By Sue Briggum
Many U.S. companies take pride in being more “sustainable” by reducing environmental impacts and engaging constructively with the communities in which they operate and the customers they serve. Corporate sustainability reporting is replete with examples of resource conservation efforts and sustained initiatives to reduce greenhouse gas footprints. Non-governmental evaluative frameworks like the Global Reporting Initiative and CDP provide powerful templates for demonstrating environmental progress.
With regard to the social justice pillar of sustainability, however, we are only beginning to understand the potential for progress.
Considered from this perspective, EPA’s Draft EJ 2020 Action Agenda outlines a framework for a fairer and more sustainable future. EPA characterizes the sustainable elements of its plan in terms of opportunity to use a community-based approach to make “a visible difference in environmentally overburdened, underserved, and economically distressed communities.” Moreover, the EJ 2020 draft framework highlights a number of practical approaches to shaping more sustainable and socially just environmental programs.
EJSCREEN provides the data to make discussions about overburdened and underserved communities concrete and factual. With data from this tool, it becomes much easier to see whether public or private efforts to improve the environment, provide jobs, or fund new amenities align with social justice or thwart it by giving more to those who already have a great deal. The tool is powerful because instead of relying on assumptions and impressions, it simply relays the facts in formats that are easy to see. For example, with EJSCREEN it will be easy to see whether a new educational grant program is benefiting communities which, because of income or language barriers, need that supplement, or whether lead paint removal funding is going to communities least able to do the work on their own.
Tools like EJSCREEN also inform EPA’s efforts to align regulatory programs with environmental justice goals by incorporating considerations of environmental justice into permit issuance. When environmental justice is part of the permitting discussion rather than a consideration after the fact, the “rules of the road” are clearer for all parties. EPA’s emphasis on constructive engagement and collaboration throughout its draft EJ 2020 framework forecasts an intent to make permitting engagement constructive and focused on problem-solving. It’s far easier to re-route traffic, refine a monitoring program, or address operational concerns in project design and permitting than to do so as a contentious afterthought. EPA’s facilitation of this kind of collaborative engagement can save all parties time and grief because community perspectives are known, considered, and addressed. The process itself builds familiarity and, in time, trust.
The most basic building block for environmental justice is its incorporation within environmental programs as crafted, not just as implemented by permit. In recent rules, EPA has employed the power of tools like EJSCREEN to understand and address geographic distributional effects. Through its Environmental Justice Research Roadmap, there will be opportunities to address the more difficult issue of how to understand and address inequities that are population-based rather than place-based – for example, how environmental and social factors can contribute to health disparities.
Regulations and permits are only as good as the assurance that they are followed. EPA’s continuing commitment to focus enforcement efforts in overburdened communities has long been applauded by the business community. It’s a key means to assure a level playing field and consistent community protection.
Finally, the strength of the 2020 Action Agenda is that it is a Framework — a consistent approach across EPA programs and authorities. If EPA engages across the agency, with the partners it identifies and in the open and communicative manner it embraces, 2020 should be replete with success stories from all stakeholders’ perspectives.
About the author: Sue Briggum is Vice President of State and Federal Public Policy, Waste Management, and a former member of the National Environmental Justice Advisory Council (NEJAC), a federal advisory committee providing advice to the EPA. Sue also co-chaired the NEJAC work group on EJ Screening, as well as served as a member of the Science Advisory Board’s (SAB) work group on EJ in Rulemaking.