WHITE HOUSE ENVIRONMENTAL JUSTICE
ADVISORY COUNCIL (WHEJAC)
MARCH 2022 MEETING SUMMARY
VIRTUAL PUBLIC MEETING
March 30-31,2022
1
-------
TABLE OF CONTENTS
PREFACE 4
MEETING SUMMARY 6
1.0 WHEJAC Meeting 6
1.1 Welcome & Introductions & Opening Remarks 6
1.2 Opening Remarks 7
1.2.1 Brenda Mallory, Chair - The Council on Environmental Quality 7
1.3 Domestic Policy Council Update 10
1.3.1 Kimberlyn Leary, Senior Policy Advisor, Racial and Economic Justice Team -
Domestic Policy Council 10
1.4 Environmental Justice and the President's Bipartisan Infrastructure Law 21
1.4.1 Candace Vahlsing, Associate Director for Office of Climate, Energy, Environment,
and Science - Office of Budget and Management; Radhika Fox, Assistant Administrator,
Office of Water - U.S. Environmental Protection Agency; Stephen Tryon, Director,
Office of Environmental Policy and Compliance - U.S. Department of Interior;
Christopher Coes, Principal Deputy Assistant Secretary for Transportation Policy - U.S.
Department of Transportation 21
1.5 Public Comment Period 35
1.5.1 Graham Hamilton - Break Free from Plastic (Washington) 35
1.5.2 Marcia Briggins - Re-Right the Culture (Uniontown, Alabama) 36
1.5.3 Cynthia Vanderpool Garcia - Alianza Nacional de Campesinas, Inc. (Maryland).. 36
1.5.4 Dave Shukla - Long Beach Alliance for Clean Energy (Long Beach, California).. 37
1.5.5 Karen Spencer (Gloucester, Massachusetts) 37
1.5.6 Brett Johnson - NYSACC, Gorham Conservation Board (Gorham, New York).... 38
1.5.7 Robin Forman - Environmental Advocate (Maryland) 38
1.5.8 Jamie Banks - Quiet Communities (Massachusetts) 38
1.5.9 Sinthya Hernandez - Lideres Campesinas (Oxnard, California) 39
1.5.10 Kari Fulton - Climate Justice Alliance (Maryland) 39
1.5.11 Dan Solitz (Oregon) 41
1.5.12 Charlotte Keys - JPAP/MTAC (Columbia, Mississippi) 41
1.5.13 John Mueller (Oklahoma) 41
1.5.14 Hormis Bedolla - Alianza Nacional de Campesinas (Wolcott, New York) 42
1.5.15 Alicyn Gitlin - Sierra Club - Grand Canyon Chapter (Flagstaff, Arizona) 43
1.5.16 Audelia Martinez - Lideres Campesinas (California) 43
1.5.17 Carlos Garcia (New York) 44
1.5.18 Brandi Crawford-Johnson (Kalamazoo, Michigan) 45
1.5.19 Dulce Salgado - Alianza Nacional de Campesinas (Oregon) 45
1.6 Closing Remarks - Announcements & Adjourn 46
2.0 Welcome, Introductions & Recap 47
2
-------
2.1 Opening Remarks 47
2.1.1 Robin Morris Collin, Senior Advisor for Environmental Justice - U.S. EPA 47
2.2 WHEJAC Climate and Economic Justice Screening Tool Workgroup Update &
Discussion 48
2.2.1 Dr. Lucas Merrill Brown, Senior Advisor for Justice40 - CEQ 48
2.3 WHEJAC Climate Resilience Workgroup Update & Discussion 60
2.4 WHEJAC Justice40 Workgroup Update & Discussion 69
2.5 WHEJAC Business Meeting Reflection & Conversation 73
2.6 Closing Remarks & Adjourn 80
AGENDA 83
ONLINE SUBMITTED WRITTEN PUBLIC COMMENTS 85
APPENDIX A: 90
ADDITIONAL SUBMITTED WRITTEN PUBLIC COMMENTS 90
APPENDIX B: 91
ATTENDEE LIST Error! Bookmark not defined.
3
-------
PREFACE
The White House Environmental Justice Advisory Council is established by Executive Order
14008, titled "Tackling the Climate Crisis at Home and Abroad" (issued on January 27, 2021).
As such, this is a non-discretionary committee and operates under the provisions of the Federal
Advisory Committee Act (FACA), 5 U.S.C. App. 2.
The WHEJAC will provide independent advice and recommendations to the Chair of the Council
on Environmental Quality (CEQ) and to the White House Interagency Council on Environmental
Justice (Interagency Council), on how to increase the Federal Government's efforts to address
current and historic environmental injustice, including recommendations for updating Executive
Order 12898. The WHEJAC will provide advice and recommendations about broad cross-cutting
issues related, but not limited to, issues of environmental justice and pollution reduction, energy,
climate change mitigation and resiliency, environmental health and racial inequity. The
WHEJAC's efforts will include abroad range of strategic scientific, technological, regulatory,
community engagement, and economic issues related to environmental justice.
The duties of the WHEJAC are to provide advice and recommendations to the Interagency
Council and the Chair of CEQ on a whole-of-government approach to environmental justice,
including but not limited to environmental justice in the following areas:
• Climate change mitigation, resilience, and disaster management.
• Toxics, pesticides, and pollution reduction in overburdened communities.
• Equitable conservation and public lands use.
• Tribal and Indigenous issues.
• Clean energy transition.
• Sustainable infrastructure, including clean water, transportation, and the built
environment.
• National Environmental Policy Act (NEPA) enforcement and civil rights.
• Increasing the Federal Government's efforts to address current and historic environmental
injustice.
EPA's Office of Environmental Justice (OEJ) maintains summary reports of all WHEJAC
meetings, which are available on the WHEJAC website at:
https://www.epa.gov/environmentaliustice/white-house-environmental-iustice-advisory-council.
Copies of materials distributed during WHEJAC meetings are also available to the public upon
request. Comments or questions can be directed via e-mail to wheiac@epa.gov
Committee Members in Attendance
• Richard Moore, Co-Chair, Los Jardines Institute
• Peggy Shepard, Co-Chair, WE ACT for Environmental Justice
• Carletta Tilousi, Vice-Chair, Havasupai Tribal
• Catherine Coleman Flowers, Vice-Chair, Center for Rural Enterprise and Environmental
Justice
• Angelo Logan, Moving Forward Network
4
-------
• Viola Waghiyi, Alaska Community Action on Toxins
• Miya Yoshitani, Asian Pacific Environmental Network
• Jade Begay, NDN Collective
• Kim Havey, City of Minneapolis
• Kyle Whyte, PhD, University of Michigan
• Tom Cormons, Appalachian Voices
• LaTricea Adams, Black Millennials for Flint
• Harold Mitchell, ReGenesis
• Beverly Wright, PhD, Deep South Center for Environmental Justice
• Susana Almanza, People Organized in Defense of Earth and Her Resources
• Robert Bullard, PhD, Texas Southern University
• Juan Parras, Texas Environmental Justice Advocacy Services
• Maria Belen-Power, GreenRoots
• Maria Lopez-Nunez, Ironbound Community Corporation
• Michele Roberts, Environmental Justice and Health Alliance for Chemical Policy Reform
• Nicky Sheats, PhD, Kean University
• Ruth Santiago, Latino Climate Action Network
5
-------
WHITE HOUSE ENVIRONMENTAL JUSTICE ADVISORY COUNCIL (WHEJAC)
Virtual Public Meeting
March 30-31, 2022
MEETING SUMMARY
The White House Environmental Justice Advisory Council (WHEJAC) convened via Zoom
meeting on Wednesday, March 30, 2022, and Thursday, March 31, 2022. This synopsis covers
WHEJAC members' deliberations during the two-day meeting. It also summarizes the issues
raised during the public comment period.
1.0 WHEJAC Meeting
This section summarizes WHEJAC members' deliberations during the two-day meeting,
including action items, requests, and recommendations.
1.1 Welcome & Introductions & Opening Remarks
Karen Martin, the Designated Federal Officer (DFO), U.S. EPA, welcomed attendees and gave
a few announcements before getting started. Since it is a virtual meeting, everyone is in listen
and view mode only, and the Q&A feature or the Raise Your Hand feature will be turned off.
Public commenters are invited to speak later that afternoon. Spanish translation and closed
captioning are available. The announcements were then read in Spanish. She then turned the
meeting over to Richard Moore, the WHEJAC Co-Chair, for the opening remarks.
Richard Moore thanked everyone for joining the public virtual meeting of the WHEJAC. We
know for all that it's been very interesting times, not only in this country but throughout the
world. He thanked the staff of CEQ and our other staff members and everyone involved for the
tremendous work and effort that's been put into a very important piece of work. He reminded
everyone of the work that's been done by many throughout the years in terms of environmental
and economic justice issues that most impact communities of color, native indigenous, and other
communities.
Peggy Shepard thanked everybody for attending the meeting and thanked CEQ Chair Brenda
Mallory and Kimberlyn Leary of the Domestic Policy Council for bringing such inspired words
today.
Catherine Coleman Flowers thanked everyone for attending the meeting. She stated that they
are at a very important crossroads, and this morning she had an opportunity to be part of an
international gathering where the discussion was on environmental justice. She thanked her
colleagues and those that have joined these meetings to make sure that this is at the center of
everything they do as it relates to trying to address the inequities in this country.
Carletta Tilousi stated that she looked forward to hearing all the communities' comments on
some of the draft work that has been produced.
DFO Martin invited the Council members to briefly introduce themselves and state their
6
-------
affiliations. Afterward, she informed the Council that the quorum was met.
1.2 Opening Remarks
Co-Chair Moore invited Brenda Mallory to give her opening remarks.
1.2.1 Brenda Mallory, Chair - The Council on Environmental Quality
Brenda Mallory thanked everyone for inviting her. She also stated that she wanted to start the
meeting with reflection and gratitude. This week marks one year since the creation of the White
House Environmental Justice Advisory Council. Thank you for one year of service, your time,
and your dedication to developing recommendations for delivering environmental justice to
communities across the country. She recognized the countless hours that go into the WHEJAC
recommendations themselves, but also the working groups, the public meetings, and then the
time that goes unseen. She also thanked her colleagues across the federal family who have
joined and presented at various WHEJAC meetings, at work group sessions, and to those who
are joining us today. Finally, just a huge thank you to anyone who has ever joined a WHEJAC
meeting and to those who will be participating in the public meeting throughout the next couple
of days.
As they mark this historic milestone, she wanted to take a quick look back at what was
accomplished together since the WHEJAC was established. She focused on three things where
the WHEJAC has played a critical role in the unprecedented environmental justice policy
initiatives the Biden/Harris administration launched over the last year.
First, just bringing community voices to the table. On the campaign trail, President Biden met
with environmental justice leaders to listen, learn, and create a plan of action. One resounding
message that he took away from these conversations was the need to bring community voices
into the policy-making process from the beginning. That was really why the WHEJAC was
created and was one of the first actions that he took when he came into office. To help
implement President Biden's unprecedented environmental justice commitments, it was critical
to establish a formal body made up of experts, researchers, and long-time activists to provide
council and guidance as we pursue our whole-of-government approach to environmental justice.
For the first time in our nation's history, an administration has brought the perspectives and
expertise of the environmental justice communities into a formal advisory role at the white
house. Throughout the course of the last year, they have intentionally sought out community
voices in other ways as well whether that's been through the president himself or his cabinet
members traveling to visit folks on the ground so that we all could have the benefit of hearing
and learning about the lived experiences of people and of the conditions that people are
enduring. She added that they have also used formal sessions like round tables and consultations
and in other ways to attempt to expand our engagement in order to facilitate community input.
And all of these efforts are designed to ensure that we're centering the voices we need to hear.
Second, the WHEJAC has provided invaluable recommendations to guide our policy choices.
Two examples which we've talked about in these meetings, the Justice40 initiative and the
Climate and Economic Justice Screening Tool, have been key ways in which we have integrated
7
-------
the recommendations of this body. In July of 2021, the Biden/Harris administration issued
interim guidance to federal agencies on how to transform eligible programs to deliver 40 percent
of their overall benefits to disadvantaged communities. This direction relied heavily on
recommendations provided by environmental justice leaders and experts, including those who
serve on the WHEJAC. The guidance identified examples of the benefits of covered investments
that agencies could consider as part of their Justice40 strategies. And more than 90 percent of
these example benefits were informed by the WHEJAC recommendations issued in May of
2021.
The guidance also identified 21 covered programs to be included in the Justice40 pilot. And the
21 programs took steps to implement the Justice40 initiative at an expedited pace with the goal
of providing lessons and best practices that could be applied across the whole of the government.
Out of the 21 programs selected to be a Justice40 pilot, 85 percent of those were informed by
what we've heard from the WHEJAC recommendations in May of 2021. So, these are really
good examples of how we tried to embrace the recommendations.
Turning quickly to the Climate and Economic Justice Screening Tool. In February, CEQ
launched the beta version or draft version of this first-of-its-kind tool. And again, they relied
heavily on the recommendations that the WHEJAC submitted for creating a tool to help identify
disadvantaged communities. They intentionally made it a draft version so that they could spend
an additional 60 days gathering more input from researchers, academics, practitioners, state and
local leaders, and the public. And taking this approach was guided by our conversations with
many environmental justice experts along the way.
The Justice40 initiative and the screening tool are among the most impactful actions the
Biden/Harris administration took in our first year to set up a systematic whole of government
approach to address environmental injustice. Both of these landmark policies were important
examples of our WHEJAC coordination. And then finally, the WHEJAC has pushed us to
deliver on our whole-of-government approach. Agency after agency from the Environmental
Protection Agency to the Department of Agriculture to the General Service Administration has
launched and strengthened environmental equity offices, task forces, and strategies.
The president directed us to reduce the pollution burdens and climate change threats that
communities are facing. And the president himself really helped deliver on this promise by
getting the bipartisan infrastructure logged on and securing historic investments to clean up
superfund sites and brownfields, replace lead pipes, deal with abandoned mines and oil wells,
and much more. And as the administration more broadly, we made big strides in the past year to
reduce the burdens and confront the injustices that many communities are facing from cracking
down on PFAS and other toxic chemicals, to cutting vehicle pollution, reforming FEMA's
disaster programs, lowering energy burdens, helping tribal nations bolster climate resilience,
electrifying ports, confronting housing segregation and unequal housing opportunities, and
stepping up the environmental enforcement inspection.
So, we meet today on the one-year anniversary of the creation of the WHEJAC recognizing how
far we've come and understanding how far we still have to go. When we meet next year, we will
have made more progress on the ground thanks to the Justice40 program. We will have released
the first-ever environmental justice scorecard to hold ourselves accountable to our historic
8
-------
commitments. We will have that improved version of the climate and economic justice screening
tool, and we will have had more meetings with community leaders, the WHEJAC, activists, and
the public so that we are ensuring that the lived experience of communities is reflected in the
policy choices that we make.
So, turning now to what's happening today, on Monday, the president released his budget which
will help us achieve our goals by providing historic support for overburdened and underserved
communities. The budget represents President Biden's vision for the administration's strategic
and sustained investments needed to address the environmental injustice. Importantly, it will
help to advance the Justice40 initiative.
Just a few highlights, it creates new programs across more than five agencies to invest in
disadvantaged communities, including a new program to decrease costs for the Low-Income
Home Energy Assistance Program or the LIHEA recipients. It invests $1.45 billion across the
Environmental Protection Agency to bolster environmental justice efforts, including $100
million for a new community air quality monitoring program, $150 million for the Department
of Housing and Urban Development to prioritize resilience and energy efficiency activities in
affordable housing and housing-related projects for tribal communities, $40 million for a new
community capacity building initiative to support historically underserved communities around
cleanup sites, and $1.4 million for the Department of Justice to establish an Office of
Environmental Justice.
And just yesterday, the Department of Energy announced the inaugural communities that have
been selected as part of the community's Local Energy Action Program. This is a new initiative
to help overburdened communities benefit from the transition to clean energy. These
communities will receive support from the Department of Energy to create action plans, to
reduce air pollution, lower energy costs, and become more resilient.
She reiterated that they know they have a lot of work ahead of us and looking forward to what
we can do together over the course of this year. The WHEJAC plays a critical role in our policy
development, and she's looking forward to receiving your final recommendations on the
scorecard and for our work in the months ahead.
She closed by providing just three quick updates in response to the letter that was sent to her on
March 8th, and she'll follow up in writing to the WHEJAC, and it can be made public at that
time. The first is on staffing and resources. She's thrilled to announce two hires at CEQ who will
support our ongoing work to implement many of our environmental justice goals and initiatives.
Amanda Aguirre has joined them as a senior advisor to her on environmental justice. And
Jessica Ennis will be starting shortly as our director of public engagement working with a wide
range of stakeholders, including environmental justice stakeholders, to ensure all voices are
heard.
Amanda and Jessica both bring a wealth of knowledge to CEQ and share our deep commitment
to listen, learn, and work alongside communities in our policy development and our shared
desire to continue to build the strength of our environmental justice team at CEQ and across the
federal government. On that note, she's pleased that administrator Regan recently made an
exciting hire on his staff by bringing Robin Morris Collin on as his senior advisor on
9
-------
environmental justice, and she'll be joining the WHEJAC public meeting tomorrow.
My second update is on the timelines. Over the last year, they have asked, and they will continue
to ask, for your input on brand new initiatives that will fundamentally transform the federal
government. And it's critical for them that they're able to hear from you on the front end of these
developments, as we did with the Justice40 initiative and the climate and economic justice
screening tool. There is a desire on the part of WHEJAC to have a better sense of our timelines
for completing actions. They are committed to giving updates on their progress as they're
working on these initiatives and as the timelines evolve. And they will try to be as transparent as
they can about delays that are encountered on the way.
Finally, the third update is on the engagement with the White House Environmental Justice
Interagency Council. Like the WHEJAC, the interagency council was established by President
Biden in Executive Order 14008 — the WHEJAC as an external body and the interagency
council as an internal body. While several members of the interagency council have joined the
WHEJAC work group and public meetings, additional coordination between the councils would
be valuable. So, they are actively working to stand up a formal meeting between the two bodies
ahead of the next WHEJAC public meeting.
1.3 Domestic Policy Council Update
Chair Mallory introduced the next speaker, Dr. Kimberlyn Leary, a senior policy advisor at the
White House Domestic Policy Council. At the White House, Dr. Leary works with the racial and
economic justice team to implement President Biden's equity agenda.
1.3.1 Kimberlyn Leary, Senior Policy Advisor, Racial and Economic Justice Team -
Domestic Policy Council
Kimberlyn Leary thanked the WHEJAC for their leadership and efficacy. She appreciates that
the history of environmental justice in the United States is intertwined with that of the Civil
Rights Movement. The 1968 Memphis Sanitation Strike advocated for fair pay and better
working conditions for Memphis garbage workers. It was also the first time that African
Americans mobilized a national broad-based group to oppose environmental injustices.
President Biden, as you know, has signed at least ten executive orders that address equity in one
way or another in very significant ways. Within his first month in office, the president signed
Executive Order 14008 tackling the climate crisis at home and abroad which created the
foundation for the most ambitious environmental justice agenda ever undertaken by an
administration, including the creation of this body, the White House Environmental Justice
Advisory Council.
Dr. Leary talked about another of these foundational executive orders — 13985, Advancing
Racial Equity and Support for Underserved Communities Through the Federal Government. She
had the honor of being part of two teams in order to help implement this executive order. She
joined OMB as a senior equity fellow last summer, and now she's the senior policy advisor at the
Domestic Policy Council. She is also an IP A, meaning she's on loan to the federal government
from the Urban Institute where she's a senior vice president at Harvard University where she
10
-------
teaches.
So, within hours of taking office, President Biden charged the whole of the federal government
with putting racial justice and equity at the very center of our collective work. This EO, which
they colloquially refer to as the Equity EO 13985, affirms that it is the duty and the
responsibility of the federal government to serve the public effectively and equitably.
Now, the executive order required three main things. The first was, as part of a whole-of-
government approach, agencies were required to engage in equity assessments. That is to
evaluate whether the key agency programs under that agency's domain create or exacerbate
barriers to equal participation from underserved communities and to shine a spotlight on the
specific barriers, gaps, and instructions that burden key communities. Among them are
communities of color, LGBTQI+ people, people with disabilities, those who are in rural
communities, and those who are part of communities that are facing persistent poverty and
inequality.
She mentioned, as someone whose academic area of study is change management in
organizations, that what agencies were actually asked to do is rather challenging — to look for
the problems within your agency. It's difficult work to say that they've been working for years
and decades to try to achieve outcomes that they believe in, and this executive order has asked
agencies to identify where they miss the mark and where barriers to equity exist, at least to
evaluate whether they were present or not. So, agencies recognize that it's difficult work to
identify the challenges their agency is facing.
The second thing agencies were asked to do was to identify actions for addressing any barriers
that they did find. Then once they identified actions, they have to create an action plan for how
they would address those barriers to equity and include in that plan relevant metrics and
accountability systems to ensure that the agencies could, over time, deliver equitable outcomes
to communities.
The third dimension of the executive order that was critical is that it established the Equitable
Data Working Group, which was charged with looking across the whole of government to
identify what are some of the challenges in our federal data systems, especially where many of
those systems, for various reasons, do not allow the collection or analysis of data in
disaggregated ways. That equitable data group was charged with producing a report of its
findings. They've recently completed that work, and they will be sharing their findings as soon
as they're able to.
The equitable data working group is relevant to both the charge of evaluating barriers to equity
and equity assessments, and it's also critical to being able to deliver equitable outcomes to
communities. Without data to understand who is or isn't receiving services that they are entitled
to receive, it's not possible to do a full equity assessment. Likewise, to know whether or not
you've been successful in addressing the barriers to equity, one needs to have the kind of data
systems that enable you in a granular way to know which barriers to equity have been closed by
which actions and which interventions. So, these three dimensions of the executive order are
interdependent and interrelated in many, many ways.
11
-------
If we zoom out a bit and think about why this executive order and what are some of its
fundamental assumptions, they are that systematic forms of injustice are often anchored within
systems. And in those systems, there may be exclusionary regulations or legacy rules that are
simply baked into everyday administrative procedures and protocols. Policymaking always can
result in unintended consequences, but systemic injustices can also reflect intentional human
choices to use policies or regulations to discount or harm others.
Executive Order 13985 also recognizes that systemic inequities, including those across the
federal government, can flourish really in practices that appear to be neutral on the surface. So,
research has shown, for example, that programs that provide services for underserved
communities may be weighted by higher levels of administrative burden. Namely, they carry
with them complex, confusing, or repetitive requirements to apply or otherwise track whether or
not you're on the right pathway to being able to receive those benefits than services that are
more likely to receive universal use.
These administrative burdens particularly impact people that may have limited English
proficiency or who are experiencing poverty or who are first-generation Americans. Here's the
important point with this; often we don't see these barriers because they're so deeply embedded
in systems that they are nearly invisible. But by making these barriers more visible through
equity assessments, including engaging with stakeholder communities, and then by designing
mitigating actions, as called providing order, the federal government, because of its scale and
scope, is uniquely positioned to scale change.
So on one hand, there is a system where unintended or even intentional actions can be embedded
in everyday protocols. And then there is the capacity of the system, because of its size and scale,
to be a way of driving affirmative change. That's what's happened over this last year. Agencies
mobilized very swiftly to meet the executive order's mandate to root out inequalities and federal
policies and programs. They did so by creating agency equity teams, and those teams were
designed to include a chief data or evaluation officer. Guidance was given that they should
include front-line staff who deal directly with the public as well as senior leaders. Agencies were
also directed to engage with underserved communities and with advocates, and they did so by
running requests for information, listening sessions, and various challenge competitions among
other ways of connecting communities.
Then, they had to stand up emissions-specific assessment process to examine how the agency's
policies, programs, and services may perpetuate barriers for underserved communities. Now,
because this is a whole-of-government approach, agencies also have the opportunity to learn
from one another and share their best practices and reshape their organizational cultures to
realize the goal to become a core component of agency decision-making.
What they've recognized over this past year with this work is that success has required both
technical knowledge, policy acumen, and also the ability to recognize that a change-management
process was often required. Now, change management inevitably involves challenge. Agency
teams working on the EO inevitably discovered that they had different ideas about the direction
that their work should take, and no doubt that happened in WHEJAC as they think about the
initiatives that are put forward. It's a routine part of driving change.
12
-------
It's possible that the stakes may be higher in the context to focus on equity. For example, when
an analysis suggests that multiple options are possible, the choice that is presumed to be the right
one may well be different for different people depending on their lived experience. And so,
teams will still have to make trade-offs even when they have the very best of data if the best of
data says that there's more than one way to move forward.
Now, there's a wide body of organizational research that suggests that diverse teams consistently
yield innovative solutions. This is only the case when teams have internalized the skills to
navigate tensions that so often interrupt problem solving. So, to support the agency teams in
doing this work included a change management dimension, OMB with whom DPC partnered in
the implementation of the executive order, hosted weekly office hours creating a platform to
encourage peer-based cross-agency problem solving.
OMB also facilitated an equity learning community for federal officials, which has now
delivered over 20 executive education modules on topics ranging from leading for equity to
reducing administrative burden. To convey the change management that was undergirding the
implementation of this executive order, they, consistently across DPC and OMB, framed the
work as involving the metaphor of a sprint to meet the exacting deadlines of the EO, and also as
a marathon to accomplish long-term goals. They also describe the capacity building that was
required as building muscles for equity to be flexed as agencies implement their plans.
On January 20th, they reached a major milestone. After conducting the equity assessments over
the course of 2021, over 90 federal agencies submitted equity strategic action plans to the White
House to address the barriers they previously identified during their equity assessments.
Collectively among the CFO act agencies — the largest 24 agencies — that group of agencies has
identified over 300 actions that agencies will take to advance equity across their mission areas.
So, this executive order is the first time a president has directed all agencies to identify, address,
and begin to reckon with systemic inequalities that remain otherwise hardwired across federal
policies, programs, and services. A presidential directive like this reflects a transformational
opportunity to correct historical wrongs against underserved communities, redirect federal
programs and policies, and invest in improving the lives of all Americans. She shared a few
examples of how the administration's actions, including the Equity EO, are changing how the
executive grants and its agencies are conducting business.
The administration has prioritized equitable spending in the American Rescue Plan and other
pandemic relief efforts to ensure that federal help is getting to those who need it the most. A
couple of examples of that include nearly three million Americans have health insurance, and,
with subsidies provided by the American Rescue Plan, approximately 66 percent of black
uninsured adults now have access to a zero-premium plan and 76 percent can find a low
premium plan. Among Hispanic and Latino uninsured adults, 69 percent may now have access
to a zero-premium plan, and 80 percent may now be able to find a low premium plan. The
American Rescue Plan has also lowered or eliminated health insurance premiums for millions of
families who are now able to enroll in health insurance marketplaces.
The expansion of the child tax credit has kept 3.6 million children from poverty, and that
program cut the poverty rate among black children by 22 percent, Hispanic children by 28
13
-------
percent, and AAPI children by 23 percent.
The President has also recognized that advancing equity requires the federal government to
become a more diverse and inclusive employer. And so, an additional executive order on
diversity, equity, inclusion, and accessibility in the federal workforce establishes an ambitious
whole-of-government initiative to take a systematic approach to embedding DEIA in federal
hiring and employment practices. That EO recognizes the barriers that job seekers can face in
accessing federal employment and in being represented at the highest levels of government.
Now, these achievements and presidential commitments are the beginning, not the end, of our
work to deliver equity and racial justice. Indeed, the one-year anniversary of EO 13985 really
positions the federal government to drive towards equity for the years to come. What's been
crucial to their efforts is recognizing that rooting out systemic inequality isn't a one-year project;
it's a sustained commitment. And our ambition is to embed equitable policy making in ways
that will long outlast this administration. That's why it's been so important during the first year
in office to build the capacity within government for equity work and to create these muscles for
agencies to identify and respond where their policies and programs perpetuate unfair outcomes.
Secondly, having built up those muscles, in the second year, they're now able to flex them in
new ways. She mentioned two platforms where that flexing is currently occurring. Certainly, the
Justice40 initiative has a goal of delivering 40 percent of the overall benefits of relevant justice
investments to disadvantaged communities, and the screening tool that Chair Mallory mentioned
is so critical to informing equitable decision-making across the federal government. The newly
released budget provides historic support for underserved communities and advances the
Justice40 commitment and makes sure that clean energy will also reach disadvantaged
communities.
The second way in which equitable policy making — flexing those muscles — is occurring, is
through the implementation of the Bipartisan Infrastructure Law, which is a once-in-a-
generation investment in our infrastructure and economic competitiveness. And it's also an
unprecedented opportunity to embed equity in how those dollars are spent and to ensure federal
dollars address the harms of discriminatory development and divestment in communities of
color in the past.
Routinely aware of how high the stakes are for communities around the country as they
implement this new funding, so many families are still reeling today from the consequences of
the inevitable infrastructure of the past. So, for example, you think about the erosion of
intergenerational wealth for families of color, whose homes were taken by eminent domain to
make way for the federal highway system. You think about the burden of asthma and pollution
in low-income communities — in black and brown neighborhoods — that have had superfund
sites built in their backyards and the economic isolation that too many rural and tribal
communities face because of infrastructure divestment. So, they have a historic opportunity
through this spending to flex those equity muscles and try to right these wrongs. And if the
Bipartisan Infrastructure Law is implemented to its full potential, it is positioned to narrow the
racial and gender wealth gap, secure goods for communities that face persistently high
unemployment, address discrimination and structural barriers that have held women and people
of color back in the workplace, advance climate justice, build rural and tribal prosperity, and
14
-------
build a more resilient and equitable future for millions of people in every state and territory.
Now, to meet these goals, the White House has been intensively developing strategies for
equitable infrastructure implementation. She gave a few examples of what these include.
Equitable implementation includes encouraging and, where it's possible, requiring the grantees
that receive federal infrastructure funding to develop local planning processes; stakeholder
engagement to ensure that underserved communities have input and influence in planning
decisions that impact their communities and their neighborhoods; going back to the equitable
data working group, collecting performance data on equity and developing data tracking tools
and reporting requirements that help to monitor equitable impacts; and advancing equity through
discretionary grants. They have an enormous opportunity to apply requirements in federal grants
that can help affirmatively advance equity. And also, it's so clearly important to reduce
administrative burden and to produce and provide technical assistance to ensure underserved
communities can access relevant federal funding.
So, when you think about advancing equity and you think about this portfolio of executive
orders, they're also using this work across the whole of government, including to inform work
implementing the American Rescue Plan and the Bipartisan Infrastructure Law. It speaks to
what it really means to do a whole-of-government initiative. It builds on itself and enables
capacity building in one part of an agency to enhance what it can do in another part of an
agency, and it allows agencies to work together to collectively share their learning. As they
engage with communities and stakeholders, they can make sure that that information and that
sensibility and those ambitions are reflected in the work that we do across the whole of
government.
Co-Chair Moore thanked Dr. Leary for her comments. He gave the procedures for the member
comment section and opened the floor to short comments. He started with systemic racism is an
issue, and environmental and economic justice is the goal. The other is that from their
experiences one finger many times in government does not work with the other finger.
Communications from an interagency council standpoint and the other federal agencies are very,
very, very crucial to WHEJAC.
Dr. Robert Bullard stated that his question was regarding the approach and the theory of
change and the overarching frame with the executive orders that deal with environmental climate
justice and the EOs that deal with racial justice. It seems that three buckets were put in terms of
a public administration approach to barriers. One was first generation. The second was limited
English, and that's language barriers. And the third one was poverty. There is a fourth one that
is called systemic racism that would not necessarily be tied to the three but would also be
impacting another population that would not be first generation, limited English speaking, or
poor.
The other part was in terms of the analogy that was given — flexing muscle. And in order to flex
muscle, that means you have to have some building blocks and sustenance that can create
strength and muscle. My question is, where are the teeth that can either deny, enforce, or
somehow mandate — not encourage — mandate resources going to where it needs to go in terms
of Justice40 and the Bipartisan Infrastructure Act? Particularly with monies that go states,
statutorily that's the way it goes, and if you're going to encourage states to do the right thing,
15
-------
that's almost like saying, we want you to do the right thing. So, my thing is, where are the teeth?
And if there are no teeth, then you don't get the right kind of nutrition to build muscle.
The last thing is enforcement tools in terms of laws that are currently on the books. He did not
hear the use of civil rights overlay in terms of the U.S. Justice Department and the civil rights
enforcement offices that are within the various agencies in terms of Title VI of the Civil Rights
Act, enforcing non-discriminatory actions by those who receive federal funds. In other words,
the recipients of federal funds. To what extent will the federal government in the Biden
administration take a vigorous and more aggressive stance in enforcing Title VI at non-
discrimination?
Without some rigorous changing of the paradigm in terms of taking an aggressive stand and
putting upfront and not running away from racial justice and systemic racism for the fear that
you're going to get sued, they will not be transformative in any way. It'll just maintain the
institutional cultural memory muscle in those agencies that have done great harm to people of
color, whether it's USD A and black farmers or the U.S. or DOT that have mowed through black
and brown neighborhoods and destroyed our neighborhoods or FEMA that has not given the
disaster recovery dollars. There are memories in those organizations/institutions that if you don't
root it out, then you'll have the same thing happening; it'll just be on a lower level.
Dr. Beverly Wright added that there seems to be a really strange virus going through the
government, and that virus is connected to the word "race" where no one can say it, and it's very
disturbing. She thought that Dr. Leary's presentation was well-prepared, well-received, and clear
and would like to get a copy of it, especially on the research that was presented in the very
beginning because to some extent, it showed just the kind of complaint that African Americans
in particular have.
It talked a lot about who was most affected, and it wasn't African Americans mentioned in that
particular response, but race was used to evaluate programs as to whether or not they were
effective. So it was able to say how many black people, brown, Latinos, and so on. But if race is
not included, there's a whole class of African Americans who will be left out and who should be
included. It's almost as if, if you are African American and are successful, you are then punished
for being so.
Well, she can tell you from personal experience in most middle-class African Americans what
happens is tremendous, and they will not end up in those categories where their neighborhoods
are destroyed and where all the worst stuff is then put where they live. Although your income
may be higher, there are all kinds of things. If you are African and speak a second language, you
surely will be represented in a lot of these scales. But if you're African American and successful
— and I can bring you to a place like New Orleans where we have middle-class and upper-
middle-class black communities that are being destroyed based on policies that exist — we fall
through the cracks because we're not, quote, poor.
She stated that she is amazed and does understand all of this is about assigning money by race.
At some point, this needs to be challenged. In the end, the reason that we're having to do all of
this is because of race, but it can't be said aloud. It can only be used in evaluation after the fact
to show whether or not black people or Latinos or whatever have benefitted from it.
16
-------
So once again, the race of people in this country who are legally enslaved by this government
happens to be the group who cannot be reached in ways that others are because we can't say
race. Race is the number one factor for everything bad that happens to African Americans in this
country. As a researcher in sociology, she finds that it is just appalling that black people are
trying to find another way around to make certain that they're included. Even in the research that
was presented, it basically showed what she thought: here they go again; they're left out. Some
people say, if you're successful and black, you're punished for it even though you're catching
the same hell that poor people are catching. Going back to what she calls a "virus", if you say
race, oh boy. Everything that drives what's wrong with this country is because of race.
Dr. Leary thanked them for some tough questions and for raising some very, very critical
critiques. She mentioned a couple of corrections to Professor Bullard. When she was talking
about the first generation, limited English proficiency, and those who suffer from persistent
poverty, that was specifically research that was about administrative burdens. The executive
order, in its very title — and this is also to Dr. Wright — addresses racial equity. It's speaking
specifically to racial equity but also looking at equity across a range of other communities as
well. As part of their equity assessments, agencies were also asked to look at the resources of
their civil rights offices or other entities within agencies that were addressing civil rights so that
they were in a position to identify where those offices may need additional resources or where
those offices might need additional personnel, just the state of that office as part of their equity
assessments.
By taking a framework around assessment, this particular executive order was operationalized in
three to five main programs with one of the programs being that on procurement because
procurement is still critical to wealth-building and has such a capacity to narrow the wealth gap
because of the size and scale of the federal marketplace.
But by looking at procurement systems, looking at the assessment of civil rights capacity, and
then inviting agencies to identify their core programs and their high-impact programs and
services, the idea there was to build that muscle to give them enough teeth and education and
support so that they could, in fact, develop the muscles to begin to identify what was not what
they had expected in their agencies, and then, to begin to use some of those tools to design a path
forward to address them.
This executive order, which concluded with the submission of action plans, is not the end of its
work. This is really about a platform to create a capacity to ask tough questions like the ones that
were asked of agencies and for them to have the tools and capacities to begin to use the data at
hand, new data tools, new assessment tools, new design tools, and more involvement with
communities to begin to put forth solutioning.
They're all very mindful as we do this work of the particular histories that African American
communities have experienced in this country and others as well of course. That's not outside of
our work at all. It's very much something that is a part of it. As they think, though, about the
whole of government, they're also thinking about the whole of the country and looking to
identify where they can make a difference and that will result in equitable outcomes in core
communities that they know have been underserved by the federal government.
17
-------
Ruth Santiago stated that with respect to Chair Mallory, she mentioned the interim guidance for
the Justice40 initiative. But as the name indicates, it's interim, and they're working on
recommendations to that and have mentioned in a few meetings that there are some glaring
problems with the interim guidance, especially concerning the constant references to clean
energy as opposed to renewable and not defining clean energy. So that could go against one of
the recommendations that we made in May about promoting renewable energy projects to tackle
precisely the climate crisis and do no further harm to environmental justice communities. They
know that that reference to the interim guidance to just clean energy could mean lots of things to
different people, and in some cases, they're seeing that it's a reference to, for example, methane
gas infrastructure. So the first is, how are they going to move along on this interim guidance to
be able to hopefully adopt the recommendations that the WHEJAC made in May?
Here in Puerto Rico, that's especially problematic and leads into the second part of her question.
This is similar to what Dr. Bullard and Dr. Wright have mentioned. What do we do with state
and territorial governments, like the government of Puerto Rico, that want to use these funds —
the Justice40 Initiative funds and disaster recovery funds — to build back business as usual
infrastructure like not only fossil plants but also centralized transmission and distribution
systems that enable those centralized plants and not do distributed renewables and empower
local communities and provide life-saving resilience?
With the experience of Hurricane Maria, people who survived were people who had localized
energy and got energy back quicker. And that's not available to low- and middle-income people
in Puerto Rico. How do we get FEMA to implement environmental justice in Puerto Rico with
this historic amount of disaster recovery funds?
Tom Cormons stated that he appreciates so much of Dr. Leary's service in the administration
because her expertise as an expert on organizational change and as a psychologist really gets to
an issue that the Justice40 Workgroup of WHEJAC and the WHEJAC have been trying to
address. We understand that Justice40 is only going to be as good as its implementation, the
screening tool's only going to be as good as its application, and that transformation of the way
that agencies operate and do business is going to be necessary for the kind of transformative
justice that we want to see affected by the program and by the screening tool.
They would all benefit from her input and thought partnership on the answer to, at a mental
level, what are the best ways to ensure that the incentives — both carrots and sticks — are there
for actors within agencies, individual agency teams, even entire agencies to truly prioritize and
devote resources to transformative community engagement, to ensure that the way funds are
deployed don't merely perpetuate or recreate existing inequities with more dollars behind them
but work to reverse those? They are putting together another set of Justice40 recommendations
as a WHEJAC as has already been mentioned. They're going to be discussing those as a full
group tomorrow. One key complement of those is around incentive structures.
The final thing is ensuring that the right set of structures is there for federal agencies and actors
within them, but then also those federal agencies impose the right incentive structures on other
entities deploying these funds, state agencies, localities, et cetera, to keep that train on the tracks
as we are heading towards transformative justice.
18
-------
Maria Lopez-Nunez stated that she heard some things that were the beginnings of things that
were discussed a lot in the workgroup, especially when it comes to Justice40 implementation,
such as the requirement of asking agencies to reflect. It's something they talk about a lot. We
need a humbler government. It's like not a secret that a lot of people have been disillusioned by
the government since the beginning of this country because of racism and unequal treatment.
And so this is a profound exercise for agencies to undergo of actually taking stock, taking
account of what have they done wrong, where do they harm, what are programs they continue to
fund that harm communities, particularly black communities and indigenous communities.
They need to get those numbers of where the money is going to, like quantities of community
members who are receiving money or not. She would like to see the tracking happen upfront of
agencies before they release the money. One thing she doesn't want to see is a financial autopsy
of Justice40 ten years from now that said it failed.
Community members need to have real-time numbers where they see Justice40 being
implemented and who's it going to? They need to count black folks, brown folks, and white
folks, then the communities will do what they've always had to do which is hold the government
accountable and petition to the government. That's incremental change. This is not a radical
thought that we're asking for more transparency from agencies and not waiting these long
timelines. They're all feeling political pressure of final drafts being unclear.
All of us want to do what's best for our communities, but it has been slow just being transparent
about having that progress bar. She echoed Ms. Santiago's points about the do no harm that they
discuss in our first set of recommendations because she is really worried about the perversion of
Justice40 to fund green hydrogen, to fund clean energy that's really being twisted, and it's things
that harm us. Then we're being presented with diversity plans that say, well, you can get a job
doing something that hurts your community.
Getting a job in an industry that continues to hurt black and brown folks is not justice, and that's
not what they mean when they say equity. They don't mean, okay, now I get to participate in my
own oppression. She's worried about the lack of guard rails for Justice40. So, she wants to know
about those guard rails and where is the direct accountability to community members. Certain
things are a no goal, and they should not even be talked about or thought about as Justice40.
They should actually count against agencies and against that whole attempt to bring equity. If
they're engaging in things that harm communities, that should never count towards the ultimate
goal of equity.
Co-Chair Moore added that the federal government, in some cases for years, has retracted data.
What we need are the barriers removed to that data and that research that's being done.
Dr. Leary responded that this work really is unprecedented in many ways, and she reflects on
this every day. For the executive order, to have 90 agencies contemporaneously doing equity
assessments in their agencies looking for barriers to equity and then to be working at the same
time to identify actions to mitigate the barriers that they identified is really what we mean by
something that's whole of government.
19
-------
In actual practice that is quite challenging work, but it is the work that people are undertaking
with a great deal of skill, expertise, and passion. She hears the passion in their voices too as they
talk about Justice40, and they wouldn't be part of this WHEJAC without that. They've raised
some really critical questions. In change, there is something to be said about the bully pulpit and
the vision that inspires people. It's critical, but it's not enough. A vision has to be complemented
with expertise and with tools.
Data is a crucial tool. Without data, again, you can't do excellent assessments, and you can't
assess how far along you are. But the data systems aren't yet where they need them to be. So,
they are trying to use the best data that we have available, to use the best data science out there
and a few techniques to be able to make our existing data better, and then to unlock the potential
of data going forward. The bully pulpit is really important to engaging communities. But it is
true that states have certain flexibilities and certain autonomies and trying to shape those is
important.
But where there are tools that allow discretionary grants to be integrated with equitable
outcomes and equity impacts, that's another opportunity that can be used simultaneously. They
also know and have been very humble about trying to learn from colleagues at the state and local
levels who have been doing equity assessments and equity action planning before the federal
government picked up on this effort. They are indebted to those researchers, those advocates,
and those communities for the place that they've gotten to right now.
About the work of change management, what justice means to different communities is not
always the same. Making room for the range of perspectives — the historical perspective as well
— of being in a place and on a platform where people can compare and contrast ideas and where
they can do so with a particular goal in mind, which is delivering equitable outcomes to
communities, that's what they have stressed throughout the work with the equity EO.
The thing about at-scale work is that any one initiative may not deliver the full outcome, but the
collective impact of multiple initiatives, especially when they're contemporaneous, can do so. A
dimension of flexing one's equity muscles is an acute awareness that policies can have on
intended consequences. But we can all get a little bit better about trying to forecast what those
might be and try to catch our remediation, if you will, earlier in the process than later.
That's what agencies have been engaged with doing with 13985 through an important reflective
process of asking questions, coming up with answers, and asking questions again just as you are
in this body.
Co-Chair Moore stated that there were several comments made in the chat and asked DFO
Martin that Dr. Leary receive those. DFO Martin agreed.
Viola Waghiyi stressed that the agencies really need to listen to what the people have to say.
People are suffering from economic violence; cancer; and high rates of other social ills, like
alcoholism, drug abuse, and homelessness. These are just on top of everything else that nobody
talks about that is very real in our communities.
Co-Chair Moore thanked Dr. Leary and made a request and a closing comment. One, this isn't
20
-------
the first time or the last time that they will be dialoguing, particularly with the Domestic Policy
Council. So, the request is that they continue this dialogue and listen to the sense of urgency that
they'll hear during the public comment period. We're dealing with life and death situations.
That's not rhetoric; that's reality. Some things can't wait another 500 years or whatever to come
to solutions.
He turned the meeting over to Vice-Chair Tilousi to introduce the next panel.
1.4 Environmental Justice and the President's Bipartisan Infrastructure Law
Vice-Chair Tilousi introduced the next panel members on Environmental Justice and the
President's Bipartisan Infrastructure Law.
1.4.1 Candace Vahlsing, Associate Director for Office of Climate, Energy, Environment,
and Science - Office of Budget and Management; Radhika Fox, Assistant Administrator,
Office of Water - U.S. Environmental Protection Agency; Stephen Tryon, Director, Office
of Environmental Policy and Compliance - U.S. Department of Interior; Christopher Coes,
Principal Deputy Assistant Secretary for Transportation Policy - U.S. Department of
Transportation
Candance Vahlsing stated that the president is committed to implementing Justice40 through
every lever, and that's exactly what the Bipartisan Infrastructure Law does. The Bipartisan
Infrastructure Law helps to deliver on the president's commitment in working with the agencies
to implement bill investments, programs, projects, and activities in accordance with the
Justice40 initiative.
