Planning for Environmental Justice
This blog was co-authored by former MFA Senior Planner Sarah Sieloff.
What Is Environmental Justice in Planning?
National Community Planning Month is an opportune time to consider how pollution doesn’t impact all people equally. The link between zip codes and average life expectancy is well documented.
Tools like the Centers for Disease Control and Prevention’s Data Visualization Gallery and the Washington State Department of Health’s Environmental Health Disparities Map show how differences in life expectancy correlate with differences in income, racial composition, or exposure to traffic exhaust.
Similar patterns exist across the U.S. Many variables impact these outcomes, but they often share a connection to planning decisions, some of which may be decades old. The history of planning in the U.S. is marred by discriminatory land use policies that deprive equal opportunity to generations of Americans.
By incorporating environmental justice (EJ) principles into planning processes, planning as a discipline is acknowledging past wrongs and taking steps to correct and prevent others.
As a concept and term, EJ has existed for decades. The U.S. Environmental Protection Agency (EPA) defines EJ as, “the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income, with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.”
New developments in EJ policy and implementation are shifting conversations in planning to ask how public goods are distributed and how the built environment either facilitates or impedes equitable access across all communities of people. Federal and state grants frequently require that applicants address EJ as part of their projects, and many state and federal agencies have taken additional actions. In 2021, the federal government announced Justice40, a commitment to channel 40 percent of the overall benefits of certain federal investments to disadvantaged communities. States from Alabama to California have taken actions ranging from requiring that permit applications address EJ to developing state EJ mapping tools and using EJ analyses to inform public outreach.
Environmental Justice in Washington State
In 2021, Washington State passed the Healthy Environment for All Act (HEAL Act), which established a state definition of EJ and mandates that certain state agencies conduct EJ assessments before undertaking activities such as establishing a grant program, awarding transportation grants or loans of $15 million, or more. Notably, the HEAL Act takes Washington State’s definition of EJ a step further than the EPA definition and includes the duty to prioritize vulnerable and overburdened communities, distribute resources equitably, and eliminate harm.
Another Washington State law, House Bill (HB) 1220 (2021), brings EJ considerations to the local level by strengthening requirements for city planning around housing provision. The law changes statutory language related to housing elements in comprehensive plans from “Encourage the availability of affordable housing to all economic segments of the population” to “Plan for and accommodate housing affordable to all economic segments of the population.”
HB 1220 also requires that cities redress and prevent racially disparate impacts, displacement, and exclusion. This means turning a critical eye to zoning and considering whether zoning has been or is being used to facilitate racial segregation; understanding whether areas were historically subject to redlining and racially discriminatory covenants; addressing systematic disinvestment and lack of access to improved services; and improving lack of infrastructure availability or insufficient level of service. Housing is a critical aspect of environmental and economic justice, affecting the health outcomes in underserved communities. For more, see this blog I wrote in 2019 as then-executive director of the nonprofit Center for Creative Land Recycling. Given what we know about the relationship between life expectancy and the built environment, the case for HB 1220 as EJ legislation is clear.
Planning Healthier Communities for Everyone Starts with a New Lens
EJ policies are introducing new requirements into familiar planning processes and funding competitions. Understanding not only EJ concepts, but also the latest research and tools is critical for policy makers and permit applicants alike. More grant applications now require applicants to explicitly address EJ, and relate EJ needs and outcomes to their projects. The guidelines for EPA’s Brownfields Grants (applications for which are being accepted through November 22) have significantly shifted over the last five years in the way EPA requires applicants to address EJ. At a minimum, planners and the people they serve should understand how to use national and state-level mapping tools, how to interpret the results, and how to link those with existing goals and projects. EPA’s EJSCREEN is a national tool now in its second iteration, as is Washington State’s Washington Tracking Network. In 2022, Oregon’s state legislature passed HB 4077, which directs the Oregon Department of Environmental Quality to establish and use a mapping program when developing agency rules, policies, or programs.
Planning healthier communities for everyone starts with a new lens through which to weigh public policy, but it doesn’t stop there. Over the past year, EJ programs and policies have seen substantial changes. As the evolution and implementation continues, public agencies and governments will be learning with and from each other. This is a conversation to watch and participate in. It asks community planning as a discipline to change the way it does business, and explicitly adapt expectations, requirements, and decision-making criteria to develop a more equitable future for everyone.
We will be publishing more content for National Community Planning Month throughout October. Stay tuned by following us on social media.
 On September 25, 2022, the Washington State Department of Commerce released its draft guidance for cities related to identifying and addressing racially disparate impacts, as required by HB 1220. Comments are due October 19, 2022. Draft guidance is available at this link.