The Department of Environmental Quality (DEQ) has been required to develop an environmental justice (EJ) mapping tool. They are currently accepting public input on the tool. Scroll to the bottom of the page to find out how you can help!
When one heavily polluting industry comes to a neighborhood it opens the door for countless others to follow- and they do. Often these communities are rural, low-income, and inhabited by people of color.
We have the opportunity now to weigh in on DEQ’s “community mapping tool”. When fully functional, this tool should assist in protecting communities from unfair and hazardous industry by informing the permitting process of which communities are at most risk for environmental injustice. Here are the points we think are worth raising-
DEQ is now calling this a “community mapping tool” rather than “EJ tool”- why?
- Words matter. The creation of this tool was prompted by a title VI settlement which specifically assured an environmental justice mapping tool. If this tool is intended to identify pollution, health disparities, and other characteristics that result in environmental injustice, then the name should be in accordance with its origin and intended purpose.
What are the numbers and formulas that provide accountability?
- A useful tool should offer some metric by which to measure what is acceptable for permitting. Does this tool provide numerical values by which DEQ and the community can determine how requests are permitted or denied based on their scale of environmental justice? How many schools will be in proximity for a hazardous industry to considered unacceptable? How many impaired waterways? Brownfields? Superfund sites? landfills? Number of individuals with asthma? How do these calculations differ from three miles away? from one mile away? What formula(s) are used to make this tool function? And how will this information be shared with communities to provide shared understanding of the tool that will determine industry in their neighborhoods?
When will this tool be implemented?
- The May 2018 Title VI Settlement between DEQ and REACH, NCEJN and Waterkeeper requires DEQ to develop the mapping tool by April 1, 2019. DEQ has stated that it wants this EJ mapping tool to be applicable to all permits that it issues, and we support that goal. But we want this tool up and running and to be utilized in consideration of the 2019 Swine General Permit.
How does this tool measure against existing tools? Whose input was requested in forming this tool?
- Several systems already exist like the CAlEnvironScreen, The EPA’s EJ Screen, and the researcher’s tool currently being developed by UNC’s school of public health. Did DEQ consult with these existing models in development of their tool? Organizations like REACH, the NCEJN, and Waterkeeper Alliance work regularly with impacted communities. Has DEQ reached out to include their input in determination of what comprises a useful tool?
How can you help?
- Take the online DEQ survey.
- Submit public comments via mail or email.
See talking points below!
FYI: You do not have to put your name on the survey. You have the ability to remain anonymous.
Talking Points On North Carolina Department of Environmental Quality “Community Mapping System” and Environmental Justice Tool
DEQ recently announced that North Carolinians have until July 10 to submit comment on the tool. Community members are encouraged to include the following points in written comments, which should be emailed to ej@ncdenr.gov, or mailed to:
NC Dept. of Environmental Quality
Attn: Renee Kramer
217 West Jones Street
1646 Mail Services Center
Raleigh, NC 27699-1646
Main Point
The initial version of the tool does not yet fulfill the Title VI settlement’s promise of a tool which incorporates “environmental, demographic, and health factors” in a way that is meaningful and relevant to communities in North Carolina. With respect to those factors, there are four main deficiencies in the current tool: (1) the size of each source of pollution should be an available layer of information; (2) population data must be provided at a finer resolution; (3) users should be able to characterize cumulative risk; and (4) the tool must be used in decision-making.
Environmental Factors
The size of each source of pollution should be an available layer of information.
DEQ’s tool shows the location of environmental permits across the state. This lets users count the number and types of facilities that exist near homes, schools, and other places of concern. But it offers no way to determine if those facilities are large or small. Do they produce a minimal amount of waste, or many tons each year? Do they have a few hogs on-site, or a few thousand?
Vulnerable communities are overburdened not only by merit of living near a high number of sources of pollution, but just as importantly by living near the largest and most dangerous polluting facilities. The ability to determine where those facilities are will allow communities and DEQ to better understand how certain groups are being impacted by permitting decisions.
DEQ should incorporate the critical data layer of facility size—as well as overall environmental indicators such as traffic data, water quality, and ambient air quality—to fulfill the promise of using relevant environmental factors in the EJ Tool.
Demographic Factors
Population data must be provided at a finer resolution.
The EJ Tool only tells us demographic information at the census tract level. Census tracts are smaller than counties but larger than census blocks and census block groups. The source of the EJ Tool’s demographic data is the American Community Survey, which also reports all of this information at the census block group level.
Census tracts in North Carolina are about three times larger than census block groups, come in irregular shapes and sizes, and can cover a very wide space—particularly in the rural communities where this tool would be most crucial. The needs of these groups are not being met as long as the tool can’t help us to more specifically target our communities.
DEQ should work immediately to provide their demographic information at the census block group level. DEQ should also provide reference demographic data which compares an area of interest to the population of the county and state.
Additionally, DEQ should look to EPA’s EJSCREEN tool, which estimates the population of an area as far down as the census block level using data from the American Community Survey. Users—especially community members who have to live near polluting operations—should not have to switch between EJSCREEN and the EJ Tool for a full picture. The EJ Tool should allow users to see data for the area most relevant to them.
Health Factors
Users should be able to characterize cumulative risks for a population of interest.
The only health data provided in the EJ Tool are county level health statistics (and state averages for comparison). DEQ states that the health data “is represented on a county level because it is the smallest scale of data available.” However, health factors go beyond these hospital statistics.
Members of vulnerable communities are not only concerned about individual permits and isolated facilities, but about their cumulative impact on our health. We want the EJ Tool to report the environmental health risks we face as a whole.
DEQ should make it simple for a user to see the total level of pollution burdening residents from nearby sources as a whole. DEQ should also work to develop a metric of the total impact to health that a community is facing, especially from the most dangerous and common of those pollutants, when compared to the county or state as a whole.
Meaningfulness and Relevance
The EJ Tool must be used in decision-making in order to be relevant.
Even if this tool were perfectly designed, it is not meaningful unless it actually affects permitting and siting decisions by DEQ. The Title VI settlement agreement stated: “In applying the EJ tool… DEQ in its discretion will be guided by” the US EPA’s “Guidance on Considering Environmental Justice During the Development of Regulatory Actions.” That Guidance clearly states that community involvement in EJ is not meaningful unless “the populations’ contributions can influence [the Agency’s] rule-making decisions.” The EJ Tool survey states that its purpose is “to assist permit decision makers with respect to development and implementation of permits in North Carolina.” The actual use of the EJ tool should reflect these stated goals.
DEQ must be ready to solve problems and injustices, not just identify them.