They will soon be releasing additional guidance on the Bipartisan Infrastructure Law, but we're
not waiting. Agencies are already taking steps to include Justice40 initiative considerations into
their funding opportunity announcements in line with the law. So, they have a great group of
people today who will provide very robust examples of some of the efforts that are already
underway. She summarized some of the other investments in addition to the agencies that will
present today.
So, just yesterday, the army corps announced nearly $3 billion in investments in the water
infrastructure across the country for more than 300 projects. A number of those projects were in
disadvantaged communities that were identified in the economic environmental justice screening
tool. A few of them include southwest coastal Louisiana hurricane protection; a project in
Pajero, California in the town of Watsonville; a project in Espanola Valley in New Mexico; and
many more.
In addition, FEMA just last week announced around $60 million of swift grants, which as part of
the Bipartisan Infrastructure Law investments allow contributing 90 percent of the federal cost-
share for properties that are within the CDC's Social Vulnerability Index. At USD A, NRCS has
made recent announcements on 108 infrastructure projects, and many of those are located in
disadvantaged communities. Radhika Fox will talk about the robust EPA water guidance that
was put out.
21
-------
And then there are also recent investments at DOE that have taken into account Justice40
considerations in implementing a presence commitment. So, for example, DOE issued a notice
of intent under the building better grid, and that includes and requires stakeholder consultation
with tribes, environmental justice communities, and other stakeholders. And we're also looking
at existing sources of funding across the government to help provide technical assistance so that
communities can access bill investments to fully leverage the Justice40 commitment and its
intersection with bill investment funding.
Radhika Fox stated that she will talk about how they're working to advance equity and
environmental justice in the context of the $50 billion that the Environmental Protection Agency
is stewarding for investments in drinking water, wastewater, and storm water infrastructure.
The $50 billion that the Environmental Protection Agency's responsible for investing as part of
the Bipartisan Infrastructure Law falls into a few key buckets of money. About 85 percent of the
funds are flowing through the state revolving loan fund dollars, meaning that EPA sends that
money to states by a formula for a broad range of drinking water, wastewater, and stormwater
projects.
There's about $5 billion that will be going out for PFOS and emerging contaminants in
communities that will also be going out by formula to states, but EPA has a bit more of an
ability to shape the criteria for those projects, and that will be coming out later in the summer.
And then finally, there's about $2 billion for our geographic programs and our national estuary
programs. So, these are water bodies like the Everglades, the Puget Sound, and the Chesapeake
Bay, and those investments are focused on climate resilience and restoring these very historic
and important water bodies.
She focused primarily on the $43 billion, or 85 percent of the funding that's going through the
SRF. A couple of weeks ago she issued an implementation memo to all of the state SRF
managers providing both directions on their obligations and how to utilize these funds as well as
expectations around how to achieve a wide range of goals with a huge focus on equity and
environmental justice. She will touch on some of that, how they did that in the context of that
implementation memo, and then what's coming off of that from the perspective of the technical
assistance and other mechanisms to work with states to hold them accountable for investing in
communities that haven't before.
So, in the implementation memo, they basically talk about how the number one priority for these
funds is to increase investment in disadvantaged communities. She pointed to several things that
they want to make sure that the WHEJAC knows about because these are things they really want
to be advocating for. So, one of the things that Congress did with the water money is that they
require that about 49 percent of the money must go out as grants and principal forgiveness loans
to communities, and they have to be invested in disadvantaged communities.
So, they worked with Congress on that, and then they have sent very clear direction to states that
as they make their decisions, those resources have to be invested in those communities. Now,
this is really, really important in the context of water because this is certainly the case in New
York; we know lower-income communities and communities of color often can't compete for
the SRF loan funds because they don't have the right base to do that. And so, we really feel that
22
-------
states must make sure that 49 percent gets to these communities.
One of the dynamics that are in play around the equitable implementation of these dollars is that
EPA does not have the authority to set the definition of disadvantaged communities. Congress
gives that authority to states to set that definition based on their needs. And what we have seen is
that some states have great definitions that are reaching the communities who need it the most,
and other states have deficient definitions around disadvantaged communities. So, in our
implementation directive to the state, they've been very, very clear that you need to look at your
definition of disadvantaged communities against the purposes of the Safe Drinking Water Act
and the Clean Water Act. They've sent a very strong signal, which they've never done before,
that they're going to be looking at the definition that states are using and working with them to
get to better definitions. So, this is a huge opportunity for advocacy at the state level.
The other thing that they did, which they had never done before in the context of SRF programs
is that they gave in the guidance preferred factors that states need to consider and should utilize
in their definition of disadvantaged communities, and they also talked about those factors that
are not good. So, for example, some of the states that have deficient definitions only use
population as the definition of disadvantaged, which obviously is not going to always get to the
communities that need it the most.
They also, in that implementation memo, highlighted and foreshadowed to the states how we're
going to be reviewing their intended use plans against that definition. They encouraged them to
really look at their priority ranking for projects to make sure it's consistent with this mandate, et
cetera. So, there's a lot in that implementation directive to the states that, one, is both setting
expectations on the front and for this bill investment; two, letting them know how EPA's going
to continue to engage with them; and then, three, for those who are doing local advocacy in
organizing, there are a lot of hooks and handles that are in this implementation memo. So that's
a big thing that we have been focused on.
There are a lot of other things in that implementation memo around the $15 billion for lead
service line replacement. Historic investment, not only because of the sheer number — they've
never had $15 billion, and they really have to thank President Biden for his vision and leadership
on this — but also this is the first time ever that the full lead service line has to be replaced for
this project to happen.
So, one of the things that they know is that there's a huge equity issue when it comes to lead
service line replacement because what often happens is that the local water utility will replace
the public side of the line, and the private side only gets replaced, frankly, where there's has a
higher income homeowner who could afford to replace that line. They know that lower-income
communities simply can't do that. You can look all around the country from Providence, Rhode
Island to Flint, Michigan to know that that is the case.
And so, what is different about this? That $15 billion can only be utilized to fully replace the
public and the private sector line. So, it's taking away that cost barrier for families. And so, I
will just also implore that through that we really have a huge education effort that they need to
undertake about this opportunity for lower-income homeowners and communities around the
country.
23
-------
There's also a lot of discussion in the SRF implementation memo around support strongly for
standards and encouragement of things like the use of project labor agreements, community
benefit agreements because they know that these are going to be some of the largest investments
in many communities around the country for water that they've ever seen.
So those are some of the highlights from the memo and happy to dig in on any of them as they
get into the discussion. The other key part of the strategy is they definitely want to send a strong
direction around meeting the goals of the Justice40 climate resilience as these resources are
invested, but they also know that that enough isn't going to get us there. We actually have to
invest in building the capacity and the agency of low-income communities and communities of
color to be able to access and compete for these funds.
So, what the EPA's also developing is a technical assistance approach that will, hopefully, go
alongside these infrastructure investments. This year they're going to be putting $50 million into
the technical assistance effort, and they hope to increase that in future years. And so, the idea is
that they will support strike teams — teams of folks in different communities and regions around
the country who can engage with disadvantaged communities, help them translate their drinking
water and wastewater-related challenge into a specific project, provide them with the
engineering support, the planning and assessment support so that they really can get their
projects, get their communities on these IUPs — that means intended use plans — for the SRF. So
that's going to be rolling out this summer.
She added that they hope to reach hundreds of communities over time. They welcome the
opportunity to engage with WHEJAC on this effort. She spotlighted one of the projects they've
built out with the WHEJAC Vice-Chair Flowers. It's a specific project focused on how they
close the wastewater access gap in communities like Lowndes County and other rural areas. The
hope is that this year help ten communities that don't have centralized wastewater infrastructure.
They'll do the wastewater assessments, develop community solutions plans, and then work
collaboratively with frontline leaders in these communities to really help these communities
access funding that will be coming through the Environmental Protection Agency but also
USD A.
She closed with this is a historic moment with these investments. But they're going through the
same programs that they've had in place for a long time that has worked for some communities
but haven't worked for a whole other host of communities. And so, the challenge right now is
how do they redesign? How would you program delivery so that we're getting to different
outcomes? And so that's what the next five years are really going to focus on at EPA.
Stephen Tryon stated that for the Department of the Interior, the Bipartisan Infrastructure Law
has 40 sections where DOI is the lead agency covering nearly $31 billion in investments and
various kinds of infrastructure ranging from water projects to wildland fire to legacy pollution,
which is what he's going to dive a little bit deeper on today.
Legacy pollution shows up in Section 40601, which addresses orphaned oil and gas wells on
federal, state, private, and tribal land. And there are Sections 40701 through 40704 that address
abandoned mines. These are both abandoned coal mines and non-coal mines. And finally,
24
-------
Section 40804 is a section on restoration, but it does include some language about restoration
being viable on previously mined sites. So, taking collectively, they look at these as the Energy
Community Revitalization Program, also spoken of as legacy pollution, and what we will do
about that.
He highlighted some of the differences in statute between how the feds are treated and how the
states are treated because it makes a little bit of a balancing act for their organization on how
heavy they can go on environmental justice between the two. He will conclude with where they
are currently at in utilizing screening tools, and, in the event that they're not utilizing screening
tools, how are they being active on environmental justice and provisions of the bill? All of the
section leaders for the Department of Interior are very conscious of the fact that they have to
build environmental justice into project selection.
So, looking at one of the provisions of the law, this is Section 40601, and it's on orphaned oil
and gas wells. These are wells that have been left behind, sometimes for more than 100 years,
where there's no operator of record. They are not in producing status, and there's no opportunity
to go for previously responsible parties. The funding is broken down as follows: there is a
federal program totaling $250 million. That very much gave consideration to environmental
justice in the ranking of projects at the bureau level before it came to the department, and, if
there's time to talk about it, there's a scoring mechanism to allow that to be considered.
The far and away largest part of this provision is state grants, and they come in three forms. So,
this is 91 percent of the funding out of $4.7 billion. Then there's a tribal program, which they're
standing up right now, covering $150 million of work. He guaranteed that there's more than
$150 million in need in Indian country. And so, one of the things that they're looking at there —
and this would be basically JusticelOO work — is making sure that every single tribe that has
ever had oil and gas activities on their properties has a property reckoning and a proper
inventory and not just the well-resourced tribes that are ready to roll with well plugging right
now. There are provisions in here for our partnerships with the Department of Energy and also
the Interstate Oil and Gas Compact Commission.
States may use funds for plugging wells, inventory, remediation, restoration, public information,
tracking methene, tracking water contamination, identifying disproportionate impacts,
administrative costs up to ten percent, and ranking wells based on public health and safety,
environmental harm, and other land-use priorities. The only one of those bullets that are actually
mandated in the law is the last one, that ranking wells should be based on some combination of
public health and safety, environmental harm, and other land-use priorities.
He contrasted with the other statute that the law "requires the federal program shall identify and
address any disproportionate burden of adverse human health or environmental effects of
orphaned wells on communities of color, low-income communities, and tribal and indigenous
communities." So, notice the language in the statute is not paralleling the language in Executive
Order 14008, which goes to the disadvantaged and begat the screening tool that was going to
identify disadvantaged communities. The language in this statute sounds a little bit more like EO
12898, emphasizing minority and low income.
And then again, they have initial grants that are getting ready to go out in the next few months,
25
-------
formula grants that were coming right behind those, and then performance grants where they
have a little more latitude in what they can require of the states based on their regulatory
structure.
In the next couple of months, they are going to go through an application opening with an
application deadline of 30 days for the Department of the Interior to act and then an obligation
deadline whereas they read the statute, "the states will have 90 days from when they draw down
from the U.S. Treasury System that makes the grant available to obligate the entire amount",
meaning most of it's going to go on contracts that will then be expended the one year following
that. So, this is the first of three waves what's called initial state grants, and that's going to keep
us very busy this summer.
The initial grant guidance has fewer requirements and previews future application requirements,
but it has an awful lot of encouragement in it that suggests that states really need to start paying
attention to tracking methane and valuing the priority of work on communities of color, low-
income communities, and tribal and indigenous communities. The future grant guidance gives a
little more oomph to make these requirements of the process.
The deadline of May 13th for the up to $25 million grants. There is no deadline for some
capacity-building grants of up to $5 million that are also called initial grants. There are a series
of standard forms and OMB forms that will be required, and then they have a whole bunch of
information in the detailed budget proposals and justifications. Applications will be posted on
our website. It's more than an innovation; it's a requirement — that we want states to be aware
that they want your application to be in ship shape enough that you don't mind sharing it with
the public. They're going to put it on our website. Our guidance provides definitions of some
key terms, including communities of color, low-income communities, and tribal and indigenous
communities. It lays out eligibility and also requirements.
Then, in these recommended elements, it asks these questions. What is your prioritization
process? How have you identified and addressed disproportionate burdens? What is your
methane measurement methodology? What is your water contamination methodology? Site
remediation? Have you met with local officials and the public in the development of your
priorities? Are you providing for training programs — for instance, to move people out of areas
where they're unemployed or underemployed — into these higher-paying jobs? Do you have
third-party partnerships, and how did you coordinate with tribes and feds?
The federal government is getting ready to publish some methane measurement methodologies
that would be shared with states. States may have some of their own, and then data standards are
going to be a huge deal with this. So, a risk-based database management system was developed
by the Groundwater Protection Council and is used by most oil and gas producing states that
each have their own modules which we're expecting will be where performance information is
captured and then ported over to us at the end of the period of performance.
They have invited comments to this email address, orphanwells@ios.doi.gov. It actually closes
at midnight tonight, and they've been getting plenty of comments along the way.
He suggested to the group that there is some tension between "shall" and "must", where the
26
-------
federal government must do these things and the states may, which I think will probably be
ironed out over a period of years, not months or days. And then, they have spent a lot of time
looking at screening tools and how best to apply them. The first tranche of funding for federal
oil and gas wells is likely to go out in the next month or two. And the way environmental justice
is considered in developing those proposals was through a ranking process used at our bureau
level which then rolls up to the headquarters level.
He is not convinced that the proponents of those projects actually used a screening tool in
developing them. They use professional judgment about the proximity of the well site to the
environmental justice community and to whether you get a benefit of one, three, or five on your
scoring criteria. In the future, they will be using screening tools. They are considering whether to
recommend those CGIST and EJSCREEN because, as I mentioned to you, the language of this
statue, communities of color, low-income communities, and tribal and indigenous sounds a little
more like 12898, which is going to be more EJ screen.
But in either event, it's fairly nuanced. He gave an example. Imagine that there was an
abandoned non-coal mine. Imagine that it's one mile from a community that would rank as
disadvantaged using CGIST or that would rank as whatever the companion word is under
EJSCREEN. That one mile away abandoned mine might not be giving off any gas, might only
have a few holes in the ground that could be a danger to kids playing around it, but might have
no circle of violations involving the water table, surface, or groundwater.
He could find, maybe, another mine that was 20 miles away from that same community, but it
was uphill, it was at the headwaters of a water source, and it was leaching arsenic into the water
source that affected the community 20 miles away. One of the challenges that we have in
training people on how to use screening tools is that both of those might be examples of a
project that was near enough to that community to say that it was an EJ affecting project. One of
them was one mile away, and one of them was 20 miles away. So that's the kind of nuance that
is new to our staff at the field level that his office is going to help lead to have a better
application of screening tools when we do this again in 2023.
Christopher Coes stated that it is very important for us to recognize the role that infrastructure
investments, particularly in the past, have often failed to meet the standard that this group holds.
Too often, it has created greater inequities and, in many cases, has even made them worse.
Because of the physical infrastructure endured for decades in families and communities, they
recognize that as an administration and as a department, they have made a commitment to doing
the right thing for our shared future by addressing these inequities, building a better and more
equitable transportation system. And they believe they can do that as part of the Bipartisan
Infrastructure Law.
But before the Bipartisan Infrastructure Law, they started really laying the groundwork. First,
they convened a department-wide equity task force which included over 160 career staff in 30
senior agencies who have been literally working in earnest. Throughout this work, U.S. DOT has
assessed whether and to what extent many of our programs and policies continue to perpetrate
systematic barriers to opportunities and benefits for people of color and underserved
communities. These assessments are right now helping us better equip our staff and also working
with our grant recipients to better develop better policies and programs to deliver the resources
27
-------
more equitably.
Also, on Monday, they prioritized equity as being a department-wide strategic goal for the first
time in their strategic plan that was released this week. The various stages they are pursuing are
to embed equity and environmental justice in the very fabric of this department, including
expanding access for underserved communities and empowering communities in our
transportation planning processes.
But they also recognize that they can't do this alone, and as part of our recent FY23 budget, they
recognize that they need to increase the level of capacity and what they are calling for over $200
million both as part of our thriving communities and civil rights technical assistance programs to
help support local organizations and local communities to meet their civil rights and
environmental justice goals.
As part of the Bipartisan Infrastructure Law, they are immensely excited about the opportunity
that we have to take this Bipartisan Infrastructure Law and create the opportunity to deliver true
to our equity and environmental justice commitments. The Bipartisan Infrastructure Law, based
on the reasons that they'll be receiving, will spur the creation of over 500,000 electric vehicle
chargers by 2030. They know with these investments that they will be able to support a number
of reconnecting community projects by removing existing interstates, redesigning rural main
streets, and repurposing former rail lines that have divided and caused harm. They know,
through these resources, that they will try to increase the number of communities that have
strategies to reduce traffic fatalities as well as interventions that reduce death or serious injuries.
They, with these resources, can replace over 10,000 fossil fuel-powered transit vehicles to make
the neighborhoods that they serve have cleaner air. They recognize that providing greater transit
access to opportunity is key, and that they'd be able to improve their transit funding which is the
largest investment in the history of transit funding. But they recognize that, in order to take these
investments that they have gotten from the American people, they must do this in a way that
drives better outcomes.
And to do that, they believe they can not only address the backlogs of roads and bridges and
busses, but this has to be done in a partnership. And they believe that, as a federal government,
there are three areas they think can play a huge role in driving these outcomes in partnership
with our state and local partners: first, by leveraging our civil rights and equity and
environmental justice authorities; two, enhancing and promoting our Justice40 initiative; and of
course, last but not least, creating better planning and capacity processes to support community-
based organizations in underserved communities to actually take greater ownership of their
future.
He started with civil rights and their enforcement. Civil rights, as a department, has not
necessarily over the last years received the resources that are needed to assure that they had
widespread compliance. They are actively working to strengthen our current civil rights office
by making a historic investment in hiring, as well as providing additional technical assistance to
grant recipients.
Last June, they also put in place a new Title VI order that requires a Title VI assessment from
28
-------
each federal grant recipient so that they have to be more proactive than reactive in terms of other
Title VI and civil rights compliance. This is a huge opportunity for state and local advocacy and
organizing efforts to ensure our federal investments are aligned to community needs and that
they can, working in partnership with community organizations and local governments, identify
the locations and projects that need special attention.
They are in active discussions with philanthropy to figure out how they can accelerate greater
capacity building to support many of your local efforts. As part of that, Justice40 is our second
approach. They know from history that our federal funding has not often been accessible to
underserved communities. The Justice40 initiative is a whole-of-government effort to ensure that
all federal agencies, including the Department of Transportation, work with state and local
governments to make good on the president's promise to deliver that at least 40 percent of the
overall benefits from our investments and climate and clean energy go to disadvantaged
communities.
They're making Justice40 central to our bipartisan infrastructure law implementation to ensure
this once-in-a-generation investment and good-paying jobs and green transportation are going to
underserved communities. As part of this, they're not just tracking where the funding is going;
they're also tracking where the benefits were going. They will be releasing and updating their
current mapping to track that. As a department, they have identified over 40 programs
representing $206 billion in U.S. DOT funding as Justice40 cover programs.
These programs will receive a prioritized program at a programmatic level of stakeholder
engagement, direct technical assistance to communities who are looking to apply, and support on
the backend for grant administration. They are incorporating Justice40 now in many of the
programs that have already been released. For example, they rolled out earlier this year, our $5
billion national EV infrastructure program for states to begin to build out our nationwide EV
charging network.
As part of the Justice40 initiative, they issued guidance to states on explicitly how to address
their priorities around equity and Justice40, particularly around stakeholder engagement,
workforce development, and the benefit of the EV funding formula. This included working with
their sister agency — the Department of Energy — on creating a new disadvantaged community's
map to advise states on where to prioritize those activities. They will, over the next several
months, be evaluating state plans based on their level of stakeholder engagement, workforce,
and economic development, and they'll be also working with states to ensure that those plans
truly ensure equitable distribution of benefits from those investments. In addition, they will be
implementing our $2.5 billion community discretionary grant program to support local EV
efforts, and they will continue to establish guidelines to support that as well. But they are not just
stopping with our EV charging investments. They're looking at our low and no fuss facility
program. They're looking at how they can reduce air pollution around ports as part of their new
port discretionary grant program to do the same.
But also, in addition to some of the traditional programs, there are a few key environmental
justice programs that were included in the Bipartisan Infrastructure Law that they will need help
to ensure that they get it right. For example, they will be announcing a new Safe Streets for All
discretionary grant program. This program is in recognition that many people are dying from
29
-------
railways and disproportionately are coming from communities that are black, indigenous, people
of color who are generally suffering the highest rates of death compared to their white
counterparts. A death is enough. They need help to ensure that these investments in how they
design the grant program are done in such a way that they are able to address these disparities.
Again, this is a $6 billion first of its kind that's supporting planning efforts specifically for local
and tribal governments only.
The second program is something that many have been working on for a long time. From the
inception of the interstate, millions of households, mostly in low-income and minority
communities, were forced out due to the construction of the railroad or highway system. Their
new Reconnecting Communities Program will focus specifically on legacy highway and rail
construction through these communities and think about equitable ways they can not only
remove or repurpose these infrastructure barriers by actually creating new thriving communities.
They are in active discussions with philanthropy and other federal agencies to provide technical
assistance directly to community-based organizations and local governments so they can ensure
that they can get this right.
The last program is our healthy streets program. In recent studies, U.S. cities and neighborhoods
that were redlined in the 1930s have higher surface temperature profiles in comparison to some
of their suburban communities. This new $500 million program will provide grants directly to
mitigate urban heat islands, improve air quality, and reduce the stormwater runoff that is seen in
many of these communities. Now, they recognize that using our civil rights lever, maximizing
the work around Justice40, and some of the key environmental justice programs that were a part
of the Bipartisan Infrastructure Law is just a step in the right direction. But they recognize that
they also have to support better planning and capacity building to grant recipients.
What is going to be essential to achieving their overall goal around environmental justice is to
ensure that underserved communities have the ability to gain and move their agenda forward.
And one of the ways we're doing that will be, one, as part of our FY22, we will be rolling out
about $20 million to community-based organizations to provide capacity building and to support
disadvantaged communities who are interested in applying to our Bipartisan Infrastructure Law
grant programs to achieve equitable and climate-friendly infrastructure projects.
In addition, they are working with the Department of Housing and Urban Development on
strategies to ensure that their investments and working with their grant recipients do not lead to
displacement or relocation. Third, we are working with a number of state and local partners on
how to improve their transportation and planning processes so that they can ensure future
investments that are coming down the pipeline are creating greater affordable housing options
and greater access to jobs.
Again, this is just the beginning of many of the efforts that they've started last year, but they
know they can't do this alone. They look forward to continuing the partnership that they've had
thus far.
Vice-Chair Tilousi opened the floor for questions and comments from Council members.
Angelo Logan stated that he's interested in hearing a bit more about the future work that DOT is
30
-------
planning to get into in terms of setting up guardrails and protections to help to protect
communities that will have negative impacts from the infrastructure projects like road widening,
freeway widening, dredging of ports, increased capacity of freight facilities that is outsized by
the funds that will be going to cleaning up the freight sector and other heavy-duty transportation.
What lots of communities that are impacted by freight are looking for is helping to make sure
that we don't take one step forward and two steps backward. So, they know that there's going to
be an increase in freight traffic, heavy-duty trucks, locomotives, trains, and ships, and it's going
to be on the increase. The amount of money that's going to reduce the amount of pollution
through electrification or otherwise is a drop in the bucket. So how do they get to a point where
they're not taking one step forward and two or three steps backward? How might they ensure
that they don't increase the negative impacts by widening roads, expanding ports, and
perpetuating the injustices that come from that transportation sector?
He asked if they have thought about that, and then how might they participate in developing or
co-creating those protections to ensure that they're making real advancements in environmental
justice for these communities?
Mr. Coes replied that where they see in terms of the guard rails is really around the work that
their civil rights team really kicked off at the end of last year as their update of our Title VI and
civil rights. That really is a great tool and process for everyone from those who have dealt with
Title VI issues before. Generally, those have come after the project has been decided or been
designed.
One of the things that they're trying to do now is actually instead of being on the reactive side,
they want to be proactive. Again, they recognize that many of our grantees need greater capacity
and greater handholding. But this is a wonderful opportunity for advocates to begin to engage
those grant recipients to ensure that three things are happening.
Number one, there is a robust public engagement that's actually happening. Each grant recipient,
as part of our Title VI, must have an updated public engagement participation strategy that's
been signed off by the Department of Transportation. Two, as part of Title VI, there is a degree
of discussion around disparate impact. What they are looking for is working with local
governments, grant recipients, and philanthropy so they can get that information before the
actual investment comes. And then, third, there is then the traditional remediation on the NEPA
side, which they will be announcing very soon some new enhancements as part of our NEPA
process. They'll be able to support a little bit more about that in the near term. He welcomes
anyone who's interested in learning more about our new Title VI order as well as our upcoming
NEPA. Please, send him an email offline, and we can definitely have a follow-up conversation.
In addition to that, they do recognize that there are many ports and many freight corridors that
need significant resources to not only electrify but also reduce pollution. One of the things that
they believe part of the Justice40 initiative is going to help us do is to actually prioritize. They
do recognize that this is a five-year infrastructure bill. But this is going to take more than a five-
year infrastructure bill to fix the problems in communities across the country.
And so, as part of that, they are looking for guidance as they have rolled out their Justice40
31
-------
mapping tool; they want to make sure they are prioritizing who should be in line by who has the
greatest harm first. They recognize that this is going to take multiple years and multiple high
levels of degree of investment, but they believe if they can get it done right now that when they
come back to Congress and the American taxpayers, they can continue to get the investments to
make sure that no community is left behind.
But also, with that, he honors the request to be in partnership with the department as they do
some community designs, particularly around some of the freight programs. As was mentioned
earlier, they have new investments in terms of how we reduce air pollution. They definitely
welcome the opportunity to do program design, not only just on the guardrails but how they
make sure they set these programs right so that they can get the advancements where they're
needed.
Ms. Santiago stated that there was a reference to the funding in the bipartisan budget bill for the
Army Corps of Engineers projects, a substantial amount. Some of them are in Puerto Rico. One
of those projects is of great concern. There's about $45 million for the Army Corps to dredge the
navigation channel in San Juan Harbor to allow for larger liquified natural gas carriers, and
they're not seeing the stakeholder engagement that is needed here. Requests for meetings are
pending with the Army Corps, and there's no response.
Then that contrasts a lot with a huge issue they're having in Puerto Rico right now with the
devastation of mangrove forests and wetlands that are under the jurisdiction of the Army Corps.
If you look at any news having to do with Puerto Rico in the past week, it is the Jobos Bay
National Estuarian Research reserve here in Salinas, Puerto Rico that has been devastated, and
the army corps is just missing in action there. They're wondering whether there's funding for
enforcement by the Army Corps because many, many cases and different coastal areas where
there's been devastation of wetlands and mangrove forests. That is mostly directed to Ms.
Vahlsing.
The other concern was for Mr. Try on. It's about the efforts to clean up the military bombing
sites on the offshore island of the Vieques. In our recommendations in May, they included the
community requests for closed detonation chambers for military ordinance. One was provided
but it's a very small one; that's a ten-inch munition. We're wondering whether in this new
funding there will be detonation chambers for the 500- to 2,000-pound bombs that are on
Vieques?
Ms. Vahlsing replied that generally, the Army Corps is working aggressively to increase its
stakeholder engagement. They should do a follow-up conversation with them because they're
making a lot of progress. The budget that the president released yesterday included to your exact
point about increasing stakeholder engagement. It included funding to put an environmental
justice staff person at each district office for all of the Army Corps across the country so that
they can really address what you're saying and make sure there is more stakeholder engagement.
But in the meantime, there was Bipartisan Infrastructure Law funding for a pilot program. She
thought it was about $100 million for the Army Corps to particularly focus on environmental
justice. She will connect her through that door to the right people at the Army Corps, and let's
talk more about how to make sure that funding is fully leveraged and including her thoughts.
32
-------
Mr. Tryon replied with regard to the Vieques and the unexploded ordinance, there may be some
possibility that the restoration provision might be able to be put to use on this long and vexing
problem. The Department of the Interior's Central Hazardous Materials Fund has helped with
some projects at Vieques, as has the National Resource Damage Assessment Program. It's
possible they talked about that at a meeting three or four months ago. Did I commit to getting
you some information on that? Did I follow through? Ms. Santiago replied yes, she hopes that
can happen. Mr. Tryon replied that he will be sure to follow through on that.
Co-Chair Moore commented that part of what he's been seeing and they've been hearing
testimony about many times is that, when positive initiatives are moved forward, rural
communities and counties get the diesel buses dumped on them.
In regard to the Department of the Interior, they've also heard testimony and comments in regard
to what's taking place in the world around uranium and the potential for uranium mining. So,
part of what they're doing then is they're dealing with legacy issues, so let's not reinvent the
wheel. Let's move forward and not backward.
Many times, what they see in all government agencies is getting bogged down in terms of the
amount of paperwork that's necessary. So, when they're hearing presentations sometimes, what
happens is it sounds good, but communities get hung up in the paperwork shuffle. So, it sounds
good on the outside, but then the practice on the inside is not the same.
Mr. Tryon responded to the uranium issue. It is a big deal. It is certainly a legacy deal because
this was the United States demanding uranium for various war efforts going back to the 1940s
that resulted in the abandoned mines that are being discussed now. Section 40701 of the bill
authorized $3 billion for abandoned mine work, non-coal, and that would've been a real shot in
the arm for some of these tribal issues. It, unfortunately, did not have an appropriation, and so
they got a fairly small appropriation for this in 2022, but the president's budget that was
announced this past Monday does have a notable increase for abandoned mines including on
tribal lands.
Dr. Nicky Sheats wanted to address his comments to all the speakers and maybe future speakers
tomorrow from the government and just follow up on comments made by several colleagues.
Others have said that they worry that there will be projects in the name of EJ that the EJ
community feels are actually detrimental to our communities. He noted that the speakers have
talked a lot about public participation and having community voices heard. And so, he wanted to
point out that, yes, public participation is necessary, but it's not sufficient because oftentimes
what happens is that there's a public participation process and the communities say, well don't
do the project and the project's done anyway. So, there's public participation, but the voice of
the community doesn't actually affect the final decision. And in this case, that would really be
harmful if there are projects either on the Justice40 or just projects from some of the agencies
that they think will move EJ forward, and the state/local EJ communities were saying no.
He urged that in this case where we're talking about projects that are supposed to have EJ
benefits and the local EJ communities make it clear they're against a project, they should not go
forward. You should find some other projects where there is an agreement between local EJ
33
-------
communities — and that can be on the state level and even on a neighborhood level — and the
government that these projects will benefit the communities. None of us want to be in the
position where the government is funding projects that are supposed to be for EJ, and the local
EJ communities are protesting those projects.
In New Jersey, they're very worried about that and they're ready to fight projects — particularly
around energy — that they're worried about false solutions, and that just won't be a good
position to put any of us in. There's a lot of justification, especially under these circumstances,
that without the approval of the local EJ communities, then some other project should be looked
for.
Juan Parras stated that his question concerns the water quality in West Texas. There's a lot of
fracking that's taking place, and it's impacting the communities in the Permian basin to the point
that a lot of them are having to resort to buying bottled water because of the regular water. When
they open up the facets, it tastes horrible, and you can smell the gasses. The other issue with
water quality is of course all the colonias that they have in the border towns in Texas, and they
need infrastructure to at least get clean water and have clean sanitation.
Co-Chair Shepard directed her question to Radhika Fox with the EPA. She certainly mentioned
that there would be environmental justice folks in every regional office, but of course, that's
been happening for decades. And in some cases, those environmental justice folks have not been
the most effective or given priority at the regional level for their work. And so, when she hears
that, yes, they're going to be more EJ people again in the regional offices, what are you going to
do differently so that they are effective and do the appropriate engagement?
They're very happy that there have been some really great people appointed to the regional
offices, but they also understand that the regional offices often have either been terrible or, in
some cases, you even forgot they were there because they were so irrelevant to what was going
on in the environmental sphere in that city or locality or state. What are you going to do to
ensure that those staff are really experienced and engaged? DFO Martin explained that Ms. Fox
had to leave the meeting, but they will follow up with her and get that response.
Ms. Waghiyi stated that it's great to hear that there will be increased stakeholder engagement
because her tribe was not party to the record of decision with Northeast Cape, and our state
basically rubberstamped the Army Corps of Engineers and let the polluter off the hook in the
case — the two former use defense sites on Saint Lawrence Island. Is she willing to let tribes be
party to the record of decisions? Her community-based participatory research project recently
continued to find PCBs, and now we identify mercury at the Suqitughneq River at Northeast
Cape. They need to be party to the record of decision.
Regarding water and sewer in Alaska, every sitting governor has promised to get rid of the
honey bucket. And yet, how are they going to ensure that states will follow through with the
recommendations when they have over 30 communities with no water and sewer. Another
comment is of false solutions regarding micronuclear reactors. It is known that a single
microreactor core could contain about ten nuclear weapons worth of nuclear and radioactive
material, and stakeholders are not consulted. These could be adjacent to our communities in
hunting/food gather locations that are proposed in Alaska. Ms. Vahlsing informed Ms. Waghiyi
34
-------
that she's not with the Army Corps but with OMB. She is happy to follow up with them about
the question about the RAS.
Vice-Chair Tilousi thanked the Council for their questions and the panelists for their
presentations regarding funding opportunities for water and transportation and willingness to
work with NGOs, tribes, and states, and also for providing us with technical assistance.
Co-Chair Moore asked if the questions and comments that were brought up in the chat be
included in the summary for the meeting notes? DFO Martin responded that she will make a
note to the meeting summary of those comments that were made since Dr. Bullard had to leave.
She reminded the members that the comments in the chat should be spoken in the meeting so
they can be part of the record. She then notified everyone that it was time for a break.
1.5 Public Comment Period
On March 30, 2022, the WHEJAC held a public comment period to allow members of the public
to discuss environmental justice concerns in their communities. A total of 19 individuals
submitted verbal public comments to the WHEJAC. An additional 39 individuals had signed up
to speak but were not in attendance. Each speaker was allotted three minutes.
Co-Chair Moore reminded everyone that they will be hearing from the diverse populations and
the voices from across the country. They are very crucial to the WHEJAC Council and the
process as a Federal Advisory Council. Additionally, it's important to provide advice and
recommendations to the Council on Environmental Quality and the Interagency Council. Some
of the agencies are listening to the meeting as it occurs.
He also explained that they prioritized hearing from people that have not been heard before as a
public speaker, so they are at the top of the list. If more than one person registers to speak from
the same organization, the first one that registered will be heard first and then the others as time
allows.
1.5.1 Graham Hamilton - Break Free from Plastic (Washington)
Graham Hamilton stated that when it comes to metrics which measure environmental injustice,
it's important to understand the historical burdens of pollution, as well as identify nascent
burdens from being leveled at underserved communities in the future. The Climate and
Economic Justice Screening Tool is a valuable asset that will improve with input from impacted
communities, just as its original version CalEnviroScreen has been shaped and molded as new
information and metrics have become available at the census block level.
However, he wanted to point out that ensuring a whole-of-government approach that addresses
current and historical environmental injustices will require that the whole of the federal
government is pointed in the same direction, and unfortunately this doesn't appear that this is the
case. Earlier this year, the Department of Energy announced a $13.4 million investment in so-
called chemical and advanced recycling technologies. And these are just energy terms that
essentially green wash the incineration of plastic waste. This is concerning because it suggests
that the administration is supporting industry sponsored schemes that directly contradict the
35
-------
purpose of the Justice40 initiative, and that once again the historic practice of putting
incinerators in EJ communities will continue with the backing of the White House.
For over two decades, industry has consistently failed to prove the environmental benefit or
economic viability of so-called chemical recycling schemes which primarily use pyrolysis and
gasification to treat mixed plastic waste. For decades these facilities have been cited in the same
marginalized communities that WHEJAC is committed protecting. And there is significant
evidence that the emissions from these plastic burning facilities pose as much of a threat to
public health, if not more, than traditional incinerators. Industry today is doing everything it can
to deregulate these toxic, unproven technologies and spur the proliferation of so-called advanced
chemical recycling operations across the U.S. The EPA is currently considering whether
pyrolysis and gasification units should retain their classification as incinerators under Section
129 of the Clean Air Act.
There are at least half a dozen companies in the U.S. right now who are working to break ground
on new plastic incineration plants, all of them in communities that have been identified by the
screening tool as marginalized and overburdened. The Climate and Economic Justice Screening
Tool can be a powerful asset, and the folks in these communities need this tool to work. But it
will only do so if the whole of government approach is consistent and that the administration and
heads of the federal agencies stop buying into false solutions from the very industries that got us
here in the first place.
1.5.2 Marcia Briggins - Re-Right the Culture (Uniontown, Alabama)
Marcia Briggins stated that Uniontown has the second largest landfill in the nation receiving 33
states' trash in a low-poverty black area. The air and water quality are poor, and the soil is full of
toxins. Currently, ADEM cannot provide an answer how to measure what's being received
amongst the 33 states of trash and toxic waste, and so they continue to get toxins. This is
currently putting us in a position where they're now receiving a new wastewater system that is
increasing the citizen's bills an additional $100 a month. And this came about with the
misappropriation of funds, where the city received $4.5 million and unfortunately was not
accounted for. And now have a $31 million bill for the Infrastructure and Jobs Act.
Now, unfortunately, the wastewater system has to go 20 miles to another city causing the
citizens to be heavily impacted while the black community areas in low-poverty housing as well
are suffering from the lack of jobs as well. This bill was specific for financial gain for the white
multi-million-dollar industries there and not for the disadvantaged African Americans that are
there. So, she asked, how can they ensure ADEM is being held accountable? Because none of
their citizens are being able to be made aware of what's currently going on while continuing to
ingest such harsh air quality, water quality, and having to be in small government assistant
homes, receiving $80 to $100 in a regular monthly bill.
We're paying a higher increase due to the misappropriation of funds. Her congressman has even
voluntarily stated that yes, they were aware of that. How can they be assured that this area is not
being wiped off, but they're being heard, and our health is actually taken into account?
1.5.3 Cynthia Vanderpool Garcia - Alianza Nacional de Campesinas, Inc. (Maryland)
36
-------
Cynthia Vanderpool Garcia deferred her time to others in her group.
1.5.4 Dave Shukla - Long Beach Alliance for Clean Energy (Long Beach, California)
Dave Shukla shared his background from Paduka, Kentucky and Long Beach growing up across
the street from a power plant and oil drilling.
The question that he asked is, as someone who for 24 years has been watching his city and some
of the companies involved — Edison, AES, some others — profit off of the destruction of his
present and his future, how it is if we don't completely decarbonize electricity and completely
de-privatize it from these entities? These entities are the problem. How is this country going to
ensure a future for him let alone for the many children that his mother has birthed in the town of
Long Beach? And finally, to underscore Angelo Logan's point, from a climate science
perspective, how do you ensure that we make one step forward actually be a step forward and not
two steps back?
1.5.5 Karen Spencer (Gloucester, Massachusetts)
Karen Spencer stated that she is speaking today as a private citizen with a deep and abiding
interest in environmental health and justice. She's cognizant that this body has the express duty
to provide advice and recommendations to the White House Environmental Justice Interagency
Council for the purpose of reducing pollution; promoting sustainable infrastructure, including
clean water; and addressing current and historic environmental injustice. To that end, she
suggests that the screening tool tracks the fluoride concentrations in drinking water in all
communities, tagging those communities that are adding fluoridation additives to their municipal
water supplies.
This is important criteria for the screening tool because hundreds of laboratory studies and scores
of human studies, including many sponsored by the NIH in just the past five years, have
validated that exposure to fluoride, even in low concentrations found in optimally fluoridated
municipal water supplies, harm bodies, bones, and brains from womb to tomb. Specifically,
when the young mother consumes fluoridated water while pregnant or prepares infant formula
with fluoridate water, her child is more likely to have learning disabilities or a lower IQ. Those
afflicted children are also likely to have at least two teeth damaged by dental fluorosis, the
visible evidence of poisoning while young.
When a person consumes fluoridated water for decades, he or she is more likely to suffer from
osteoarthritis and skeletal fragility. When a community is fluoridated, it has higher rates of low
thyroid disease and more gastrointestinal disease. When diabetics and kidney patients drink more
water than the typical person, they receive doses far in excess of the current and misguided
safety threshold, which in turn further damages their kidneys and interferes with glucose
metabolism. A vicious cycle that also puts consumers at higher risk of other illnesses, a few of
which I just mentioned.
When fluoridation chemicals are added to municipal water, more buffering chemicals are
required in a futile attempt to prevent infrastructure corrosion. Caustic fluoridation chemicals,
37
-------
which are harvested from the pollution control systems of industry, are also contaminated with
lead, arsenic, barium, aluminum, cadmium, et cetera. About one percent of the fluoride and
associated chemicals in metal are consumed by people, the rest being destinated for the
environment where it damages flora and fauna. When the consumer is part of an environmental
justice community, avoiding the poison on tap is very costly and next to impossible because,
when fluoride is in water, it is in everything prepared with that water.
Counselors, the myth about fluoridation being a magic potion has been busted, but those in
positions of power are often the last to know the truth. She ended with this one truth: WHEJAC
has a duty under Justice40 and clean water initiatives to, one, track fluoride in water; two,
prohibit using national resources to expand fluoridation; and three, take affirmative action to end
fluoridation programs because fluoridation is an environmental injustice in public policy. I have
uploaded this oral comment as well as close to 100 scientific citations substantiating my
statements.
1.5.6 Brett Johnson - NYSACC, Gorham Conservation Board (Gorham, New York)
Brett Johnson stated that he has no comments. Everyone gave him a lot to reason and think
about.
1.5.7 Robin Forman - Environmental Advocate (Maryland)
Robin Forman stated that listening to everybody has given her a great deal to think about. And
she has a lot of concerns that she will just send via email. It would be much more concise that
way. She will forward that after this conference.
1.5.8 Jamie Banks - Quiet Communities (Massachusetts)
Jamie Banks stated that EJSCREEN 2.0 is intended to protect public health and the
environment, yet it does not include noise as an indicator, putting EJ communities at risk from
noise related health and environmental harms. Noise was first recognized as a public health
hazard in 1968. The need to address it is described in the Clean Air Act of 1970. The Noise
Control Act of 1972 states, "It is the policy of the United States to promote an environment for
all Americans free from noise that jeopardizes their health or welfare." Noise causes hearing loss
and tinnitus, contributes to various health problems, and impairs children's learning and work
productivity. It comes from transportation, industry, construction, mining, blasting, and so forth.
There's a nexus between noise and fossil fuels. Chronic noise, even at low levels, can cause
annoyance, sleep issues, and stress that in turn contribute to cardiovascular and cerebrovascular
disease, metabolic disturbances, worsening psychological disorders, and early death. It threatens
the health of more than 100 million Americans with children among the most vulnerable and
environmental justice communities affected disproportionately. Measures can be taken. For
example, installing sound insulation and relocating noise sources have been shown to reduce
noise and reverse its adverse impacts on learning and cardiovascular health. Quieter equipment
are available.
In its recent policy statement called "Noise as a Public Health Hazard," the American Public
38
-------
Health Association calls on the federal government to ensure that the reduction of noise
exposures is part of all environmental health efforts, acknowledge the disparate impacts of noise
on communities of color and low income communities, and implement programs and policies
across all federal agencies, including the EPA, Departments of Labor, Transportation, Defense,
Health and Human Services, Education, and Housing and Urban Development, and the Federal
Aviation Administration, National Institute of Standards and Technology, and the Consumer
Product Safety Commission. The Bipartisan Infrastructure Law will allocate funds to build safer
and more sustainable airports, highways, and transportation infrastructure.
Including noise as an indicator in EJSCREEN 2.0 will help reduce the impacts of noise and
related air pollution from these projects on the health and well-being of EJ communities. Failure
to include it exposes those communities to potential harms to health, learning, and well-being.
1.5.9 Sinthya Hernandez - Lideres Campesinas (Oxnard, California)
Sinthya Hernandez (through an interpreter) stated that she is a farmworker. She is also a limited
English speaker. Unfortunately, they have a very big problem. On the fields, they work under
very high temperatures — 95 to 98 degrees. They do not stop working, and they have suffered by
fainting, getting dehydrated, and they suffer with pesticides that they spray on the fields. They
are not given a good attitude when someone complains or when someone says something about
what happens on the field. Nobody supports them. They do not get help with any of that. They
know that they should work a little bit more in order to have somebody pay attention to us. They
need to work with open doors, and they need to see how they can get help to have a law so the
temperature can be a little bit lower, that they should stop working when the temperatures are so
high. They don't have good drinking water. They are given drinking water that tastes bad and it is
dirty and they have to work like that. She would like somebody to take into account what
happens with them.
1.5.10 Kari Fulton - Climate Justice Alliance and the United Frontline Table (Maryland)
Kari Fulton stated that she is not only representing the Climate Justice Alliance but also the
United Frontline Table. The United Frontline Table is a national network of black, indigenous,
Asian, Pacific Islander, Latinx, Latino, and working-class led organizations representing
hundreds of organizations and communities across the United States. Their membership
collectively represents hundreds of thousands of people in frontline communities around the
country facing the brunt of historic racism, poverty, pollution, climate change, and other
inequities. But they're working together towards a regenerative future that repairs historic harms
and inequality and invests in the resilience of the most impacted communities. They look
forward to a robust Justice40 program and offer the following comments to strengthen it and
achieve the full breadth of its envisioned impact.
