On Thursday, the EPA released its final EJ 2020 Action Agenda. EPA’s stated vision is to integrate environmental justice into everything that they do, cultivate strong partnerships to improve on-the-ground results, and chart a path forward for achieving better environmental outcomes and reducing disparities in the nation’s most overburdened communities.
In July, Gasp submitted comments on the draft agenda. We focused our comments on several, specific aspects of the plan:
- Chapter 3: Permitting: In the Draft Agenda, EPA asserted that EPA permit writers will consider whether there are environmental justice concerns present in the community affected by the permit. Gasp encouraged EPA also to consider institutionalized racism such as racial zoning laws that resulted in the creation of environmental justice communities. We suggested that EPA should pay special attention to the disparate impacts created when local agencies submit to EPA Title V permits. Gasp also recommended that community trainings for commenting on Title V permits occur well before the deadline for comments so that community members may weigh in on the permits adversely affecting their health and environment.
- Chapter 4: Compliance and Enforcement: In the Draft Agenda, EPA asserted that EPA emphasizes that “shared accountability toward protecting the most vulnerable necessarily involves strengthening our joint commitment with states.” Gasp encouraged collaboration between EPA and ADEM. But we also asserted that EPA must not only collaborate with state agencies, but they also must strengthen oversight of these state agencies. This would mean that EPA must use its full authority, including objecting to Title V air permits, disapproving state programs or withdrawing delegation of their authority to state agencies when basic protections are not being afforded to environmental justice communities.
- Chapter 5: Science: , EPA stated in the Draft Agenda that their objective was to “[s]trengthen the scientific foundation for considering environmental justice in decision making through research on decision support tools, cumulative impacts and risks, innovative monitoring and solution technologies.” Gasp urged that EPA must make a good faith effort to align their assessment of environmental health threats with the most up-to-date science (i.e. applying the most protective cancer risk level in environmental justice communities). Gasp enthusiastically welcomed EPA’s focus and encouragement of citizen science. However, we also stressed that EPA would need also to provide clear instructions to communities who are embracing citizen science. It would be useful if EPA could approve, or at the very least, highlight certain monitors or monitoring techniques that EPA deems to be reliable. Furthermore, EPA should also seriously consider such data collected by communities.
- Chapter 6: State and Local Government: In the Draft Agenda, EPA’s stated objective was to achieve “significant environmental results and meaningful public participation in the nation’s most overburdened and vulnerable communities in partnership with state and local co-regulators; and build the joint capacity of EPA, state and local co-regulators to address environmental justice concerns in our day-to-day program work.” Gasp suggested EPA could fulfill this objective by holding annual enforcement conferences or roundtable discussions in each EPA region by bringing together local and state agencies and communities and creating Title V permit task forces.
- Chapter 10: Air Quality: In the Draft Agenda, EPA aimed to “[a]chieve air quality that meets the fine particle pollution national ambient air quality standards for all low-income populations as soon as practicable and no later than the statutory attainment date. Low-income populations are among those most at-risk to adverse health effects from exposure to fine particle pollution.” Gasp stressed that EPA should be strengthening Alabama’s ambient air monitoring network. To address environmental justice issues created by air pollution, EPA must hold local regulators and industries to a higher standard than mere compliance with the NAAQS. When reviewing state ambient air monitoring plans, particularly those submitted by ADEM and JCDH, EPA should incorporate environmental justice principles when reviewing and approving these plans.
Gasp is pleased to see that EPA took our and other commenters’ comments to the Draft Agenda seriously. The EJ 2020 Action Agenda marks an important, proactive step for EPA and we look forward to its implementation and the much-needed relief it could bring to environmental justice communities in Alabama and throughout the nation.
