EPA's Draft Environmental Justice Strategic Plan -- A "Giant Step Backward"

 

July 15, 2005. EPA's Draft Strategic Plan -- A "Giant Step Backward"

Environmental Justice scholar Robert D. Bullard has harsh words to describe the EPA's Draft Environmental Justice Strategic Plan [make hot link]. In written comments, he described the plan as a "Giant Step Backward." To view full text of Professor Bullard's comments click HERE. Professor Bullard's comments are summarized below:

• EPA's abbreviated public comment period did not allow adequate time for the public to review the Draft Framework/Outline. EPA should extend the public comment period.
• The Draft Framework/Outline does not offer a clear and coherent framework for consistently implementing the intent of the Environmental Justice Executive Order 12898
• The Draft Framework/Outline fails to identify "affected communities" and the key recipients of environmental justice: namely, minority populations and low-income populations
• The Draft Framework/Outline does nothing to reduce or eliminate existing environmental health threats that disproportionately affect minority populations and low-income populations.
• The Draft Framework/Outline clearly undermines the intent of Executive Order 12898 by failing to acknowledge and implement a Strategic Plan that identifies minority population and low-income populations (groups that are clearly identified in the Executive Order as protected classes)
• The Draft Framework/Outline is a "giant step backward" and a significant departure from decades of environmental justice policies, directives, guidance, and definitions, including the protected classes covered under Title VI of the Civil Rights Act of 1964.
• The Draft Framework/Outline gives other federal agencies a road map to do nothing.
  
• EPA's "Environmental Justice Mission Statement" misses the mark altogether and runs counter to Executive Order 12898 and recent Congressional mandates calling on EPA to ensure that none of its funds are used "in contravention of, or to delay the implementation of" Executive Order 12898.
  
• The Draft Framework/Outline abandons several decades of studies that clearly link environmental hazards, race/class health disparities, and unequal protection.
  
• The Draft Framework/Outline does not address environmental policies and practices that result in unfair, unjust, and inequitable outcomes for minority populations and low-income populations.
  
• EPA's Draft Framework/Outline does not ask the hard questions that go to the heart of environmental injustice: What groups are most affected? Why are they affected? Who did it? What can be done to remedy the problem? How can communities be justly compensated and reparations paid to individuals harmed by industry and government actions? How can the problem be prevented?
  

Conclusion

The Draft Framework/Outline would allow EPA to shirk it's responsibility for addressing environmental justice problems in minority population and low-income population and divert resources away from implementing the Executive Order—actions that run counter to more than a decade of policy decisions and recent environmental justice legislation from the U.S. Congress.

While we agree that EPA was created to protect and enforce the law without regard to race, color, national origin, or income status. However, the Executive Order is not for everybody. The Executive Order, as made explicit in its title, Federal Action to Address Environmental Justice in Minority Populations and Low-Income Populations, has a specific target population and recipient group. EPA's Draft Framework/Outline should stay focused on this target population and recipient group in implementing the Executive Order.

EPA should go back to the drawing board and develop a comprehensive environmental justice Strategic Plan that builds on a decade of sound environmental justice policies with the goal of consistently implementing the intent of Executive Order 12898.