Number one, meaningful access and impact. They ensure that the program application process
does not inhibit access. For example, consider creating application processes where eligible
entities, including community-based organizations, small businesses, and local governments,
where applicable, can apply for multiple grants from across federal departments through one
application. Such a process can facilitate communities with limited capacity and the greatest
need to participate fairly and meaningfully. Devote a portion of Justice40 resources to technical
39
-------
assistance from agencies on proposal development, application process, implementation and
long-term governments, especially for those communities with greatest EJ burdens to facilitate
maximum access to programs by eligible entities and lasting impact from Justice40 investments.
Three, ensure maximum dollar amounts in funded Justice40 projects are contracted with local,
PLC, and worker-owned businesses. PLC means black, indigenous, and other people of color
and marginalized communities. Or, if they lack capacity to take on Justice40 projects at scale,
require that winning contractors subcontract with otherwise eligible BIPOC and worker-owned
contractors and allow them to shadow the lead contractor on site to develop experience and skill.
Four, require all implementing agencies to undertake robust stakeholder and community
engagement at every stage of project development and implementation, including via direct
outreach to frontline and environmental justice communities, hearings, or listening sessions in
targeted geographies, field liaisons, attention to language justice, et cetera
Five, develop a transparent auditing framework to track progress toward and beyond the 40
percent of funding to be invested in disadvantaged frontline communities. Do no harm.
Six, ensure that all federal climate investments have clear requirements to explicitly prohibit
increases of harmful burdens on disadvantaged communities. Require agencies to conduct and
publicly report impact assessments that project potential harms of investments — programs, rules,
et cetera before issuing any projects or program funds. Justice40 funding should not be allocated
to any projects, programs, or investments that will harm any frontline constituency. For Justice40
to keep its promises, funding decisions much be required to respect and balance the interests of
all frontline constituencies rather than forcing them into competition.
They also want a comprehensive approach. Develop funding criteria that require investments to
support development and investment in collective community ownership of essential assets such
as affordable housing, microgrids, worker-owned businesses, community land trusts, community
development finance corporations, in order to build the resilience of frontline communities over
the long-term.
Create separate programs and funding mechanisms responsive to the specific needs of the Gulf
South, Native American tribes and communities, and U.S. territories including Puerto Rico, the
Northern Mariana Islands, American Samoa, and Guam. Undertake comprehensive outreach
across communities in these areas with the attention to appropriate language access to ensure
awareness and equitable uptake of justice. In general, OMB should exercise oversight of
agencies in the designation of Justice40 covered programs beyond those named in the pilot
program. Seeking, really first, with a focus on formally designated as a part of Justice40 specific
relevant programs and any relevant provisions from Build Back Better that pass into law and
more broadly speaking to expand the scope of Justice40 into additional specific areas including
in public health, education, immigration, open space, land conservation, ecosystems, protection
and restoration, and other areas with clear climate impacts.
All implicated agencies should be responsible for developing plans and detailing how each of
their covered programs will be tailored to achieve Justice40 investment goals. Agencies should
issue rules or policies to accompany formula funding in all Justice40 policy areas, instructing a
40
-------
broad range of recipients including states, counties, and tribal governments about their
obligations to adhere to Justice40. Require that competitive grant programs that fall within
Justice40 utilize the climate and an economic justice screening tool in rating proposals. Proposals
benefitting the most vulnerable communities should receive higher consideration. Also ensure
that the greatest extent possible that Justice40 efforts are embedded in the long-term guidance
rules and policy of implementing agencies so progress to achieve Justice40 targets continues
regardless of political changes in the administration.
The administration should work with members of Congress to advance legislation that codifies
the Justice40 initiative, ensure that agencies — the CDQ and the OMB — have adequate levels of
funding and staffing for long-term implementation, give guidance for agencies to develop clear
multi-year targets and time tables, and to the greatest extent possible, ensure uniform uptake of
the Justice40 initiative across agencies leveraging the advisory role of the WHEJAC and the
interagency efforts of the WHEJAC. We strongly recommend that any further Justice40
guidance from the Biden administration to implementing entities include direction that conforms
to the above recommendations.
1.5.11 Dan Solitz (Oregon)
Dan Solitz stated that he's calling in response to the president's 2023 budget on environmental
management, cutting back the cleanup in Cold War legacy sites and shifting that money to more
weapons and nuclear weapons production. If recent events haven't taught us anything, it's that
this isn't really the way to go. They need to clean up those sites and figure out a way to clean up
the cloud that may be hanging over us.
1.5.12 Charlotte Keys - JPAP/MTAC (Columbia, Mississippi)
Charlotte Keys stated that, coming from a faith-based community, there are so many different
things to address. She is more concerned about making sure that the Justice40 program is set up
to help ensure more community engagement and participation with the funding. Listening to
different ones talking about the water, the public transportation, and all of the different aspects, it
is so important to understand that they are still dealing with similar issues of racism as it relates
to public participation with a seat at the table and dealing with health, housing, clean drinking
water, job creation, job development, enforcement, and a lot of the different aspects of
collaborative problem solving because she felt strongly that if anything is to be addressed and
any problems to be solved, it's going to take a collaborative effort.
Without the grassroots environmental justice communities at the table with the states or the local
city fathers that have a lot of political will, people will still be disconnected from being able to
access resources and have a seat at the table. It has to be some type of task force, advisory
council, or something set up for more grassroots participation in an equitable manner as it relates
to the funding for Justice40.
1.5.13 John Mueller (Oklahoma)
John Mueller stated that he's an environmental activist with 13 years of studying the practice of
artificial water fluoridation, studying again in my public service career as a water civil engineer
41
-------
and water treatment professional. Recognizing that today's public comment should be relevant to
the beta version of the Climate and Economic Justice Screening Tool, he emphasized — again in
addition to last month's meeting and in previous comments — the need for the screening tool to
include a data set of all drinking water utilities which participate in the CDC's community water
fluoridation program for which the CDC has a readily accessible database.
So why must the screening tool include that dataset? Simply because Administrator Regan has
the unprecedented opportunity under the Biden/Harris administration to end the EPA's policy of
allowing the addition of contaminated industrial pollutants to public water supplies, especially in
light of the most current high-quality scientific studies, a number of which have been funded by
NIH and which policy is revealed in the quotation, "In regard to the use of fluorosilicic acid as a
source of fluoride for fluoridation, this agency regards such use as an ideal environmental
solution to a long-standing problem by recovering a byproduct fluorosilicic acid from fertilizer
manufacturing, water and air pollution are minimized, and water utilities have a low-cost source
of fluoride available to them." And that is from a letter dated March 30th, 1983, 39 years ago
today from the EPA Office of Water to a dentist in Newtonville, Massachusetts, which has
endured to this day.
What is most striking and compelling about that statement and its underlying philosophy is their
obsolescence while continuing to fly in the face of today's increased environmental awareness
and awareness of toxic contaminants posing risks to public health like PFAS, for example, and
lead, which we've known about for decades but we don't deliberately add it to the water. The
greatly misunderstood practice of fluoridation needs to be terminated in favor of more effective
programs to improve our nation's embarrassing oral health conditions among the disenfranchised
and vulnerable subpopulations.
Programs at schools for periodic dental checkups and oral health education are proven effective
programs. If replacing lead pipes is a high priority, then EPA must also prohibit the deliberate
addition of toxic pollutants that flow through those pipes, old and new. He will be submitting
additional materials pertaining to the mentioned opportunities for Administrator Regan.
1.5.14 Hormis Bedolla - Alianza Nacional de Campesinas (Wolcott, New York)
Hormis Bedolla (through an interpreter) stated that she is a farmworker. She has worked for
about 19 years in agriculture, specifically in the industry of apples. Her state is second in
production after Washington. She has had direct contact for those 19 years with pesticides. She
has applied pesticides and herbicides at many levels of toxicity, some of them with reentry of 72
hours because of its level of toxicity. She had been indirectly and directly affected because of
that. She has three children. Her eldest was born before her exposure to pesticides. The other
two were born after her contact. Her second child was born with learning disabilities. He's in a
group of special education. Her third child was born with renal problems. He only has one
kidney, and the only one that is working has been affected. All this is due to pesticides.
The county where she lives is a disadvantaged community. Not only has her family been affected
but many farmworkers because they are in direct contact with contaminated water and air. This
is a rural area. Many people come here to work in the fields. She is talking about hundreds of
thousands of people, so they have been affected directly because of the use of pesticides.
42
-------
She is asking to have more regulations regarding pesticides. There should be important people
that come to the sites because they are violated. All the regulations are violated, and that's why
the farmworkers are exposed directly to all these pesticides. They're very harmful to our health,
not just to their health, but to the water, the air, and the environment. She is asking for more
attention.
1.5.15 Alicyn Gitlin - Sierra Club - Grand Canyon Chapter (Flagstaff, Arizona)
Alycyn Gitlin stated that she was speaking on behalf of the Grand Canyon region, the ancestral
and current homeland of at least 14 tribal nations. In recent weeks, the federal government has
seemed eager to rush our nation back into a frenzy of nuclear development despite never having
cleaned up from the previous boom-bust cycle. Once again, we see wealthy, and often foreign-
owned companies ready to profit off of our outdated mining laws and weak environmental
protections. Much of the extraction, milling, and spent fuel storage continues to occur in places
where the weight of the risks is on the backs of indigenous peoples. These boom-bust cycles
continue, but the contamination is forever as we fail to clean up uranium-contaminated water
supplies. In my region, the so-called reclaimed uranium mine sites can exhibit greater levels of
soil contamination than active mines.
The EJSCREEN tool is an important one. However, the full contents of the WHEJAC final
recommendations need to be encoded in regulation and policy. It might be useful to even have a
second tool to assess whether proposals fit within the WHEJAC recommendations prior to even
thinking about their placement. The Justice40 initiative pledges 40 percent of overall benefits
from federal investments in climate and clean energy to disadvantaged communities, yet she is
hearing energy rhetoric from DC that seems to have a crisis of creativity. She's hearing of oil,
gas, and nuclear. She's hearing of mining for uranium and other minerals that will harm native
communities.
In contrast, the WHEJAC's final recommendations list the procurement of nuclear power as an
example of the types of projects that will not benefit a community, and that is being ignored. We
need strong policy statements that are responsive to the Advisory Council and set our nation up
for a healthy and prosperous future. We shouldn't be able to ignore the WHEJAC
recommendations and develop extractive policies that echo tragedies abroad with new harms at
home. Yet she's watching in my region as the owners of the Pinyon Plain Uranium Mine and the
White Mesa Mill use war and tragedy as an excuse to create new nuclear landscapes. Are these
the intentions of people who care about life and who care about the health and well-being of
people? No.
She fears that in my region where a quarter of Navaho women have high levels of uranium in
their bodies, and the Pinyon Plain Mine pumps millions of gallons of uranium and arsenic-
contaminated water from its shaft every year that we are about to repeat terrible injustices of the
past. With Justice40, we should invest in a new way, not waste more time and more lives. We
should be elevating indigenous and affected communities as leaders in creating solutions. Thank
you, so much, for your time and for all the important work that you do.
1.5.16 Audelia Martinez - Lideres Campesinas (California)
43
-------
Audelia Martinez (through an interpreter) stated that she is a farmworker, and she has worked
for more than 20 years in the field, same as all her acquaintances and family. With heat, the
climate, and the pesticides, they change so much that here in the community where we live in
Monterey, we need to continue working in order to make it. When she arrived at that place, she
was living with her husband. All the time, we worked with lettuce, grape, and broccoli. Right
now, she has asthma and psoriasis. Her husband passed away from lung cancer.
Here in her community, there are many children that are autistic. It is windy every afternoon, and
there's a lot of dirt because they are around fields. On a daily basis, they have pesticides on the
field. There are many elderly people dying of cancer and asthma attacks, and that is why she
believes that it is good to fight and try to find alternatives to get rid of all the pesticides. Mostly
everything has to do with climate change because they see that that is affecting most people with
disabilities or people with illnesses. Yes, they are asking EPA to notify us at least 72 hours or 48
hours before putting some type of pesticides in the community. Like some people said,
everything that has to do with climate change has to do with pesticides as well. So yes, they are
asking for this huge favor. Think about our families, our children, and our elderly. Here in the
community, we have schools and we are surrounded by all types of fields where they are
harvesting and putting that type of pesticide.
1.5.17 Carlos Garcia (New York)
Carlos Garcia stated that his public comment is hoping that the Council is understanding and
prioritizing a just transition and understanding where the trends of the energy market and policies
are really moving towards, and how they can address a lot of the current EJ issues such as
fugitive and criteria air pollutants due to the energy infrastructure and how they can kind of
combine the prioritization of decreasing criteria and fugitive methane emissions, and criteria air
pollutants, along with galvanizing the energy markets and companies to address those concerns.
And so, one of the things that they are proposing as flume energy is to be able to have waste
energy, methane, and criteria air pollutant captures at wastewater treatment facilities, turning that
into clean energy through non-combustion fuel cells and then galvanizing how EV adoption of
EJ communities through EV charging ports, whether that's light to medium or heavy-duty
charging ports, in EJ communities being fueled by the gasses that are being captured from
wastewater treatment facilities. They understand the concern of the EJ communities about
perverse or negative externalities due to waste energy products. They feel that in wastewater
treatment facilities there is no perverse incentive that could really be used except the only added
benefit of capturing fugitive emissions, methane and criteria air pollutants, that come from
wastewater treatment facilities and being able to galvanize developments in the name of a just
transition for environmental justice communities.
He'll be reaching out to a few of the Council members to understand their proposal and hopefully
garner some support. But he also again just wanted to echo everyone's comments before me that
we really appreciate all the time and work and late hours that are put into helping this Justice40
initiative. For those who have worked in New York EJ policy and energy markets and the EJ
fight, they really appreciate and are very proud that the White House and the federal government
are now taking the mantle and trying to continue the good effort that New York is spearheading.
44
-------
1.5.18 Brandi Crawford-Johnson (Kalamazoo, Michigan)
Brandi Crawford-Johnson stated that she's tired. She's tired of having high blood pressure,
tired of heart palpitations, panic attacks, for fighting for people to stop being poisoned in my
community in Kalamazoo, Michigan. Yesterday, she got an email from the state health
department saying that their health investigation is being delayed for the third time, and it was
very depressing. She's just done everything she possibly can. She heard Dr. Bullard talking about
civil rights, and she has a civil rights complaint against EGLE with Michigan. She's talked to
ECRCO about her civil rights complaint, which is an informal resolution right now, and she's
asked them to take funding away from EGLE. They're doing the same stuff they've done since
the Flint water crisis. Nothing has changed. They're still giving permits to polluters that are out
of compliance to continue expansions and to continue poisoning fenceline communities. And it's
just got to stop.
She likes that the administration is putting more funding towards environmental justice, but she
just doesn't see any action happening fast enough. She's said this before, we have FEMA, and
FEMA brings in help for tornado victims and hurricane victims, but nobody is bringing help to
these fenceline communities that are being poisoned to death. Graphic Packaging started up their
expansion three weeks ago and increased pollution by about 200 percent — greenhouse gasses,
hydrogen sulfide, sulfur dioxide, mercury, lead, you name it. And they've had two 20-year-olds
die from asthma in the three weeks since they started their expansion, and one person had a heart
attack during an asthma attack that is on life support and in a coma. He's 31-years-old.
And this is still not serious enough for our state health department, the EPA, or EGLE to come in
and bring help to this community. They have had two reports since 2020, one from a toxicologist
saying the severe health risks to employees at both plants — the wastewater plant next door to
Graphic Packaging and Graphic Packaging — and to the residents living in this valley
neighborhood where all these gasses are trapped and poisoning everyone to death. There is a 14-
year death gap in this neighborhood. There are 14-to-15-year death gaps in all fenceline
communities across the United States. We've got to start treating this as the emergency that it is.
These people are being poisoned to death. Pollution is poison, and it's got to stop now. We
cannot wait any longer. We have to treat this as an emergency. These people are dying.
1.5.19 Dulce Salgado - Alianza Nacional de Campesinas (Oregon)
Dulce Salgado (through an interpreter) stated that she is a farmworker and is a wife of a
farmworker. She's been a farmworker for six years. She has experienced a diversity from
beautiful spring to the freezing winter. In the last years in the field, they have felt very strong
heat waves in the summer. For instance, last year in 2021, they experienced the hottest days they
have ever had. Temperatures rose to 113 degrees. The heat was so intense that many of the
harvesters were affected, and the harvesting was not as abundant as in previous years.
Personally, she's been able to feel such intense heat, and it has been so hard to work. She has also
seen many of her friends suffer dehydration. The heat is so suffocating that sometimes it's even
hard to breathe in this hot air and many faint. Some farmworkers have died because of the heat
waves.
45
-------
In the fields, they have to wear hats to cover their faces and protect themselves from the sun, and
even then, that's not enough. They end up each day with a red face burned by the sun and our
arms and our neck the same. According to some experts, over time, this exposure to UV rays can
cause skin cancer, not to mention the damage from pesticides. Heat is very dangerous, and if we
don't drink enough water, we can be dehydrated or even worse get urinary infections. The work
in the fields has become dangerous in periods of heat. Most of the time, they don't have fresh
drinking water or shade where they can refuge from the heat during their breaks.
Many of them don't even imagine the precarious ways in which they are working, but they're
essential workers. Their work is important. They must do it because not only are they taking food
to their homes, but they also bring food to all the tables in this area. They know the recognition
of the work in the economy of the country, but also in the implementation of laws to have a safe
environment for their children. They are requesting reforms that will permit the conservation of
the environment. This is in everyone's hands and for the future of the next generation. That is
what she's asking.
1.6 Closing Remarks - Announcements & Adjourn
Co-Chair Moore understands that it's a long haul for those that have testified previously and for
those that testify repeatedly. The Advisory Council has traveled all over this country. They've
seen and visited many of the communities, and they can assure everyone that their comments and
recommendations are not only listened to but are understood. Co-Chair Shepard thanked
everyone for their presentations and the public comments. Vice-Chair Tilousi stated that she
hears what everyone is saying and that remedies are not moving fast enough.
Vice-Chair Flowers stated that, as they look at how to bring equity to these areas that have
suffered for so long, there is a process underway in some states, and they are taking away home
rule from local communities from being engaged. How can that impact the implementation of
Justice40 in communities where community engagement is being taken away from the
communities themselves? This is actually taking place in the statehouse where they are
partnering with a lot of these entities that have created the problems that we're talking about.
Ms. Santiago stated that the comments that they have heard are important and deserve a
response from the different agencies that have the responsibility to address them. They sent a
letter to CDQ to have more staffing and other agencies that can actually implement the Justice40
initiative. They need to make sure that that implementation happens so that these comments that
they hear meeting after meeting get addressed.
Mr. Parras stated that since 1994, they have been working on environmental justice. He thought
progress has been extremely slow but hopes that meetings like this will continue to at least speed
up the progress because they should not have to address environmental justice concern issues
much longer. Unfortunately, we will.
Michele Roberts stated that she hears the anxiety of, how long is long? But then equally, they
need to make sure that they get it right. The reason is that we've lost so many people and are
losing so many people. She believes that together they can indeed push to make sure that in this
political will of the moment that they make the words of the president manifest themselves into
46
-------
making sure they do receive and provide for those communities. Together, they can indeed push
this administration and our Congress to have the exceptional right political and moral courage
and will to make sure that they leave no one and no community behind.
DFO Martin adjourned the meeting for the day.
2.0 Welcome, Introductions & Recap
On Thursday, March 31, DFO Martin welcomed everyone to the second day of the meeting.
She gave a few instructions and then handed the meeting over to Ms. Shepard. Co-Chair
Shepard recapped the prior day's meeting and set the stage for the day's meeting.
The chairs and vice-chairs introduced themselves, and DFO Martin proceeded with the roll call
and informed everyone that the quorum was met.
2.1 Opening Remarks
Co-Chair Shepard introduced the next speaker.
2.1.1 Robin Morris Collin, Senior Advisor for Environmental Justice - U.S. EPA
Robin Morris Collin congratulated the WHEJAC on their first anniversary. She apologized that
Administrator Michael Regan was on international travel and couldn't attend.
EPA is honored to support this historically important work. They have supported the operation
and the work of the WHEJAC with our redoubtable DFO, Karen Martin, and other staff
members. What promise they have in this moment. As they look at the moment that they have
right now, she looked back at the faces of some of her long-time friends and thought about 30
years ago where they were. They were having a hard time just finding sofa-change-kind of
money to get around and talk to each other. This past week, they got $100 million to do
environmental justice work. She savored the moment. They have come a long way, and they
have a long way to go. She knows that, but it is thanks to the people around this table, the
WHEJAC, and all of the many community members who have struggled and some people who
didn't make it to today. Thank you to all of them because we're here now.
They are blessed to have the support of a president of the United States and a vice president of
the United States who have made environmental justice their priority. And, for the first time,
they've given us historically meaningful funding, money to back up a promise and a commitment
that they have made. She joined EPA only a month ago, and this is her first opportunity to
address them as the senior advisor to Mr. Regan on environmental justice. It is an honor to work
for Mr. Regan, and she is honored to be the one chosen to do this work.
Their mission in leading EPA forward is to protect human health and the environment. All
communities are guaranteed the protection of environmental law. Some communities have been
left out for not just decades but hundreds of years. What it feels like to be left outside the
protection of the law is to live exposed to the worst, most harmful, most dangerous elements and
impacts that our industrial society has. That is an atrocity. They've addressed that in the EJ
movement. They have asked for human rights. They have demanded our human rights. Now,
47
-------
they are in a position to demand that the equal protection guarantees that all communities should
be protected by environmental justice, must be ensured, must be delivered upon. It is her honor
to work with an administrator and other leaders inside the EPA who are committed to that work
as well.
Environmental justice is the way a democracy ensures that promise. That means that all
communities are ensured that they get the protection that they deserve. This is a historic moment.
However briefly they have to savor it, they should, and they should celebrate it. In addition, it
gives her hope and pride to look at the opportunities that they have to achieve a vision of
environmental protection that includes all communities.
To end briefly here, she will be back. She will return with a more complete account that
WHEJAC has asked them to provide with respect to the activities of EPA. In this brief moment
that they have together in the start of their relationship, she wanted to share her sense of what her
role is in this position at this moment. What they can do together is to focus the power and the
resources on places that have been unfairly and harmfully impacted in multiple cumulative
synergistic ways. They as an agency must change the response to those communities from what
they cannot do to what they can and will do. That is her commitment, and she is again deeply
honored to be in their presence.
Co-Chair Shepard turned the meeting over to Vice-Chair Flowers to open up a discussion on
the beta version of the Climate and Economic Justice Screening Tool.
2.2 WHEJAC Climate and Economic Justice Screening Tool Workgroup Update &
Discussion
Vice-Chair Flowers introduced Dr. Lucas Merrill Brown who will give a demo of the beta
version of the Climate and Economic Justice Screening Tool. She stated that after the demo
WHEJAC members will have the opportunity to provide comments and recommendations about
the tool to help the workgroup in developing recommendations for a final vote during a future
meeting.
2.2.1 Dr. Lucas Merrill Brown, Senior Advisor for Justice40 - CEQ
Dr. Lucas Merrill Brown stated that he is grateful to be presenting this tool that many members
of the WHEJAC, himself, and many other members of the Council on Environmental Quality
and the U.S. Digital Service have been working on for a long time. It became a labor of love.
He stated that the presentation will walk through the background of the Climate and Economic
Justice Screening Tool and do a brief demo of the tool, which is currently live at
screeningtool.geoplatform.gov. It also comes up if you google Climate and Economic Justice
Screening Tool. He encouraged everyone to multitask and take a look at that while he talked.
Then, finally, he will emphasize and reemphasize all the different ways that they are soliciting
their feedback on this tool. They are looking to hear from everyone about the communities, about
data, about environmental issues that are not currently represented in the tool, and for everyone
to give us recommendations on how to improve this tool overall and make sure it matches the
lived experiences and the environmental justice issues affecting communities across this country.
48
-------
The requirement for The Climate and Economic Justice Screening Tool comes from the
executive order on addressing the climate crisis at home and abroad. It asks the Council on
Environmental Quality to create this geospatial tool with interactive maps highlighting
disadvantaged communities that are marginalized, underserved, and overburdened by pollution.
In practice, agencies will be using this tool in order to implement the Justice40 Initiative. The
Justice40 Initiative directs 40 percent of the overall benefit of certain federal investments to
disadvantaged communities. These are 40 percent of the benefits from programs that touch on
any of seven issue areas, so any programs touching on climate, clean energy and energy
efficiency, clean transit, affordable and sustainable housing, training and workforce
development, clean water and wastewater infrastructure, and the remediation of legacy pollution.
This tool is used to identify the communities that will be prioritized to receive those 40 percent
of the benefits.
They've had several goals that they've kept close to their heart as we are developing this tool.
One is to provide this data-informed methodology for identifying disadvantaged communities.
They want this definition to be clear and consistent as well. Further, it's helpful to one consistent
definition across the federal government of how agencies implement the Justice40 Initiative to
provide consistency in outreach and stakeholder engagement with communities that are
prioritized, as well as making sure communities know that they are prioritized across the
hundreds of different programs covered by Justice40. This tool will be continually updated and
improved as feedback comes in from people and as new data becomes available over time. This
tool should reflect the realities on the ground and the lived experiences of people across the
country. And they want it to be easy to understand and use. Now, they can dive into the tool.
This is the landing page that will be seen when you go to the tool. Again, it's
screeningtool.geoplatform.gov, or you can just search the name Climate and Economic Justice
Screening Tool. It notes everywhere that this is a beta site; it is in progress. It is doing this public
beta period right now where they've published a draft definition of disadvantaged communities in
order to get more in-depth feedback from the public and advisory bodies on the definition of
disadvantaged communities and the tool overall. So far, that feedback had been extremely
helpful, and they are updating the tool in response. They will also be making this entire site
available in Spanish as soon as possible.
This gives you some context on the background of the Screening Tool and Justice40 that he just
went through on the slides. These are the calls to action. So if you are a federal program manager
or if you're a federal staff that is using this tool in order to help prioritize benefits from your
program, here's a good place to start by going into the Methodology & Data page. If you're a
community member who wants to explore data about communities across the U.S. including
your own and provide feedback, here's a good place to start with Exploring the Tool.
Again, their very favorite word, sending feedback. We have a number of different mechanisms to
solicit feedback from the public, including the simplest one, just send an email to this email
address: Screeningtool-Support@omb.eop.gov. It also has a survey that's available on every page
of the site. This asks you about who you are and how you might be using the tool as well as it
offers the opportunity to suggest and recommend specific datasets, so why you think this dataset
should be included, maybe a URL if it's already a public dataset. This is really helpful for us as
49
-------
well.
He also wanted to call attention to the fact that this community is entirely available as an open-
source project, meaning that all of the code used to produce the analysis, used to crunch the
numbers, used to create the formula of which communities are designated as disadvantaged, the
visualizations, the map. It is all fully public and accessible. You can explore and see details
about how all this works. If you have a little bit of programming knowledge, you can copy this
and use it for your own purposes, for your own screening tools. Or you can suggest bug fixes and
updates and modifications. They have had a number of contributions from the open-source
community that have been very helpful as well. This offers some information about the
codebase. That information is also translated into Spanish so that Spanish-language speakers can
get involved equally.
If you are interested in getting involved in the open-source community, you could learn more and
join. There are regular gatherings of the open-source community that you can join, and there's
information on that down here. They also provide a lot of information if you would like to see
the data directly. For instance, many people ask for the Shapefiles in order to use this data in
ArcGIS or the GeoJSON data. Those are available on this Datasets page.
On the Methodology & Data page, it provided more information about the formula that is used to
determine disadvantaged communities, the methodology. Communities are highlighted as
disadvantaged if they exceed a threshold for one or more environmental and climate indicators
and meet the threshold of the socioeconomic indicators. These are explained in detail on this
page. This is kind of the description of how the methodology works. If you have any interest in a
particular indicator and you'd like to learn more about, well, what does that data element really
mean, you can simply click into the name of that dataset and learn a lot more about it as well as
where the data originally comes from and when it was last updated. Again, if you have questions,
feedback, or suggestions on any of this, please submit your feedback. They're very eager to hear
from you. On this page, you can also download all of the data so that you can use it for your own
purposes in Excel and CSV.
Coming over here to the Explore the Tool map, it has a little bit of information about the tool,
including the definition of census tracts. These are the units that they use to identify
communities. A census tract is a geographic boundary that comes from the U.S. census. It
represents usually about 4,000 people. One thing he always cautions people about is that when
you're zoomed out at this bird's eye view of the United States, the census tracts that you're seeing
from this distance are often extremely large rural tracts. For instance, in South Dakota, there
might be a single tract that stretches over tens of miles in order to included 4,000 people.
Whereas, when you zoom into a city like Chicago, you can start to see the hundreds of census
tracts and communities that are getting highlighted as disadvantaged communities by the tool.
The reason he brought this up is not to use visual cues from the zoomed-out map to infer
anything about the distribution of disadvantaged communities across the country because you're
mostly seeing the rural tracts when you're that zoomed out.
Zooming in, if you click on any of the tracts that are highlighted in this greyish blue as
disadvantaged, you can get more information about that community. This community is
identified as disadvantaged. It has about a thousand people living there. It's disadvantaged in five
50
-------
of the seven categories that we have for our metrics, and it's at or above 11 of those thresholds.
You also have some indication of the number of different environmental and climate burden
thresholds being exceeded by this.
Our very favorite word, feedback. If you have some information about this specific community
that you would like to communicate or you think that it should not be highlighted as a
disadvantaged community and it is; or you think that it should be highlighted as a disadvantaged
community and it's not; or you believe that the data is not fully capturing the lived experience in
this community, just go ahead and click and send feedback there, and that will give us kind of
precise, targeted feedback about this specific census tract.
One way in which they are actively taking your feedback is that a number of commenters at
some of our public training and engagement sessions or members of the WHEJAC have provided
feedback that the sidebar here was a little bit confusing in the initial form. So they have now
rolled out a new design that they hope, based on testing, seems to be a better way to explain what
is happening with the methodology. But, please, send them more feedback if it's not working for
you. You can see that one of the reasons that this community is highlighted in the clean transit
category is that it has a very high level of diesel particulate matter exposure, 98th percentile. The
percentile means that it has more diesel particulate exposure than 98 percent of the census tracts
across the entire United States. It has a 99 percentile of traffic proximity and volume, which is
not too surprising being close to 90-94 here. It is also an extremely low-income community with
the 99th percentile of a population of low-income residents, with a high rate of people who are
not currently enrolled in higher-educational institutions.
You can open up the categories as well. This is very close to risk management plan facilities. It
has very high levels of toxic concentrations in local streams, has extremely high rates in all four
of these health categories, more than 99 percent of the country, high rates of asthma, diabetes,
heart disease, and low life expectancy. Finally, it has high rates of low median income,
unemployment, and poverty. So you can really see a number of dimensions that are being
tracked in the screening tool, and they look forward to tracking more based on recommendations
during this public beta. It has handy helpful buttons here on the side that allow you to zoom into
different areas, like Alaska, Hawaii, Puerto Rico, American Samoa, or the Mariana Islands, some
of those areas that are a little further off the map. Based on feedback from the WHEJAC, they
have also been working to make sure that the visual experience of the map works well in rural
America as well as urban America and have been working to improve that as well. By the way,
you can also click on any community on the map, even if it's not identified as disadvantaged, and
learn about the characteristics and statistics of that community.
Once again, there's another way to download the current list of communities and datasets used.
There are a couple of notes on territories and tribal nations. And one of those other ways of
soliciting feedback is through a request for information on the federal register. The request for
information is a little bit of a more formal process for soliciting public comments, and it has
some questions here that ask and solicit your input. It also has this Public Engagement page that
lists upcoming training and public meetings related to the Climate and Economic Justice
Screening Tool. They do have a public listening session focused just on this tool coming up on
April 15th, and the registration link is here.
51
-------
If you do download the data onto your computer through any one of those links, you'll be able to
see all the information that is available in the tool and do what you want with it. These are all
73,000 census tracts in the country, all of the data about them, about their expected rate of
agricultural losses due to climate risks, their currently experienced PM2.5, their rate of traffic
proximity and volume. If you did want to learn some information about a particular area, you can
type in these filters and use these to select places you're looking for, like in Lowndes County,
Alabama, you can see that all four census tracts here are identified as disadvantaged
communities.
Again, they would really love to hear from you, not only from you, but if you do have the
capacity to collect and solicit responses from other members of your community or communities
you're connected to. There have been a number of groups and organizations who've kind of been
organizing their communities to submit comments on this tool. They would love to hear from
them. Send an email. You can respond to the request for information. You can complete the
survey. You can join the open-source community on Github. You can attend an upcoming
listening session. The links for all of these things are available on the site. As shown before, they
do have this upcoming listening session on Friday, April 15th.
Vice-Chair Flowers stated that it's amazing to see how it came from being a concept to being a
reality. She thanked him for the work that was put into that. She notified everyone that there
were questions on the screen to guide the comments and questions on the tool from the members.
She began the discussion with the race question. Can they get to race? As they look at all of these
different communities that have been identified, are these showing up as being particular
communities or greater number of communities that are either marginalized or communities that
consist of people of color or indigenous? Did that show up at all? Dr. Brown replied that they
certainly hear and understand and acknowledge the long history and deep importance of race and
racism in environmental justice issues. There have been countless studies and just simply lived
experiences that indicate the importance of that in environmental justice history. They are very
much here to listen to recommendations and solicit feedback, and so they welcome explicit
recommendations to include race in the tool. At this time, he's mostly there to listen and learn.
Ms. Santiago appreciated that this tool is attempting to identify the most overburdened
communities in terms of pollution. With the limited experience she's had with the tool, in the
case of the communities that are most overburdened with pollution in Puerto Rico, the tool does
not seem to be reflecting that. They know that there's some data limitations as to the territories in
Puerto Rico as the notes indicate. There are only four criteria or indicators. What she found is
that, of those limited four, only two were found in an area that has the most polluting power
plants. That's one question; how did that happen?
Second, for example, they do know that territories and poorer jurisdictions sometimes have a
hard time collecting data. But in this case, as to emissions safe from power plants in Puerto Rico,
there is data from the EPA, so you don't need to rely exclusively on the monitoring from the
local environmental quality board or agencies. That's the second part of the question; was that
data taken into account in determining if indeed these sources of pollution were considered in the
tool? Do you understand my questions?
52
-------
Dr. Brown responded that his understanding is that in this session they'll be soliciting comments
and recommendations and providing feedback on the tool itself. The suggestion of looking at
those additional datasets from the EPA in Puerto Rico is a great one, but they would love to hear
the recommendations and questions from the whole group.
DFO Martin clarified that the questions and comments should be in response to the questions
that the workgroup has posed, not necessarily for Lucas about the tool. All those questions that
are for Lucas need to be discussed as a body in the group so they can develop recommendations
for what we're going to put forward later this year.
Mr. Cormons thanked Dr. Brown, CQ, and USDS for taking something that was a bold concept
and turning it into an emerging and developing reality in the form of the tool. It's wonderful that
it's open sourced, that the data and the protocols for analysis are publicly available, can be
scrutinized, can be used to whatever ends advocates and members of the public see fit. That's a
really healthy approach.
A few things related to the first question about additional information — this is the point at which
the tool is being GroundTruthed, and we're able to see where it has blind spots, where there are
communities that are disadvantaged, that are subject to EJ impacts and the tool isn't showing
that. So he's really interested in our collective-best thinking on what other data sources can be
added to help eliminate those blind spots as much as possible and recognize that a lot of the data
out there are not perfect. He thinks that data that can help us to avoid these false negatives or
blind spots and improve the accuracy of the tool — even if those data aren't always perfect —
should really consider including those layers and using them in the disadvantaged determination.
Additionally, there may be layers that can be added that don't necessarily go toward the
determination of disadvantaged or not disadvantaged but can be really useful as the public, as
advocates, as agencies are wrapping their heads around the problem and the best ways to address
the problem.
Finally, he put one more question out there for this discussion which is, to what degree do we
envision this screening tool in addition to helping agencies to determine and providing the
answer for agencies, which communities are disadvantaged and therefore eligible for Justice40
funding? They're also hoping that additional data layers in the tool and the confluence of factors
can see cumulative impacts for certain communities, et cetera, that can inform agencies'
decisions about tough choices about prioritization of certain funds.
Dr. Wright stated that she has two pet peeves about the questions: the first is the cumulative and
the race one, and the last one would be the accountably measure. They've all talked about
something when it came to accountability. They were recommending that we have these state
committees put in place or some kind of committee that's put in place within each state where the
EJ lens would be then applied as to where program monies were being allocated and that they
met the Justice40 lens. That was one recommendation.
On the question of race, she thinks race should be included. Not to get dramatic but Ahmaud
Arbery is dead today. He was jogging through a white neighborhood. That might be one factor
that other people do. No matter how many factors you add to that case, the end result is that he is
dead, and he's dead because he was black. So, when you remove that he was black, you don't
53
-------
have the reason for his being murdered.
The same kind of thinking happened with the Screening Tool. There are some things that happen
to us just because we are black. Blacks are the only group that was legally enslaved by this
country, and there are things that go to us that don't go to anybody else, as is true, also, of Native
Americans. Things happened to them because they are Native American. You can add every
other thing that happens to every minority group, but there are things that happened to Native
Americans because of their situation in this country, that we stole their land from them. The
Screening Tool will miss the mark completely if it doesn't have race because, living in this skin
that she's in, there are things that happen to me just because of my race. She's seen what's
happened to my family because of their race. She's really and truly frightened about not
including race, looking at all of the things that everybody else is saying.
Her recommendation would be that race is included. She doesn't know if the whole group would
agree with that because of the fear, but there needs to be some mechanism that deals with race,
like with Natives, with black people, and with immigrants. Some of those things are covered for
people who are immigrants and the language barriers, but what do you do with people who speak
English? They're not immigrants. This was home for Natives. Blacks were dragged here, but this
is all they know. There are some special considerations for African Americans in particular and
Native Americans that are different from all of the immigrants to this country.
She feels that this is a huge problem because this is what they've been fighting for all this time.
What she wants to hear are, what recommendations they can make to respond to the questions
that they have about the Screening Tool? It's like having a disease, and they diagnose it. And
they get everything right, but the one thing they get wrong is what kills you. So the operation is a
success, but the patient is dead. Some of them will definitely be left out. The same thing is the
situation for Puerto Rico, in particular. There are some things that are just a problem for Puerto
Rico. They have all the other things that we all have. Then they have their problem. She is
concerned that, when there is a specific issue for certain groups because of their relationship with
this country and their history within this country, that will be overlooked. And the result will be
great, great, too, but a whole bunch of us have been left out or missed because we didn't include
race in particular. She would really like to know what their recommendation should be whether
they accept it or not. I think that they should stand up. It should be a righteous statement. They
weren't brought here to be timid. They were brought here to tell the truth.
So how the administration then decides to deal with it is on them. But it should not be on us to
compromise. That compromise comes from them, not from us. They're asked to be the voice of
the underserved, of the overburdened. That's what we were charged with. If they decide, well, we
agree with you, but we think politically it's not the right time. That's for them to do, not for us to
do. That's kind of where she stands, and she'd like to hear from other people as well.
She's an academician. She knows how to debate. Her feelings don't get hurt. If you disagree with
it, feel free to say it. She's fine with that because she doesn't want to come across like a bully
because she's not. But she feels strongly about this, and she's anxious to hear what other people
have to say.
Ms. Waghiyi stated that English is her second language, so it takes her more time to process
54
-------
things. She agreed with Dr. Wright. Regarding the third bullet, she totally agreed to use race as
an indicator. Here we are in the 21st century. As a brown woman, it has failed us up to today,
March 31, 2022. It has failed her people. It has failed her. All the systems in place have failed
them: black, brown, people of color, and even low-income white people. But when we don't
include race, it's our dignity as well. We have been bringing this up every decade. It needs to be
incorporated. She's open to hearing other suggestions before she contributes more, but she totally
agrees; it should be in the screen tool.
As far as the fourth bullet, she joined this conversation this morning. She didn't get a chance to
read what was sent to the workgroup members by being four hours behind from the east coast.
She had recommended that they take out, are there lessons we can learn for other screening tools
that have and have not used race? They should take out "attempt to address." They should not be
attempting; they should be addressing. Currently, the screening tool does not address cumulative
impacts in any way and should prioritize them among disadvantaged communities. "Do you
think the screening tool should attempt.." Take out "should attempt to." They need to address
cumulative impacts.
Then, the scorecard, "What mechanisms for accountability should be in place for states and
localities..." Her state has been failing us. Here they are, one of the newer states in the nation.
Thank you for acknowledging that they are all on stolen lands. Her state does not recognize the
tribes, and most tribes in her state are against development because they're in close proximity to
our homes, hunting, and food gathering locations. Her state is heavy fossil fuel industry, and now
they're looking at false solutions. But there should be a scorecard for these states and localities. If
they do not pass, then we need to give them time to remedy the shortcomings to ensure that
meaningful changes are implemented to ensure the goal of Justice40. Even the 60 percent of the
rest of the resources and investment still need to be accountable and need to be in place for states
and localities for the implementation of the Justice40.
Susana Almanza stated that she would like to have added on there the heat island because a lot
of communities of color live in the heat island effect, and that needs to be added to the screening
tool. The other one is flooding because most communities live downstream from water and
discharge and so forth. They should also add flooding to the map. Then, she agrees with adding
race because race has been used to redline the whole United States. Race was used to segregate
in the whole United States, and race was used to make many of the laws to favor the white
establishment. So race has been used in the whole history of the United States. And now that
people of color want to use race, all of a sudden, it probably wouldn't pass in the Supreme Court,
and it will be challenged. So be it. They know that we have a right-wing Supreme Court, but that
doesn't mean they don't challenge the status quo and give the reasoning that white people have
always used race when it came to making all kinds of laws and segregating.
Ms. Lopez-Nunez stated that these are their recommendations, so she's confused as to why they
wouldn't recommend that race be a factor for every reason that Susana said. Also, she doesn't see
how this can be a tool that calls itself climate and economic justice without including race.
Environmental justice does not exist without race. She's disturbed that this trend of people
thinking environmental justice is justice for the environment because it's not; it's justice for black
and brown, indigenous and everyone of color, non-white folks, who have been left out.
Obviously, race should be included.
55
-------
She is really concerned about cumulative impacts. They should be part of our recommendations -
- those cumulative impacts get included because I'm disturbed that some dwell on which
community has the most percentile. It's about the magnifying effect. For example, she lives next
to the water, but when the waters come in, it's toxic waters because it's going to pass by the
sewage plant. It's going to pass by the power plants, by everything, and it's toxic water that'll go
into our basement and have that impact. These things compound on each other, and she's
disturbed that a screening tool would exclude that altogether. She doesn't think they need to be
that beta, that version 1.0.
In terms of accountability, when you click on the screening tool, if it's going to be the one-stop
shop, it should also show how much federal money from the different agencies has flown to the
different zip codes because I think that that'll actually get us accountability. They'll be able to
see. Wow, look. These are all the disadvantaged communities, and wow, they've gotten zero
dollars or a small percentage, just like they could see the other datasets for communities that are
not Justice40 designated, then we should be able to see where the money's flowing. That should
be kind of incorporated into the Screening Tool, and that'll be a way to ensure accountability. It
should not just be demographic things about stigma but also something that reflects back to the
government — how it's doing and where it's spending its money.
LaTricea Adams stated that not including race in this tool makes it not a tool. If we are not
going to be serious about environmental racism and white supremacy, then this was all done in
vain. It is very clear that as a collective, as an advisory, we're all on the same page as it relates to
race. But it really requires the administration, all the powers that be, to shake some stuff up.
Regardless of if it gets shut down, it is disrespectful and a slap in the face to every black and
brown person that has been advocating and fighting for decades for us to get to this point where,
literally, they tell black and brown people that we don't matter. If you don't include this in this
tool, that's what's being communicated.
In addition to that, how could we hold any state accountable to environmental justice when we're
not really getting to the core of justice because we're not including race? So she wants to go on
the record to say that it is not time to be cowardly. It is really important right now more than ever
for us to stand up against white supremacy and really focus on the injustice and the complete
disgust that has happened to black and brown people for centuries.
Co-Chair Shepard wanted to make a couple of comments. She's from New York, and New
York State has a Climate Leadership Community Protection Act which some people say
Justice40 was modeled on in terms of New York saying that a minimum of 35 percent of benefits
of investments should go to frontline communities. What they have done is to include race in
their tool. Again, this has been accepted by the state Department of Environmental Conservation.
One of the working groups is also looking to define benefits as dollars. There's no reason that a
benefit is not a dollar. So New York is looking to also define benefits as dollars.
She also mentioned that New York is using redlining again as another criterion or metric.
Initially, the tech person or tech company thought it was very complex to do, but they were able
to do it. Redlining is another key metric that can be used. Then, back in May, the workgroup
talked about the screening tool being able to track where the benefits went, where the money
56
-------
went. She hopes they haven't lost thinking about that metric, but it's very important that the
screening tool also be a tracker for where the benefits and the money have gone so that we can
easily click and see that. Again, given the amount of time the screening tool has taken and the
amount of attention, it certainly needs to be able to track benefits and investment.
Vice-Chair Tilousi stated that as far as the website is concerned, it was mentioned earlier that
the data was going to be collected through census data. A map was displayed earlier to show
what areas were identified. In their communities, specifically in Arizona, a lot of their
communities are very remote, so the census people that go out into our reservations don't get the
proper data. As she saw at another presentation a month ago, her part of the village in Arizona
was not highlighted. The latest census was not accurate. They counted 34 people on her
reservation. So she cautioned about utilizing that particular census data for some of our tribal
communities, especially the Hopi reservation and the Navajo reservation because it's very hard to
get proper census data.
