for Formosa’s TPDES permit...Ms. Vitale also testified that she told John Hyak of Formosa about these sightings as well as has sent him water samples with the pellets about five or six times, including at least one time prior to 2010. This, along with the June 2010 EPA Report I cited in my July Report, demonstrates to me that Formosa was aware of problems related to discharges of plastics from its facility since at least in 2010.” (6)

Creators of the Student Health Index recommend using the tool in combination with qualitative data collection and stakeholder/community engagement (e.g. working with school leaders, local community leaders, and healthcare providers).

A full guide to using the dashboard is available here.

Data sources utilized by the index are not always the most current due to data collection limitations (e.g. covid-19 has caused disruptions in the collection of CDE data).

The Index is limited in that it does not offer data for schools that were not large enough to warrant the construction of a School-based Health Center. Thus, schools that did not meet specific enrollment targets were excluded from the dashboard. This includes rural schools (designed as such by the USDA) with an enrollment under 500 students, urban schools (without a high school) with less than 500 students, and urban schools (with a high school) with less than 1000 students. California had more than 10,000 active public schools in 2020-21. The final dashboard for the Student Health Index includes 4,821 schools.

The lack of available data on health indicators at a school-level restricted the Student Health Index to using proxies for the health outcomes. Some health indicators are included, but they are not school-specific, instead linked to specific schools geographically through the census tract. However, community-level data does not always accurately reflect the characteristics of a school’s population. As a result, school-level indicators in the Index were weighted more heavily than community-level indicators.

Additionally, race was not included as a measure in the Student Health Index because of California’s Proposition 20, which prohibits the allocation of public resources based on race and ethnicity. However, the dataset does contain measures of non-white students at each school. 

The Index has also been limited as a quantitative measure of need, which may overlook the influence of other factors that might be better illuminated through qualitative evidence (e.g. stakeholder engagement, focus groups, interviews, etc.).

No information thus far

The Student Health Index can produce visualizations that represent data on conditions, school characteristics and risk factors that affect education outcomes and could be improved through access to school-based health care. These visualizations can be used to demonstrate need for expanding school-based health care access in California.

In addition to maps, the index can also be used to generate graphs and visual displays of data (e.g. ratio of highest need schools to all schools, by county).

The visualizations can be used to demonstrate the correlations between final need scores and race, the impact of specific indicators in health, and the concentration of need to certain regions of California (hot spot analysis).

The Student Health Index enables users to identify where SBHCs will have the most impact for students. The index uses 12 indicators, each of which can be scored from 1 to 4 for any given school. These scores are generated using percentiles and represent relative values. The 12 indicator scores are combined into a Need Score, which is calculated using percentiles along a scale of 1 to 4. Schools with a score of 4 (in the 4th quartile) have the highest Need scores relative to other schools in California.

The index is composed of 12 diverse indicators (percentages, rates, and index values) that have been transformed using percentiles in order to enable comparisons on a common scale. These indicators are divided into 3 categories: health indicators, school-level indicators, and socioeconomic indicators.

Health Indicators

1. Diabetes
2. Asthma ED admissions
3. Teen birth
4. Health Professional Shortage Areas (HPSA)

Socioeconomic Indicators

1. Poverty among individuals under 18
2. Uninsured among under 19
3. Healthy Places Index

School-Level Indicators

1. Percent FRPL (students eligible for free or reduced-price meals)
2. Percent English Learners
3. Percent Chronically Absent
4. Percent experiencing homelessness
5. Suspension rate

Other Data

1. Mental health hospitalization rate
2. Percent in foster care

Indicator selection was guided by CDC estimations on the primary contributing factors that shape health (social determinants of health, medical care, and health behaviors). The indicators included in the index are all either directly associated with the absence of health services that could be provided at a school level, act as proxies for health behaviors, or represent social determinants of health that could be addressed through access to school-based health services.

Indicator selection was influenced by recommendations from the Research Initiative of the Campaign for Educational Equity at Columbia Teachers College, which found that seven health disparities affecting school-aged youth could be addressed through school health programs. These disparities include: (1) vision, (2) asthma, (3) teen pregnancy, (4) aggression and violence (including bullying), (5) physical activity, (6) hunger, and (7) inattention and hyperactivity.

More detailed description of the rationale shaping indicator selection is available here.

Census tract, school-level

The Student Health Index draws from data that is publicly available and up to date on a statewide level. Sources include the University of California San Francisco Health Atlas, the American Community Survey, the U.S. Census Bureau, the California Department of Education’s Downloadable Data Files site, and the CDC.

Detailed list of sources:

PLACES Project, CDC (available through the UCSF Health Atlas)

CalEnviroScreen (available through the UCSF Health Atlas)

Opportunity Atlas (available through the UCSF Health Atlas)

Health Resources and Services Administration (available through the UCSF Health Atlas)

American Community Survey (available through the UCSF Health Atlas)

California Department of Education’s Downloadable Data Files site

Kidsdata.org