She's a little disappointed as far as race not being included in the screening tool. She echoed the
concerns of her fellow WHEJAC members. If that is not included, she sees the tool as being
flawed.
Going on to the third comment as far as how states will be held accountable, what mechanisms
should be in place for states? She doesn't know how that's going to be working as far as
accountability because, in the state of Arizona, they have the Arizona Department of
Environmental Quality approving environmental aquifer permits as we speak, air quality permits
without any proper consideration of tribes or communities that are going to be directly affected.
How do they let the state departments know, and how will they be enforced? How will the
screening tool be able to enforce these in our state, in particular, Arizona and the southwest?
She didn't see anything regarding uranium or nuclear cleanup. There's a lot of toxics here in
Arizona, abandoned mines in Arizona, that people live next to. And they're still not being
cleaned by EPA or the state. Nobody's being held accountable. If they do, they do just a partial
job, and they leave. So how do we make sure this tool is going to be enforceable? They really
need to do cleanup of the uranium and make sure that they're not coming into their states and
continuing to do uranium mining with no enforcement or no clean-up enforcement as well.
Mr. Logan added some quick comments and recommendations. He supported the consensus of
the WHEJAC in including race in the screening tool. In terms of the tool itself, he's trying to
figure out where the gaps are. It's going to take a little bit of time generally. He hoped that they
have more time to also give more feedback. When he was looking at the neighborhood in which
he is from and grew up and where his mother and family live, there's a discrepancy when it
comes to a tool like CalEnviroScreen, which puts our community at the 99th percentile, which is
in the highest percentile for environmental injustice or disadvantaged community. When he
looked at the tool here, it actually puts the community as a non-disadvantaged community,
meaning that it's not disadvantaged. So there's definitely some gaps in terms of the data and
information.
One of the things that are important to include or consider is the way in which the modeling is
put together around the PM2.5. There may be a source category for one individual facility, but
57
-------
for facilities that are mobile sourced in nature, we need to look at every source category within
that facility. As it relates to diesel particulate matter, diesel particulate matter should be
considered to be higher weighted because of its toxicity, so it's just looking at the weight of the
DPM.
When it comes to traffic proximity, there are modeling and counts for traffic generally. They
should also add, as a higher or more heavily weighted factor, heavy-duty transportation, like
heavy-duty trucks for instance, not just trucks are added as just another mobile source or traffic
exposure but have it more heavily weighted. Then, also, we should include other mobile sources,
such as rail yards, intermodal facilities, warehouses from the nature, also ports, for instance.
When we're looking at the proximity to the traffic, are we looking at, also, proximity to traffic
along riverways, waterways, seaports, and the like, so exposure to marine vessels and
oceangoing vessels and other off-road vehicles?
In terms of lead paint, when we're looking at the lead paint as a factor, it should also include
other exposures to lead. So a lot of our communities are exposed to lead via drinking water. In
his community, there's exposure to ambient lead due to battery and lead smelters so include
ambient lead exposure into that as a factor as well.
Within the National Priority List, it shouldn't just include superfund sites but also brownfields, as
well, as a factor. Then, lastly, he wanted to put into the discussion around educational enrollment
as a factor. Educational enrollment is a good indicator. But really, at the end of the day, it comes
down to educational achievement. I know many people that are enrolled in higher education, and
they're on the ten-year track or 20-year track or never finish. That that's a factor in terms of the
achievement, where they get to, or if they accomplish their goals in education as a factor for this
particular tool.
Miya Yoshitani wanted to underscore the key things that have already been said, the consensus
around including race. To add from experience in California, they were prohibited from adding
race into the CalEnviroScreen, and the notable inaccuracies because of that and that there is
limitations to the screening tool without race, even though there are some ways that you can,
quote/unquote, approximate, but you can never actually attain what you would be able to attain
with including race. Everyone has spoken as to how important that is.
On the inaccuracies of census data in particular and repairs that can be made to that, she wanted
to talk about the cumulative impacts piece and how important it is to include ways to calculate
cumulative impacts on a mapping tool and why that is definitely showing up some inaccuracies
and some major gaps in this tool. The side of that needs to include not just cumulative impacts of
point source pollution or industrial pollution, also lifting up the mobile sources, but also, the
cumulative impacts when combined with climate vulnerability impacts. It's important to include
temporary events that, over the average of a year, maybe won't light up on a screen because
they're so significant. Examples include things like flaring at refineries or wildfires and smoke
contamination or exposure especially to vulnerable communities who are either working or
living outside or more exposed to the outdoors. It's not capturing the way that climate is
exacerbating the existing overburden of pollution in these communities.
The last point she made is that it needs the cumulative impact score so that you're also able to use
58
-------
the tool as a preventative tool preventing further pollution and permitting in these places that are
already overburdened. So it's not just about the investments, but it's about protecting
communities that are currently already facing an undue burden from further pollution, whether
climate or otherwise.
Co-Chair Moore stated that he totally agrees with the comments that have been made. It would
be no surprise to anyone that they talk about systemic racism in all categories, policy and
otherwise. It's the responsibility of the WHEJAC Council and this workgroup and everyone to
make recommendations to this administration. That's what's being spoken to.
He also realizes, in his capacity not only as a Co-Chair but as a WHEJAC Member, that he's not
here representing my organization. He remembered some years back when there was a report
that was done by industry particularly talking about where they should locate their facilities.
Based upon that, they identified several key factors in the siting of facilities. One was in
uneducated communities. Once was in politically disempowered communities. And then the
interesting one in that report said primarily Catholic communities. He then made a comment in
New Mexico; who are primarily Catholic communities? It's very clear that they were talking
about primarily Latino, Hispanic, Mexicano, Chicano, and other communities. Very clearly, it's
his opinion that race should be added into this. It's the responsibility of the WHEJAC Council to
listen to public comments, to keep those public commenters and the issues that they're speaking
about in mind as the Council makes recommendations. The Council can see, hear, visit; they can
do whatever to a large extent, and many of those communities will testify.
When we're talking about point four, the mechanisms for accountability, the other thing that has
consistently come up here is not only accountability but responsibility. Responsibility is also
additionally crucial to the word accountability. They have been talking about, in terms of this
screening tool and the scorecard, what if some measures are put out, but in the case of states or
other localities, they don't match that up with the scorecard or so on? Then, either the money
should be taken from them or, in fact, should've never been given to them in the first place if
that's the case.
His last comment was they have to be extremely cautious as a WHEJAC Council that they don't
unintentionally set up structures as various ethnic groups are not pitting against each other in the
process of moving forward with these recommendations. He's very clear of what his color of skin
is. He's very clear of his ethnic background. So we can go on and on at the end of the day and
talk about who has been repressed or oppressed or whatever more than others. But their
responsibility is to provide the clearest proof-given recommendations to this administration.
Maria Belen Power wanted to make three quick comments. One is just echoing everyone's
concern around race not being included and wanted to echo the urgency to do that, to include
race as a criterion. The other piece is echoing that cumulative impact. In Massachusetts right
now, they are developing how to do those analyses after the roadmap bill that was just passed
and included environmental justice. So the process of developing those tools to do cumulative
impact analysis needs to be public and transparent so that they are accurate and reflect what's
happening on the ground.
Then, just a third comment around census and data. It's been mentioned before, and she wanted
59
-------
to highlight the concern around immigrants not being counted, especially in census data in
particular in 2020 during an administration that inflicted a lot of fear and pain into immigrant
communities, and not just undocumented immigrants but perhaps mixed-status families where
some folks may be documented, and others may not. So there's a huge population not being
counted or included, especially undocumented folks that are fleeing war and violence that has
been inflicted by this very government and country in Latin America and everywhere else
abroad.
Dr. Sheats stated that he's on the Screening Tool workgroup. He asked that if anyone has more
comments or questions, just keep sending them in. The workgroup asked the question so that
other people could hear what the Council wanted. In their initial document, if you go back and
look, they actually recommended the use of everything you're talking about. But I think it's
important that everybody hear it comes from the entire Council also.
They have to write it the right way. By not using race, what they were worried about is that black
and other off-color middle-class communities will be left out. They see that when people have
done the analysis. They are seeing that in certain cases. They want the tool to be broader so it
doesn't miss these communities, but at the same time, they want to prioritize other communities
that have a high level of cumulative impacts. They wanted to achieve those at the same time.
One thing that occurred to him that, frankly, they forgot to ask the question on is also where
those cutoffs came from. Like it has to be above the 90th percentile or 60th, 50th percentile? Just
how those were actually developed because that can give you very different results also. He
thanked everybody for the suggestions, and they'll try to incorporate them all and give them
something back.
Vice-Chair Flowers wanted to make a suggestion as well. She's more concerned about the
accountability of states than she is about race. She's very concerned about the people that are
living with raw sewage on the ground, and she's also concerned about those communities that are
suffering from climate and environmental justice. And she's not willing to down a mountain of
race to have the unintended consequences of these people not getting any help at all. She would
like to go on the record to say that she would rather focus on accountability because she lives in
a state where even if race was used and it was able to get by, the people that need to get the help
will not get it. She thanked everybody for their positions and opinions. She felt that it was very
important to be honest and to state hers as well.
Co-Chair Shepard thanked the whole team for a really good conversation that is really going to
enrich their recommendations. She turned the meeting over to the brand new Climate Resilience
Workgroup that's just gotten a mandate from the White House CEQ.
2.3 WHEJAC Climate Resilience Workgroup Update & Discussion
Ms. Lopez-Nunez stated that they're going to be dealing with similar issues. Clearly, in the
screening tool, there isn't overlay of what happens with climate vulnerabilities. But they know
that climate vulnerabilities affect especially black and brown communities and low-income
communities across the country. There's this myth out there that climate change is affecting us
all, but it's affecting some of us much, much worse. How do they make sure that they're
capturing the vulnerabilities, the weaknesses, in our disaster response right now? They are not
60
-------
doing a good job. That has been long evident.
They've had more than a decade since Katrina, and she's not sure that the federal government has
learned its lessons when it comes to disaster and disaster preparedness. They've seen it here in
New Jersey just now with Ida and for most of the country. Ida started in the south and made all
its way into the northeast and still had enough force to kill people in basement apartments
because a lot of people live in basement apartments and got flooded out, and there was nowhere
to go. FEMA doesn't often cover renters. There are so many overlapping issues that they're going
to get a chance to deal with on the Climate Resiliency Workgroup.
She also asked for more people to officially join and show up to their meeting so that they can
have robust discussions. They're going to deal with FEMA, with housing, and some other issues.
They have a little bit of a long charge, but let's get started on the questions because they want the
WHEJAC's input from the beginning. And luckily, they have a good runway so that everyone
can talk now as it's drafted. Obviously, they'll come forth with the first set of recommendations
in a couple of months.
Ms. Yoshitani acknowledged the communities that were impacted by tornados and the storms
that hit the south just yesterday. Every time they get on these calls, there's going to be another
one of these events to acknowledge. That gets at the heart of what they're needing to do and
make recommendations with this working group. She thanked her co-chair for being her partner
in crime with this new workgroup, the WHEJAC co-chairs, and the whole Council for making
time to actually begin this process of getting recommendations that are based on the experience
of this body and the communities that they represent and the public. Yesterday, they heard so
many important public comments that could also be applied to some of our recommendations for
this workgroup.
Their work so far has focused a lot on the historic pollution and the inequities of environmental
justice, like the poisoning of our air, water, land, and our bodies. It's been a lot about equity and
racial justice in the ways that they also mitigate or prevent future climate change. One of the
reasons that the recommendations for this workgroup — for this area of disaster relief or just
recovery, as it should be known, and of community resilience — is so important is because it
allows us to make recommendations on the way that we want our communities to be supported,
to prepare for the inevitable, the built-in, the growing future impacts of climate change, not just
the historic damage but to prepare for what's to come what's already built in because of climate
change. Really importantly, it gives them an opportunity to be able to design, build, and pay for
the resilient, healthy, thriving communities that we all deserve.
She wanted to encourage WHEJAC recommendations and questions that they're going to start
looking at. They want to hear from the public — when we have a chance to hear from public
comment — to share stories from their communities of how they have experienced the impacts
not just of climate disasters, like the hurricanes, the wildfires, the droughts, the floods, the
heatwaves, the tornados, but how they've experienced the unfair and unequal treatment of
government agencies meant to protect and support us but instead have caused entire communities
to be permanently displaced to experience even more industrial pollution or to languish in toxic
cones and neighborhoods that have lost value because of the damage and at the same time to
have to pay even higher prices for transportation, for energy, for food, for water, for housing.
61
-------
Communities have been redlined, as was mentioned before, for decades by government policy to
these same neighborhoods and regions.
Though, we should all be sharing these experiences and also sharing the real grave and critical
concerns that recovery efforts and funding perpetuates existing pollution and inequitable systems
and housing, energy, transporting, and all kinds of infrastructure, that disaster capitalism is
allowed to profit from the climate catastrophe that EJ communities are already dealing with. So
we should be sharing all these things. She encouraged people to share both experience and
concerns. She also wanted them to be able to, at the same time or in addition, share their vision
for what it could look like if our families were just not better protected from future disasters
through equitable, climate-resilient infrastructure that we want to be built. Also, if we had a fair
and just transition for workers and environmental justice communities to resilient thriving
communities and local economies that thrive and are healthy, they could be more intact, stronger
and sustainable, more democratic, more healthy, and more liberated than they were before. It's in
that spirit that she hoped they'd be able to bring these questions in front of everyone from the
workgroup and start a discussion that is pointing them not just in the direction of the mistakes
that were made in the past. That's obviously the place to start so we don't repeat the inequities of
the past but also to really chart, through the recommendations, what it could look like if we were
building the resilient communities that we needed.
With that spirit, she opened up the discussion time to the Council for everyone to weigh in on the
questions that are in front of the workgroup. She reminded people that these questions shouldn't
be a barrier or an impediment to giving any recommendations that people want to offer. Not that
anyone has in the past but don't feel too penned in by the questions themselves. They really want
to get the wisdom.
She read the questions. What type of support is needed for disadvantaged communities to
participate in federal disaster preparedness or relief programs? How can federal disaster relief
and aid programs better serve disadvantaged communities that have historically received fewer
federal benefits? What process steps and information will help eliminate these disparities? What
steps can federal agencies and the White House take to reduce disparities in climate change
impacts for communities, including but not limited to risks from extreme heat, flood, wildfire,
drought, and coastal challenges?
Dr. Wright made a suggestion. She appreciated the presentation by Dr. Leary yesterday, which
was full admission that the government has acted for centuries in a racist manner and that many
of the people who work for the government see the world in a racist way. The results of that have
been policies that have been race-neutral that have then yielded results that didn't benefit
disadvantaged communities. One of the things that they can do is put some guidelines in place
and have a screening tool of their own. First of all, it should dictate where benefits should be
going and another tool to determine whether or not those benefits went in those places. They
need to colorize their offices. In the deep south, it needs to be colorized. She used the word
colorized because she liked that better than other words. It's prettier than some of the other things
you could say. You could have a great tool, but if you put it in that same dirty body, you're going
to get the same thing.
After Katrina, everybody could see for themselves who was left behind. Even the experiences
62
-------
that she had trying to get things from the Red Cross, and the Red Cross was in the white
neighborhoods. They were in no place where black people hung out. She accidentally found one
by going to a clinic. Nobody was there, but there was a Red Cross, and there were thousands of
people in line where black people were. So the problem is not that the government doesn't know
what the needs are. It's not even that they don't know where it should go; it's the process that
they're using to get it there and they're utilizing people who are racist and agencies who practice
discrimination and all of the things that we don't like. That autopsy that Dr. Leary was talking
about is very much needed. We've been saying this before.
She wants people to stop asking people of color how to solve a white problem. She can't tell
them how to do that. They need to figure it out, ask the questions among themselves, and put it in
place. They need some kind of system that, first of all, deals with diversifying the organization,
diversifying FEMA, and giving sensitivity training but then having a way to track and monitor
what comes out of those offices. If that were the case, we'd just be dealing with, oh, does the
government not know that they should do this or that for people who have been affected by
disasters?
They know what to do; it's that it's not getting to us. The reason is not even complicated, but it is
pretty deep because it deals with the human spirit and how we value or devalue human beings.
That's not an answer, but this is really what we're dealing with. She would love to talk about the
things that those of us who've been through these horrible disasters did not get and who was left
behind and what she thinks should happen so that doesn't happen again.
Dr. Bullard stated that this is not complicated. The fact that, when Dr. Leary presented her three
areas, there was one major area that was left out. We have laws that cover discrimination by
agencies and by recipients of federal funds. One way that a just and equitable recovery happens
is to address sending funds to areas that are climate sensitive and rigorously applying the Civil
Rights Act of 1964 Title VI. You don't need a screening tool. Title VI is a screening tool. If an
agency like a state is receiving monies to deal with disasters and if that money is being proposed
to be spent in a way that is discriminatory, FEMA, HUD, DOT, EPA, all the agencies have
discretion to not send the money.
Case number one, Hurricane Harvey devasted Houston, Harris County, and parts of Texas.
Houston and Harris County got the greatest hit. When the money from HUD, not FEMA, was
sent down, Community Development Block got money to fix houses and make families whole.
The State of Texas' General Land Office, which is a state agency that handles recovery, allocated
zero dollars to Houston and Harris County. Houston is 75 percent people of color; Harris County
is 69 percent. The two cities and counties that got the greatest hit was supposed to get zero.
Marcia Fudge at HUD, a former congresswoman from Cleveland who has extensive experience
in Congress in dealing with discrimination in housing, et cetera, she basically kicked back the
State of Texas an allocation for Harris County and said, "No, this is discriminatory. You don't get
a dime." They had to go back and regroup. When they regrouped, Harris County's getting
something like $550-, $600 million. That's not perfect, but it's greater than zero. Houston right
now is still fighting to get a dime of that money. When it gets kicked back to HUD for them to
relook at it, she has the right to say no. The way she's saying no is looking at federal funds being
used to discriminate by the State of Texas. We don't need a new law right now. We have one.
63
-------
We don't need a new screening tool. We have one.
Here's another one. When the Stafford Act kicks in and the president declares a disaster area,
FEMA basically looks at it and declares how much money it's going to send. The state itself
decides how it's going to spend the money. And by law, the Stafford Act uses cost-benefit
analysis, but it's not limited to that. Because of this WHEJAC and because of pressure from EJ
groups and the Justice40 Administration, FEMA is now using one of its programs, the Social
Vulnerability Index. SVI was developed by CDC, the Center for Disease Control. If they use the
cost-benefit analysis, because they can't throw that out because that's the Stafford Act but use the
Social Vulnerability Index in addition to what was mandated, you're more likely to get more
vulnerable, hard-hit communities that would not pass that test. The cost-benefit analysis test
would award the money to the $800,000 homes on the west side, and the $80,000 homes on the
east side don't get jack. Having adaptations and having already developed metrics need to be
applied to existing metrics to deliver more just and equitable kinds of outcomes. That's going on
right now, but those are baby steps.
Those are just two examples where, right now, FEMA's own 2020 report shows that the money's
not reaching the most vulnerable and the hardest hit. So it has to do something, and that's one
way to adjust. It's an adjustment. It's not a total overhaul. He will volunteer to be on the
committee if they have room. Ms. Yoshitani stated that they definitely have room and would be
happy to have him.
Ms. Santiago commented that what changes need to be made has a lot to do with what they've
talked a lot before about states taking the money and doing whatever. The example that Dr.
Bullard just gave about HUD and telling the State of Texas that what it submitted did not comply
with what was required to really provide disaster assistance is the key because federal agencies
have to implement federal law and policies and executive orders. We're not seeing that,
especially with FEMA. She brought up the case of Puerto Rico where FEMA is actually telling
us that whatever the government of Puerto Rico, the current governor elected with 32 percent of
the vote, what he submits to them, FEMA is going to approve that and write a blank check
essentially for the largest allocation of funds in FEMA's history. That is not the case. FEMA has
ministerial duties here. FEMA has to make sure that it has done a proper NEPA analysis that
includes an EJ analysis and otherwise implements this administration's Executive Orders 14008
and 12898.
They're not seeing the federal government, especially FEMA, implementing its own policies and
laws. This passive approach of sort of delegating everything to the states just doesn't work
because jurisdictions that really don't have environmental justice on their list of priorities are not
implementing it not surprisingly. It really requires the federal government to implement those
regulations and the laws and the executive orders.
If you go to many places nowadays — and let's say Puerto Rico in particular — and you consult
with local communities and say how would you prefer that this historic amount, the largest
amount of FEMA funds ever allocated for the electric system, how do you prefer that to be
spent? On the one hand, rebuild the centralized grid, or on the other hand provide onsite rooftop
or distributed renewables and battery-energy storage systems, energy efficiency programs,
demand response, the whole set of alternatives to centralized, fossil-fired, import-dependent,
64
-------
undemocratic electric system that we have? If FEMA and HUD and other agencies could require
that kind of consultation, that would be another way of really delivering disaster relief to
communities. They need that local consultation, actually direct consultation to communities.
Mr. Logan had a comment or question on the first question regarding how might this program
provide more support for our communities in federal disaster preparedness and relief programs?
By no means is he suggesting that we let the federal government or FEMA or other agencies off
the hook. They should definitely do their job by protecting communities and their residents that
they're responsible for. Saying that, we know that the federal government has fallen short when it
comes to disasters. At the end of the day, communities and community organizations are the
safety net for our community. Community leaders step up and help to support the local
communities and folks in need. We're kind of left to our own to fend for ourselves. So it's
important to recognize that. It's important for the federal government to recognize that they're
falling short, and they need to step up. But they also need to support that safety net that we've
created for ourselves. Saying that, there should be programs that support financially community-
based organizations and community groups with general support so that they can build up their
capacity so that, in the case of disaster, they have the bandwidth, they have the ability to be that
safety net that they have been and they've stepped up, and so that they can determine for
themselves what those programs are, what the approaches are.
It may be completely different for one community versus another community. One community
may want to set up hard brick-and-mortar types of systems, like having Zodiac boats and having
secure relief facilities and having emergency medication and supply sources and so forth. Others
may have other types of mental health support units kind of at the ready. So it's important for
them to advocate for the federal government to support communities with general financial
support and let the organizations and groups determine for themselves what they need to kind of
step up in the case of a disaster. That should be a large amount of money and resources to be
determined by that local community on their own terms.
Ms. Waghiyi stated that there are 229 tribes in Alaska, and there are 573 in the nation. That's a
lot of tribes in our state. They have communities falling into the Bering Sea due to erosion,
violent storms. There's no ice, so there's erosion. The ice is melting because of the warming of
the planet. The Arctic is warming three times faster than the rest of the planet. They have been
the canary in the coal mine for decades. Our elders recognize the importance of protecting our
Bering Sea, which they called their farm. Ninety percent of our homes eat only traditional foods,
majority of them marine mammals. And yet Shishmaref and other communities are falling into
the Bering Sea because the funding that they received decades ago had to be matched.
These tribes are poor. And yet, this should not be happening. They are going to continue. They
have high rates of death, ten times more cancer than our state of Alaska. Ten times more cancer
because of the military toxics. Here they are, yet, at another war with Russia. There's legacy Cold
War-era toxics on her island that are still harming the health of their people. They have a cancer
crisis, and now a climate crisis, including bird die-off, seal die-off, fish die-off, and whale die-
offs. These are burdens they didn't create. Like the woman we heard yesterday, she is tired.
They've been testifying, speaking in these rooms for decades. She has to go home and recover,
pouring my heart out. And I'm being honest.
65
-------
This is what she does to help her people, to deaf ears and broken promises. She has been chosen
to be a voice for Alaska and arctic-indigenous people because of the crisis of our food. The
Arctic Ocean has the most microplastics, so these marine mammals are eating plastic because the
surface of the ocean is warming. So the food they depend on has to go deeper. That's why we're
seeing all these die-offs. When they can't eat, they're going to die off as a race. Yet here they are
pleading again, over and over.
Regarding communities that need to relocate, there's an urgency. Help these people, the first
people of this nation whose lands were stolen, and they're not getting any assistance from our
state or federal government. They need housing adequate for the arctic. By the time the homes
that are sent here arrive, they're million-dollar homes because of the shipping, the HUD homes,
the pre-fad homes that are not made for the arctic. There's no insulation on the floors. There are
no adequate vents. Because our homes are closed in longer during the winter. They're getting
mold.
Overcrowding, 20 people in one home. Her state congresspeople came to Alaska and talk about
the housing crisis a year ago. They've never seen any assistance. It's a photo-op opportunity for
them. And now the crash of our traditional foods in the oceans, we have people going hungry
when there's a crash in the fisheries. Bristol Bay has one of the largest fisheries on the planet.
When there's a crash in the commercial fishery, they get monetary aid. Their food sources are
crashing. They're not getting any aid. Her people are going hungry.
They have military toxics. In the previous discussion in the screening tool, they're called
superfund sites. But the military is the largest polluter on the planet. It should be labeled as
military toxics. They have persistent organic pollutants. We now know the arctic is a
hemispheric sink. Because of the warming, they are seeing changes in the ozone layer, life-
threatening changes to arctic indigenous people. The other arctic nations in the European Union
have better policies and laws protecting their people. However, here we are in the United States
of America, and our people are forgotten. They're never at the table when decisions are being
made for us miles and miles away. These are some of the things she would like to bring up.
Ms. Almanza stated that some of her recommendations are more prevention control, but we
need to control the amount of impervious coverage on properties because covering the earth with
cement increases the flooding. There are no strict regulations on what's happening across the
United States. The other one is the infrastructure to relieve flooding. So you'll find that, in a lot
of grassroots or communities of color and poor communities, the infrastructure, the sewer
system, it's so antiquated, and it's old. So it doesn't address the heavy flows of the rains that we're
now getting through climate change, so that sewer system has to be funding appropriated. Of
course, we have to address the erosion controls that are happening because of all the
development that's going on, the cementing of our earth.
The other one is that we need to provide solar energy for low-income and people of color
because, during these hard times and these heatwaves, the people who are dying and suffering
are those that do not have that solar energy and access to it. Also, we need to address the digital
divide when it comes to disasters and crises because everything's on the internet — the warning —
as if everybody is hooked up, and they're not. Even to get resources, you have to have that
internet access. Then, of course, provide the resources for neighborhood planning at the
66
-------
neighborhood planning area by and for the neighborhood.
Ms. Yoshitani reminded everyone that these were the questions that were part of the charge. The
working group didn't make up these questions. These were the questions that came to them. So
that's part of why she wanted to encourage people to not be limited by their recommendations
just to these questions because they're going to try to be a little more expansive with the
recommendations coming from the workgroup.
Kim Havey shared concepts around resiliency that he's been working on with a group of city
officials across the country and also within his area in the Twin Cities. One of the things they're
looking at is creating community-based community centers that are acting as resilience hubs that
provide access to a lot of the different types of emergency services in times of need but also act
as a regular community resource for education, for community events, for food distribution, for
community gardening, for elderly care, what have you. So looking at the concept of resilience
hubs would be really interesting because it's something the federal government can do and has,
actually, with different funds to sort of harden buildings and things, really has looked at but
hasn't done in any significant way.
There are also really good opportunities, as Ruth mentioned earlier before, to utilize new
technologies around renewable energy, battery backup systems, and microgrids. Minneapolis just
received some federal technical assistance through the DOE LEAP grant program to really work
on a microgrid system in north Minneapolis. It's going to connect three buildings of the
Minneapolis Public School Systems, one of which is their main nutrition center or kitchen for the
school system. They have about 25,000 students or so in the school system. So they know how to
make a lot of food.
Basically, the solar rays along with the technology and battery backup would be able to allow the
nutrition center to run a nearly full operation on a continuous basis. So there are really, really
some unique opportunities when they have disasters that knock out power or create access, again,
to the internet or create just safe shelter if it's very cold or extreme heat. They've been seeing that
a lot more in Minneapolis now. They're not really a city that's built for a lot of heat, but we've
been seeing it gets so much hotter for so many longer days. By 2050, they say that they will be
going from, right now, about 13 days over 90 to 65 days over 90 over the summer. That'll be an
extremely different experience than it currently is here in Minneapolis, and they're not really set
up for that kind of heat. Not everyone has air conditioning.
Looking at how they utilize the infrastructure around the resilience hub and also around, really,
the whole idea of weatherization improvements on buildings is great. The resilience of our
buildings is all in the same kind of thing whether they have insulation, whether there's the ability
to seal doors and cracks and things. He was actually in Galveston during last year's February
deep freeze. It was not surprising why it was so challenging to keep the buildings heated because
there was zero insulation in any of the buildings anywhere. You could see right through the floor
almost. They don't fund that in a lot of those areas because it's not something that's been used.
Again, resilience-wise, make stronger structures, be able to handle higher heat extremes without
power. They don't need all of this, everything being cooled and heated all the time. So they have
to create this into the design and weatherization of our buildings. That's another way that they
67
-------
really need to look at resiliency. To leverage the energy reductions is also a resiliency strategy.
Ultimately, for a community to be resilient, it has to be a healthy community, really being able to
integrate with health indicators. They have a lot of data on asthma, and they talked about redlines
earlier today. You can literally see the redlining area that, from 1940, is basically similar to
where we have also currently highest asthma rates and highest cumulative pollution. Talking
about resiliency and health and that cumulative pollution, cumulative pollution is probably the
most impactful in regard to the indicator of whether communities have long-term health issues.
It's not rocket science to make that connection. That's why it's so important to have these metrics
that look at cumulative pollution and long-term exposure. Much lower quality of health is very
tied to that. Resilience in a community has to mean that we also have to figure out how we're
measuring the health of that community as well too.
Dr. Wright stated that she has three suggestions based on actual experience. The first is that
federal contracts that are given out to respond to disasters need to be revisited. What happens is
that, when there are disasters, you have these huge companies with federal contracts. They come
from all over; rarely are they local. So they literally put local businesses out of business because
the job of redoing roofs and all of that goes away.
The same thing is true with feeding people. New Orleans, some of the best chefs in the world,
ready to feed people who were left behind, and they could not. They would send army rations in,
all kinds of terrible food, which costs a lot more than a pot of red beans and rice, which they
would've enjoyed much more. Just dealing with federal contracts and how that really impacts
people on the ground, is it really helping people to recover if you're destroying the economic
engine of a community with large outside contracts?
Also, revisiting the Stafford Act which guides so much of this stuff. After Katrina, the
communities that were able to get funding to raise their homes were based on a formula that
made no sense. In order for you to get hazard mitigation funds from FEMA, you have to have
had at least two other incidences with flooding. Well, the places that flooded because of the
hurricane were not the places that naturally flooded in the city. So the hazardous mitigation
money went to the very elite, very expensive houses. They got 500,000 to raise a house. New
Orleans East, where mostly black and poor people live, got nothing because they have not had
repeat flooding. That's really an unbelievable mistake based on the way the law was written.
The other thing is to look at city emergency management plans. Now that we know what will be
coming, the emergency management plan that the city of New Orleans had was totally
ineffective, where large numbers of buses went underwater in a city where the majority of the
people had low-paying, tourist jobs. Then, they don't get paid until Monday. They do that so
people will come to work on the weekend. And the hurricane came on Sunday. So a lot of people
who didn't leave could not leave because they live from week to week. So those emergency
management plans need to be put in place and reflect, basically, what the possibilities are. We
were planning for hurricanes, and now all of a sudden, we have tornados. She doesn't know what
to do with a tornado. She's an expert on hurricanes, but not tornadoes. A lot of things need to be
revisited.
The way the Army Corps of Engineers actually deal with large projects — she called them the
68
-------
dirt movers because that's what they do. After Katrina, they had the wealthiest communities that
got the least amount of damage got the highest amount of levy protection. So they already had
more levy protection than anybody else. As it turns out, their projects were already in the hopper.
So when the money came, all of that money went to the projects that were in the hopper rather
than have them respond to the disaster that was on the ground and the need. So there are things
that need to be revisited and examined to make it look more like what's happening on the ground
and that it does not end up, really, causing more pain and harm to people who have been affected
by these disastrous storms.
Jade Begay stated that in Noatak, Alaska, FEMA did not show up for Noatak during a relocation
effort. This is a Yupik community in Alaska, and they are currently in the process of having to
relocate from this village to a new village. They have received very little support from the
federal government in this relocation process to the point that outside organizations and
contractors are having to come in to assist with this entire relocation. As you can imagine,
putting the burden on this community that has contributed the least to climate change is wrong in
so many different ways. She wanted to flag that this is a situation that is happening right now as
we speak that could be studied.
If people from various groups in the EPA or other departments and agencies engage with this
community, there could be lots of lessons learned as to what didn't work. At what point did this
community need support? At what point could there have been helpful intervention from the
federal government, federal aid, and different parts of the federal government? It seemed like an
important one to study and learn from and respond to right now as the community is still needing
lots of funding in their relocation efforts.
Ms. Yoshitani suggested that more folks need to join the Committee. Last time, the workgroup
members were outnumbered by agency staff, so they'd love to have more company. Mr. Logan
asked for a bit of clarity on what the commitment is if they were to consider joining the
workgroup, what the time commitment is. Ms. Yoshitani replied that they meet every other
week on Wednesdays. They have an hour-and-a-half long meeting once every other week so far.
DFO Martin added that they're meeting on the second Wednesday and the fourth Tuesday.
Ms. Lopez-Nunez thanked those who made comments and expressed an interest in joining the
workgroup. She hopes that they start talking more about climate justice and the way that
environmental justice is climate justice. There's no separation. Storms are not going to surprise
us. We know that they're going to keep coming, and they're going to keep coming with a lot of
frequency. So, with that frequency, we need to be prepared. And we need to make sure our
people are prepared so that our people survive and that our people build back much, much better,
that we change the way the system's been working, not just reacting to all the bad things, but that
we have vision about the next life we're going to live because it's just going to be true that sea
levels are going to rise and things are going to get hotter and worse for a lot of us. There's a lot of
gravity to the charge that this workgroup has, and she hopes they can rise to that gravity and help
protect the people. DFO Martin announced that it was time for a break.
2.4 WHEJAC Justice40 Workgroup Update & Discussion
Co-Chair Shepard stated that they will be discussing the Justice40 implementation workgroup's
69
-------
recommendations. They have developed a draft. It's the Phase 1 recommendations to the White
House. They hope to vote on and improve them at the next meeting. The WHEJAC did submit
recommendations back in May on eligible projects, but now, these are recommendations about
how the administration should actually implement Justice40.
Also, the workgroup has really spent the last few weeks populating a Google Doc, and they are
about to send that draft to an editor to get it formatted and to just ensure that it's accessible and
reads well. They are concerned that they would like to have more discussion and more
recommendations from the entire FACA. So, they're going to present how the report is formatted
and what the categories are so that they could begin to have a discussion.
Dr. Wright reminded everyone that they should be addressing both the federal government and
the state's accountability. Their job here is to make certain that the voice of the underserved and
overburdened is represented in the implementation of Justice40. For her, this is the hardest job
and she thanked everyone for the support she's received.
Co-Chair Shepard explained how they have formatted the report. They are looking at cross-
cutting agency recommendations. What do they mean by that? Well, for instance, what's a cross-
cutting agency recommendation? Maybe prohibiting the use of all agency funds for fossil fuel
generation and infrastructure. That might be an example of a cross-cutting recommendation.
Another one could be that Justice40 investment shouldn't reproduce existing inequities by
providing technical assistance or identifying barriers that less well-resourced entities have in
securing competitive grants, looking at a number of recommendations that apply to all agencies.
They look at the theme of public participation. They're talking about things like agencies should
be mandated to translate and interpret all outreach materials in a variety of languages and talk
about ways that they can ensure that communities that don't have access or expertise to
understand complex environmental impact statements get that kind of access.
There are a number of recommendations that they're making under public participation. When
they think of transformative practices, they're talking about doing business in a different way, not
business as usual, and really talking about how they benefit those who have not had access to the
system instead of the usual suspects. They also have a theme of grants and funding. Again,
making recommendations about how a grant should cover and approve and direct cost rates.
They should not be based on reimbursement, how reporting can be simplified.
When they talk about proposed infrastructure projects, they get a little more specific in talking
about how feedback should come from overburdened communities and how that feedback should
be incorporated into program or project design, that infrastructure projects funded by the federal
government should prioritize fair labor standards and use of MWBEs. Again, talking about
workforce development programs and those kinds of projects in regard to infrastructure.
Accountability incentive structures recommendations, for instance, one recommendation might
be that every agency should develop an annual report on their implementation of Justice40 that's
disseminated publicly. Again, how do they ensure that that accountability happens? Develop a
remedy or a penalty for states or agencies that don't comply with the intent of Justice40
investments. Again, that accountability theme is going to how they ensure compliance with the
70
-------
federal intention.
Then they had a category of specific agency recommendations. They've listed a number of
agencies where we have very specific recommendations for how they should implement
Justice40.
So, that's really how they're formatting the report. It'd be great if there are observations or
comments on the formatting. Have we left something out? Is there a better way to do this?
Certainly, they want to hear your recommendations about these categories and the kinds of
recommendations that you would want to see made. They have sent the draft out several times to
the entire FACA, and hopefully, they've had a chance to take a look at some of the
recommendations from the workgroup. She opened the floor to questions and comments.
Dr. Wright stated that over all of these months that they've been having discussions and making
recommendations through our discussion, is there any other way that they could be certain that
they captured what they've all said through these few months? For instance, they made
mentioned a lot of ideas throughout the discussions, but she didn't see them in the document. She
wanted to make sure the ideas were captured as recommendations. Co-Chair Shepard reminded
everyone that if someone is making a recommendation, they need to write it down so that it can
go in the Google Doc. If someone does not have access or for some reason cannot use the
Google Doc, they can email it to DFO Martin.
Ms. Waghiyi recommended that tribes are allowed to attend government-to-government
meetings to get recommendations from tribes. A lot of times, when they meet with the
government, the decision-makers are never there or there's unfinished business. An example is an
Indian Affairs Committee had a hearing on our island a year ago. They did not get to the military
toxics issue that was on the agenda because there was a pending storm coming, and they didn't
want to get stormbound on the island. This is not government-to-government consultation. They
need to meet with tribes.
Mr. Logan stated that he had a recommendation on number one specifically — prohibit the use
of all agency funds for fossil fuel generation and infrastructure across the government. He would
like to expand that to other areas that can increase impacts on our communities. Specifically,
they should recommend a prohibition of funds used to expand highways and freeways, adding
lanes, adding traffic, adding diesel trucks to the road, making the kind of impacts on local
communities that much more harmful. That should also apply to the expansion of other freight
facilities, like logistic centers, rail yards, and ports.
The expansion of these facilities adds more throughput, traffic, diesel exhaust, and other toxic
pollutants to communities. By including that, there's a potential of opening up like a can of
worms in terms of who can expand it to add all kinds of different toxic and/or polluting sources.
He wanted to just broach that and figure out the best way to approach it to include some of these
other types of investments that can add more harm to communities. He understands there's a
Google Doc and that they can add to that, but he thought that there is some need to have a
conversation about, where do we draw the line in terms of what we're asking for the prohibition
on expenditures of the federal government. Co-Chair Shepard asked if the conversation should
be now or in the working group? Mr. Logan replied that they can probably have a more
71
-------
productive conversation in the working group.
Vice-Chair Tilousi stated that she'd like to understand the process better. She wanted to submit
written recommendations but didn't understand where and how her recommendations were to be
implemented. DFO Martin replied that she does go through the summaries and pull out the
recommendations and send them to the workgroups. The process works like this. The workgroup
gets the charge. They come up with preliminary recommendations. They get sent out to the full
WHEJAC and the public for input, comments, and additional recommendations. The workgroup
synthesizes those comments and gives another version to look at. More comments are given, and
the final document is sent.
Ms. Waghiyi ask if the recommendations in number one (Cross Cutting Agency
Recommendations), are they for the number two agencies that are listed? Co-Chair Shepard
replied that the recommendations in number one are for all agencies in those particular
categories. Ms. Waghiyi asked if the recommendations from Justice40 will go to the agencies
listed in two? Co-Chair Shepard replied that they go all to CEQ. DFO Martin confirmed that
all the recommendations will be shared with CEQ. They had quite a few recommendations that
were just general federal government wide; that's the first group. The second group includes
recommendations specific to individual agencies. Anyone can add something missing in a
section or add a missing agency.
Ms. Waghiyi suggested adding the Department of Defense and the Army Corps of Engineers for
the toxic substances' disease registry. The recommendation for the Department of Defense is to
do congressional investigations in all the formerly used defense sites. Some that are on the
superfund list that ranked high enough but were never placed on it. They have never had
adequate site characterization, or they closed prematurely. The stakeholder's data and
stakeholders' recommendations or tribes were not a party to these records of decisions. Dr.
Wright and Co-Chair Shepard clarified that it has to be submitted in writing by April 8, not
only said in the meeting, to be included in the document.
Dr. Sheats stated that looking at general recommendation number one, prohibit the use of all
agency funds for fossil fuel generation and infrastructure across the government, he assumed that
it will also include prohibiting the use of funds for CCS there. He wondered if they should spell
that out and not leave it to chance. He will send that recommendation in writing.
Ms. Power liked Dr. Sheats' comment about carbon culture around fossil fuel. She will send that
recommendation to the fall solutions. Ms. Waghiyi suggested adding solar energy to prevent
mining for lithium Indian country. That's creating more harm, and they need to clearly look at
harm to environment and people in these solutions.
Mr. Cormons pulled out and highlighted one piece that relates to part of the conversation
yesterday after Dr. Leary spoke to the group. He underscored the major shifts in agency
functioning that they need to see to truly realize the spirit and the letter of Justice40.
Transformative practices were mentioned earlier, and they're not in a position where they can
settle for anything less than transformation right now. That includes transformation in the way
agencies approach their work. Having experts in the administration, like Dr. Leary, who are
psychologists who focus on how to make change within organizations and applying that kind of
72
-------
knowledge to federal agencies is of paramount importance right now.
The aspect of the direct recommendations that he wants to lean into is the section on incentive
structures because it's really critical if they want to see a change to be sure that from the
individual level to the team level to the full agency level that there are clear incentive structures,
clear carets, clear sticks in place that look at how agencies are fulfilling Justice40
recommendations, how well they're doing at appropriate stakeholder engagement, et cetera, and
frankly, that things like pay in bonuses and evaluations are tied to those metrics to really create
that HR infrastructure in agencies to ensure that the things that needed to be prioritized for
change in transformation are. So, that's something that he hopes that as a workgroup, they can
continue to study and look into to inform the recommendations. Co-chair Shepard asked if he's
talking about the accountability of agency staff and advancing environmental justice and
Justice40? Mr. Cormons agreed — building the structures within agencies to ensure that
accountability.
Dr. Wright wanted to clarify that there are no recommendations to EPA in this group. The only
agencies they have recommendations for are the ones that are listed in number two. That's it?
Co-Chair Shepard replied that it's in the middle of the list. Dr. Wright apologized for not
seeing it.
Co-Chair Shepard asked when the next Justice40 workgroup meeting is? DFO Martin replied
that is April 20th.
Mr. Logan wanted to know how to consult with the working group about his recommendations
before the dates given. DFO Martin replied that he can still do both, submit it in writing and
join the meeting as long as they're not over quorum because this is the largest workgroup. Co-
Chair Shepard added that, for the most part, there's usually a space or two empty, so just let
them know if he's attending or not.
Ms. Santiago thought they were supposed to meet on Wednesday, April 6th. DFO Martin
replied that she had sent a cancelation notice for all meetings that week because she will be out
of the office on leave.
Ms. Lopez-Nunez asked when the final guidance is supposed to be issued to the White House.
Corey Solow, Deputy Director for Environmental Justice - CEQ, replied that they understand
and deeply appreciate the need for timelines and for transparency in the work that they're doing,
and they're doing their best to keep them all updated. She doesn't have a date at this time to be
able to share, but their recommendations on the Justice40 initiative from last May were
instrumental and continue to be in the development of the July guidance that was issued. They
will keep the WHEJAC updated as they continue to move forward with their processes on the
White House side.
Co-Chair Shepard stated that they were transitioning into the business portion of the meeting.
2.5 WHEJAC Business Meeting Reflection & Conversation
Co-Chair Shepard stated this is time to reflect on the meeting, the public comment period, any
73
-------
other workgroup updates from the workgroups that have already been presented. There are no
action items today. This is a space to have that kind of catch-all discussion.
She heard some very compelling public testimony and some 10- and 20-point plans that sound
much like some of the recommendations. She opened the floor for discussion.
Ms. Santiago wanted to go back to the climate and economic justice screening tool discussion a
little bit because she wanted to add something. It was mostly said that the tool is not as easy and
that the methodology and the indicators need to be expanded and that surprises were found when
they looked at certain areas that they're familiar with, like Puerto Rico, one of the places with the
largest Afro Puerto Rican populations and among the highest poverty rates and very polluted is
two of the four indicators.
She also wanted to go into the aspect of race as an indicator or race as criteria for allotment
allocation of the benefits under Justice40. She agreed with what a lot of people said, but she
wanted to add that the concern is that including race as one of the criteria would open up the
possibility of an attack on the whole tool. She thinks that this position that they're seeing would
imperil the whole program, the whole possibility of the allocation funds. There's an attempt to
provide a lot of other criteria, especially poverty, that aligns a lot traditionally with race in a way
to get those benefits to the overburdened, disadvantaged, or the environmental justice
communities.
She wondered whether this is possible, whether someone has or can provide them with a
document that lays out that risk about including race and having a possible attack where the
courts would apply the strict scrutiny standard to the tool and the initiative and find that it was
inappropriate to do? As surprising as that may be to all because of race, as most people have
said, racism is what brought them to where we are in terms of the overburdening of communities
of color and poor communities.
She asked if there is a memo, or can they have access to a memo that lays out what this risk is
and what this danger is? She's seen a little bit about the discussion of certain supreme court cases
where they rule out the use of race for certain benefits. It would be helpful to know if there is a
memo saying, this is the risk we see, this is the case law, or these are the decisions that could
lead them to the problems with this tool but have a fair analysis about other situations where that
has not been the case, where race has been used successfully to determine benefits.
Co-Chair Shepard asked if she wants Ms. Solow to go back to CEQ and provide a legal opinion
on why they do not want to focus on race? Ms. Santiago replied that legal opinion is right, but
not why they don't want to focus on race. Is there a balanced approach to see what the reasons
are for not considering race but also consideration of situations where race has been used to
allocate benefits so that they see the whole picture of the legal analysis that's gone into this? Co-
Chair Shepard asked if they can just make that request, or do they have to put that in a letter?
DFO Martin replied that it doesn't have to go in a letter. If they want to vote to move that
forward, they can do that and document it and forward it to CEQ.
Co-Chair Shepard informed everyone that they have exactly the number of members they need
right now for a quorum to vote, but if anyone is to leave, they will not have a quorum. Anything
74
-------
that anyone thinks they might have to vote on, let's kind of hear it soon so that they don't lose
anyone. Dr. Wright reminded her that there should be a discussion before the vote. Co-Chair
Shepard thanked her for the reminder.
Dr. Wright stated that from what she can tell, there are two legal opinions. There's one group
who believes that it shouldn't be a problem and there's another group that does. If you get one,
the one they'll get is the one that the agency supports. That's one thing. She feels that this is not a
decision that they make. Their charge is clear. If it becomes a political decision, a strategy, then
that's on the Biden administration, and they'll have to live with whatever they bring back to them.
She doesn't want to feel compelled because they feel it's a high risk to not move forward.
The Council's opinion needs to be based on principle and that the politicians do what they do.
We're not politicians. It would be at our disadvantage if we did that because she's not going to
change her mind about what she believes is a principal kind of thing. Then when we ask that
question, they'll come and say, well, we gave them all this information. We told them what the
risk was. They still wanted to go ahead, so the Council ends up creating a situation of us against
them unnecessarily because, in the end, it is their decision, but this is ours in terms of what our
recommendation is.
It wouldn't be the first time that no one's listened to their recommendations. She always thinks
about they have to be strategic, but sometimes, by not putting pressure on people to do it is the
right thing to do, the right thing never happens. In the end, it's going to be the Biden
administration's decision regardless of what we do. She would not like to get into a situation
where they're saying, these are the facts for us. She wouldn't like the republicans to hear the
Council talking about it so much because then they'll start working on it very quickly if we put it
in. We're making a case for it and here we go.
She's kind of against sending an official letter asking for that. If we could get something from the
insiders, if you know what I mean, we could be inside outside as we call them. We get a lot of
stuff that comes anonymously. She would certainly maybe like to see that, but she's heard from
two sides of this situation already, and she thinks it wouldn't be a wise thing to do at this point
because it's so political.
Mr. Logan stated that he thinks that there's a risk of asking for a legal opinion on this issue
because, if the opinion comes back that we don't like, it's going to help to aid the opposition in
kind advocating for what they want and what we don't want. It kind of puts us in, I think, a risk-
averse position. He is not completely opposed to it, but he does think that it's probably a decision
that we shouldn't make today. We should take some time to think through it just a bit.
Ms. Waghiyi stated that she heard from public commenter Dan Solitz that the president will be
moving Cold War legacy site budget to make more weapons of mass destruction already on their
lands. There's more legacy military toxics harming the health and well-being of people globally
now than the cost of the current war. This is not right, and it's alarming to hear that they're doing
this. There's already harm being done to communities throughout the globe from military toxics.
Taking that funding away when these sites have never been properly characterized or remediated
is wrong. She doesn't like to say clean up because they will never be cleaned. This is very
75
-------
alarming to her, and we've been fighting to hold the military accountable since they left her
island. They were a very important strategic location during the Cold War, and yet, to hear
they're moving funding from Cold War legacy funding sites to make more weapons is unethical
to her.
She heard a public commenter say that she was tired of coming to these rooms to share her story
over and over. That's why it's so important that we have these agencies come to listen to these
public meetings because she's been in the same boat for 19 years to share their story over and
over and not see results.
Vice-Chair Flowers said she wanted to second what Ms. Santiago said. It's important to make
informed decisions, and one reason why is one of the things that Brian Stevenson has been very
successful at is being strategic and making sure that he chose cases that could benefit not just one
person, but a lot of people. Likewise, it relates to the criminal justice system. They must talk
about environmental justice and communities that have been suffering.
There's a balanced way to present this. They could see cases for and against and see exactly how
many cases have actually upheld race being used as an indicator when federal funds are
dispersed. She would like to see an example of that and what the political climate is and whether
or not it's happened. Her concern is not to throw out the whole program on this issue because the
communities that she represents have been suffering for years.
When she flushes her toilet, she doesn't see it, and most people that are on this call don't see it
either. Some people have been seeing this for years and folks have been passing by and going to
Selma and going to Montgomery and have not stopped to see it or to offer any help. She is very
passionate about seeing that issue be addressed.
Last night, she was up because, in Lowndes County, there was a tornado on the ground. The first
thing they say is, if you're in a trailer, leave. Most of those people are living in mobile homes,
and they have nowhere to go. These storms are getting worse, and they're getting them every
week. The same thing is happening in New Orleans because she's exchanged text messages with
Dr. Wright about what is happening there as well. She wanted to go on the record that she wants
to be against using anything that will keep people from getting help.
Ms. Lopez-Nunez stated that this conversation is making her get nervous, but she does support
them in making informed decisions. But she doesn't feel comfortable with laying out a roadmap
for people that hate the use of race in any programs because, if the administration has decided
not to use race, they've done some research. As Dr. Wright said, it's their decision in the end, and
they've been informed by something.
She wonders if there is a compromise here. They might be able to hear rationales in like a
business meeting or a workgroup meeting because she wouldn't want them writing a detailed
memo. She's not sure that they would comply. Legally thinking, it's all strategy in the end. If the
administration is being asked to put out their strategy, she doesn't think that that is strategic of us
to do. Race doesn't just affect us here on this program, but race is used in other programs. In the
light of thinking strategically, she does want to know why they made their decision, but she
doesn't want that spelled out on paper because there are so many people that hate folks of color
76
-------
in this country. She would love a document like that to be able to launch fair defenses. So far,
they've been ahead of us and have been able to cut down our rights significantly.
She wouldn't want to make it easier for those that would try to hurt us, but she does think that the
members of the WHEJAC should be aware of what the thinking was as much detail as we can be
provided as we're provided with other briefs and rationales. She definitely does not support
getting it in writing and laid out for everybody to see including those that would harm us. That
makes her very uncomfortable.
Co-Chair Moore recommended that they don't move forward with sending a letter. He thinks
they may have taken care of that already. He also agreed with the other comments. He wanted to
reiterate that there are things that they do as WHEJAC, and then there are things that they don't
do as WHEJAC as our individual organizations, institutions, or whatever. They just need to be
extremely cautious about how they move forward on this issue.
Dr. Wright said she's not against getting information and having an informed decision, but she
doesn't think that that should be done officially through this body. That's her point. There are
cases and different groups that have made decisions to move forward with the race and others
who made decisions to move without race, like California versus New York.
She wanted to reiterate that the political decision is a Biden administration's one, and they will
make it. But the political decision is not our decision. One of being strategic is saying that race
should remain in this decision so that the Biden administration can begin to think more
innovatively of how to get things through making certain that not including race doesn't harm
people, and she thinks it does. It's a huge topic. It's not one that started today about whether or
not race should be included in the years of fights we've had, affirmative action, for example.
The same thing happened with that issue as the conservative republicans move and take charge.
It becomes a political decision for them. She's saying no official letter should go from this body
asking the administration to respond to it. However else you want to get information, that's fine.
She thinks that that would be toxic, and it could hurt all of us in the end including the Biden
administration, whether you use our letter to say the WHEJAC recommended this and you did
something else.
She wanted to bring forward the situation that's happening, Dr. Sheats, with the Environmental
Justice Leadership Forum where they have environmental organizations who don't agree with us
on everything. They grew to agree with nuclear. They agree with these other things that we don't.
Their platform moves forward with standing where they are, and our platform moves forward
standing on the principles that we have. There are two different entities here, and she doesn't
want to be confused as being involved in the political decisions but dealing with the moral issues
and being strategic. There's a strategy to hold into race. It forces them to push a little harder to
get something done in another way.
Otherwise, we're just in the boat with them moving very slowly towards reaching the point
where we want to be. It's an outsider agitator approach that has gotten us what we have. We went
back and forth on slavery how many times on segregation and integration. The NAACP had to
push forward on a principle, and they did lose often, but they finally won. That's her point. She
77
-------
sees that as being who we are, not the political side that will make that strategic decision.
Ms. Power asked if it's possible to have a verbal briefing, like a conversation, with the
administration so that they hear from the WHEJAC. So we don't send a letter in writing, and they
don't respond in writing. But is it possible to have the administration join the WHEJAC during a
meeting to have this conversation and to be able to ask questions and go back and forth? Co-
Chair Shepard replied that they could make that request and she would imagine that they come
before them. Is there a consensus that we want to do that? Dr. Sheats replied that caution is in
order here, and, if we did want information, you might want to also have another source, like the
NAACP legal defense and education fund in addition if you wanted to do that at all.
Dr. Bullard wanted to clarify that, when you say the administration come and speak, well, that's
Brenda Mallory. That's CEQ. That's the White House Council Environmental Quality. So, the
administration's position is clear. The CEQ and CEJST data are clear. It's obvious when they
present this stuff when they get to the race thing, they wax eloquently when they're talking about
their bottles and their whatever. When they get to the race, they start stumbling and stuttering
back and forth or pulling off a Forest Gump. You have to realize that they do not want to touch
what they see as a third rail. Co-Chair Shepard transitioned to a new topic.
Mr. Logan wanted to raise the issue of the third recommendation. He wanted to know where
they are and get an update on their recommendation for the executive order. He looked on the
website, and the recommendations are no longer on the website. Where are they on this? Can
they elevate this to a level to get some action? Even if it's a response rejection, they deserve to
know what that response is. Vice-Chair Tilousi said that she's been asking WHEJAC members
that same question because it bothers her as they proceed forward. The executive order is the
basic foundation of what we're trying to do here. We were last told that it was due to lack of
staffing, and we have not heard anything back from CEQ.
Ms. Solow appreciated Vice-Chair Tilousi and Mr. Logan's questions about revisions and
updates to Executive Order 12898. As Chair Mallory has said at numerous meetings, they greatly
appreciate all the time and energy and effort that went into the recommendations that were
produced last spring, including ways to reinvigorate this outstanding executive order. They are
continuing to do that work within the White House and, as Chair Mallory noted yesterday, look
forward to being able to provide you with updates as soon as they become available. They
greatly appreciate the Council's work and patience with them. They take very seriously the
responsibility of moving forward with an environmental justice-related executive order.
Mr. Logan suggested that they add this topic to the agenda for the next meeting so that they
make sure that they're following up with it with enough time that it deserves to have a full
discussion? Co-Chair Moore suggested that they draft up a very short letter around this
particular item with the executive order and that they agree as an advisory council to move that
forward. Dr. Wright expressed her frustration with the lack of response to questions asked
during the meeting.
Co-Chair Moore replied that part of the reason why he said that is because we requested this
before. In some cases, some of the staff may not be able to answer the question. Dr. Wright
responded that if staff cannot provide a response or do not know the answer just say so.
78
-------
Co-Chair Shepard asked if all questions will be responded to in two weeks; is that correct?
DFO Martin responded that the two weeks is not part of the time limit. CEQ gives agencies two
weeks to review because they have to go through a review process. Those questions that are
submitted may go public, so they have to be vetted before CEQ can get the answers back to the
members. What they have committed to is to start rolling these out on a weekly or biweekly basi
to the questions that CEQ has received responses to. The Council just got a batch of them in that
they'll be sharing over the next week, but for every question that has been asked, they have been
tracking and working with CEQ to get responses from the agencies.
DFO Martin then added that all of the reports are on the WHEJAC web page. The one from last
year is there. She has to see why the scorecard one is not there. It was there, but she dropped the
links in the chat. The reports are out there. The cover letter is first, and then the next document is
the actual report. Mr. Logan apologized that he's having a hard time following that. He only sees
the cover letter. If he's having a hard time finding it, he assumes that other folks are as well.
DFO Martin said she'll check them.
Mr. Logan recommended again that they have a very specific agendized item for the next
meeting on this topic with some very clear requests from CEQ and other folks on the response.
Co-Chair Shepard agreed that that will be put on the agenda. She stated that they were out of
time and stated that there was no consensus to go forward on asking the administration to come
and talk to us or write to us about their decision on race.
Mr. Havey agreed that they shouldn't make a formal request to sort of justify why race is not
included. He wanted to make a recommendation that they do want to have race included. They
do have that coming strongly forward. The Council should be stating what they believe in and
make the recommendation, and ultimately, it's the Biden administration that will make a final
decision on it. But the Council should be on the record with making a vote and a
recommendation that race is included in that justice screening tool.
Co-Chair Shepard reminded him that there's already a recommendation in the Justice40
implementation that race is used. They have not voted on that suite of recommendations yet at
this meeting. She didn't know if that recommendation had been made for the screening tool.
Vice-Chair Flowers responded that she thought they were discussing whether or not they were
going to wait and find out whether or not there's a verbal discussion to determine what that
means when they take those positions. She would like to go back and offer an alternate position,
which is, why don't they wait until they get the verbal requests to explain this, whether it's from
the administration and the Legal Defense Fund or a counter position so that we can answer these
questions and then people won't have doubt whenever they make these decisions. She thinks they
need a little bit more information, then they should have a vote. But if people want to do that
without having that information, they can move forward. Co-Chair Shepard asked for
clarification.
Vice-Chair Flowers replied that she thought the consensus was that they weren't going to ask
for them to write an opinion, that we would instead ask for them to give a verbal opinion. Dr.
Sheats said that they should also have another opinion from maybe the NAACP Legal Defense
Fund as well when that is presented to them. That would give us more information to make an
79
-------
informed decision about this because, right now, one argument said they should do it based on
principle. She wants to do it based on principle, but her principle is to make sure that we don't do
something that could stop the program ultimately. In terms of the way the rest of the WHEJAC
feels about it, that's what's being discussed now.
Dr. Wright stated that this is where they kind of disagree. She doesn't believe that their principal
decision will affect the administration's political decision, and they've already made their point.
They said it over and over again that they're not including race. What the Council feels isn't
being considered at all at this point. It's not considered. The administration has decided race is
not included, and the only thing she's saying is that that's not the position they should take. She
doesn't think it is. WHEJAC should take the principal opinion, and let them do the political stuff,
which they will do.
The administration is not going to do anything that they think would stop this program. The only
reason that she's saying they shouldn't send an official letter is because it gets official, and it
looks like a struggle between us and the administration. She's not against people getting
information, but she suggested that they kind of do that privately, like she has done and listened
to both sides. Dr. Seats would be a really good person to talk to, to show you the different sides
and what people are saying and a few other committees that are around. She doesn't think that it
would be politically strategic for them to do that inside of the WHEJAC. She thinks that this
particular setting officially is not the same. That's all.
Co-Chair Shepard stated that they're not going to decide this tonight, and the vote on the
recommendations for the screening tool is not until the June meeting. They have other times they
can discuss this and make this a key agenda item. Dr. Sheats wanted to clarify with if they
wanted the information, then they should also have someone else. To him, it's a big if about
whether they should ask for that information, especially in a public setting.
Amanda Aguirre, Senior Advisor in the Office of Environmental Justice - CEQ, clarified to Mr.
Logan and Dr. Wright that Ms. Solow answered the question to the best of her knowledge in
where they're at. She said that she's not comfortable answering that question about the response
time because part of the reason is it's not a CEQ sole response. It would have to go through other
offices such as OMB and U.S. Digital Services and other entities depending on the question.
They're going to go back and figure out what that response is and what that time is. Know that it
is being worked on, and that the reason she's not giving a response right now is that she's not
going to give one that she can't hold to knowing that she can't control all of the departments here
at the agency and she's still getting my footing. She's also happy to talk offline and figure out a
more expeditious way they can move this moving forward.
Co-Chair Shepard stated that the business part of the meeting is closed. They're going to take
the issue of race up at another working group meeting. Those recommendations are not due until
the vote in June. So, they do have time to further discuss this issue.
2.6 Closing Remarks & Adjourn
Ms. Solow stated that they desire to be able to provide thoughtful, thorough, and correct
responses to all the questions that are posed by the WHEJAC members. She does take very
80
-------
seriously the responsibility and the opportunity to provide that information because they know
how important it is to the development of your recommendations.
As was mentioned numerous times during today's meeting and yesterday's meeting, this week
marks one year since the creation of this historic body and the WHEJAC has been working
incredibly hard at every public meeting, which they've now had three just this year. She thanked
them again for their hard work.
She also thanked her colleague Dr. Lucas Brown for the presentation that he did on the current
version of the screening tool. He has been leading public technical trainings on the current
version of the tool, and it was important to be able to provide today's briefing as well. There is a
public comment period on the tool, and they are very eager to receive people's recommendations
on how they can further update and refine the tool moving forward.
She also thanked the members of the public who joined this two-day meeting and stayed late into
the evenings. Their participation and active engagement are critical to the work for all of us
across the federal government and also for the development of the WHEJAC recommendations.
Co-Chair Shepard stated that she was hearing the frustration that there is absolutely no
understanding that after six months, they cannot get a response, whether it's we're working on it,
we're not working on it, we don't have people to work on it, or some response. But there can't be
zero response after six months of asking. That just cannot continue. Chair Mallory needs to know
it cannot continue.
Co-Chair Moore reiterated about writing the letter on responsibility and accountability. If
people expect the WHEJAC to be responsible and accountable, then at the same time, the
agencies need to be responsible and accountable. This isn't the first time the staff has heard
about the executive order or many of the other issues that they're talking about. As a Council, it's
their responsibility at times to go above the staff, not disrespect the existing staff but to the
person that needs to respond to this.
Vice-Chair Flowers stated that she learned a lot, but they feel their frustration and would like to
see something happen. She understands that the government moves slowly. That's why she's not
in government, but this is an opportunity that they've never had before. Now, hopefully, they'll
see some success. Although they disagree with each other, they're all committed to making sure
that justice is brought to the communities that have been overburdened and left behind.
Vice-Chair Tilousi thanked the public for their frustrations and stories and their comments on
the screening tool. The Council needs to move as fast as they can because lives are in their
hands.
DFO Martin thanked everyone and adjourned the meeting.
[THE MEETING WAS ADJOURNED]
81
-------
82
-------
AGENDA
°^3 t
THE COUNCIL ON ENVIRONMENTAL QUALITY
WHITE HOUSE ENVIRONMENTAL JUSTICE ADVISORY COUNCIL
VIRTUAL PUBLIC MEETING
AGENDA
MARCH 30, 2022 3:00 P.M. - 8:00 P.M. ET
3:00 p.m. - 3:15 p.m.
INTRODUCTIONS & OPENING REMARKS
o Karen L. Martin, Designated Federal Officer-U.S. Environmental Protection Agency
o Richard Moore, White House Environmental Justice Council Co-Chair - Los Jardines Institute
o Peggy Shepard, White House Environmental Justice Council Co-Chair - WE ACT for Environmental Justice
o Catherine Coleman Flowers, White House Environmental Justice Council Vice Chair - Center for Rural
Enterprise and Environmental Justice
o Carletta Tilousi, White House Environmental Justice Council Vice Chair - Havasupai Tribe
3:15 p.m. - 3:30 p.m.
OPENING REMARKS
o Brenda Mallory, Chair - The Council on Environmental Quality
3:30 p.m. - 4:30 p.m.
DOMESTIC POLICY COUNCIL UPDATE
o Kimberlyn Leary, Senior Policy Advisor, Racial and Economic Justice Team -Domestic Policy Council
4:30 p.m. - 5:30 p.m.
ENVIRONMENTAL JUSTICE AND THE PRESIDENT'S BIPARTISAN INFRASTRUCTURE LAW
o Radhika Fox, Assistant Administrator, Office of Water - U.S. Environmental Protection Agency
o Stephen Tryon, Director, Office of Environmental Policy and Compliance - U.S. Department of Interior
o Christopher Coes, Principal Deputy Assistant Secretary for Transportation Policy - U.S. Department of
Transportation
5:30 p.m. - 5:45 p.m.
BREAK
5:45 p.m. - 7:45 p.m.
PUBLIC COMMENT PERIOD
Members of the public will be given three (3) minutes to present comments relevant to the beta version of
the Climate and Economic Justice Screening Tool and federal government agencies ' implementation of the
Justice40 Initiative.
7:45 p.m. - 8:00 p.m.
CLOSING REMARKS-ANNOUCEMENTS 8, ADJOURN
o Richard Moore, White House Environmental Justice Council Co-Chair - Los Jardines Institute
o Peggy Shepard, White House Environmental Justice Council Co-Chair - WE ACT for Environmental Justice
o Karen L. Martin, Designated Federal Officer-U.S. Environmental Protection Agency
83
-------
AGENDA
MARCH 31, 2022 3:00 P.M. - 7:30 P.M. ET
3:00 p.m. - 3:15 p.m.
WELCOME, INTRODUCTONS & RECAP
o Karen L. Martin, Designated Federal Officer - U.S. Environmental Protection Agency
o Peggy Shepard, White House Environmental Justice Council Co-Chair - WE ACT for Environmental Justice
o Richard Moore, White House Environmental Justice Council Co-Chair - Los Jardines Institute
o Catherine Coleman Flowers, White House Environmental Justice Council Vice Chair - Center for Rural
Enterprise and Environmental Justice
o Carletta Tilousi, White House Environmental Justice Council Vice Chair - Havasupai Tribe
3:15 p.m.-3:30 p.m.
OPENING REMARKS
o Robin Morris Collin, Senior Advisor for Environmental Justice - U.S. Environmental Protection Agency
3:30 p.m. - 4:30 p.m.
WHEJAC CLIMATE AND ECONOMIC JUSTICE SCREENING TOOL WORKGROUP UPDATE &
DISCUSSION
o Catherine Coleman Flowers, Workgroup Chair - Center for Rural Enterprise and Environmental Justice
4:30 p.m. - 5:30 p.m.
WHEJAC CLIMATE RESILIENCE WORKGROUP UPDATE & DISCUSSION
o Maria Lopez-Nunez, Workgroup Co-Chair - Ironbound Community Corporation
o Miya Yoshitani, Workgroup Co-Chair - Asian Pacific Environmental Network
5:30 p.m. - 5:45 p.m.
BREAK
5:45 p.m.-6:45 p.m.
WHEJAC JUSTICE40 WORKGROUP UPDATE & DISCUSSION
o Peggy Shepard, Workgroup Co-Chair - WE ACT for Environmental Justice
o Beverly Wright, PhD, Workgroup Co-Chair - Deep South Center for Environmental Justice
6:45 p.m. -7:15 p.m.
WHEJAC BUSINESS MEETING REFLECTION & CONVERSATION
The WHEJAC will use this time to reflect on the meeting proceedings and public comment period; provide
workgroup updates: discuss action items and finalize next steps.
o Karen L. Martin, Designated Federal Officer-U.S. Environmental Protection Agency
o Richard Moore, White House Environmental Justice Council Co-Chair - Los Jardines Institute
o Peggy Shepard, White House Environmental Justice Council Co-Chair - WE ACT for Environmental Justice
o Catherine Coleman Flowers, White House Environmental Justice Council Vice Chair - Center for Rural
Enterprise and Environmental Justice
o Carletta Tilousi. White House Environmental Justice Council Vice Chair - Havasupai Tribe
7:15 p.m.-7:30 p.m.
CLOSING REMARKS & ADJOURN
o Corey Solow, Deputy Director for Environmental Justice - The Council on Environmental Quality
o Richard Moore, White House Environmental Justice Council Co-Chair - Los Jardines Institute
o Peggy Shepard, White House Environmental Justice Council Co-Chair - WE ACT for Environmental Justice
o Catherine Coleman Flowers, White House Environmental Justice Council Vice Chair - Center for Rural
Enterprise and Environmental Justice
o Carletta Tilousi, White House Environmental Justice Council Vice Chair - Havasupai Tribe
o Karen L. Martin, Designated Federal Officer - U.S. Environmental Protection Agency
84
-------
ONLINE SUBMITTED WRITTEN PUBLIC
COMMENTS
Northeast -1
Maine, Massachusetts, Rhode Island, Connecticut, New Hampshire, Vermont,
New York, Pennsylvania, New Jersey, Delaware, Maryland, DC
Full Name (First and Last): Khali Maddox-Abdegeo
Name of Organization or Community: UMASS CHAN/Baystate Hospital Community Faculty
City and State: Springfield, Massachusetts
Brief description about the concern: Concerned about the effects in populations in Springfield,
Massachusetts/New England of mid-western manufacturing/ industrial pollution and toxic nuclear waste
pollution in rain and north Atlantic Ocean effects on seafood and humans? In addition, how soon will
corroded at-risk outdated urban and rural water pipe and sewage systems be replaced in the majority of
USA population centers?
What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:
I believe that it is a matter of dire national emergency that the U.S. Congress and the heavy
manufacturing industries including mining and the drug and timber industries a create a budget within
60 days that will be fully funded immediately upon ratification signing by the President of the United
States. We have funds for war pollution. Divert those funds to civil needs and stop being blind for
profits!
Southeast -2
West Virginia, Virginia, Kentucky, Tennessee, North Carolina, South
Carolina, Georgia, Alabama, Mississippi, Arkansas, Louisiana, Florida
Hello, I just want to give you a brief summary on what is going on with this company. My mom
has lived at 523 Midway Ln, Louisa, VA 23093 for 60 years. I have been trying to get help, but it
was difficult due to COVID. I have included photos and videos of the emissions, smoke, ash and
dust coming from the plant. You also see how close they are to us. They are currently operating
off a temporary permit and try to get a permanent permit. I apologize for the difference format.
The letter below is what I sent to DEQ: I have recently learned that a permit application is
pending regarding the Boxley Zion-Crossroads asphalt plant in Louisa. I would like to request a
formal public notice and an opportunity for public comment on the pending permit application.
Given the plant's proximity to my property and home (just 50 feet away), a public comment
opportunity would allow me, my family, and neighbors to voice our concerns. Some of the harms
I plan to share, experienced as a direct result of the Boxley Zion-Crossroads asphalt plant, are:
ODOR: The plant emits an odor that not only smells like tar and chemicals, but also threatens my
own and my family's health. The plant's fumes have caused my mother to suffer headaches and
caused me to experience a burning sensation in my nose and throat. When I sought medical
advice about these ailments, my nurse informed me that the plant's emissions are hazardous, and
recommended that my mother and I double mask, limit time outdoors, and change clothes after
being outdoors. NOISE: When the plant operates, it generates a loud, persistent hum, audible
from inside my home. The trucks entering and exiting the plant also produce excessive noise by
beeping when backing up, using air brakes, and slamming their tailgates. DUST: The plant's
85
-------
operations generate a considerable about of dust that comes onto my property, caking the ground,
our cars, and everything else in a layer of dust. The odor, noise, and dust created by the plant are
prohibiting me and my family from able to enjoy our property. We are no longer unable to work
from home and cannot host cookouts or invite family over. Thank you for your
consideration. Please reply to this email so I can be sure that DEQ has received it. I can also
forward the permit, it has not been approved by DEQ, let me know if you need it. Your
assistance will be greatly appreciated. Thank you, Theresa Coffey
Rivian - The "CLIMATE agenda destruction" spreads to Rutledge Georgia. While "certain"
landowners are purchased by the State of Georgia ( https://www.ai c.com/news/1 ocal-official-
siblings-stand-to-profit-from-rivian-factorv-land-deal/70IJWBMTXRCN70Q5LEWWFZL3A4/
) Other, poorer (unconnected to public
officials) - landowners are ignored.
The ENVIRONMENTAL INJUSTICE
happening in Rutledge Georgia is a
tragedy occurring as we speak. Georgia
Governor Brian Kemp has budgeted (and
passed) $125 million to purchase land for
a select "connected" few people for a
proposed massive Rivian electric vehicle
project .... While the other renters and low
income landowners will live with the
harmful effects of a massive 20,000,000
square foot automobile and battery
manufacturing facility at their ' t \
backdoor. Environment Justice 38 page
report. History indicates we should ALL
be protected from heavy industrial
manufacturing encroaching on ANY
residents. It appears the State of Georgia finds itself at the forefront of INJUSTICE all in the
name of "climate agenda destruction" for electric vehicles. As the "State of Georgia" brings
numerous Georgia EPD employees on to "committees" to promote the Rivian plant and local
"Walton County" (as the construction permitting County) hires the former Georgia EPD Director
as a lobbyist, the environmental destruction will be ignored. Environmental enforcement will
fall to the wayside of climate change alarmists and their environmental construction
destruction.
3. Site Design and Environmental
Mission Statement: To have subject matter experts provide feedback to ensure that Rivian's site and
operation meets requisite State, Federal, and local ordinances to protect the environment and
communities. To provide feedback on site design such that design and operation maximize positive
impacts on the community and minimize any negative impacts.
Staff lead: John Eunice, Deputy Director, Environmental Protection Division, Georgia Department of
Natural Resources ^^
Assistant: Charna Parker, Director, Walton County Planning and Development
Members:
James Boylan, Assistant Branch Chief, Air Protection Branch^eorgi^Environmental^Protection^^
Ed Hutter, Vice President, Hutter & Associates LLC
Chuck Jarrell, Director, Morgan County Planning Department
Betty Jean Jordan, PE, Owner, Polyscape, LLC
Barbara Schlageter, Planning and Zoning Administrator, City of Social Circle
Anna Truszczynski, Branch Chief, Watershed Protection Branch, Georgia Environmental Protection
Division
Randy Vinson, President, Live/Work Building Co. LLC
4. Quality of Life
REGIONAL COUNCIL final report:
The climate change agenda is claiming
entire communities as the sacrificial
lambs. Rutledge Georgia residents are
fighting to avoid the hostile takeover
and protect their air, water and skies. I
hope you consider the environmental
destruction as you promote "climate"
agenda initiatives and policy. Even the
local Regional planning agency has
huge reservations on the local
impact. NORTH EAST GEORGIA
86
-------
https://negrc.Org/uploads/sites/4/2022/01/DRI3560.ProiectAdventure.MorganCountv.FinalRepor
t.pdf The State of GEORGIA should never be able to BYPASS the Federal #cleanwaterrules or
the Morgan County environmental regulations for Groundwater protection. Our WATER
protection matters! https://www.morganga.org/DocumentCenter/View/319/Article-14—Env-
Regs Morgan County Comprehensive Plan - natural resources
protection! https://www.morgancountvga.gOv/DocumentCenter/View/57/4—Comp-Plan-
Chapter-3?bidld= OUR COMMUNITY and our residents should not be the sacrificial lambs for
the "Green New Deal" agenda. The "climate agenda" environmental destruction must be
stopped. Thank you for your consideration. Tonya Bechtler, Rutledge, Morgan County Georgia
To whom it may concern, and I hope it does concern you, I am writing to ask what can be done
for the communities surrounding the proposed Rivian EV/battery plant in Rutledge GA. To date
Rivian hasn't applied for any permits and the official plans haven't been submitted to the
government yet we've heard that they will break ground by the end of the month. This is a deeply
rooted agricultural community with a rich history and none of us were told about this "megasite"
or the plant until the Governor announced it in the news in December. Since then we've been
asking questions and getting very few answers. There are a number of factors surrounding this
particular plant that are alarming. The NEGRC DRI report mentions this on page 2:
https://www.stantonsprings.eom/uploads/7/5/0/2/75024267/dri3560.proiectadventure.morgancou
ntv.finalreport.pdf" A plant of this size would negatively impact the groundwater recharge area
by converting millions of square feet into impervious surfaces. In addition, the DRI submittal
noted that the plant is expected to generate "some hazardous waste, such as: paints, solvents,
adhesives, batteries, [...] that are typical of such manufacturing facilities." These types of waste
could be particularly harmful to the local groundwater recharge area as well. No mitigation
proposal was provided; the applicant indicated that mitigation and disposal plans are currently
being developed." You can read more about the local impact in these links:
https://www.lakeoconeenews.us/article/rivian-impact-part-two?
https://www.covnews.com/opinion/chas-moore-not-so-fast-savs-opponent-rivian/? This 20
million square foot facility would sit upon one of the largest aquifers in the Southeast. If this was
solely an EV assembly plant then I wouldn't be as concerned, however, the problem is the battery
production side of the plant which uses highly toxic chemicals and requires an exorbitant amount
of water which we really cannot handle given the groundwater recharge area. There are many of
us on wells and we're concerned about the amount of water being used, not to mention being
poisoned from the toxic waste they will produce which will ultimately leak into our groundwater.
Rivian still hasn't provided a complete plan as to how they will handle this and our repeated
requests for answers have been ignored.
https://www.stantonsprings.eom/uploads/7/5/0/2/75024267/plan for groundwater recharge by
t h 2.10.22.pdf At that same meeting one of the JDA board members actually said "yes" when
asked about his private wells and whether he would sell us his water after this project runs ours
dry. There are many conflicts of interest and "those in the know" stand to gain while this whole
area will lose its beautiful agricultural way of life that we are taking a stand for! Look who the
head of the JDA was for 20 + years and the land in question happens to be his family farm which
has been in the business of making hay for over 100 years, https://www.aic.com/news/local-
official-siblings-stand-to-profit-from-rivian-factorv-land-
deal/70IJWBMTXRCN7005LEWWFZL3A4/ It is located at 5100 David Academy Road in
Rutledge GA 30663. https://www.stantonsprings.eom/uploads/7/5/0/2/75024267/site plan.pdf
This is a huge environmental disaster that we can avoid and I am hoping you can help us by
looking into the matter further as our emails and questions to the State of GA as well as Rivian
87
-------
have all but been ignored. Sincerely, Julie Cooper
Please do not allow the construction and implementation of the Rivian plant in Rutledge, Georgia. It is
harmful to our water sources and our rural way of life. Please consider how you would feel if this mega
plant was put in your backyard. We were not given any voice or choice in this matter. Please halt the
planning and construction of this harmful site. Please consider moving it to a site that already has
industrial use in place. Thank you for your consideration.
Midwest -3
Ohio, Indiana, Michigan, Illinois, Missouri, Wisconsin, Minnesota, Iowa,
Kansas, Nebraska, South Dakota, North Dakota
None-
Southwest -4
Texas, Oklahoma, New Mexico, Arizona
Full Name (First and Last): Garcia Erika
Name of Organization or Community: Noise pollution Free America
City and State: Spring Tx
Brief description about the concern: c) For purposes of this section: (1) an act is deemed to occur in a
public place or near a private residence if it produces its offensive or proscribed consequences in the
public place or near a private residence; and (2) a noise is presumed to be unreasonable if the noise
exceeds a decibel level of 85 after the person making the noise receives notice from a magistrate or
peace officer that the noise is a public nuisance, (d) An offense under this section is a Class C
misdemeanor unless committed under Subsection (a)(7) or (a)(8), in which event it is a Class B
misdemeanor, (e) It is a defense to prosecution for an offense under Subsection (a)(7) or (9) that the
person who discharged the firearm had a reasonable fear of bodily injury to the person or to another by
a dangerous wild animal as defined by Section 822.101, Health and Safety Code.
What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:
Pass Noise Act. Noise is environmental pollution and affects the mental health of the public when
exposed to long term unnecessary noise whether it's from an amplifier or machinery.
West -5
Colorado, Wyoming, Montana, Idaho, Washington, Oregon, Utah, Nevada,
California, Alaska, Hawaii
Full Name (First and Last): Kailea Frederick
Name of Organization or Community: NDN Collective
City and State: Petaluma, California
Brief description about the concern: Dear CEQ and the WHEJAC Council, My name is Kailea Frederick
and I am a part of the Climate Justice Team with NDN Collective. NDN Collective is an Indigenous led
organization whose mission is to build Indigenous power. For the last year, our campaign has been
working with a team of engineering experts to produce a report that details how the infrastructure of
the Dakota Access Pipeline is faulty and unsafe and why the entirety of the DAPL process has lacked
integrity through due process. This report is the first that: Lays out a full and factual timeline of the DAPL
88
-------
process Shows the depth and details of co-conspiring between the Army Corps of Engineers and the
owners of DAPL Illuminates the level of recklessness both parties are willing to take in the name of
profit. It is important that this report is read and circulated as we await the draft EIS being released from
the Army Corps of Engineers. Last year on April 9th the Biden Administration decided to allow oil to
continue flowing through the Dakota Access Pipeline despite the fact that it is operating illegally and
violates not only NEPA but treaty rights of the Standing Rock Sioux Tribe. A year later, we have published
this factual report so that the Biden Administration, specifically the EPA and CEQ are aware of the
transgressions that the tribes whose drinking water, Traditional Knowledge and sacred sites are at risk,
have experienced. It is critical that the Biden Administration step in and hold the ACOE accountable, as
the Dakota Access Pipeline sets a dangerous precedent for the quality of future infrastructure and the
way that relationships with tribes are handled. The Biden Administration touts itself for being the
administration ready to tackle the climate crisis, as well as honoring racial equity and the nation-to-
nation relationship with tribes. In the case of this pipeline these goals are in violation of the public facing
stance that the White House is seeking to hold itself accountable to. This report aids to both remind the
Biden Administration of its goals and that there is immense work to be done to strengthen NEPA and
FPIC within the CEQ and EPA. Thank you for your time.
What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:
We want the WHEJAC to share this report with the appropriate agencies and urge these agencies to be
in dialogue with NDN Collective and the Tribes on this matter. Additionally, we also call for the EPA and
CEQ to pressure President Biden to stop the flow of oil while the pipeline operates illegally.
Full Name (First and Last): Danny Garza
Name of Organization or Community: Plata Arroyo N.A.
City and State: San Jose
Brief description about the concern: Help fond official descriptions that will inform Community about
how to address Pollution on Possible Development
What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:
Please provide written information
Full Name (First and Last): Charlene Hopey
Name of Organization or Community: Topanga, CA/Los Angeles County
Brief description about the concern: Edison, our electric provider has upped the number of volts in our
power lines because that is what has a protective carrier in our fire prone area. But we are a very small
mountain community and to not need that amount of power to keep us up and running. Some are
saying this is to supply energy to Wireless Cell Sites that use a significant amount of energy that takes it
away from regular homes and businesses and contributes significantly to Global Warming. The problem
is, after these lines were installed, people were having adverse physical reaction - maybe electrical hot
spots or hot lines, leaking energy. But our Board of Supervisors will not pay attention to what people are
saying. Two people have moved to another part of the county and are no longer having the physical
reactions. What can we do?
What do you want the WHEJAC to advise the White House Council on Environmental Quality to do?:
Advise us on this issue of electrical leaks or electrical hot spots and advise on action we can take to get
our County and Edison to listen. Two of the people had an electrical reading of their homes that showed
high levels of this electricity in their homes.
89
-------
APPENDIX A:
ADDITIONAL SUBMITTED WRITTEN
PUBLIC COMMENTS
TABLE OF CONTENTS
APHA Healthcare Waste Policy Statement-Public tomments_March 30-31, 2022
2
CSA letter of Commitment related to EJP-Public Comments March 30-31, 2022
20
Environmental1 Justice, Osmunson-Public Corr,ment3_March 30-31, 2022
23
Fluoridation Census-Public Comments_March 30-31,2022
60
Justice40-UFT-Publlc Comments_March 30-31, 2022
149
Quiet Communities, Jamie Banks-Public Commer>ts_March 30-31, 2022
153
The Chisholm Legacy Project-Public Comments_M arch 30-31, 2022
154
UN General Assembly-Public Comments_March30-31, 2022
158
WHEJAC wireless-Public Comments_March30-31, 2022
161
90
-------
TABLE OF CONTENTS
APHA Healthcare Waste Policy Statement-Public Comments_March 30-31, 2022
2
CSA Letter of Commitment related to EJP-Public Comments_March 30-31, 2022
20
Environmental Justice, Osmunson-Public Comments_March 30-31, 2022
23
Fluoridation Census-Public Comments_March 30-31, 2022
60
Justice40-UFT-Public Comments_March 30-31, 2022
149
Quiet Communities, Jamie Banks-Public Comments_March 30-31, 2022
153
The Chisholm Legacy Project-Public Comments_March30-31, 2022
154
UN General Assembly-Public Comments_March30-31, 2022
158
WHEJAC wireless-Public Comments_March30-31, 2022
161
-------
I. Title: The Overlooked Public Health Crisis of Healthcare Waste: A Call for Oversight,
Protections, & Tracking
a. Natalie Sampson (primary contact)
b. University of Michigan-Dearborn
c. 19000 Hubbard Dr., Dearborn, MI 48198
d. 248-767-7149
e. nsampson@umich.edu
f. Member #: 9860705
g. Environment Section
a. Tiffany Canate, MPH
b. Boston University School of Public Health
c. 598 S Margaret Ct, WPB, FL, 33413
d. 561-373-6792
e. tcanate@bu.edu
f. Member#: 10588499
g. Environment Section, Health Policy & I.aw Section
a. Crystal Dixon, MPH, MA, MCHF.S1<
b. Wake Forest University
c. 1834 Wake Forest Rd, Winston-Salem. \('27|ng
d. dixonct@,wfu.edu
e. 336-758-5369
f. Member #: 9993 16
g. Environment Section
a. Kandyce Dunlap, MI'll. ("I H IS i<
b. University of Alabama
c. 2201 48th St. E, Tuscaloosa. AL 35405
d. 715-927-2558
e. kbdunlap ICiT'na.eJu
f. Member#: 9999914
g. Environment Section, Community Health Planning and Policy Development Section
a. Jav Her/mark, RN, MSN
b. SalcWoik Washington
c. 2152 M12 St., Seattle, WA 98133
d. 206-947-7012
e. Member #: N/A
f. N/A
a. Na'Taki Osborne Jelks, PhD, MPH
b. Spelman College
c. 350 Spelman Lane SW, Box 235, Atlanta, GA 30314
1
-------
d. 404-825-3872
e. nosborne@spelman.edu
f. Member#: 10029321
g. Environment Section, Community Health Planning and Policy Development Section
a. Denise Patel
b. Global Alliance for Incinerator Alternatives
c. 1958 University Avenue; Berkeley, CA 94704 USA
d. 510-883-9490
e. Member #9995165
f. Environment Section
a. Eric Persaud, DrPH, MEA
b. Unaffiliated
c. 109-03 103 Ave, Queens, NY 11419
d. 347-351-0978
e. eric.persaud@nih.gov
f. Member# 10258570
g. Occupational Health and Safety Section
a. Vincent Martin
b. Original United Citizens of SW Detroit
c. 313-671-4050
d. vml962@gmail.com
e. Member #: N/A
f. N/A
a. Kelly McLaughlin, MPH, MCHES®
b. New Jersey Department of 1 lealth
c. 135 E State Street, Trenton. \.l 08625
d. 551-579-9486
e. KellY.McLjuehho@dolt.ta.gov
f. Member# 10040756
g. Community Health Planning and Policy Development Section
a. Michele Okoh, J.D., M.P.H. candidate '22
b. Duke Environmental law & Policy Clinic
c. 210 Science Dr., Box 90360, Durham, NC 27708-0360
d. 337-207-2382
e. okoh@law.duke.edu
f. Member# 10107652
g. Environment Section; Law Section; Chemicals & Health Committee; Environmental
Justice Committee; Children's Environmental Health Committee
a. Lindsay Tall on, PhD, CPH
b. Massachusetts College of Pharmacy and Health Sciences
2
-------
c. 179 Longwood Avenue, Boston, MA 02115
d. 617-732-2146
e. LindsaY.Tallon@mcphs.edu
f. Member #9872961
g. Environment Section
a. Theodora Tsongas, PhD, MS
b. Unaffiliated
c. 7324 SE Madison Street, Portland OR 97215
d. 503-347-5281
e. ttson gas@,gm ai 1. com
f. Member #3066883
g. Environment Section, Occupational Health Section, Climate Change and I leal ill
Intersectional Committee
a. Olivia Wilson
b. Milken Institute School of Public Health, The George Washington University
c. 503 Roosevelt Blvd, Falls Church, VA 22''44
d. 404-769-3401
e. olivia. wilson@gwu.edu
f. Environment Section
a. Omega and Brenda Wilson, Co-Founders
b. West End Revitalization Association (Wl-RA)
c. PO Box 661, Mebane, NC 27302
d. wera" . . , www.weranc.org
e. (336)675-1608
f. Member # Damu Smith Awardees
g. Environment Section
a. Margarita Asiain
b. Unaffiliated
c. 404 Peoples Lane. Saugerties, NY 12477
d. 917-701-0021
e. roalliaritaiaiain@gmail.com
f Member M- \".\
g. N/A
III. Sponsorship/co-sponsorship: This proposed policy statement is submitted on behalf of the
APHA Environment Section.
IV. Collaborating Units: N/A
V. Endorsement: The following sections have been invited to endorse this statement:
3
-------
1. Occupational Health & Safety
2. Ethics
3. Law
4. Pharmacy
5. Medical Care
6. Community Health Planning & Policy Development
VI. Summary:
Healthcare waste adversely impacts society in ways that have been overlooked for decades, an
issue that the COVID-19 pandemic has accelerated significantly. This policy statement addresses
the human impacts that occur as healthcare waste is processed, transported, kindlilled. or
incinerated. With limited federal tracking and lack of regulation, patterns of environmental
racism persist. Communities of color and those who are low wealth most often experience the
greatest occupational and environmental health burdens through their work and disposal of waste
in their communities. Many communities have called for action for decades, as our massive
healthcare industry contributes greatly to these harms ('entering these communities, public
health professionals must advocate for: 1) lawmakers lo increase federal tracking and oversight
of the healthcare and waste industries' processing of healthcare waste , 2) federal agencies,
particularly the US Environmental Protection Agency and Occupational Safety and Health
Administration, to support communities and the related workforce with appropriate rules,
enforcement, guidance, and funding for increased protections, and 3) the healthcare industry to
reconsider sustainability initiatives in ways that address environmental justice issues with respect
to waste generation, management, transport, processing, and siting. Some public health experts
also anticipate that we may be entering a 'pandemic age,' which suggests that without
intervention, intersecting issues of infectious disease, climate change, waste, and environmental
and occupational health and justice will remain and reoccur.
V] I. Relationship lo existing APHA policy statements:
• 202116: Ensuring Equity in Transportation and Land Use Decisions to Promote Health
and Well-Being in Metropolitan Areas
• 20218: Health Inequities in the US Coronavirus Disease 2019 Pandemic and Response
• LB20-04: Structural Racism is a Public Health Crisis: Impact on the Black Community
• 20197: Addressing Environmental Justice to Achieve Health Equity
• 20189: Achieving Health Equity in the United States
• 202116: Public Health Opportunities to Address the Health Effects of Air Pollution
4
-------
• 20158: Preventing Occupational Transmission of Globally Emerging Infectious Disease
Threat
• 20078: Addressing the Urgent Threat of Global Climate Change to Public Health and the
Environment
• 200412: Support for Community-Based Participatory Research in Public Health
• 20017: Research and Intervention on Racism as a Fundamental Cause of Ethnic
Disparities in Health
• 8911: Resource and Solid Waste Management
VIII. Rationale for Consideration:
The APHA Joint Policy Commission and staff have not identified this topic as a policy statement
gap for the current year. However, the last policy statement drafted to explicitly address waste as
a public health issue was in 1986 (8911: Resource and Solid Waste Maiiaifeiiicni) API IA
recently approved policy statements related to structural racism (LB20-04) and environmental
justice (EJ) (20197) that provide a foundation for this statement on healthcare waste as a public
health issue. Further, recent statements related to COYID-N are relevant (e.g., 20218), as the
COVID-19 pandemic has illuminated the scale and implications of our healthcare waste stream.
However, none of these policies combine the issues of I'M and equitable waste management with
clear evidence and actionable steps needed to address this longtime overlooked major public
health issue. This proposed policy statement is in response to EJ leaders calling on public health,
occupational health, healthcare, and legal advocates to address this long-standing issue that
continued to worsen during the ("()\" 11)-19 pandemic. (See:
ht_ /vti ivi vtvaxVPZebXEx¥z65LnG5Ci/view.)
5
-------
VIII. Problem Statement:
For decades, environmental racism has underlain the management and siting of waste of all types
in the US. In 1979, a group of Black homeowners in Houston, Texas formed the Northeast
Community Action Group and used legal tactics to cease the placement of a sanitary landfill in
their neighborhood. Even though their lawsuit, Bean v. Southwestern Waste Management, Inc.,
failed to stop development of the landfill, it raised awareness about the consequential health
effects of waste. In 1982, protests further galvanized the Environmental Justice (EJ) movement
when Warren County, North Carolina residents fought back against dumping 60,000 tons of
PCB-contaminated soil in their community.1 The United Church of Christ led a historic analysis
in 1987 with a follow-up conducted in 2007.2'3 These reports confirmed that race predicted
hazardous waste siting in the US, above and beyond one's income. More recently, investigation
of municipal solid waste incinerators found 79% are located in overburdened EJ communities.4
In Michigan, for example, six of the state's eight hazardous waste facilities are located in Wayne
County, a majority Black county in one of the most segregated regions in the nation, with nearly
70% of this waste coming from outside of the state.5 Tait et al.'s recent systematic review
concluded from 93 studies that adverse health effects could potentially occur in communities
nearest sites where hazardous waste is dumped or processed, including but not limited to
development of various cancers, congenital abnormalities, and asthma.6 These experiences and
data repeatedly highlight the burden of waste disproportionately placed on communities of color.
As EJ leaders and the World Health Organization (WHO) have documented, the COVID-19
pandemic accelerated these unaddressed inequities dramatically with increased healthcare waste
from testing, biowaste, vaccinations, and single-use plastics.7'8 Those affected by environmental
racism have also experienced the greatest losses in their communities from SARS-CoV-2 with
compounding physical and social environmental health inequities.9 Whether healthcare waste is
declared hazardous or managed as less-regulated municipal solid waste (MSW), it has been more
likely to harm the health of communities of color in the US for generations.6
Public health experts also anticipate we may be entering a 'pandemic age',10 and intersecting
issues of infectious disease, waste, climate change, and environmental and occupational injustice
require intervention. Incinerators and landfills, as the fate of much healthcare waste, are a major
source of emissions, perpetuating climate change and its public health implications. The US
6
-------
healthcare industry is responsible for one-fourth of global healthcare greenhouse emissions, more
than any other country.11 In 2018, this resulted in an estimated loss of 388,000 disability-adjusted
life-years.12 To align with its ethical commitment to doing no harm, the healthcare industry must
reduce its carbon footprint and adverse impacts for communities frontline to its waste stream.
Major Types of Healthcare Waste with Implications for Public Health
The WHO defines healthcare waste as all waste related to medical procedures, including waste
generated within healthcare facilities, laboratories, research centers, home healthcare, and other
minor sources.8 The public health implications of personal protective equipment (PPE), single-
use and medical waste plastics, pharmaceuticals, and regulated medical waste (RMW) are briefly
described below. In sum, the US healthcare industry generates an estimated 5-6 million tons of
waste each year, which is often disposed of through incineration, landfilling, and chemical and
thermal disinfection.13 Approximately 85% of healthcare waste is non-hazardous, and 15% is
infectious, toxic, or radioactive.14 Waste from historically minor sources has accelerated
dramatically during the COVID-19 pandemic also, complicating our waste streams. For instance,
developed by major manufacturers like LabCorp, home and community antibody and diagnostic
tests are a part of life for millions as SARS-CoV-2 becomes endemic in many nations.15 Beyond
these data, the human toll on those working with or living near this waste should remain front of
mind for public health professionals.
PPE must be made available and is often mandated in healthcare settings, as it can protect
individuals from contracting infections such as SARS-CoV-2. However, improper disposal of
PPE can leave lasting environmental impacts. Every month, 129 billion face masks and 65
billion gloves are used to protect citizens worldwide and few healthcare facilities rely on
reusable types of respiratory protection.16 Discarded PPE and other plastic items litter streets,
parks, beaches, and waterways adding various environmental impacts of improper disposal.17'18
The healthcare industry relies heavily on medical waste plastics (MWPs), and much medical
equipment (e.g., tubing, blood sample tubes) is disposable and plastic.16"19 Each day, 20-25% of
healthcare waste can be attributed to plastic packaging and products.20 Researchers found that
90% of IV bags can be recycled, for instance. Yet, the majority of IV bags, which make up 10%
of total MWPs, unnecessarily undergo treatment and disposal as hazardous waste.21 The use of
7
-------
single-use plastics in healthcare grew exponentially with the onset of the COVID-19 pandemic.
Multiple locations in the US paused recycling programs at various times with concerns of SARS-
CoV-2 spread, causing the prioritization of incineration and landfilling to manage MWPs with
increased water and air pollution.16'22'23 With more plastic manufactured from fossil fuels, there
are more carbon dioxide and methane emissions leading to further climate disruption.
Pharmaceuticals also contribute to medical waste, and toxicity of their chemical breakdown in
wastewater is not well known. Unknown toxicity combined with a lack of monitoring and
control measures, imposes a significant public health challenge.24 Presence of pharmaceuticals in
the environment is linked to antimicrobial resistance (AMR). Uncontrolled discharges from
pharmaceutical manufacturing have devastating impacts on water systems, as well as people and
animals in contact with resulting resistant microbes. Exposure to environmental sources of
antimicrobial drugs places vulnerable populations, such as pregnant women from low-income
backgrounds, at a higher risk for community-acquired AMR infections.25 The threat of AMR
compromises management of infectious diseases when pathogens causing resistant infections
thrive in healthcare settings putting all patients at risk regardless of severity and type of illness.26
RMW is healthcare waste that poses a risk of infection from materials such as blood and other
body fluids. This includes microbiological laboratory waste, pathological and anatomical waste,
blood specimens and products, and other body-fluid specimens, as well as vaccine sharps and
vials.27'28'29 RMW is sometimes autoclaved (i.e., sterilized with steam), disinfected with
chemicals, or incinerated. Incineration leads to emissions, including carcinogenic dioxins and
furans, and should be avoided when unnecessary.30 Large healthcare facilities treat infectious
waste on-site, but most rely on other companies to take it off-site. By the end of 2021, RMW had
also increased at unprecedented rates with more than 8 billion SARS-CoV-2 vaccine doses given
globally, resulting in an additional 143 tons of RMW.8 Again, we must recognize the humanity
underlying RMW, which also entails bodily remains, including from lives lost to SARS-CoV-2.
Between 2020 and 2022, our nation saw disaster morgues, mass graves, and air permit violations
from sudden increases in cremation.31'32
RMW is generally handled by workers who disproportionately represent underserved and
underrepresented populations—from the healthcare site to the end-point facilities.33 These
workers face occupational hazards due to the potentially infectious or hazardous nature of some
8
-------
healthcare waste or emissions from their transport and processing. For instance, Black, Latinx,
Native American, and Alaskan Native populations are more likely to work in essential jobs
where they may be exposed to infectious agents.34 These populations are likely to experience
more work and life stressors than others in the healthcare workforce, with some lacking the
option to take sick leave (paid or otherwise) or access quality healthcare themselves. There is an
urgent need to better protect workers from adverse exposures associated with RMW through
improved workplace policies that rely on the hierarchy of controls, reflect on-the-ground
experiences of workers, and consider social determinants of health.
Medical Waste Management & Regulations
Given a patchwork of federal, state, and local regulations and privatization of medical waste
handling by companies such as Stericycle, it is hard to understand and address the scale and
impacts of RMW in the US. The Occupational Safety and Health Administration (OSHA) and
Centers for Disease Control and Prevention (CDC) provide guidance for discarding RMW, and
facilities that generate this type of waste are advised to have a medical waste management plan
to prevent infection.35'36'37 The Environmental Protection Agency (EPA) oversees waste
management through the Resource Conservation and Recovery Act (RCRA), which gives a legal
framework for management of hazardous and non-hazardous solid waste. If RMW is incinerated,
EPA regulates its emissions through the Clean Air Act's Hospital Medical Infectious Waste
Incinerator standards. OSHA has responsibilities over workplace safety for those managing
waste. The CDC is responsible for infectious disease management of waste. With the CDC,
OSHA, the Department of Agriculture, and the Federal Emergency Management Agency, the
Department of Transportation enforces Hazardous Materials Regulations with requirements for
transport of RMW, as workers and communities may be at risk if problems occur in transit.
Even with this guidance, there are no federal regulations for RMW tracking, making it hard to
identify which communities are disproportionately burdened with associated environmental
exposures. The Medical Waste Tracking Act (MWTA) of 1988 followed RCRA's "cradle-to-
grave" approach to waste regulation where the EPA tracked RMW from generation to disposal,
but this was only implemented in a handful of states and expired after two years.38 Many states
developed independent laws; some patterned after the MWTA, but state medical waste
regulations vary in stringency. For example, some states require registration for medical waste
9
-------
generators, but most states do not. Without federal regulation, there is no limit on transporting
medical waste from a state with more stringent regulations to one with more lax regulations.
IX. Evidence-Based Strategies to Address the Problem:
Waste Reduction Strategies within the Healthcare System
Professionals in the healthcare industry have advocated for the six Rs of waste reduction in
healthcare settings—reevaluating, reusing, reprocessing, repurposing, recycling and refuse.39 For
instance, this means reconsidering operating room materials inventory, reusing sharps containers,
and increasing recovery programs for medical support donations to prevent the creation of RMW,
additional MSW, and pharmaceutical waste.
Adjustments in materials that healthcare facilities use may help reduce llieir waste and carbon
footprint. Investments in reusable PPE have shown ecological and safety benefits, for instance. In
a pilot study, the Ronald Reagan UCLA Medical Center switched to reusable surgical gowns.
Over 3 years, 297 tons of waste were diverted from the landfill The gowns were thicker, offering
more protection than traditional single-use gowns Researchers have also identified instances
that usability of medical supplies could safely extend beyond current expiration dates.
Healthcare facilities can also make more concerted efforts to separate and recycle plastic wastes
that are not single-use or infectious 2,11 Kaiser Permanente and Cleveland Clinic have developed
hospital-led recycling programs to reduce the amount of waste they send to the landfill.42
Segregating waste at point of generation prevents harm to those handling the waste down the
line. Autoclaving contaminated waste improves the efficiency of recycling processes and reduces
the amount of waste going to landfills and is an alternative to air polluting incineration.43'44 Out-
of-date incinerators likely cause adverse health effects, and newer models while safer are still
quite harmful " One technique, Sterilwave, for instance, treats SARS-CoV-2 waste on-site,
avoiding community transmission during handling and enabling it to be handled as MSW, in
addition to reducing waste weight.42 Plastic wastes generated from hospital cafeterias in the US
represent about 16 to 20% of total MWPs generated, products which could be recycled without
decontamination.21 Existing programs that return product packaging to vaccine companies for
reuse and recycling are another example of waste reduction models. Essentially, healthcare waste
10
-------
management plans can reduce transmission and spread of disease and increase the recyclability
of materials, reducing medical facilities' contributions to landfill mass.43
State or Federal Policy Strategies
As with many nations, the U.S. has broad and imperfect policies related to healthcare waste, with
limited data and implementation, and enforcement largely falling on individual states, provinces,
or local municipalities. For instance, the North Carolina Department of Environ men la I Quality has
identified potential areas to minimize their medical waste; estimates of waste |iiv\ cnlion \ aiy
from 11,000 lbs/year to 230,000 lbs/year, depending on the changes made 11 Such analyses with
data on healthcare waste stream patterns and flow is necessary to ensure e\ idence-based strategies
are effective at promoting public health and EJ at the state or federal le\ el
To improve its own poorly regulated system, the US can look lo other nations for innovative
practices and legislative strategies to minimize waste and reduce risk of disease transmission. In
Canada, healthcare waste must be deconlaminated with proof of treatment before entering a
landfill, and policies and enforcement prc\ eni exorbitant disposal fees and illegal dumping.45 The
European Union classifies healthcare waste as hazardous waste with strict restrictions on its
incineration.46 In Sweden, expired or unused pharmaceuticals must be returned to pharmacies.45 In
Australia, Queensland has stringent legislation that prioritizes waste management to achieve the
best environmental outcome42 Jordan uses three primary principles for dealing with hazardous
waste: reduction of unnecessary healthcare waste, isolation of regular waste from hazardous
waste, and "proper treatment" to reduce risk to healthcare workers and society.43 In India,
Management and Handling Rules of 1998 call for waste segregation at point of generation, and
"highly infectious" biomedical waste is autoclaved.47 In Hubei, China, the government provides
mobile incineration and autoclave systems and collects extensive data on healthcare waste.43
Based on lessons learned from other countries, clear data gaps within the U.S., and lack of
federal guidance, US agencies and healthcare facilities must re-assess existing practices and
develop an evidence-based waste management plan that fully considers occupational and
environmental health and justice impacts. The Affordable Care Act (ACA) also presents a
missed opportunity to address healthcare waste in the US. Spelled out by the ACA under tax
code Section 501(r)(3)(A), tax-exempt hospital organizations are required to conduct a
11
-------
community health needs assessment (CHNA) every three years and adopt an implementation
strategy to meet community health needs identified through the CHNA. However, CHNAs do
not require assessment or interventions to account for healthcare waste.48 Overall, changes to
state and federal policies and within the healthcare industry require shifts in knowledge,
behaviors, and social norms as lack of proper information, fear of infection transmission, and a
lack of accurate and consistent definitions leads to excess waste and environmental harm.21
X. Opposing Arguments/Evidence:
Three main points of contention arise related to this policy statement that can he disputed with
evidence: (1) there is insufficient evidence to tie waste management practices directly to their
implications for communities of color or low-wealth communities, (2) single-use plastics are
critical to reduce infectious disease transmission, especially during pandemics, and (3) waste can
generate energy and is an opportunity for increasing susliii nahility with net benefits.
First, opponents may suggest the association between hazardous waste exposure and health
impacts in communities of color and low-wealth communities is inconclusive. As explained
above, there is no accurate way of knowing how much healthcare waste is handled across the US.
Yet, we know that communities surrounding landfills and incinerators experience adverse health
effects.11 Furthermore, the association between waste facility siting and surrounding communities'
racial and ethnic composition ¦V4" indicates that waste management processes disproportionately
impact communities of color. Il is imperative to implement protocols at the federal level to ensure
overburdened populations are not further impacted by waste transport, processing, and siting.
Secondly, while single-use plastics reduce transmission of infectious disease, given the ecological
impact of the production and use of fossil fuel-based products, single-use PPE is simply not a
healthy, sustainable practice,49 and alternatives are necessary. Disinfection and reuse may be
possible on a large scale and is in preliminary stages of investigation by some hospitals as
researchers work to ensure that degradation of the PPE material is not compromised from serving
its primary function of protecting and reducing infectious disease transmission.49
A third opposing argument attempts to make the case for sustainability in using waste to generate
electricity or produce other products, but good intentions may perpetuate disproportionate
environmental health impacts. The focus on sustainability and 'green' technology ignores
12
-------
consequent healthcare waste and its impacts. Healthcare waste may be used for energy production
and pyrolysis may be used to produce "value added products" from waste,43 such as the use of
incinerator ash in cement. Autoclaving, microwaving, and steam treatment with internal mixing
are alternatives to waste incineration, which releases carcinogens. Waste-to-energy innovations
must assess health and justice implications and prioritize public health from start to finish.
XI. Action Steps
Healthcare waste is a matter of occupational and environmental health and justice licyond the
scope of this policy statement, vital issues remain related to waste in home, veterinary, and
community healthcare settings. APHA offers these recommendations
1. Federal lawmakers must increase oversight of healthcare waste and delineate federal definitions of
medical waste whereby current state-by-state policies perpetuate IJ issues Congress must hold
public hearings and call for a report by the Go\ eminent Accountability Office to outline state-
level challenges and opportunities for environmental protections with respect to healthcare waste.
Once better informed, lawmakers should more clearly delegate responsibility for management,
tracking, and protections of healthcare waste to the appropriate federal and local agencies.
2. As called for in the Medical Waste Tracking Act of 1988 (MWTA), the U.S. EPA should establish
a tracking system for communities, scholars, and agencies to easily understand who is transporting
healthcare waste wilhin and across state lines, US territories, and Tribal lands, and out of the US.
Information about Superlund, brow nil elds, landfill, and incinerator sites may be available, but less
is known about waste flow patterns. Such data reporting should be required of states and private
waste management companies for integration into state or federal databases, such as EJScreen.
3. State and local governments must consider implications of existing and future waste management
infrastructure. Legislators could require health impact assessments or cumulative impact analyses
to understand waste flow and who is most impacted by odors, noise, and air, water, or land
pollution (and resulting health outcomes) associated with waste sites. Local governments should
consider the legacy of past zoning decisions with regards to waste siting.
4. Non-profit hospital organizations must include healthcare waste in their Community Health Needs
Assessment (CHNA). The CHNA should address how waste impacts the community working at
and living near hospitals, as well as impacts in communities where waste is transported or sited.
13
-------
5. State or federal lawmakers should propose policies that require the private sector (e.g., packaging
and biopharmaceutical manufacturers) to pay the cost of waste. This may entail government
incentives from take-back programs. Such programs must require manufacturers to have a
sustainability plan for waste and be designed in ways that prevent industry loopholes that
sometimes emerge with 'polluter pays' policies.
6. Sustainability experts in the healthcare industry must work with public health leaders to improve
supply chain management and changes in materials, such as medical equipment lluil can be
sanitized and reused. A life-cycle systems perspective from design and purchase decisions lo
safety training should involve workers, especially those representing underser\ ed comnuinilies
that are most likely to work with waste and at the highest risk.
7. Lawmakers should require OSHA to improve current required education and training for
supervisors and workers to raise awareness and skills in protecting themselves from healthcare
waste, including training on the past and present of the IJ movement. This should be designed
with stakeholders of underrepresented communities most at risk of occupational hazards to ensure
training is relevant, practical, and reflective of workers" experiences.
8. All healthcare facilities should form a dedicated committee to review waste management plans
periodically. Workers must have eflecti\ e input into all phases of their work from design to
completion. Plans should follow industry and consensus environmental, safety, and health
standards. Plans should also define roles and responsibilities of personnel clearly and comply with
the hierarchy of controls for waste management (i.e., first engineering controls, then
administrative controls, then PIM-)
9. Although there are many opportunities to reduce healthcare waste, lawmakers, OSHA, and
industry leaders must adopt policies to first and foremost ensure effective safety controls and
adequate PPE for workers who regularly put their lives on the line to keep essential healthcare
services operational and accessible for millions of Americans, including those who manage and
process healthcare waste. This is essential to address racial inequities in the workplace and
maintain a healthy workforce during pandemics, as well as during daily health care activities.
14
-------
XII. References
1. Bullard, RD. Dumping in Dixie: race, class, and environmental quality. Boulder, CO:
Westview Press, 1994.
2. United Church of Christ. Commission for Racial Justice. Toxic wastes and race in the United
States: a national report on the racial and socio-economic characteristics of communities
with hazardous waste sites. 1987. Accessed February 2, 2022.
http://uccfiles.eom/pdf/ToxicWastes&Race.pdf.
3. Bullard, RD., Mohai P, Saha R, Wright B. Toxic wastes and race at twenty: why race still
matters after all of these years. Environ Law. 2008;38(2), 371-411.
4. The New School: Tishman Environment and Design Center. U.S. Municipal Solid \Vasle
Incinerators: An Industry in Decline. Staticl.squarespace.com. Published May 2<)|i.)
Accessed January 29, 2022.
https://statii I squarespace.com/static/ 7\l 14Jab43967cc000 1 ad00012d
220e/1566329840732/CR GaiaReportFinal ""J I p. It
5. Great Lakes Environmental Law Center. Our Home is Not a Dumping Ground. Glec.org.
Published August 2, 2020. Accessed January 29, 2022.
https://www.glelc.Org/news/2020/8/2/communitv-i esidents-enviromnental-iustice-advocates-
call-on-the-roichigan-departroent-of-enyironroent-gfeat-tffes-and-energy-to-address-
di scriminati on-in-l ocati on-of-hazardou ~ ~ -jf" -1f
6. TaitPW, Brew J, Che A, et al. The health impacts of waste incineration: a systematic review.
Aust N Z J of Public Health. 2020;44(1) 4')-4S
7. West End Revitalization Association. Right to Basic Amenities. Submitted to U.S. House
Committee on Energy & Commerce, June 9, 2020.
8. WHO, 2014 World Health Organization. Global analysis of healthcare waste in the context
of COVID-19: Status, impacts and recommendations. Geneva: World Health Organization.
2022. Accessed February 2, 2022. >¦¦¦ w.who.int/publications/i/item/9789240039612.
9. Powers M, Brown P, Poudrier G, et al. COVID-19 as Eco-Pandemic Injustice: Opportunities
for Collective and Antiracist Approaches to Environmental Health. Journal of Health and
Social Behavior. 2021 ;62(2):222-229. doi: 10.1177/00221465211005704.
10. Morens DM & Fauci AS. Emerging pandemic diseases: How we got to COVID-19. Cell.
2020; 182(5), 1007-1092.
11. Health Care Without Harm. Health care's climate footprint: how the health sector contributes
to the global climate crisis and opportunities for action. Noharm-global.org. Published
September 2019. Accessed January 29, 2022. https://noharm-
gl obal. org/ si tes/default/fi 1 es/docum ents-
files/5961/HealthCaresCliroateFootprint 09^ If.
12. Eckelman MJ, Huang K, Lagasse R, Senay E, Dubrow R, & Sherman JD. Health care
pollution and public health damage in the United States: an update. Health Affairs.
2020;39(12),2071-2079. https://doi.org/10.1377/hlthaff.2020.Q1247.
15
-------
13. Practice Greenhealth. Waste: Understand hospital waste streams, how to measure them, and
how to reduce waste at your facility. Practicegreenhealth.org. Published 2019. Accessed
January 29, 2022. https://practicegreenhealth.org/topics/waste.
14. World Health Organization. Health-care waste. WHO.int. Published February 8, 2018.
Accessed January 29, 2022. https://www.who.int/news-rooro/fact-sheets/detail/health-care-
waste.
15. Tran, NC, Albahra, S, Rashidi, H, May, L. Innovations in infectious disease testing:
Leveraging COVID-19 pandemic technologies for the future. Clinical Biochem. 2022.
doi.org/l >/j .clinbiochem.20:
16. Prata JC, Silva, AL, Walker TR, Duarte AC, Rocha-Santos T. COVID-1 ^ pandemic
repercussions on the use and management of plastics. Environ. Sci. Technol. 2<)2<); 54 (13),
7760- 7765. doi:10.1021/acs.est.0c02178.
,/;i ,
17. Haddad MB, De-la-Torre GE, Abelouah MR, Hajji S, Alia AA. Personal protective
equipment (PPE) pollution associated with the COVID-19 pandemic along the coastline of
Agadir, Morocco. Sci Total Environ. 2021;798:149282. doi: 10.1016/j.scitotenv.2021.149282.
18. Klemes JJ., Yee VF, Tan RR, Jiang P. Minimizing the present and future plastic waste,
energy and environmental footprints related to COVID-19 Renew Sustain Energy Rev.
2020; 127.
19. Rizan C, Mortimer F, Stancliffe R, Bhutta MF. Plastics in healthcare: time for a re-
evaluation. JR SocMed. 2020;113(7):49-53. doi: 10.1177/0141076819890554.
20. Healthcare Plastics Recycling Council. Solutions for Hospitals. Hprc.org. Published 2020.
Accessed November 11, 2021. https uwwimic oig/hospitals.
21. Lee B, Ellenbecker MJ, Moure-Eraso R. Analyses of the recycling potential of medical
plastic wastes. Waste Management, 2002;22(5), 461-470. doi:https://doi. org/10.1016/S0956-
053X(02V)0006-5.
22. Blair J & Mataraarachchi S. A Review of Landfills, Waste and the Nearly Forgotten Nexus
with Climate Change. Environments. 2021 ;8(8):73.
https://doi.o ents8080073.
23. Christensen TH & Bisinella V. Climate change impacts of introducing carbon capture and
utilisation (CCU) in waste incineration. Waste Management. 2021;126,754-770.
24. Nassiri Koopaei N & Abdollahi M. Health risks associated with the pharmaceuticals in
wastewater. Daru J of Pharm Sci. 2017;25(1):9.
25. Suda K, & Tadrous M. (2021). Sum of the parts: Ensuring a resilient global drug supply
chain. Infection Control & Hospital Epidemiology. 2021;42(5), 598-599.
doi:10.1017/ice.2021.138.
26. Maghear A, Milkowska M. The environmental impact of pharmaceutical manufacturing:
How does industry address its own waste? No-harm-europe.org. Healthcare Without Harm
Europe. Published December 2018. Accessed January 29, 2022. https://noharm-
europe.org/sites/default/files/documents-
files/5731/2018 PharmaceuticallndustryReport WEB.pdf.
16
-------
27. Centers for Disease Control and Prevention. Infection Control. Guidelines for Environmental
Infection Control in Health-Care Facilities. Cdc.gov. Published 2003, updated May 14, 2019.
Accessed January 29, 2022.
https://www.cdc.gov/infectioncontrol/guidelines/environmental/recommendations.html.
28. United States Environmental Protection Agency. Medical waste. EPA.gov. Published March
29, 2021. Accessed October 19, 2021 https://www.epa.gov/rcra/medical-waste.
29. US Department of Labor, Occupational Safety and Health Administration. Occupational
Exposure to Bloodborne Pathogens: final rule (29 CFR 1910.1030). Federal Register
1991;56:64004-182. (n.d.). Osha.gov. Accessed January 29,
2022. https://www.osha.gov/laws-regs/regulations/standardnumber/1910
30. US Centers for Disease Control and Promotion. Guidelines for Environmental /iifcciioii
Control in Health-Care Facilities. 2003. Accessed February 2,
2022. https://www.cdc. gov/infectioncontrol/guidelines/environgiental/bacteSroiind/medical-
waste.html.
31. Behara, BC. Challenges in handling COVID-19 waste and its management mechanism: A
review. EnvironNanotechnolMonitManag. 2021; 15. doi. 10.1016/J.ENMM.2021.100432
32. South Coast Air Quality Management District. Emergency Order for Crematoriums due to
COVID-19. [Press release] Published January 17, 2021. Accessed February 8, 2022.
http://www.aqmd.gov/docs/default-source/news-archive/2021 /emergencv-order-for-
crematoriums-ianl7-2021.pdf
33. Faghri PD, Dobson M, Landsbergis P, Schnall PL. COVID-19 Pandemic: What has work
got to do with it? J Occup Environ Med. 2021; 63 (4).
34. Asfaw A. Racial Disparity in Potential Occupational Exposure to COVID-19. J Racial Ethn
Health Disparities. 2021; 1 -14. doi: 10.1007/s40615-021 -01110-8.
35. US Department of Labor, Occupational Safety and Health Administration. Occupational
Exposure to Bloodborne Pathogens: final rule (29 CFR 1910.1030). Federal Register
1991;56:64004-182. (n.d.). Osha.gov. Accessed January 29,
2022. https://www.osha.gov/laws-regs/regulations/standardnumber/1910
36. US Centers for Disease Control and Promotion. Guidelines for Environmental Infection
Control in Hea/lh-( \ire l
-------
40. Practice Greenhealth. Case study: Reusable isolation gowns. In Practice GreenHealth.
Accessed October 1, 2021. https://practicegreenhealth.org/sites/default/files/upload-
files/case studies/ucla isolation gown case studv.pdf.
41. Padmanabhan KK & Barik D. Health hazards of medical waste and its disposal. Energy from
Toxic Organic Waste for Heat and Power Generation. 2019;99-118. doi:10.1016/B978-0-08-
102528-4.00008-0.
42. Wyssusek KH, Keys MT, van Zundert AJ. Operating room greening initiatives - the old, the
new, and the way forward: a narrative review. Waste Management & Research.
2019:37(113-19. dot.org/ 10.1 1 ""70734242X18793937.
43. Das KA, Islam N, Billah M & Sarker A. COVID-19 pandemic and healthcare solid waste
management strategy - A mini-review. Sci Total Environ. 2021 ;778.
d citoteiw.20
44. North Carolina Department of Environmental Quality. Medical w aste is pari <>J a larger solid
waste problem. 2021. [presentation]
45. Windfeld ES, & Brooks MSL (2015). Medical waste management-A review. Journal of
environmental management, 163, 98-108. doi.or _
46. Rogowska J, Zimmerman A, Muszynska A, Rantajczyk W & Wolska L. Pharmaceutical
household waste practices: preliminary findings from a case study in Poland. Environmental
Management. 2019;64( 1), 97-106. doi.ore/10.1007/s00267-019-01174-7.
47. Passupathi P, Sindhus S, Ponnusha BS & Ambika A. Biomedical waste management for the
health care industry. International Journal of Biological Waste & Medical Research.
2011;2(1),472-486.
48. Franz B, Cronin CE & Singh S. Are nonprofit hospitals addressing the most critical
community health needs that they identify in their community health needs assessments?
Journal of Public Health Management and Practice. 2021;27(1), 80-87.
doi .org/10.1097/PH i j 10.14.
49. Singh N, Tang Y & Ogusteitan OA. Environmentally sustainable management of personal
protective equipment. Environmental Justice & Technology. 2020;54(14),8500-8502.
doi. org/10.1021/acs.est.0c03022.
18
-------
CITIZEN SCIENCE ASSOCIATION
Citizen5cience.org | info@citizenscience.org | @CitSciAssoc
Letter of commitment to the Environmental Justice Community from CSA Leadership
31 January 2022
For the last two years members of CSA Board and staff have been working alongside CSA
Environmental Justice Practitioners Working Croup (EJPWC) leaders to bridge the
science-to-action gap in research, especially as it relates to equity in science and in
community partnerships. The leadership of the EJPWC has provided an invaluable service
to both CSA and the field of citizen science as a whole by engaging with us in open,
honest, and transparent conversations about the state of the field.
In February 2020, the EJPWC leadership presented CSA with a Memorandum of
Understanding (MOU) and Memorandum of Agreement (MOA) detailing a set of guiding
principles and best practices for engaging with Environmental Justice (EJ) communities and
organizations. That document has since served as the foundation for a formative shift in
the operations, policies, and programs of CSA.
With this letter we formally acknowledge that science has caused historic, systemic, and
ongoing harm to, and exploitation of, minoritized and marginalized communities,
particularly Black, Indigenous, and other People of Color, as detailed in the MOU and MOA.
We further acknowledge that such harms and exploitations have in many cases been
perpetrated in the name and guise of participation in science and community engagement.
CSA has a responsibility, as an Association with an interest in upholding integrity in public
engagement in research, to attend to those harms. To this end, we affirm CSA's
commitment to the objectives, principles, and practices outlined in those documents. This
entails addressing, and growing capacity to address, specific work to:
• Maintain and foster a strong network of community based EJ practitioners;
• Create learning spaces and dialogue with EJ communities/leaders and research
focused counterparts aiming to discuss equitable partnerships and opportunities
for collaboration;
• Work to improve upon environmental justice participation and representation in
the CSA and the conference planning;
• Offer representative categories for EJ/lndigenous practitioners for CSA
membership and conference registration;
• Develop and uphold operating guidelines that protect the interests of grassroots
EJ leaders and organizations when a) working directly with CSA, and b) when
working in this field (e.g., with colleges/universities or other scientific
institutions);
• Addressing fair inclusion and representation of Indigenous focused academic
institutions, HBCUs (Historically Black College and Universities), and Hispanic,
Latinx, and Tribal centered universities that number in the 100s;
-------
• Elevating research models that support corrective solutions for adversely
impacted Ej/lndigenous areas: such as WERA's CO MR Model (community
owned and managed research) that leverage legal compliance and
enforcement;
• Funding Ej/lndigenous input, training of CSA members, and on-site
participation in various state, regional, national, and international venues.
As a non-profit Association focused on the advancement of integrity in citizen and
community science, we additionally recognize that there are larger systemic issues, harms,
and opportunities that we can confront and address, as related to our purview and
mission, such as:
• The scientific exploitation of people of color and indigenous areas by major
academic universities without equitable funding and solutions-oriented use of
research results;
• Operational and proactive support of existing and new/proposed federal law
written specifically to protect the rights and improve quality of life of
Ej/lndigenous communities where such proposals could or do reference the
roles and rights of communities leading or leveraging science partnerships for
change.
We commit - to the EJPWC and the CSA community - that we will continue to actively
and increasingly support and pursue opportunities that address justice, equity, diversity,
inclusion, and funding parity in community and citizen science. This commitment will be
actioned throughout our strategic plan, mission, principles, governance, and
programs/activities. We are mindful that this work requires long-term commitments, such
that change (albeit too long delayed and never fast enough) can be not just incremental
but sustained and with an eye to sustained and more systemic impacts.
As the leadership of this organization we can take action and take accountability. We also
recognize that we can't make change on our own. Change will come from across this
community, with many working together to move this commitment forward. We commit
to being a long-term partner, ally, and leader in this work, and value the opportunity to
work alongside the EJPWC and (increasingly) other individuals and partner organizations
moving forward.
On behalf of the CSA Board and with their unanimous vote of support,
Director, CSA
CitizenScience.org | info@citizenscience.org | ©CitSciAssoc
-------
• White House Environmental Justice Interagency Council, Chair and
Members wheiac@epa.aov.
Bill Osmunson DDS MPH March 17, 2022
bill@teachinasmiles.com
" Sec. 219. Policy . . . turning disadvantaged communities . . . into healthy,
thriving communities,"
A clinician causing harm to their patient can harm that patient and the patient can
sue for damages. A public health policy causing harm to millions, can keep going
on and on for generations causing harm to millions and harming the environment.
As a practicing dentist (1977) with master's degree in public health (1972), I
promoted fluoridation (adding fluoride to public water) for about 25 years until I
read the research for myself. The evidence for me caused a significant paradigm
shift.
WHY IS FLUORIDATION AN ENVIRONMENTAL JUSTICE ISSUE? (see more
below)
My understanding of environmental justice is "equitable distribution of
environmental benefits and burdens associated with economic production" referred
to here as "equity."
Like lead, arsenic, strychnine, and other toxins, even very small amounts of fluoride
ingestion harms the developing brain lowering IQ. The research reports 5 to 20 IQ
points lost. For you and me with 130 plus IQ, snipping a few IQ points may not be
noticed. Cutting a person with 75 IQ points down can be life altering with increased
costs and grief in special education, loss of happiness, loss of relationships,
frustration, increased incarceration, lower income, increased divorce rate, increased
homelessness, job insecurity, and significant costs to society. All caused by our
governments.
CALL TO ACTION: Equitable distribution of harm is not justice and WHEJAC
is requested to call experts in toxicology, pharmacology, neurology,
epidemiology, biochemistry, together and evaluate the current science on
risk-benefit of water fluoridation.
Who has jurisdiction over fluoridation policy? (see more below)
The short answer is "no one."
The FDA regulates drugs, but not public water and FDA says, "not us."
The EPA regulates public water, but not drugs and EPA says, "not us." For those
who choose to add fluoride, the EPA provides guidance, which is essentially the
same as approval and in violation of the SDWA.
l
-------
The CDC Oral Health Division is a mirror of private industry, the American Dental
Association who's members make many millions on fluoride. (My office about
$160,000/year.) The CDC does not determine the safety of drugs, they promote
policy.
The PHS does not determine the efficacy, dosage, or safety of any drug.
State Health Agencies rely on the Federal agencies.
Frequently the voters, cities and/or water districts attempt to do good by adding
fluoride to water, over-riding the FDA.
NO AUTHORITY DETERMINES SAFETY OF INGESTING FLUORIDE. The EPA
has been hauled into court over their Maximum Contaminant Level Goals of fluoride
which is currently at 4.0 ppm and the National Research Council in 2006
determined was not protective.
For example, in a legal deposition, under oath, Principal Investigator Dr. Gary
Slade, the best dental expert the EPA could hire for their defense, acknowledged
that he was not an expert in any non-dental effects of fluoride and had never
conducted any original research on any adverse effects, including neurotoxicity. He
also acknowledged he had never done original research on dental effects of fluoride
exposure during the first year of life. He also stated he was not an expert on risk-
benefit assessment and would not undertake to assess the risk-benefit ratio
between dental benefits and neurodevelopmental harms. In his deposition, Dr.
Slade also acknowledges several reasons for the uncertainty of dental benefits from
fluoridated water. He acknowledges that very few studies have ever been blinded,
that none of his own studies of fluoride and dental caries have used blinding, that
lack of blinding can introduce bias in the direction favored by the researchers, and
that no RCT has ever been done with fluoridated water. Based on the information
available to us, it appears Dr. Slade has neither attempted to assess the risk-
benefit ratio of neurodevelopmental harm against reduced dental caries, nor
attempted to acquire "a thorough knowledge of the scientific literature" on the
risks, as required under the Declaration of Helsinki principles. His lack of expertise
in non-dental effects of fluoride and his acknowledgement that he is not qualified to
do risk-benefit assessments are not acceptable excuses for the apparent absence of
one in his study proposal. And that testimony is an example of the best dentists
have to offer in defense of fluoridation.
None of the organizations promoting fluoridation have published their risk-benefit
evaluation. Dentists, physicians, public health professionals claim they are not
responsible for a risk-benefit analysis.
State departments of health have responded to our request for evaluation of safety
claiming they do not evaluate the safety and rely on others, and refuse to divulge
those unnamed "others".
2
-------
Several streams of evidence must be considered to make judgment,
including but not limited to:
Outline
I. Background and Lack of Quality Studies on Fluoride Ingestion P. 4
II. Total Fluoride Exposure P. 8
III. Lack of known Mechanism for Benefit of Fluoride Ingestion P. 10
IV. Lack of Benefit from Fluoride Ingestion P. 11
V. Risks from Fluoride Exposure P. 14
VI. Fluoride Toxicity, Oversight, & Ethics of Fluoride Ingestion P 34
3
-------
I. Background and Lack of Quality Studies on Fluoride Ingestion and Lack
of Benefit.
The addition of fluoride to public water or bottled water, referred here to as
fluoridation, has been called in the United States one of the 20th Century's greatest
Public Health Achievements. In most developed countries fluoridation and fluoride
supplements are not significantly practiced (if at all) for a number of reasons,
outlined below.
Numerous studies have been published claiming fluoridation, fluoride
ingestion, supplements (pills or liquid) have significant benefit; however, Leverett
(1997) did a randomized clinical trial of the effect of prenatal fluoride supplements
followed until age 5. The treatment group received 1 mg of fluoride/day, similar to
fluoridated water and postnatal dietary fluoride supplements encouraged. Cavities
measured at age 3 and 5. 92% of children remained caries free and only 26
subjects had very mild dental fluorosis. "Overall, there were no statistically
significant differences with respect to caries and fluorosis in deciduous teeth."
No RCT's are reported for fluoride ingestion as supplements, fluoridated
bottled water or fluoridation for infants, children or adults. Quality research is long
overdue. The FDA denied approval of fluoride ingestion finding the evidence for
efficacy, "incomplete."
Fluoride is not an essential mineral. No physiologic function requires
fluoride. A lack of fluoride exposure does not cause dental caries. Sodium fluoride
does not have an FDA NDA number when ingested with the intent to prevent dental
caries and is listed as a drug in the US Pharmacopoeia. Sodium fluoride is not
listed in the Orange Book of FDA approved drugs for use with the intent to prevent
or mitigate dental caries. More below.
Many published studies on fluoride and dental caries regurgitate the highly
marketed mantra of fluoride's benefit for reducing dental caries without reference
to quality RCT studies because there none. Topical fluoride does have good
evidence of benefit and is FDA approved, not systemic.
A careful evaluation of studies on systemic benefit finds numerous limitations
often including but not limited to:
A. Not one Study corrects for Unknown Confounding Factors
B. Not one Prospective Randomized Controlled Trial
C. Socioeconomic status usually not controlled
D. Inadequate size
E. Difficulty in diagnosing decay
F. Delay in tooth eruption not controlled
G. Diet: Vitamin D, calcium, strontium, sugar, fresh and frozen year-round
vegetables and fruit consumption not controlled.
H. Total exposure of Fluoride not determined
I. Oral hygiene not determined
4
-------
J. Not evaluating Life-time benefit
K. Estimating or assuming subject actually drinks the water.
L. Dental treatment expenses not considered
M, Mother's F exposure, Breast fed (almost no fluoride) and infant formula with a
high dose of fluoride
N. Fraud, gross errors, and bias not corrected.
0. Genetics not considered
All of those are limitations and significant, but not a single study on the
ingestion of fluoride controls for the huge unknown(s) which reduced dental caries
prior to fluoride use and reduction of caries in other countries never fluoridated (A
above) and Limeback's graph next page.
No study controls for the causes in decline from 12 cavities per 12 year old in
the early 1920's to less than 6 cavities per 12 year old when fluoridation and
fluoride toothpastes could have had a significant impact. The following graph by
Colquhoun 1997 ISFR illustrates this point.
Credibility is stretched beyond reason to suggest fluoridation reduced caries
before fluoridation started, or that the huge caries crushing unknowns prior to
fluoridation stopped at the same rate as the benefits from fluoridation started.
My point should be clear, with over 70% of the USA fluoridated without their
consent, randomized controlled trials should have been done and the US Food and
Drug Administration approval with NDA should have been obtained. The need for
this research could have a significant impact on public health.
Limeback H (unpublished) illustrated the complex fluoride/caries connection
with the following.
5
-------
Dental
Decay
Many factors lowered
dental decay worldwide
-both before and after
water fluoridation
developed countries WHO
fluoridated
/fr toothpaste^
fissure
Australia
sw'
^Chlor- Afsealants A
A
lack'of sugar
liSMSF>Xylitol
1940
1950
1960
1970
1980
YEAR
1990
2000
Some dentists suggest sugar reduction (diet) maybe a more important factor
for caries prevention than fluoride and or oral hygiene in primary teeth. To give
fluoride the credit for the significant caries reduction over the last, perhaps
Century, is not based on the evidence.
At the same time the CDC was claiming fluoridation was one of public
health's greatest achievements of the 20th Century, the CDC was reminding us that
fluoridation had primarily topical benefit and rather than systemic benefit.
6
-------
The CDC presents the following Figure 1 as evidence of fluoridation's efficacy.
No one disputes
the two events have
happened. Just because
two events happen does
not prove their
correlation.
Certainly, more
communities received
fluoridated water and
individual DMFT
decreased, nice but the
relationship is not
plausible. The CDC
omitted the pre
fluoridation trend of
decreasing caries and
suggests a 17% increase
in the number of people fluoridated in random cities nation-wide, provided a huge
70% reduction in dental caries in the entire USA. To achieve those stunning results
would not have been possible if the fluoride were targeted at specific high-risk
individuals, let alone random cities.
Without FDA approval, the addition of an unapproved drug to public water must be
considered an experiment without informed consent.
NIH Guidelines for Informed Consent: "Potential participants should make
their own decision about whether they want to participate or continue
participating in research. This is done through a process of informed consent
in which individuals (1) are accurately informed of the purpose, methods,
risks, benefits, and alternatives to the research, (2) understand this
information and how it relates to their own clinical situation or interests, and
(3) make a voluntary decision about whether to participate."
However, the fluoridation experiment is being done not only without individual
consent or doctor's prescription, nor Institutional Review Board Approval, but no
reasonable data is being collected to evaluate whether the experiment is safe and
effective. The 75 year old public health policy is a runaway disaster of our own
making. Knowledgeable public loses trust in government agencies when those
agencies ignore the science.
FIGURE 1. Percentage of population residing in areas with fluoridated community
water systems and mean number of decayed, missing (because of caries), or filled
permanent teeth (DMFT) among children aged 12 years — United States, 1967-1992
£3 100
(T3
3 90
53 SO
ro
1 70-
o
-E 60 -
LL
c 50
1= 40 ¦
10"
0
Sources:
Mean DMFT
Percentage Drinking
Fluoridated Water
- 3 <*>
Year
1. CDC. Fluoridation census 1992. Atlanta, Georgia: US Department of Health and Human Serv-
ices, Public Health Service, CDC, National Center for Prevention Services, Division of Oral
Health, 1993.
2. National Center for Health Statistics. Decayed, missing, and filled teeth among youth 12-
17 years—United States. Rockville, Maryland: US Department of Health, Education, and
Welfare, Public Health Service, Health Resources Administration, 1974. Vital and health
statistics, vol 11., no. 144. DHEW publication no. (HRAJ75-1626.
3. National Center for Health Statistics. Decayed, missing, and filled teeth among persons 1-
74 years—United States. Hyattsville, Maryland: US Department of Health and Human
Services, Public Health Service, Office of Health Research, Statistics, and Technology, 1981.
Vital and health statistics, vol 11, no. 223. DHHS publication no. (PHSI81-1673.
4. National Institute of Dental Research. Oral health of United States children:the National Survey
of Dental Cartes in U.S. School Children, 1986-1987. Bethesda, Maryland: US Department
of Health and Human Services, Public Health Service, National Institutes of Health, 1989. NIH
publication no. 89-2247.
5. CDC, unpublished data, third National Health and Nutrition Examination Survey, 1988-1994.
7
-------
II. Total Exposure, Too Much Fluoride.
Fluoride exposure appears to be increasing and it makes no sense to give
children more fluoride when they already ingest too much fluoride.
When fluoridation first started the public was assured perhaps 10% to 15%
(Dean) of the public might show signs of very mild, hardly detectible, dental
fluorosis. See Beltran-Aauilar 2002, reported 38%. In 2004 dental fluorosis
increase to 41%. In 2019 Neurath et al published NHANES data finding 60%. Such
huge increases were disputed and Neurath responded. Dona reported NHANES
data from 2015-2016 at 70%. At what point are public health leaders willing to
admit too many are ingesting too much fluoride?
Compare Neurath's data from 2004 to 2012, illustrated below, and the
significant decrease in unaffected children from 60% to 30% and increase of
moderate/severe from 7% to 28%.
6%
8%
very miild
questionable
moderate
mild
very mild
questionable
unaffected
unaffected
60%
0% 20% AO% 60%
Probability
moderate
mild
very mild
questionable
unaffected
I
15%
19%
moderate
mild
very mild
questionable
unaffected
0% 20% AO% 60%
Probability
Many foods, beverages, dental products and medications contain fluoride. 2-
year old ingest a mean percentage of 65% of the toothpaste they use and 75% or
more if not rinsing. ". . . some children probably get more than the recommended
amount of fluoride from toothpaste alone. . . " p 42 he National Research Counc
ir 2006 (NRC 2006).
Table 2-7 of the NRC (2006) Report estimated topical fluoride intake from
toothpaste for infants 0.5 to 1 year at 0.1 mg/kg/day and for children 1-2 years of
age at 0.15 mg/kg/day. P. 42.
The US EPA has an RfD (Reference Dose) of 0.06 mg/kg/day, about half
what the mean child is ingesting from toothpaste alone. Total fluoride exposure
must include from toothpaste and fluoridation and foods and medications and all
sources. It is no surprise dental fluorosis rates have increased far beyond EPA's
RfD. EPA's RfD is based on an uncertainty factor 1:1 and margin of error of 1:1,
yet EPA provides no evidence for why fluoride is a protected contaminant in water.
8
-------
However, the infant on formula made with fluoridated water and NO
toothpaste would also receive about 0.2 mg/kg/day, much higher than EPA's RfD of
0.06 mg/kg/day. See more details: The National Research Council in 2006.
The EPA Dose Response Analysis 2010, Figure 8-1, below, illustrates the
percentage of children exceeding the RfD if the EPA increased the RfD to 0.08
mg/kg/day. In other words, doing the opposite of the NRC 2006 recommendation
and "declaring" fluoride exposure safer, being less protective. Even with reduction
of safety, too many children still ingest too much fluoride. (Percentage above the
black line.)
0.5 to <1 1 to <4 4 to <7 7 to <11 11 to 14 >14
Age Range in Years
Figure 8-1. Total Daily Fluoride Intake Estimates Relative to the Proposed RfD Using 90tli Percentile
Drinking Water Intake Data for Consumers Only and the Mean Drinking Water Fluoride Concentratioi
(0.87 rng L)
Note, in their Figure 8-1 infants are not included, 10% of children and infants
ingesting the most are not included, RfD increases by 33% and still a significant
percentage of children are ingesting too much fluoride. Mothers of the unborn may
have the greatest risk of excess fluoride exposure and not included.
However, normal fluoride urine and serum fluoride concentrations have not
been established. The best evidence to date might be from developmental
neurotoxic studies, suggesting 0.2 mg/L of urine to cause only 1 IQ loss. More on
that later.
9
-------
III. Lack of known Mechanism for Systemic Fluoride Exposure on Caries
Mitigation
The benefit of topical fluoride, such as fluoridated toothpaste has significant
quality RCT support and known mechanism.
Surprisingly, no mechanism for fluoride's systemic benefit has been clearly
stated. Fluoride does not migrate or move from the pulp chamber to the surface of
the tooth where the dental caries start and/or are active.
Enamel and dentin demonstrate significant transport hindrance. The
effective pore radii of the transport pathways in the enamel are approximately 0.7-
0.9 nm. In other words, measured evidence of fluoride tooth concentrations at the
different levels of the dentin and enamel demonstrate fluoride can't get from the
blood through the calcified tooth to where the dental caries start. Except for the
surface, fluoride concentrations are similar regardless of exposure.
A very small amount of ingested fluoride makes its way to saliva to provide
some topical fluoride after tooth eruption, but this amount is 50 to 100 fold less
than what is obtained from fluoride naturally occurring in food and beverages.
Contact time on the teeth during drinking is minimal. And like ECC causing caries
mostly to upper anterior teeth when milk/juice sits on the teeth of the infant while
they sleep, if fluoride in water had significant topical benefit, we would see most
protection to the upper teeth.
Dental fluorosis, a biomarker of excess exposure, happens prior to eruption;
however, I have not found research demonstrating lower caries with higher fluoride
concentrations on the outside of the tooth prior to eruption.
Until a mechanism for significant fluoride from ingestion to reach the surface
of the tooth is elucidated, systemic fluoride's benefit is a questionable theory.
Fluoride is not a nutrient nor essential for any bodily function.
"The prevalence of dental caries in a population is not inversely related to the
concentration of fluoride in enamel, and a higher concentration of enamel fluoride is
not necessarily more efficacious in preventing dental caries."
SOURCE: CDC. 2001. Recommendations for using fluoride to prevent and control
dental caries in the United States. Mortality and Morbidity Weekly
Review 50(RR14):l-42.
"Fluoride is not essential for human growth and development."
SOURCE: European Commission. 2011. Critical review of any new evidence on the
hazard profile, health effects, and human exposure to fluoride and the fluoridating
agents of drinking water. Scientific Committee on Health and Environmental Risks
fSCHERI. page 4.
"Fluoride is not in any natural human metabolic pathway."
SOURCE: Cheng KK, et al. 2007. Adding fluoride to water supplies. British Medical
journal 335:699-702
10
-------
IV. Lack of Systemic Fluoride's Benefit
As a practicing dentist, I promoted fluoride ingestion including fluoridation for
the first 25 years of practice. I was convinced from my Public Health Education,
Continuing Education and what I could see in my patients mouths clear convincing
evidence of benefit, I was mistaken.
My patients insisted I look again at both science and ethics. Several years of
evaluating current research fluoride's benefit, I realized I was seeing the difference
in socioeconomic effect rather than fluoride's effect. The wealthier are healthier
and the healthier are wealthier. Whether ingested fluoride has benefit is difficult to
detect without quality RCTs.
Although the 2015 Cochrane Review of fluoridation suggested benefit, the
review did not include any RCTs and reported,
"There was insufficient information available to find out whether the introduction
of a water fluoridation program changed existing differences in tooth decay across
socioeconomic groups."
"There was insufficient information available to understand the effect of stopping
water fluoridation programs on tooth decay."
"No studies met the reviewer's inclusion criteria that investigated the
effectiveness of water fluoridation for preventing tooth decay in adults, rather than
children."
Most developed countries have reduced dental caries to similar low levels
regardless of fluoridation. Neurath (2006) Fluoride Research using WHO data.
Tooth Decay Trends: Fluoridated vs. Unfluoridateil Countries
Year
UHFLOOKi DATED
- Austria
Bekj'Lri
- D-?n:r crte
Tin laid
- rI'rancc
- Germany
- Iceland
- naif
i-npan
Netherlands
Norway
- Sweden
S -//ilzerland
United Kingdom
FLUORIDATED
Australia
• Ireland
New Zealand
-United States
li
-------
Chen (2007) BMJ included fluoridated salt and found the same result reporting
no public health benefit from systemic fluoride exposure.
Most developed countries do not fluoridate their water and reduction in caries is
similar to fluoridated countries.
Austria REJECTED: "toxic fluorides" NOT added
Belgium REJECTED: encourages self-determination - those who want fluoride
should get it themselves.
Finland STOPPED: "...do not favor or recommend fluoridation of drinking water.
There are better ways of providing the fluoride our teeth need." A recent study
found ..."no indication of an increasing trend of caries...."
Germany STOPPED: A recent study found no evidence of an increasing trend of
caries
Denmark REJECTED: "...toxic fluorides have never been added to the public water
supplies in Denmark."
Norway REJECTED: "...drinking water should not be fluoridated"
Sweden BANNED: "not allowed". No safety data available!
Netherlands REJECTED: Inevitably, whenever there is a court decision against
fluoridation, the dental lobby pushes to have the judgment overturned on a
technicality or they try to get the laws changed to legalize it. Their tactics didn't
work in the vast majority of Europe.
Hungary STOPPED: for technical reasons in the '60s. However, despite
technological advances, Hungary remains unfluoridated.
Japan REJECTED: "...may cause health problems...." The 0.8 -1.5 mg regulated
level is for calcium-fluoride, not the hazardous waste by-product which is added
with artificial fluoridation.
Israel SUSPENDED mandatory fluoridation until the issue is reexamined from all
aspects.: June 21, 2006 "The labor, welfare and health Knesset committee"
China BANNED: "not allowed" China exports fluoride to fluoridating countries.
France Was 50% of salt and now less than 30% of fluoridated Salt
Ireland 74% Fluoridated
UK 9%
Fluoridated lida, H., and Kumar, J.V. 2009. The association
between enamel fluorosis and dental caries in
Data from lida et al
graphed right and is
consistent with most
currently published studies
reporting an increase in
fluorosis with increased
fluoride exposure and
hardly detectible caries
reduction and increase in
caries with increased
fluoride exposure • Water fluoride concentration (mg/L)
U.S. schoolchildren. JADA 140:855-862.
¦ fluorosis
s caries experience
Permanent teeth in children (ages 7-17)
12
-------
V. Risks from Fluoride Exposure
EPA scientists speaking through their Union, noted:
"In summary, we hold that fluoridation is an unreasonable risk. That is, the
toxicity of fluoride is so great and the purported benefits associated with it are so
small - if there are any at all - that requiring every man, woman and child in
America to ingest it borders on criminal behavior on the part of
governments."
Dr. J. William Hirzy, Senior Vice-President, Headquarters Union,
US Environmental Protection Agency, March 26, 2001
The National Research Council in 2006 (NRC 2006) listed areas of concern for harm
and risks of fluoride ingestion, including:
1. Tooth Damage
2. Rheumatoid and Osteoarthritic-like Pain and skeletal fluorosis
3. Bone Cancer
13
-------
4. Bone Fractures
5. Thyroid Reduction Diabetes Obesity
6. Kidney damage
7. Reproductive problems
8. Lower IQ and increased Mental Retardation
9. Allergies (overactive immune system)
10. Gastrointestinal disorders
Sixteen years after the NRC 2006 report, we have a great deal more
research on each of these areas of risk. I will not go into a detailed review here. A
search at www.pubmed.gov lists thousands.
Since 2017, 23 human studies report an association between fluoride
exposure and reduced IQ. See more below.
A most significant question is dosage. How much fluoride does it take to
cause harm for each person at each stage of life? Not everyone drinks the same
amount of water: mean is about 1 liter/day, 90th percentile about 2 liters/day and
some drink over 10 liters/day. Dosage is uncontrolled and individually DNA and
general health unknown.
A serious question to be answered is what percentage of the population
harmed is acceptable? As a dentist, I don't want any of my patients harmed. Thus,
a margin of error, uncertainty factor must be included. The EPA uses 1:1 which is
no protection. At least ten or a hundred should be used.
Research and informed consent for a RCT should limit, control and measure
dosage and provide warnings that any or all of the above risks are possible or
probable.
1. Dental Fluorosis and Teeth.
The following picture is of my patient raised on fluoridated bottled water,
Nursery Water. His mother was careful to avoid fluoridated toothpaste and he was
partially breast fed for 6 months and formula made with Nursery Water by DS
Waters containing about 1 ppm fluoride. Why did my patient get severe dental
fluorosis (diagnosed by three dentists) on what appears to be such low levels of
fluoride exposure? Was he genetically predisposed? Did he have other habits of
eating fluoride his mother did not know about? Were there other chemicals which
made him more sensitive? We don't know.
His diagnosis of severe dental fluorosis has been made by three dentists and
a careful differential diagnosis has ruled out other etiologies.
14
-------
During discoveries for this patient, DS Waters provided a "Warning Letter"
from the FDA certified mail to Mr, Stewart Allen and Mr. Dillon Schickli of DS Waters
of America, Inc., June 8, 2009.
. . we have found your product label has serious violations of the Federal
Food, Drug and Cosmetic Act, , . Your product is misbranded ... for infants
or toddlers less than two years of age. ..."
No fluoride product for ingestion with intent to prevent disease has gone
through the FDA approval process and approved, no NDA. However, Congress did
provide an exemption for a health claim to be made for a product which a couple of
other Federal Agencies claimed benefit. Fluoridated bottled water has not received
an NDA and is not for infants and toddlers. Any health claim for ingested fluoride is
NOT based on FDA scientific review.
I treat dental fluorosis when a patient requests. Various treatments are
possible, the most extensive and best is with porcelain veneers. Veneers cost
between $800 to $1,500 per tooth and last an average of about 15 years.
Fluoride can increase tooth and bone density which can have a positive and
negative effect. A harder tooth surface can resist caries; however, the tooth can
become more fracture prone. Only three studies on complete cusp fracture were
found and the more fluoridated communities had triple the number of complete
cusp fractures. More studies should be done because I make a living from treating.
And further, a hard tooth makes caries in the grooves more difficult to
diagnose resulting a "Fluoride Bomb" where the enamel stays intact while the caries
bombs out the tooth inside. "Softer" enamel fractures earlier and the diagnosis of
caries is earlier, providing earlier more conservative treatment.
15
-------
The photos below demonstrate the "Fluoride Bomb." Tooth enamel appears
very strong and hard. My initial diagnosis was decalcification and sealants would be
beneficial. The difficulty seeing in the back of the mouth did not at first indicate
dental caries. A more careful look and I decided to clean the grooves well first.
Top left picture before diagnosis. Top right photo I started to clean the grooves
revealing more caries than expected. Bottom left the caries removed showed two
bombed out teeth which would have been diagnosed sooner, treated sooner, more
tooth structure saved, if the enamel were not so hard. The second molar now has a
higher risk of complete cusp fracture and needing a crown.
Perhaps the "Fluoride Bomb" is one reason measured evidence of caries cost
savings has not been published. Instead cost savings are often based on estimates
of assumptions.
be
oftci I I
um ii iy ui uciicniiii^ 11 ui
First, fluoridation would not prevent this damage and these children may
have been on fluoridated water. Second, note only the top teeth have dental
caries. The tongue protected the bottom teeth from the juice; however, the
pictures are used to suggest fluoridation would have prevented the caries.
Mother's milk often has no detectible fluoride and Mean of 0.004 ppm (NRC 2006).
-------
2. Rheumatoid and Osteoarthritic-like Pain. And skeletal fluorosis. See link for
studies
Cohorts of research must be advised the study could lead to sore joints and
muscle pain later in life. I am not a rheumatologist. Determining whether a
person's joint and muscle pain was in part contributed by excess fluoride would not
be easy.
Skeletal fluorosis is also a risk usually found with higher levels of exposure,
renal insufficiency, or genetic predisposition.
3. Bone Cancer. See link for significant studies. A Epubmed search of "fluoride
cancer" resulted in 3,509 studies. A search of "fluoride bone cancer" resulted in 596
studies. Labeled sodium fluoride is approved for diagnosis by the FDA and accounts
for many studies.
Numerous authors find fluoride to be a "known carcinogen." Fluoride is
sometimes used to cause cancer in animals so various cancer treatments can be
tested on numerous animals with the same cancers.
OSTEOSARCOMA appears to be the most studied. Several human epidemiological
studies have found an association between fluoride in drinking water and the
occurrence of osteosarcoma (bone cancer) in young males. (Bassin 2006; Cohn
1992; Hoover 1991). These studies are consistent with the National Toxicology
Program's (NTP) cancer bioassay which found that fluoride-treated male rats had a
dose-dependent increase in osteosarcoma. (Bucher 1991). Although a number of
studies have failed to detect an association between fluoride and osteosarcoma,
none of these studies have measured the risk of fluoride at specific windows in
time, which is the critical question with respect to fluoride and osteosarcoma.
As acknowledged by the NTP and most other observers, a
fluoride/osteosarcoma connection is biologically plausible. The biological plausibility
centers around three facts: 1) Bone is the principal site of fluoride accumulation,
particularly during the growth spurts of childhood; 2) Fluoride is a mutagen when
present at sufficient concentrations, and 3) Fluoride stimulates the proliferation of
bone-forming cells (osteoblasts), which may "increase the risk for some of the
dividing cells to become malignant." (NRC 2006).
17
-------
A number of studies have failed to detect an association between fluoride and
osteosarcoma. None of these studies, however, have looked at the risk of fluoride
during specific ages in life. Age specific is important because, in 2001, an age-
specific analysis of a national case-control study that previously reported no
association between lifelong exposure to fluoridated water and osteosarcoma
(Douglass 1995) found that boys consuming fluoridated water during their 6th, 7th,
and 8th years of life (the mid childhood growth spurt) had a statistically significant,
"remarkably robust," risk of developing osteosarcoma during their teenage years.
(Bassin 2001). Initially published as a PhD dissertation at Harvard, the study was
later published in Cancer Causes & Control.
Although a study in 2011 purported to refute the findings that fluoride causes
osteosarcoma (Kim 2011), the study's methods — by the authors' own admission —
were incapable of assessing the age-specific risk during the critical window period
(ages 6 to 8) that Bassin identified as the critical risk period from fluoride exposure.
And further, Kim's study compared concentrations in two forms of cancer rather
than the much lower fluoride concentration in healthy bone. Comparing two bone
cancers did not show a significant difference in fluoride bone concentration.
Certainly not evidence of safety.
Many authors report fluoride is a known carcinogen, such as:
Known Carcinogen: Pal (2014): "Fluoride, a well-established environmental
carcinogen, has been found to cause various neurodegenerative diseases in human.
Sub-acute exposure to fluoride at a dose of 20mg/kgb.w./day for 30 days caused
significant alteration in pro-oxidant/anti-oxidant status of brain tissue as reflected
by perturbation of reduced glutathione content, increased lipid peroxidation, protein
carbonylation, nitric oxide and free hydroxy! radical production and decreased
activities of antioxidant enzymes. Decreased proteolytic and transaminase enzymes'
activities, protein and nucleic acid contents and associated DNA damage were
observed in the brain of fluoride intoxicated rats. The neurotransmitters dopamine
(DA), norepinephrine (NE) and serotonin level was also significantly altered after
fluoride exposure. Protective effect of resveratrol on fluoride-induced metabolic and
oxidative dysfunctions was evaluated. Resveratrol was found to inhibit changes in
metabolic activities restoring antioxidant status, biogenic amine level and structural
organization of the brain. Our findings indicated that resveratrol imparted
antioxidative role in ameliorating fluoride-induced metabolic and oxidative stress in
different regions of the brain. "1
4. Bone Fractures see link for studies. A Epubmed search on "fluoride bone
fracture" resulted in 686 studies. Although not all studies report an increase in
1 Pal S, Sarkar C, Protective effect of resveratrol on fluoride induced alteration in protein and nucleic acid
metabolism, DNA damage 32 and biogenic amines in rat brain Environ Toxicol Pharmacol. 2014 Sep;38(2):684-99.
doi: 10.1016/j.etap.2014.07.009. Epub 2014 Jul 23.
18
-------
fractures, the preponderance of the evidence supports an increased risk of fracture
later in life.
Fluoride has been used to increase mineral density. However, any RCT on fluoride's
potential benefit must include the potential for bone fractures and tooth fractures
later in life.
5. Thyroid Reduction see link for studies. An Epubmed search for "fluoride thyroid"
resulted in over 400 studies. Effects of fluoride on the thyroid have been known for
decades. Recently, studies are reporting harm with ever lower concentrations and
low iodine seems to further increase the risk.
Any RCT on fluoride's potential benefit must include the potential for thyroid harm,
endocrine harm, cellular harm, etc.
6. Kidnev damage see link for studies and see summaries of studies. An
Epubmed search for "fluoride kidney" resulted in over 1,600 studies.
About half of the fluoride absorbed into the blood is removed from the body by the
kidneys. When they kidneys are harmed, other toxins may build up in the body.
7. Reproductive problems see link for studies. Animals studies. Human studies. A
Epubmed search of "fluoride reproductive" resulted in over 1,200 studies.
8. Lower IO and ADHD
Over the last decade the focus of fluoride research and human harm from
fluoride has been on developmental neurotoxicity. First the mechanism:
Mechanism of DNA Damage: Zhang (2008) "Some recent studies have
suggested that DNA damage may be a potential neurotoxic mechanism of fluoride.
The tail length, as measured by an ocular micrometer, is increased in fluoride-
treated human embryonic hepatocytes in a previous study carried out to investigate
the geneotic effect of fluoride (Wang et al., 2004). In the present study, we
performed OTM and percentage of DNA in the tail as indices of DNA damage. OTM,
multiplication of the tail length and percentage of DNA in the tail, objectively and
sensitively reflects the effect of fluoride on DNA damage. Our findings showed that
fluoride-induced DNA damageand OTM was more a sensitive measure than
percentage of DNA in the tail. The correlation analysis showed a positive correlation
between ROS formation and OTM level (r2=0.583, P < 0.05), which indicated that
ROS might play an important role in the course of DNA damage."2
2 Zhang M, et al. (2008). Effects of fluoride on DNA damage, S-phase cell-cycle arrest and the expression of NF-
kappaB in primary 27 cultured rat hippocampal neurons. Toxicology Letters 179(l):l-5.
19
-------
Currently the National Toxicology Program (NTP), having spent seven years
evaluating the developmental neurotoxicity of fluoride, has a draft review but not
the final published which has been promised every few months. March 2022 is the
latest expected publication. The conclusion so far is fluoride is a presumed
neurotoxin.
However, the NTP has a cut-off date for research and may not include the
latest studies. Of significance is Grandlean et al, 2001. M Benchmark Dose
Analysis for Maternal Pregnancy Urine-Fluoride and IQ in Children." Concluding,
"Thus, the joint data show a BMCL in terms of the adjusted U-F concentrations in
the pregnant women of approximately 0.2 mg/L." Urine fluoride concentrations run
similar to water fluoride concentrations and mg/L are the same as ppm. Pregnant
mothers should not drink fluoridated water which appears to reduce the IQ of their
child by about 5 IQ points. Grandjean, Fig 1 illustrates about 5 IQ loss for urine
fluoride concentration at 0.75 mg/L which concentration is similar to the water
fluoride concentration a mother drinks.
linear
squared
piecewise linear
¦o
'D
Fig 1. Association between creatinine-
iidjttttkxl maternal urinary-fluoride (U-
F) concentration in pregnancy and
child IQ Joss for the larger num-
ber of children (joint for GC] in
ELEMENT and Ml KMC). Covariate-
adjustcd models arc shown for the lin-
ear (solid), squared (dotted), and piece-
wise (dashed) linear curve with break-
point 0,75 mg/L, The BMC is the U-
F concentration that corresponds to an
10 l
-------
The developing brain is critical for success in life. The two bell curves below
illustrate the effect of 5 IQ loss for the population. Note more than half as many
mentally retarded and less than half as many gifted. For those of us with high IQ,
5 points is not as serious for basic functions as a person with 70.
The Significance of Small Effects 5 Point Decrease in Mean IQ
Example: population of ?AO million
mean 100 mean 95
Lower IQ is linked to less happiness and shorter lifespans, higher risk of adult
mental disorders, increased incarceration, increased divorce, increased educational
expense with special education, decreased employment continuity and more grief.
Here are the 23 IQ studies reported in the last 4 years, which do not include
reviews. The NTP references for their review is helpful. As research gets more
refined and developmental neurotoxicity of fluoride, an ever increasing concern
develops for fluoride's harm to the developing brain.
#1. 2021 - Indonesia. 100 students, age 6-12 years old. Relationship
between dental fluorosis and lower IQ.
Yani SI, Seweng A, Mallongi A, Nur R, Abdullah MT, Salmah U, Sirajuddin S, Basir-
Cyio M, Mahfudz, Anshary A. 2021. The influence of fluoride in drinking water on
the incidence of fluorosis and intelligence of elementary school students in Palu
City. Gaceta Sanitaria 35(Supplement 2):S159-S163.
Conclusions:"...
"The intelligence of children who suffered from fluorosis is lower than the
intelligence of children who do not suffer from fluorosis."
"The level of intelligence of students who live in the high-fluorine area is lower than
students who live in low fluorine area."
21
-------
#2. 2021 - China. 444 adults in Xuzhou City, Jiangsu Province.
Ren C, Zhang P, Yao XY, Li HH, Chen R, Zhang CY, Geng DQ. 2021. The cognitive
impairment and risk factors of the older people living in high fluorosis areas: DKK1
was low compared with
need attention. BMC Public Health 21:2237. December 9.
Results:
"The level of SOD of subjects in high fluorine drinking water
those in normal areas...
"The mRNA level of DKK1 and the level of cognitive function showed a positive
correlation and DKK1 was one of five risk factors involved in cognitive impairment
of older people living in high fluorosis areas."
# 3. 2021 - China. 709 children in Tianjin, age 6-13 years old. AChE may
partly mediate the prevalence of dental fluorosis and lower IQ.
Wang S, Zhao Q, Li G, Wang M, Liu H, Yu X, Chen J, Li P, Dong L, Zhou G, Cui Y,
Wang M, Liu L, Wang A. 2021. The cholinergic system, intelligence, and dental
fluorosis in school-aoed children with low-to-moderate fluoride
exposure. Ecotoxicology and Environmental Safety.
Conclusions:
"... Our findings suggest low-to-moderate fluoride exposure was associated with
dysfunction of cholinergic system for children. AChE may partly mediate the
prevalence of DF [dental fluorosis] and lower probability of having superior and
above intelligence."
Graphical abstract:
22
-------
Low-to-moderate
fluoride exposure
Increased prevalence
of DF, lower intelligence
#4. 2021 - Mexico. 103 Mother-Offspring pairs, tested at 12 months and
24 months. Funded by NIH & NIEHS.
Cantoral A, Tellez-Rojo MM, Malin AJ, Schriaas L, Osorio-Valencia E, Mercado A,
Martinez-Mier EA, Wright RO, Till C. 2021. Dietary fluoride intake during pregnancy
and neurodevelopment in toddlers: A prospective study in the progress
cohort. NeuroToxicology.
Conclusions:
"In this prospective cohort study, higher exposure to fluoride from food and
beverage consumption in pregnancy was associated with reduced cognitive
outcome, but not with language and motor outcome in male offspring over the first
two years of life."
#5. 2021 - China. 952 resident children, age 7 to 13 years old.
Yu X, Xia L, Zhang S, Zhou G, Li Y, Liu H, Hou C, Zhao Q, Dong L, Cui Y, Zeng Q,
Wang A, Liu L. 2021. Dietary fluoride intake during pregnancy and
neurodevelopment in toddlers: A prospective study in the progress
23
-------
cohort. Environment International 155:106681.
Conclusions:
"Our study suggests that fluoride is inversely associated with intelligence.
Moreover, the interactions of fluoride with mitochondrial function-related SNP-set,
genes and pathways may also be involved in high intelligence loss."
#6. 2021 - China. 567 children, age 6-11 fears old.
Zhao L, Yu C, Lv J, Cui Y, Wang Y, Hou C, Yu J, Guo B, Liu H, Li L. 2021. Fluoride
exposure, dopamine relative gene polymorphism and intelligence: A cross-sectional
study in China. Ecotoxicology and Environmental Safety 209:111826. [Epub ahead
of print].
Conclusions:
"Our study examined the association between excessive fluoride exposure in
prenatal and childhood periods and the intelligence of school-age children. We
found that prenatal excessive fluoride exposure could cause lower IQ scores,
especially the decreased odds of developing excellent intelligence. Meanwhile, a
negative association between fluoride exposure and children's IQ scores was
observed in children without prenatal exposure.
#7. 2020 - India. 120 children, age 8-10 years old. Relationship between
dental fluorosis and lower IQ.
Prabhakar A, Abdulkhayarkutty K, Cheruvallil SV, Sudhakaran P. 2020. Effect of
Endemic Fluorosis on Cognitive Function of School Children in Alappuzha District.
Kerala: A Cross Sectional Study. Annals of Indian Academy of Neurology.
24(5):715-720. November 6.
Conclusions:
"[Dental] Fluorosis is associated with impaired cognition in children. There is a
positive correlation between severity of dental fluorosis and the grade of cognitive
impairment."
#8. 2020 - China. 99 children, age 8-12 years old. Relationship between
dental fluorosis and lower IQ.
24
-------
Lou D, Luo Y, Liu J, Zheng D, Ma R, Chen F, Yu Y, Guan Z. 2020. Refinement
Impairments of Verbal-Performance Intelligent Quotient in Children Exposed to
Fluoride Produced bv Coal Burning. Biological Trace Element Research.
Conclusions:
"In conclusion, we believe that reducing fluoride intake with the assistance of the
government can reduce fluorosis as well as the severity of intellectual impairment
caused by fluorosis. Fluorosis in children can cause IQ impairment, especially the
VIQ that is represented by language learning and vocabulary comprehension."
#9. 2020 - Canada. 398 Mother-Offspring pairs. Fetus and Infants up to 3-
4 year-olds. Funded by NIEHS.
Till C, Green R, Flora D, Hornung R, Martinez-Miller EA, Blazer M, Farmus L, Ayotte
P, Muckle G, Lanphear B. 2020. Fluoride exposure from infant formula and child IO
in a Canadian birth cohort. Environment International 134:105315. (Published in
November 2019)
Conclusions:
"In summary, fluoride intake among infants younger than 6 months may exceed
the tolerable upper limits if they are fed exclusively with formula reconstituted with
fluoridated tap water. After adjusting for fetal exposure, we found that fluoride
exposure during infancy predicts diminished non-verbal intelligence in children..."
#10. 2020 - China. 633 children, age 7-13 years old.
Xu K, An N, Huang H, Duan L, Ma J, Ding J, He T, Zhu J, Li Z, Cheng X, Zhou G, Ba
Y. 2020. Fluoride exposure and intelligence in school-age children: evidence
from different windows of exposure susceptibility. BMC Public
Health 20:1657. November 4.
Conclusions:
The authors "found that prenatal excessive fluoride exposure could cause lower IQ
scores, especially the decreased odds of developing excellent intelligence.
Meanwhile, a negative association between fluoride exposure and children's IQ
scores was observed in children without prenatal exposure."
25
-------
#11. 2019 - China. 571 children, age 7-13 years old, from endemic and
non-endemic fluorosis areas in Tianjin.
Wang M, Liu L, Li H, LI Y, Liu H, Hou C, Zeng Q, Li P, Zhao Q, Dong L, Zhou G, Yu
X, Liu L, Guan Q, Zhang S, Wang A. 2019. Thyroid function, intelligence, and low-
moderate fluoride exposure among Chinese school-aae children. Environment
International 134:105229. [Epub ahead of print].
Conclusions:
The study suggests low-moderate fluoride exposure is associated with alterations in
childhood thyroid function that may modify the association between fluoride and
intelligence. In the current work, results demonstrated clearly that, across the full
range of water and urinary fluoride concentrations and using a measure to focus on
children's IQ scores, higher fluoride levels were associated with lower IQ scores."
#12. 2019 - Canada. 512 Mother-Offspring pairs between the ages 3 and 4
at testing. Funded by NIEHS.
Green R, Lanphear B, Hornung R, Flora D, Martinez-Mier EA, Neufeld R, Ayotte P,
Muckle G, Till C. 2019. Association Between Maternal Fluoride Exposure During
Pregnancy and IQ Scores in Offspring in Canada. JAMA Pediatrics.
Conclusions:
"In this study, maternal exposure to higher levels of fluoride during pregnancy was
associated with lower IQ scores in children aged 3 to 4 years. These findings
indicate the possible need to reduce fluoride intake during pregnancy."
Listen to discussion of JAMA editors on their process to publish this study.
#13. 2018 - China. 323 children, age 7-12 years old. Urine fluoride levels
and age-specific IQ scores.
Cui Y, Zhang B, Ma J, Wang Y, Zhao L, Hou C, Yu J, Zhao Y, Zhang Z, Nie J, Gao T,
Zhou G, Liu H. 2018. Dopamine receptor D2 oene polymorphism, urine fluoride,
and intelligence impairment of children in China: A school-based cross-sectional
study. Ecotoxicoiogy and Environmental Safety, Sept ll;165:270-277.
26
-------
Conclusions:
"Strengths of our study include using urine fluoride as an internal exposure index
and thus minimizing the measurement error of exposure, adjusting up to 30
potential confounding covariates including child age and gene polymorphismin
regressing IQ on urine fluoride in children, and careful modeling with applications of
cross-validation, bootstrap techniques, and sensitivity analysis.
"In the overall participants, by LOWESS, the IQ decreased in a roughly linear
manner as the log-urine fluoride increased (Fig. 1A).
"The authors also determined a safety threshold of urine fluoride on intelligence
impairment in the subgroup TT as 1.73 mg/L urine fluoride with a 95% CI of (1.51
mg/L, 1.97 mg/L)."
#14. 2018 - Egypt. 1,000 children, age 4-11 years old.
El Sehmawy AAEW, Hammouda SM, Ibrahim GE, Barghash SS, Elamir RY.
2018. Relationship between Drinking Water Fluoride and Intelligence Quotient in
Egyptian School Children. Occupational Medicine & Health Affairs, Aug 13: 6:3.
Conclusions:
"In this study there's a highly significant decrease in average IQ level in group of
children with high fluoride level more than 1.5 mg /dL than the group of children
with low fluoride level less than 1.5 mg /dL with the mean IQ was (96.25 ± 19.63)
and (103.11 ± 28.00) for both groups respectively with p value (p<0.001), the
graphical representation of the observation is shown in Figure 2."
#15. 2018 - Kenya. 269 school children, age 13-15 years old.
Induswe B, Opinya G, Khasakhala LI, Owino R. 2018. The Auditory Working
Memory of 13-15-Year-Old Adolescents Using Water with Varying Fluoride
Concentrations from Selected Public Primary Schools in North Kaiiado Sub
County. American Journal of Medicine and Medical Science s, Jan; 8(0):274-290.
Conclusions:
"In conclusion, low fluoride in the water seemed to enhance the AWM (Auditory
27
-------
Working Memory). However, the AWM declined with an increase in the fluoride
concentration in water."
#16. 2018 - Sudan. 775 primary students, 315 boys and 460 girls from 27
schools.
Mustafa DE, Younis UM, Elhag SA. (2018). The relationship between the fluoride
levels in drinking water and the schooling performance of children in rural areas of
Khartoum State, Sudan (pdf). Fluoride 51(2): 102-113.
Results:
"Negative correlation coefficients were found for the average score for all the
subjects and for the overall score, with the result being statistically significant in
five out of the eight subjects and in the overall score (Tables 4 and 5). ... significant
correlations undoubtedly exit between the drinking water F level and the schooling
performances in all the subjects except for one, technology, which might be due to
the nature of the subject."
#17. 2018 - China. 268 children, age 8 -12 years old: 134 children each
from endemic fluorosis area and non-endemic fluorosis areas.
Pang H, Yu L, Lai X, Chen Q. 2018. Relation Between Intelligence and COMT Gene
Polymorphism in Children Aged 8-12 in the Endemic Fluorosis Area and Non-
Endemic Fluorosis Area. Chinese Journal of Control of Endemic Diseases 32(2): 151-
152. Study in Chinese translated into English.
Conclusions:
"This study found that there was a great difference in the level of intelligence
between children in the endemic fluorosis area and those in the non-endemic
fluorosis area and such difference was statistically significant (P < 0.05)." ... "The
rate of mental retardation (IQ < 69) in children in the endemic fluorosis area was
significantly higher than that in the non-endemic fluorosis area, and the difference
was statistically significant (P < 0.05)."
#18. 2018 - China. 2,886 resident children, age 7 to 13 years
old. Relationship between dental fluorosis and lower IQ.
28
-------
Yu X, Chen J, Li Y, Liu H, et al. (2018). Threshold effects of moderately excessive
fluoride exposure on children's health: A potential association between dental
fluorosis and loss of excellent intelligence. Environment International, Jun 2;
118:116-124.
Conclusions:
"In conclusion, chronic exposure to excessive fluoride, even at a moderate level,
was inversely associated with children's dental health and intelligence scores,
especially excellent intelligence performance, with threshold and saturation effects
observed in the dose-response relationships. Additionally, DF [dental fluorosis]
severity is positively associated with the loss of high intelligence, and may be useful
for the identification of individuals with the loss of excellent intelligence."
#19. 2017 - Mexico. 299 Mother-Offspring pairs. Tests at age 4 and 6-12
years. Funding from NIH, NIEHS, and EPA.
Bashash M, Thomas D, Hu H, Martinez-Mier EA, Sanchez BN, Basu N, Peterson KE,
Ettinger AS, Wright R, Zhang Z, Liu Y, Schnaas L, Mercado-Garcfa A, Tellez-Rojo
MM, Hernandez-Avila M. 2017. Prenatal Fluoride Exposure and Cognitive Outcomes
in Children at 4 and 6-12 Years of Age in Mexico. Environmental Health
Perspectives, Sept 19;125(9):097017.
Conclusions:
"In this study, higher prenatal fluoride exposure, in the general range of exposures
reported for other general population samples of pregnant women and nonpregnant
adults, was associated with lower scores on tests of cognitive function in the
offspring at age 4 and 6-12 y."
#20. 2017 - Mexico. 65 Mother-Offspring pairs, aged 3-15 months, in an
endemic hydrofuorosis area.
Valdez Jimenez L, Lopez Guzman OD, Cervantes Flores M, Costilla-Salazar R,
Calderon Hernandez J, Alcaraz Contreras Y, Rocha-Amador DO. 2017. In utero
exposure to fluoride and cognitive development delay in
infants. Neurotoxicology Mar;59:65-70.
29
-------
Results:
"In this study near to 60% of the children consumed contaminated water and the
prevalence of children with IQ below 90 points was 25% in the control group (F
urine 1.5 mg/g creatinine) in comparison with the 58% of children in the exposed
group (F urine >5 mg/g creatinine) (OR = 4.1, CI 95% 1.3-13.2) (data
unpublished). "Only 66.2% of the babies were at term. "We found higher levels of F
in urine across trimester in premature compared with full term 2.4 vs 1.6 mg/l
(1st); 2.3 vs 1.8 mg/l (2nd); and 4.1 vs 2.8 mg/l (3rd) (data not shown)."
#21. 2017 - China. 118 newborns, 68 newborns to 12 months of age, from
coal-burning fluorosis areas.
Chang A, Shi Y, Sun H, Zhang L. 2017. Analysis on the Effect of Coal-Burning
Fluorosis on the Physical Development and Intelligence Development of Newborns
Delivered bv Pregnant Women with Coal-Burning Fluorosis. Chinese Journal of
Control of Endemic Diseases, 32(8): 872-87.
Conclusions:
"Comparison of the mental development index (MDI) and psychomotor
development index (PDI) (assessed using the Standardized Scale for the
Intelligence Development of Children formulated by the Children Development
Center of China [CDCC]) of newborns in the two groups at 3, 6, 9 and 12 months
after birth showed that both the MDI and the PDI in the observation group were
significantly lower than those in the control group (P< 0.05), which suggests that
maternal fluorosis have a significant impact on the intelligence development of
newborns."
#22. 2017 - China. 284 children, age 8-12 years old: 167 were from coal
burning-related endemic fluorosis areas and 117 were the control.
Jin T, Wang Z, Wei Y, Wu Y, Han T, Zhang H. (2017). Investigation of Intelligence
Levels of Children of 8 to 12 Years of Age in Coal Burning-Related Endemic
Fluorosis Areas. Journal of Environment and Health 34(3): 229-231.
Conclusions:
30
-------
"The intelligence of the 12-year-old group in the endemic area was lower than that
of the control area, with the difference having statistical significance (Z = 3.244, P
= 0.001)/'
#23. 2017 - India. 219 children, age 12-14 fears old: 75 from low F area,
75 medium F area, and 69 from high F area.
Razdan P, Patthi B, Kumar JK, Agnihotri N, Chaudhan P, Prasad M. (2017). Effect of
fluoride concentration in drinking water on intelligence quotient of 12-14-vear-old
children in Mathura District: A cross-sectional study. Journal of International
Society of Preventive & Community Dentistry 7(5): 252-258.
Conclusions:
"Concentration of Fluoride in the ingested water was significantly associated with
the IQ of children. Outcome measures revealed that exposure to higher levels of F
determined by dental fluorosis status of child inferred higher IQ deficit."
Do we need more evidence before we tell our children and grandchildren to reduce
fluoride exposure?
Attention Deficit Disorder
For example, Riddell et. Al, 2019 "Association of water fluoride and urinary
fluoride concentrations with attention deficit hyperactivity disorder in
Canadian youth '
" We found that Canadian youth exposed to higher tap water fluoride levels had a
higher risk of receiving an ADHD diagnosis and reported more symptoms of
hyperactivity and inattention. Specifically, an increase of 1.0?mg/L in water fluoride
concentration was associated with a 6.1 times higher odds of an ADHD diagnosis
after accounting for potential confounding variables, such as exposure to second-
hand smoke, household income, and blood lead level. Likewise, water fluoride
concentration was positively associated with hyperactive/inattentive symptoms,
especially among older youth."
9. Allergies (overactive immune system)
Physicians Desk Reference: "In hypersensitive individuals, fluorides occasionally
cause skin eruptions such as atopic dermatitis, eczema or urticaria. Gastric distress,
31
-------
headache and weakness have also been reported. These hypersensitivity reactions
usually disappear promptly after discontinuation of the fluoride."
Some individuals are chemically sensitive to fluoride with various symptoms which
make research more complex. One mother said her daughter develops a rash with
fluoridated water. As a competitive athlete they would visit different towns. After a
shower at a hotel this mother would check to see if her daughter had the rash.
Then she would call the water district for that area and ask if the water was
fluoridated. The rash was consistent with fluoridation.
Another mother I have worked with and know well has an autistic child, now an
adult, and her comments here are significant.
Julie Simms https://www.voutube.com/watch?v=Js-2-aVnVE4
Audrey Adams https://www.voutube.com/watch?v=ORfvHwuohz4
"My 36 year old autistic son Kyle has severe chemical sensitivities, discovered in
1999 after a long and painful search for answers to his many ailments and bizarre
symptoms that had eluded doctors for years. Then, after changing his diet and
environment to eliminate chemicals, his medical conditions improved but he still
had chronic pain and daily headaches. At the suggestion of another mom with two
autistic teenagers, I finally eliminated all fluoridated water for drinking and cooking
in 2000. The pain faded awav in three days.
"As the years went by, Kyle's ability to detoxify decreased and his reactivity to
chemicals increased. In 2008, he was experiencing severe headaches again, often
migraines, but oddly they happened mostly in the mornings, after he got out of bed
but before going to work. We tried every imaginable intervention without success.
"One day another mother of an autistic son told me about her son's reactions, and
her own, to bathing in fluoridated water. I was dumbfounded that I hadn't even
thought of transdermal exposure from my son's morning shower! We had a
chlorine filter on the showerhead, but it didn't take the fluoride out. I switched his
shower to the evening to test the theory-—he had another headache pounding soon
after.
"I've tested various waters, including chlorinated-only, and the common pain
denominator, consistently, is fluoridated water. It took me 14 years to discover
Kyle's reactivity to fluoride, plus another 9 to recognize the pain from fluoridated
showers.
"Of all the chemicals that Kyle reacts to, fluoride in water is the hardest and most
expensive to avoid.
"The common belief is that fluoridated water is safe for everyone. I know from my
own experience that this is not true. Please don't pass any legislation or new
32
-------
funding---as is included in SB-5693---that would multiply these health harms and
suffering across our state.
Audrey Adams
14411 150th Ave SE
Renton WA 98059"
I have found no good evidence fluoride causes autism. However, parents of autistic
kids have reported their child is chemically sensitive and finding fluoride is one of
those chemicals.
10. Gastrointestinal disorders
GI disorders are a plausible result of fluoride ingestion. I have not recently looked
again into the research on fluoride's effects on the GI tract. See link attached.
33
-------
VI. Fluoride Toxicity and Regulatory Oversight.
Sodium fluoride is considered lethal at about 5 mg/Kg BW,3 which is in
contrast to the more stable calcium fluoride at about 5,000 mg/Kg BW found more
commonly in hard water naturally containing fluoride.
Washington State Law RCW 69.38 defines a poison as: "Any other substance
designated by the state board of pharmacy which, when introduced into the human
body in quantities of sixty grains or less, causes violent sickness or death." Sixty
grains is 3,889 mg. Sodium fluoride is defined by law as a poison, exempt when
regulated under drug laws.
Oregon and Federal law defines a highly toxic substance (poison) as a
substance which causes serious illness or death at 50 mg/Kg of body weight or less.
The toxicity of fluoride at 5 mg/Kg BW is less than 50mg/Kg BW and therefore
fluoridation compounds are poisons and are exempt from poison laws when
regulated as approved drugs, but NOT exempt as foods.
Fluoride is highly toxic and considered a poison by state and Federal poison
laws, exempt when regulated as a pesticide or drug. The Washington State Board
of Pharmacy determined fluoride is a legend drug.
Drug Therapy (Digest) in 1975 reported the FDA sent letters to 35
manufacturers of fluoride supplements/ . .there is no substantial evidence of
drug effectiveness as prescribed, recommended or suggested in its labeling. . .
marketing is in violation of the new drug provisions of the Federal Food, Drug, and
Cosmetic Act; they have, therefore, requested that marketing of these products be
discontinued."
In 2016 the FDA sent a letter to Kirkman Laboratories their fluoride drops
and tablets were unapproved drugs, misbranded, and in violation.
The FDA has approved fluoridated toothpaste with the warning, "Do Not
Swallow." Keep out of Reach of Children. Use a pea size amount and if more than
used for brushing is swallowed, contact the poison control center. The amount of
concern for the FDA is 0.25 mg, the same as a glass of fluoridated water.
3 "It may be concluded that if a child ingests a fluoride dose in excess of 15 mg F/kg, then death is likely to occur. A
dose as low as 5 mg F/kg may be fatal for some children. Therefore, the probably toxic dose (PTD), defined as the
threshold dose that could cause serious or life-threatening systemic signs and symptoms and that should trigger
immediate emergency treatment and hospitalization, is 5 mg F/kg." SOURCE: Whitford G. (1996). Fluoride
Toxicology and Health Effects. In: Fejerskov O, Ekstrand J, Burt B, Eds. Fluoride in Dentistry, 2nd Edition.
Munksgaard, Denmark, p 171."
34
-------
SDWA: "No national primary drinking water regulation may require the
addition of any substance for preventive health care purposes unrelated to
contamination of drinking water." 42 USC 300a-l(,b')(,ll'):
"The Safe Drinking Water Act prohibits the deliberate addition of any
substance to drinking water for health-related purposes other than disinfection of
the water." FOI Response HQ-FOI-01418-10
In letters from the EPA and FDA, the EPA claims it does not determine the
efficacy or safety of fluoride because the FDA has jurisdiction over drugs.
In turn, the FDA claims it does not have jurisdiction over water because the
EPA does.
State Departments and Boards of Health, Centers for Disease Control,
Surgeon General, American Dental Association all respond they rely on others to
determine the efficacy, dosage and safety of ingested fluoride.
Ethics: An Epubmed search of "fluoridation ethics" resulted in 254 studies
with mixed opinions. Fluoridated salt found the least ethical objections. Most
studies assume fluoride ingestion reduces caries and has FDA approval.
When "FDA" was added to the search, only one of the three studies was
applicable and considered fluoridation of water unethical. Caries is not a highly
contagious lethal disease justifying supplementing without individual consent.
"My adult autistic son Kyle is severely hypersensitive to fluoride in all forms
and cannot consume fluoridated water, or anything made with it, and cannot
shower in it without suffering pain. Because of this and the extreme difficulty
avoiding fluoridated water in caring for my son, I agreed to be a plaintiff on Kyle's
behalf in a lawsuit against the EPA to force them to consider the latest science and
toxicology on fluoride, not just the outdated science of 70 years ago that never
even considered the effects of fluoride to the developing brain.
As Stuart Cooper of Fluoride Action Network explains about the lawsuit:
"There is now a large body of government-funded research indicating that fluoride
is neurotoxic, and is associated with lowered IQ in children and a significant
increase in ADHD diagnosis and related behaviors in children at doses experienced
in fluoridated communities. Experts in toxicology have likened the size of the effect
to that from lead, and the level of evidence that fluoride is neurotoxic now far
exceeds the evidence that was in place when lead was banned from gasoline.
"The neurotoxicity concerns are so serious that the National Toxicology Program
(NTP) has been conducting a review of the human studies on linking fluoride to
cognitive impairment. In their recent draft systematic review , the NTP declared,
35
-------
"fluoride is presumed to be a cognitive neurodevelopmental hazard to humans,"
i.e., causes brain damage to fetuses and infants, especially lowered IQs based on
the large number, quality, and consistency of recent peer-reviewed studies. NTP
identified 29 brain studies considered "high quality." Of those, 27 found significant
adverse effects associated with low-level fluoride exposure, and of those, 10 at
levels found in fluoridated water.
"Neurotoxicity concerns are also now being heard in federal court. (Click here to
watch a 16-minute overview of the trial presented by the attorney for the plaintiffs)
A coalition of environmental and public health groups has sued the EPA under
Section 21 of the Toxic Substances Control Act (TSCA), seeking a ban on water
fluoridation chemicals. The U.S. District Court for the Northern District of California
has already held the first phase of the trial in the summer of 2020, and after Covid
delays in 2021 the court is expected to have a decision on whether fluoridation is
an unreasonable risk to health by the end of this year.
"A ruling that fluoridation is a risk would reasonably lead to an EPA prohibition on
the use of fluoridation chemicals. Thus, it would be reckless for the legislature to
pass a bill requiring municipalities spend large amounts of money assessing the
implementation of fluoridation, and using tax dollars to facilitate and promote this
outdated and dying practice while we await a final report from the NTP and a ruling
from a federal judge on the neurotoxic hazard posed by fluoridation additives.
"The Judge in the case has already stated that he believes fluoride is in-fact a
developmental hazard, but he is awaiting the NTP's review to ensure he is able to
provide as comprehensive a judgment as possible." Audrey Adams
The journal Nature recently published an article that discusses the trial and the new
science.
Federal Lawsuit Deposition Testimony from CDC and EPA (three short videos'): Here
are three very short clips of deposition testimony under oath from representatives
of the CDC and EPA:
In the first video, Casey Hannan, the Director of the CDC's Oral Health Division,
testifies that the CDC has no data establishing the safety of fluoride's effect on the
brain, despite decades of touting the safety of fluoridation for all citizens, including
children. httPs://www.voutube.com/watch?v=XkILustif5A (1:14)
In the second video. Casey Hannan (of the CDC) admits there is no prenatal or
early-life benefit from fluoride despite its known neurotoxicity to this same sub-
population. httPs://www.voutube.com/watch?v=2vDMwhWsa4U (8:40)
In the third video, Joyce Donohue, PhD, a scientist from the EPA's Office of Water
admits that the EPA's current fluoride risk assessment, and thus fluoridation
regulations, are out of date and should be updated in response to the collection of
36
-------
studies showing neurotoxicity published since 2017.
https://www.voutube.com/watch?v=rkMAJ itEOk (1:07)
Steven Gilbert, Toxicologist, University of Washington, wrote a downloadable book,
"A Small Dose of Toxicology", including Chapter 15 on fluoride that helps a
layperson (or legislator) put fluoride in perspective with other toxicants that pose
risks to human health, especially children.
https://www.asmalldoseoftoxicoloQv.org/download-in-enalish
Genetics
Jarqufn-Yneza L (2018)4 "Conclusions: An association of rs 412777 polymorphism
in the C0L1A2 gene with dental fluorosis was found. Therefore, genetic variants
represent a relevant risk factor to develop dental fluorosis, as it was proven in this
study conducted in Mexican children."
Toxins affecting the DNA can have a multigenerational effect. In animal studies I
have seen one that had a negative neurotoxic effect to the third generation.
Suzuki M (20155) "In this study, we demonstrate that fluoride exposure generates
reactive oxygen species (ROS) and the resulting oxidative damage is counteracted
by SIRTl/autophagy induction through c-Jun N-terminal kinase (JNK) signaling in
ameloblasts. In the mouse-ameloblast-derived cell line LS8, fluoride induced ROS,
mitochondrial damage including cytochrome-c release, up-regulation of UCP2,
attenuation of ATP synthesis, and H2AX phosphorylation (yH2AX), which is a
marker of DNA damage. We evaluated the effects of the ROS inhibitor N-
acety/cysteine (NAC) and the JNK inhibitor SP600125 on fluoride-induced
SIRTl/autophagy activation. NAC decreased fluoride-induced ROS generation and
attenuated JNK and c-Jun phosphorylation. NAC decreased SIRT1 phosphorylation
and formation of the autophagy marker LC3II, which resulted in an increase in the
apoptosis mediators yH2AX and cleaved/activated caspase-3. SP600125 attenuated
fluoride-induced SIRT1 phosphorylation, indicating that fluoride activates
SIRTl/autophagy via the ROS-mediated JNK pathway. In enamel organs from rats
4 Jarqufn-Yneza L, Alegrfa-Torres JA, Castillo CG, de Jesus Mejfa-Saavedra J. Dental fluorosis
and a polymorphism in the C0L1A2 gene in Mexican children. Arch Oral Biol. 2018
Dec;96:21-25. doi: 10.1016/j.archoralbio.2018.08.010. Epub 2018 Aug 23. PMID:
30172079.
5 Suzuki M, Bandoski C, Bartlett JD. Fluoride induces oxidative damage and
SIRTl/autophagy through ROS-mediated JNK signaling. Free Radic Biol Med. 2015
Dec;89:369-78. doi: 10.1016/j.freeradbiomed.2015.08.015. Epub 2015 Sep 30. PMID:
26431905; PMCID: PMC4684823
37
-------
or mice treated with 50, 100, or 125 ppm fluoride for 6 weeks, cytochrome-c
release and the DNA damage markers 8-oxoguanine, p-ATM, and yH2AX were
increased compared to those in controls (0 ppm fluoride). These results suggest
that fluoride-induced ROS generation causes mitochondrial damage and DNA
damage, which may lead to impairment of ameloblast function. To counteract this
impairment, SIRTl/autophagy is induced via JNK signaling to protect
cells/ameloblasts from fluoride-induced oxidative damage that may cause dental
fluorosis."
For the protection of the most vulnerable, the FDA must correctly regulate fluoride
ingestion, stop fluoridation of bottled water and regulate fluoride as an unapproved
drug.
Sincerely,
Bill Osmunson DDS MPH
38
-------
FLUORIDATION
CENSUS
1989- SUMMARY
JULY - 1991
U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
Public Health Service
Centers for Disease Control
National Center for Prevention Services
Dental Disease Prevention Activity
Atlanta, Georgia 30333
CDC INFORMATION CENTER
centers for disease control
ATLANTA, GA 30333
-------
TABLE OF CONTENTS
PAGE
INTRODUCTION iii
METHODOLOGY iv
SUMMARY OF FLUORIDATION
STATISTICS 1
TABLE I Population and Percent Served with Adjusted and
Natural Fluoridated Water by Region and State as of
December 31, 1989 2
TABLE II Number of Public Water Systems, Communities, and Population
Using Adjusted and Natural Fluoridation by Region and State
as of December 31, 1989 4
TABLE III School Population and Number of Schools Using Adjusted and
Natural Fluoridation by Region and State as of December 31,
1989 6
TABLE IV Population, Number of American Indian and Alaskan Native
Reservations Using Adjusted and Natural Fluoridation, by Region
and State as of December 31, 1989. 7
TABLE V Resident Population, Number of Military Installations Using
Adjusted and Natural Fluoridation, by Region and State as of
December 31, 1989 9
TABLE VI Number of Public Water Systems and Population Served by Each
of the Major Chemicals by Regions as of December 31,
1989 11
FLUORIDATION STATISTICS FIGURES AND
CHARTS 12a
Chart 1 Percent of Public Water Supply Population Using Fluoridated
Water and State Ranking 13
Chart 2 U.S. Fluoridation Status December 31, 1989 14
Chart 3 U.S. Fluoridation Status by DHHS Region December 31, 1989 15
Chart 4 Fluoridation Growth, by Population United States,
1945-1989 16
Chart 5 U.S. Population on Public Water Systems 17
Chart 6 Total U.S. Population Year 1989 18
Chart 7 Total Public Water Supply Population Year 1989 19
Chart 8 Number of Public Water Systems EPA Data 1989.. 20
Chart 9 Number of Fluoridated Public Water Systems Fluoridation
Census 1989 - Summary 21
Chart 10 Type of Public Water Systems Fluoridating Year 1989.... 22
Chart 11 Fluoridation Adjusted and Natural Fluoridation Census 1989 -
Summary 23
i
OG* 'ii'ilrt
-------
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
TABLE OF CONTENTS
FLUORIDATION STATISTICS STATE SUMMARIES
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana .
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
FLUORIDATION STATISTICS TERRITORY SUMMARIES
American Samoa
Northern Marianas
Guam
Republic of Palau
Trust Territories
Virgin Islands
ii
-------
.INTRODUCTION
The adjustment of the fluoride content of community water supplies to an
optimal level to prevent tooth decay began on January 25, 1945, in Grand
Rapids, Michigan. At the present time, over 128 million citizens in more than
8,081 communities throughout the Nation are receiving the benefits of
optimally adjusted fluoridated water. An additional 9 million people in 1,869
communities are using water with naturally occurring fluoride at levels of 0.7
parts per million or higher. Therefore, 44 years after the first water system
was fluoridated, more than 54 percent of the Nation's population has access to
water with a dentally significant concentration of fluoride.
Adjusted fluoridation is the conscious maintenance of the optimal fluoride
concentration in the water supply for reducing dental caries and minimizing
the risk of dental fluorosis. The optimal concentration may be accomplished
by adding fluoride chemicals to fluoride deficient water; by blending two or
more sources of water naturally containing fluoride to achieve the optimal
concentration; or partial defluoridation, that is, removing naturally
occurring excessive fluorides to obtain the recommended level. Water systems
are considered to have optimal level of natural fluoride if they contain
naturally occurring fluoride at or above the minimum recommended control
range. Water systems and communities with optimally adjusted fluoride and
naturally occurring fluoride in water are listed in this publication.
Adjusted water systems are fluoridated at the optimal level according to the
average maximum daily air temperature in the community. (Recommended
concentrations, according to National Interim Primary Drinking Water
Regulations, 1975, are shown on Table A.) Although the term natural
fluoridation has no particular scientific or official connotation, it has been
used in this publication for the sake of simplification.
TABLE A
RECOMMENDED OPTIMAL FLUORIDE LEVEL
Annual Average of
Maximum Daily Air
Temperatures (°F)
Optimal Fluoride
Recommended Control Range
Community Systems
School Systems
Community
(ppm)
School2
(ppm)
0.1
Below
0.5
Above
20%
Low
20%
High
40.0 - 53.7
1.2
5.4
1.1
1.7
4.3
6.5
53.8 - 58.3
1.1
5.0
1.0
1.6
4.0
6.0
58.4 - 63.8
1.0
4.5
0.9
1.5
3.6
5.4
63.9 - 70.6
0.9
4.1
0.8
1.4
3.3
4.9
70.7 - 79.2
0.8
3.6
0.7
1.3
2.9
4.3
79.3 - 90.5
0.7
3.2
0.6
1.2
2.6
3.8
1. Based on temperature data obtained for a minimum of five years.
2. Based on 4.5 times the optimum fluoride level for communities.
Source: Centers for Disease Control, National Center for Prevention Services,
Dental Disease Prevention Activity.
iii
-------
METHODOLOGY
A computer printout of the fluoridation status for each state as it was
collected for the 1988 Fluoridation Census Summary was forwarded to every
state health department as a guide to updating information for the
Fluoridation Census 1989 Summary. They were requested to update, change, and
verify the information presented and to include new fluoridation installations
while deleting those that were inappropriate. A request was made to update
the population figures to reflect 1989 census estimates. This information was
then submitted for the Fluoridation Census 1989: States were asked to report
each fluoridated water system and the communities each system served; the
status of fluoridation, adjusted, consecutive, or natural; the system from
which water was purchased, if consecutive; the population receiving
fluoridated water; the date on which fluoridation started; and the chemical
used for fluoridation, if adjusted.
The updated information was returned to CDC where a master file was created to
incorporate the new format and to reflect changes made in the previous data
provided by state health officials. The states were informed that unless they
made specific changes in their state's printout, the data on the existing
printout would be used in the publication of the Fluoridation Census 1989
Summary. In essence, this publication is a report of the status of
fluoridation made by the states, and the data herewith reported have been
provided by the individual states.
Previous Status Reports were:
Fluoridation Census. 1967. Division of Dental Health, National Institutes of
Health, U.S. Department of Health, Education, and Welfare. U.S. Government
Printing Office Publication #1968 0-310-023.
Fluoridation Census. 1969. Division of Dental Health, National Institutes of
Health, U.S. Department of Health, Education, and Welfare. Natural Fluoride
Content of Community Water Supplies, Division of Dental Health, NIH, DHEW.
U.S Government Printing Office Publication #1970 0-380-791.
Fluoridation Census. 1975. Dental Disease Prevention Activity, Bureau of State
Services, Center for Disease Control, Public Health Service, U.S. Department
of Health, Education, and Welfare. U.S Government Printing Office Publication
# 1977 - 740-116/3782, Region No. 4.
Fluoridation Census. 1980. Dental Disease Prevention Activity, Center for
Prevention Services, Centers for Disease Control, Public Health Service, U.S.
Department of Health and Human Services. U.S. Government Printing Office
Publication #1984 - 751-641, Region No. 4.
Fluoridation Census. 1985. Dental Disease Prevention Activity, Center for
Prevention Services, Centers for Disease Control, Public Health Service, U.S.
Department of Health and Human Services. U.S. Government Printing Office
Publication # 1988 - 535-439.
Fluoridation Census Summary. 1988. Dental Disease Prevention Activity, Center
for Prevention Services, Centers for Disease Control, Public Health Service,
U.S. Department of Health and Human Services.
iv
-------
SUMMARY OF
FLUORIDATION
STATISTICS
-------
TABLE 1
POPULATION AND PERCENT SERVED WITH ADJUSTED AND NATURAL FLUORIDATED
WATER BY REGION AND STATE AS OF DECEMBER 31, 1989
TOTAL
POPULATION"
POPULATION
BY PUBLIC WATER
SUPPLY"
POPULATION
FLUORIDATED
WATER
% PUBLIC WATER
SUPPLY
POPULATION
DRINKING
FLUORIDATED WATER
RANK
UNITED STATES
248,243,000
220,179,000
135,256.757
61.4
REGIOH I
13,046,000
11,453,000
7,175,756
Illillliffi^Iiillllij
CONNECTICUT
3,239,000
2,727,000
2,362,309
86.6
13
MAINE
1,222,000
819,000
438,041
53.5
36
MASSACHUSETTS
5,913,000
5,810,000
3,262,426
56.2
34
NEW HAMPSHIRE
1,107,000
734,000
147,367
20.1
46
RHODE ISLAND
998,000
942,000
732,986
77.8
21
VERMONT
567,000
421,000
232,627
55.3
35
REGIOH II
25,686,000
2B,380.000
15,365.540
NEW JERSEY*
7,736,000
7,736,000
1,170,047
15.1
49
NEW YORK
17,950,000
16,612,000
11,674,181
70.3
26
PUERTO RICO"
3,291,000
3,291,000
2,521,312
62.5
29
REGIOH III
25,966,000
2,1.830,000
14,748,622
ilillllllllllllilll
DELAWARE
673,000
625,000
439,871
70.4
25
DISTRICT OF COLUMBIA
604,000
604,000
604,000
100.0
1
MARYLAND
4,694,000
3,818,000
3,438,289
90.1
8
PENNSYLVANIA
12,040,000
10,154,000
5,153,056
50.7
38
VIRGINIA
6,098,000
4,950,000
3,927,673
79.3
19
WEST VIRGINIA
1,857,000
1,679,000
1,185,733
70.6
24
REGIOH IT
44,596,000
37,464,000
27,226.863
ALABAMA
4,118,000
3,768,000
3,111,359
82.6
18
FLORIDA
12,671,000
10,966,000
6,625,372
56.4
33
GEORGIA
6,436,000
5,499,000
4,711,222
85.7
15
KENTUCKY
3,727,000
3,307,000
2,606,159
78.8
20
MISSISSIPPI
2,621,000
2,417,000
1,236,414
51.2
37
NORTH CAROLINA
6,571,000
4,634,000
3,329,736
71.9
22
SOUTH CAROLINA
3,512,000
2,779,000
2,423,325
84.2
16
TENNESSEE
4,940,000
4,094,000
3,557,276
86.9
12
REGIOH V
46,651,000
37.55/, 000
34,903,643
ILLINOIS
11,658,000
10,605,000
10,605,000
100.0
1
INDIANA
5,593,000
3,761,000
3,759,967
99.9
3
MICHIGAN
9,273,000
6,863,000
6,187,361
90.2
7
MINNESOTA
4,353,000
3,688,000
3,079,917
83.5
17
OHIO
10,907,000
9,314,000
8,291,075
89.0
10
WISCONSIN
4,867,000
3,326,000
2,980,323
89.6
9
"Based oil 1986 Bureau of Census estimates
**Federal Reporting Data Systems PWS service populations exceeded the Bureau of Census estimates for DC, HI, IL, NJ, NV,
TX & PR.
+Data for these States based on previous Fluoridation Censuses.
2
-------
TABLE 1 (CONTINUED)
POPULATION AND PERCENT SERVED WITH ADJUSTED AND NATURAL FLUORIDATED
WATER BY REGION AND STATE AS OF DECEMBER 31, 1989
TOTAL
POPULATION"
POPULATION
BY PUBLIC WATER
SUPPLY"
POPULATION
FLUORIDATED
WATER
% PUBLIC WATER SUPPLY
POPULATION DRINKING
FLUORIDATED WATER
RANK
UNITED STATES
248,243,000
220,179,000
135,256,757
61.4
REGION VI
28,551,000
27,073,000
16,599,420
ARKANSAS
2,406,000
1,963,000
1,179,731
60.1
31
LOUISIANA
4,382,000
4,091,000
1,978,703
48.4
39
NEW MEXICO
1,528,000
1,306,000
810,586
62.1
30
OKLAHOMA
3,224,000
2,722,000
1,617,232
59.4
32
TEXAS
16,991,000
16,991,000
11,013,168
64.8
28
REGION VII
12,123,000
10,552,000
6,947,743
IOWA
2,840,000
2,361,000
2,037,802
86.3
14
KANSAS
2,513,000
2,469,000
992,375
40.2
42
MISSOURI
5,159,000
4,616,000
3,128,456
67.8
27
NEBRASKA
1,611,000
1,106,000
789,110
71.3
23
REGION VIII
7,680,000
7,015,000
4,321,663
llllfsiiiiiliiiiiiiiiiii
COLORADO
3,317,000
2,270,000
2,961,682
90.6
6
MONTANA*
806,000
580,000
169,085
29.2
44
NORTH DAKOTA
660,000
513,000
475,074
92.6
5
SOUTH DAKOTA
715,000
555,000
546,177
98.4
4
UTAH
1,707,000
1,707,000
42,733
2.5
51
WYOMING
475,000
390,000
126,912
32.5
43
REGION IX
34,842.000
31,743,000
5,052,270
ARIZONA
3,556,000
3,091,000
617,749
20.0
47
CALIFORNIA
29,063,000
26,428,000
4,268,060
16.2
48
HAWAII
1,112,000
1,112,000
142,570
12.8
50
NEVADA*
1,111,000
1,111,000
23,891
2.2
52
REGION X
9,122,000
7,112,000
2,913,237
ALASKA
527,000
363,000
321,321
88.5
11
IDAHO
1,014,000
700,000
300,027
42.9
41
OREGON
2,820,000
2,188,000
506,920
23.2
45
WASHINGTON
4,761,000
3,861,000
1,784,969
46.2
40
"Based on 1989 Bureau of Census estimates
**Federal Reporting Data System PWS service populations exceeded the Bureau of Census estimates for DC, HI, IL, NJ, NV, UT,
TX & PR.
+Data for these States based on previous Fluoridation Censuses.
3
-------
TABLE II
NUMBER OF PUBLIC WATER SYSTEMS, COMMUNITIES, AND POPULATIONS USING
ADJUSTED AND NATURAL FLUORIDATION BY REGION AS OF DECEMBER 31, 1989
USING ADJUSTED
USING NATURAL
SYSTEMS'
COMMUNITIES
POPULATION
SYSTEMS'
COtMUNITIES
POPULATION
UNITED STATES
9,411
8,081
128,457,294
3,463
1,869
9,315,642
REGIOH I
250
S47
7.163.529
71
3
12,227
CONNECTICUT
36
88
2,361,279
4
1
1,030
MAINE
62
90
438,041
0
0
0
MASSACHUSETTS
73
110
3,262,029
3
0
397
NEW HAMPSHIRE
11
9
136,567
64
2
10,800
RHODE ISLAND
18
20
732,986
0
0
0
VERMONT
59
30
232,627
0
0
0
REGION II
720
700
15,250,259
19
23
115,281
NEW JERSEY
28
66
1,056,302
15
20
113,745
NEW YORK
653
592
11,672,645
4
3
1,536
PUERTO RICO
39
42
2,521,312
0
0
0
REGION III
503
950
14,760,398
268
87
268,224
DELAWARE
9
11
432,700
5
3
7,171
DISTRICT OF COLUMBIA
2
1
604,000
0
0
0
MARYLAND
100
74
3,389,676
54
34
48,613
PENNSYLVANIA
135
545
5,153,056
0
0
0
VIRGINIA
122
175
3,715,892
208
50
211,781
WEST VIRGINIA
138
144
1,185,074
1
0
659
REGIOH IV
1,812
1,268
25,778,797
292
iiiiiiiiiliiiiii
1,450,066
ALABAMA
252
173
3,047,360
28
19
63,999
FLORIDA
101
131
5,371,616
27
30
881,756
GEORGIA
283
239
4,694,957
5
4
16,265
KENTUCKY
293
212
2,606,159
0
0
0
MISSISSPPI
216
127
1,140,324
69
12
96,090
NORTH CAROLINA
237
148
3,248,435
29
23
81,301
SOUTH CAROLINA
170
42
2,112,670
134
2
310,655
TENNESSEE
260
196
3,557,276
0
0
0
REGION V
3,526
2,810
35,555,915
869
529
1,582,407
ILLINOIS
1,342
979
9,964,403
206
147
641,021
INDIANA
434
305
3,496,527
93
79
263,440
MICHIGAN
362
240
6,068,551
94
52
118,810
MINNESOTA
667
650
3,075,805
14
12
4,112
OHIO
395
367
8,047,628
310
115
243,447
WISCONSIN
326
269
2,803,780
152
124
176,543
*Note: Systems refers to fluoridating systems plus consecutive systems.
4
-------
TABLE II (CONTINUED)
NUMBER OF PUBLIC WATER SYSTEMS, COMMUNITIES, AND POPULATIONS USING
ADJUSTED AND NATURAL FLUORIDATION BY REGION AS OF DECEMBER 31, 1989
USING ADJUSTED
USING NATURAL
SYSTEMS*
COMMUNITIES
POPULATION
SYSTEMS'
COMMUNITIES
POPULATION
UNITED STATES
9,411
8,081
128,457,294
3,463
1,869
9,315,642
REGION VI
750
487
13,138,025
778
401
2,462,895
ARKANSAS
164
115
1,168,376
14
7
12,855
LOUISIANA
51
73
1,744,824
95
33
233,879
NEW MEXICO
70
18
564,973
86
41
245,613
OKLAHOMA
173
102
1,508,080
55
36
109,152
TEXAS
292
179
8,151,772
528
284
2,861,396
REGION VII
721
738
6,295,549
434
350
652,194
IOWA
, 345
343
1,724,723
226
174
313,079
KANSAS
105
129
838,100
83
77
154,275
MISSOURI
216
209
2,975,665
82
64
152,791
NEBRASKA
55
57
757,061
43
35
32,049
REGION VIII
!!§iiiiiiiiii
465
3,323,399
536
Illiliiflliilll
998,264
COLORADO
150
60
2,161,000
298
106
800,682
MONTANA
32
9
65,296
64
28
103,789
NORTH DAKOTA
133
132
448,039
78
60
27,035
SOUTH DAKOTA
261
251
506,931
69
61
39,246
UTAH
11
4
36,709
15
7
6,024
WYOMING
8
9
105,424
12
11
21,488
KBGIOfT XX
166
95
4,625,525
12Q
47
426,745
ARIZONA
71
7
212,586
103
43
405,163
CALIFORNIA
74
82
4,267,960
1
0
100
HAWAII
10
3
142,570
0
0
0
NEVADA
11
3
2,409
16
4
21,482
REGION X
357
221
2,565,898
76
66
347,339
ALASKA
197
135
321,321
0
0
0
IDAHO
14
6
54,687
40
34
245,340
OREGON
37
30
465,220
20
20
41,700
WASHINGTON
109
50
1,724,670
16
12
60,299
*Note: Systems refers to fluoridating systems plus consecutive systems.
5
-------
TABLE III
SCHOOL POPULATION AND NUMBER OF SCHOOLS USING ADJUSTED
AND NATURAL FLUORIDATION BY REGION AND STATE AS OF DECEMBER 31, 1989
USING ADJUSTED*
USING NATURAL"
POPULATION
NUMBER OF
SCHOOLS
POPULATION
NUMBER OF
SCHOOLS
UNITED STATES
122,458
351
8,824
12
REGION I
5,630
23
0
0
VERMONT
5,630
23
0
0
REGION III
3,020
5
D
0
VIRGINIA
3,020
5
0
0
REGION IV
67,0*1
182
0
0
KENTUCKY
24,933
78
0
0
NORTH CAROLINA
41,658
103
0
0
SOUTH CAROLINA
450
1
0
0
REGION V
~4,703
133
6.719
2
INDIANA
35,899
85
0
0
MINNESOTA
1,543
5
0
0
WISCONSIN
7,261
43
6,719
2
REGION VI
1,410
2
1,045
6
NEW MEXICO
1,410
2
1,045
0
REGION VII
0
0
400
0
MISSOURI
0
0
400
0
REGION IX
170
1
660
3
ARIZONA
170
1
660
3
REGION X
484
5
0
0
ALASKA
484
5
0
0
~Schools are fluoridated at 4.5 times the recommended optimal level for communities.
Note: Schools include all American Indian and Alaskan Native Reservation Schools
6
-------
TABLE IV
POPULATION, NUMBER OF AMERICAN INDIAN AND ALASKAN NATIVE
RESERVATIONS USING ADJUSTED AND NATURAL FLUORIDATION, BY REGION AND STATE AS OF
DECEMBER 31, 1989
SYSTEMS
ADJUSTED
NATURAL
POPULATION
NUMBER OF
SYSTEMS
POPULATION
NUMBER OF
SYSTEMS
UNITED STATES
255,030
458
17,348
58
REGION I
1,225
2
O
O
MAINE
1,225
2
0
0
REGION IV
4,13S
10
0
1
FLORIDA
N/R
2
0
0
MISSISSIPPI
2,378
3
0
0
NORTH CAROLINA
1,761
5
N/R
1
REGION V
8,137
11
O
0
WISCONSIN
8,137
11
0
0
REGION VI
52,060
48
lllllllllllll
30
NEW MEXICO
51,520
46
8,978
30
OKLAHOMA
540
2
0
0
REGION VII
7,296
5
o
0
IOWA
266
1
0
0
MISSOURI
A, 080
1
0
0
NEBRASKA
2,930
3
0
0
REGION VIII
48,192
11111111111
1,143
7
COLORADO
1,400
1
0
0
MONTANA
5,877
19
419
3
NORTH DAKOTA
10,189
16
465
1
SOUTH KAKOTA
23,949
65
84
1
UTAH
5,109
7
175
2
WYOMING
1,668
1
0
0
REGION IX
69,253
98
6,777
19
ARIZONA
60,816
67
6,070
15
CALIFORNIA
6,053
21
100
1
NEVADA
2,384
10
607
3
REGION X
64,728
175
450
1
ALASKA
50,428
140
0
0
IDAHO
1,295
4
0
0
OREGON
3,480
5
0
0
WASHINGTON
9,525
26
450
1
7
-------
TABLE IV (CONTINUED)
POPULATION, NUMBER OF AMERICAN INDIAN AND ALASKAN NATIVE
RESERVATIONS USING ADJUSTED AND NATURAL FLUORIDATION, BY REGION AND STATE AS OF
DECEMBER 31, 1989
SCHOOLS*
ADJUSTED
NATURAL
POPULATION
NUMBER OF
SYSTEMS
POPULATION
NUMBER OF
SCHOOLS
UNITED STATES
2,064
8
8.824
12
REGION V
0
0
6,719
2
WISCONSIN
0
0
6,719
2
REGION VI
1,410
2
1,045
6
NEW MEXICO
1, A10
2
1,045
6
REGION VII
lllllllsilifili
0
l§p|lilii|llll
1
MISSOURI
0
0
400
1
REGION XX
llllliilllll!
llilllliilllll
lllilliiiiiii:
3
ARIZONA
170
i
660
3
REGION X
484
5
0
0
ALASKA
484
5
0
0
~Schools are fluoridated at 4.5 times the recommended optimal level for communities.
8
-------
TABLE V
RESIDENT POPULATION, NUMBER OF MILITARY INSTALLATIONS USING
ADJUSTED AND NATURAL FLUORIDATION, BY REGION AND STATE, AS OF DECEMBER 31, 1989
ADJUSTED
NATURAL
RESIDENT
POPULATION
USING ADJUSTED
INSTALLATIONS
ADJUSTED
RESIDENT
POPULATION
USING ADJUSTED
INSTALLATIONS
NATURAL
UNITED STATES
1,252,436
131
51,45*
18
REGION I
18,225
5
O
0
MAINE
10,200
2
0
0
MASSACHUSETTS
8,000
2
0
0
NEW HAMPSHIRE
25
1
0
0
REGION II
45,552
6
0
0
NEW JERSEY
35,952
3
0
0
NEW YORK
9,600
3
0
0
REGION III
70,117
!§!!!lllll!ll!l
2
DELAWARE
6,400
2
0
0
MARYLAND
52,003
7
2,027
2
VIRGINIA
11,714
2
0
0
REGION IT
512,599
*5
8,276
2
ALABAMA
31,763
4
0
0
FLORIDA
109,127
12
5,100
1
GEORGIA
89,900
6
0
0
KENTUCKY
23,400
1
0
0
MISSISSIPPI
32,497
3
0
0
NORTH CAROLINA
120,200
10
0
0
SOUTH CAROLINA
44,593
6
3,176
1
TENNESSEE
61,119
3
0
0
REGION V
82,995
9
1,639
2
ILLINOIS
61,795
5
139
1
INDIANA
1,500
1
0
0
MICHIGAN
19,700
3
0
0
OHIO
0
0
1,500
1
9
-------
TABLE V (CONTINUED)
RESIDENT POPULATION, NUMBER OF MILITARY INSTALLATIONS USING
ADJUSTED AND NATURAL FLUORIDATION, BY REGION AND STATE, AS OF DECEMBER 31, 1989
ADJUSTED
NATURAL
RESIDENT
POPULATION
USING ADJUSTED
INSTALLATIONS
ADJUSTED
RESIDENT
POPULATION
USING ADJUSTED
INSTALLATION
NATURAL
UNITED STATES
1,252,436
131
51,454
18
REGION VI
169,421
22
7,200
3
ARKANSAS
14,170
2
0
0
LOUISIANA
22,100
3
1,700
1
OKLAHOMA
16,224
5
0
0
TEXAS
116,927
12
5,500
2
KEGIOH VII
64,287
.'.'.'.".5".
4,000
1
KANSAS
33,000
3
0
0
MISSOURI
22,500
1
4,000
1
NEBRASKA
8,787
1
0
0
REGION Till
47,418
5
7.602
2
MONTANA
3,000
1
7,602
2
NORTH DAKOTA
29,518
2
0
0
SOUTH DAKOTA
5,000
1
0
0
UTAH
9,900
1
' 0
0
REGION IX
1*2,570
illllliill!!
20,710
6
ARIZONA
0
0
19,200
5
HAWAII
142,570
10
0
0
NEVADA
0
0
1,510
1
REGION X
99,252
13
0
0
ALASKA
35,543
9
0
0
IDAHO
6,000
1
0
0
WASHINTON
57,709
3
0
0
10
-------
TABLE VI
NUMBER OF PUBLIC WATER SUPPLY SYSTEMS AND POPULATION SERVED BY EACH
OF THE MAJOR CHEMICALS BY REGION AS OF DECEMBER 31, 1989
HYDROFLUOSILICIC
ACID
SODIUM
SILICOFLUORIDE
SODIUM
FLUORIDE
POPULATION
#SYSTEMS
POPULATION
^SYSTEMS
POPULATION
^SYSTEMS
UNITED STATES
75,295,924
5,187
35,050,494
1,432
11,474,400
2,431
REGION I
4,165,319
103
1,582,467
28
950,443
126
CONNECTICUT
1,668,039
24
559,500
5
133,740
7
MAINE
283,601
35
72,500
2
81,940
25
MASSACHUSETTS
2,373,338
22
270,980
5
617,711
46
NEW HAMPSHIRE
87,942
5
0
0
48,625
6
RHODE ISLAND
88,199
1
639,487
15
0
0
VERMONT
114,200
16
50,000
1
68,427
42
REGION II
4,289,766
556
8.001,726
67
2,756,369
83
NEW JERSEY
645,005
18
317,600
3
80,697
6
NEW YORK
3,644,761
538
7,684,126
64
154,360
38
PUERTO RICO
0
0
0
0
2,521,312
39
REGION III
9,127,881
207
2.019.624
1,545,948
174
DELAWARE
0
0
140,000
1
43,400
5
DISTRICT OF COLUMBIA
604,000
1
0
0
0
0
MARYLAND
2,065,870
56
130,353
7
38,350
12
PENNSYLVANIA
3,746,844
71
513,269
28
245,742
23
VIRGINIA
1,913,821
54
885,770
29
900,960
37
WEST VIRGINIA
517,346
25
350,232
16
317,496
97
REGION IV
13,414,146
lllllilllllll
8,470,948
373
2,712,369
672
ALABAMA
2,984,903
241
53,852
8
0
0
FLORIDA
2,709,456
66
2,382,120
10
9,412
5
GEORGIA
2,335,346
106
863,150
38
995,111
120
KENTUCKY
1,704,706
91
649,679
51
222,097
143
MISSISSIPPI
20,665
7
372,740
11
746,541
196
NORTH CAROLINA
1,156,172
58
1,378,260
13
343,607
126
SOUTH CAROLINA
986,652
59
918,879
" 85
206,839
25
TENNESSEE
1,516,246
46
1,852,268
157
188,762
¦ 57
REGION T
27,628,710
2,527
6,470,647
304
1,322,492
662
ILLINOIS
9,042,175
991
546,203
86
371,004
261
INDIANA
1,513,878
110
1,278,753
44
702,375
278
MICHIGAN
5,328,349
290
609,621
46
38,239
10
MINNESOTA
2,832,691
614
201,461
17
39,267
32
OHIO
4,811,100
277
3,148,770
85
56,933
28
WISCONSIN
2,195,156
245
570,744
26
36,496
53
Note: Chemical used was not indicated for all systems, so these data are not consistent with other summary tables.
1 1
-------
TABLE VI (CONTINUED)
NUMBER OF PUBLIC WATER SUPPLY SYSTEMS AND POPULATION SERVED BY EACH
OF THE MAJOR CHEMICALS BY REGION AS OF DECEMBER 31, 1989
HYDROFLUOSILICIC
ACID
SODIUM
SILICOFLUORIDE
SODIUM
FLUORIDE
POPULATION
# SYSTEMS
POPULATION
# SYSTEMS
POPULATION
# SYSTEMS
UNITED STATES
75,295,924
5,187
35,050,494
1,432
11,474,400
2.431
REGION VI
8,490,225
360
3,888,665
260
746,450
130
ARKANSAS
677,248
69
481,729
89
7,514
6
LOUISIANA
1,747,024
52
0
0
0
0
NEW MEXICO
399,250
4
10,000
1
155,723
65
OKLAHOMA
188,642
34
1,099,206
118
220,232
21
TEXAS
5,478,061
201
2,297,730
52
362,981
38
RECTOR VII
4.983,675
464
1,175,103
102
321,427
141
IOWA
1,350,754
318
354,458
14
18,747
10
KANSAS
389,565
30
615,321
64
30,273
4
MISSOURI
2,538,719
73
168,618
18
268,328
125
NEBRASKA
704,637
43
36,706
6
4,079
2
REGION VIII
464,728
239
2,557,728
164
262.149
154
COLORADO
82,500
3
1,983,240
115
83,260
27
MONTANA
0
0
40,100
4
25,196
28
NORTH DAKOTA
156,131
92
256,628
15
35,280
26
SOUTH DAKOTA
210,250
141
168,551
23
106,436
68
UTAH
4,300
2
17,000
1
10,309
4
WYOMING
11,547
1
92.209
6
1,668
1
REGION IX
1.178,919
14
135,000
1
207,963
101
ARIZONA
12,000
1
135,000
1
56,386
61
CALIFORNIA
1,166,919
13
0
0
6,598
19
HAWAII
0
0
0
0
142,570
0
NEVADA
0
0
0
0
2,409
11
REGION X
1.102,555
43
738,586
52
648,790
188
ALASKA
0
0
0
0
257,639
125
IDAHO
0
0
48,842
8
5,845
6
OREGON
22,800
2
426,090
26
16,330
9
WASHINGTON
1,079,755
41
263,654
18
368,976
48
Note: Chemical used was not indicated for all systems, so these data are not consistent with other sunmary tables.
12
-------
FLUORIDATION
STATISTICS
CHARTS
-------
Chart 1
PERCENT OF PUBLIC WATER SUPPLY POPULATION USING FLUORIDATED WATER AND STATE RANK
WA
46.2
#40
OR
23.2
#45
CA
NV
2.2
#52
#48
ID
42.9
#41
UT
2.5
#51
AZ
20.0
#47
MT
29.2
WY
32.5
#43
CO
90.6
#6
NM
62.1
#30
ND
92.6
#5
SD
98.4
*L
NE
71.3
#23
MN
83.5/
#17
KS
TX
64.8
#28
IA
86.3
#14
Wl
89.6
#9
MO
LA
48..
#39
Ml
90.2
#7
NY
70.3
#26
VT7
40.2
67.8 S
CM
4
#27
OK
59.4
^#32
AR A
60.1 }
#31 /
IL
100.
#1
IN
99.91
#3
OH
89.0
#10,
KY
78.8 #20>
' TN
PA
50.7
#38_
VA(
79.3,
#19.
NC
86.9
#12
MS
AL \
51.2
82.6
#37
#18
GA
85.7
#15
71.9
84.2 sc;
#16/
#22)
#331
Rl
•DE
¦MD
^DC
AK 88.5 #11
CT 86.6 # 13
DE 70.4 #25
DC 100.0 #1
HI 12.8 #50
MA 56.2 #34
MD 90.1 #8
NH 20.1 #46
NJ 15.1 #49
PR 62.5 #29
Rl 77.8 #21
VT 55.3 #35
CDC/CPS/DDPA
-------
Chart 2
U.S. FLUORIDATION STATUS
DECEMBER 31, 1989
UNITED STATES
PUBLIC WATER SYSTEM
FLUORIDATED
PERCENT P.W.S. POP.
PERCENT U.S. POP.
POPULATION
POPULATION
POPULATION
FLUORIDATED
FLUORIDATED
DECEMBER 31, 1989
248,243,000
220,179,000
135,256,757
61.4
54.5
DECEMBER 31, 1985
243,195,000
211,730,873
130,172,334
61
54
CDC/CPS/DDPA
-------
Chart 3
U.S. FLUORIDATION STATUS
BY DHHS REGION
DECEMBER 31, 1989
TOTAL
P.W. SYSTEM
FLUORIDATED
PERCENT P.W.S.
PERCENT TOTAL
POPULATION
POPULATION
POPULATION
FLUORIDATED
i . .
FLUORIDATED
TOTAL U.S.
248,243,000
220,179,000
135,256,757
61.4
54.5
REGION I
13,046,000
11,453,000
7,175,756
62.7
55.0
REGION II
25,686,000
28,380,000
15,365,540
54.1
59.8
REGION III
25,966,000
21,830,000
14,748,622
67.6
56.8
REGION IV
44,496,000
37,464,000
27,228,863
72.7
61.2
REGION V
46,651,000
37,557,000
34,903,643
92.9
74.8
REGION VI
28,531,000
27,073,000
16,599,420
61.3
58.2
REGION VII
12,123,000
10,552,000
6,947,743
65.8
57.3
REGION VII
7,680,000
7,015,000
4,321,663
61.6
56.3
REGION IX
34,842,000
31,743,000
5,052,270
15.9
14.5
REGION X
9,122,000
7,112,000
2,913,237
41.0
31.9
CDC/CPS/DDPA
-------
Fluoridation Growth, by Population, chai™
United States, 1945 - 1989
Population (Millions)
Year
Total U.S. Population Public Water Supply Total F Water Naturally Fluoridated
Population Population Water Population
CDC/CPS/DDPA
-------
U.S. Population on Public Water Systems Chart 5
YEAR 1989
88.7%
~ P.W.S. Population
~ Private Well Population
;
U.S. Population - 248,243,000
CDC/CPS/DDPA
-------
Total U.S. Population
YEAR 1989
Chart 6
U.S. Population = 248,243,000
CDC/CPS/DDPA
-------
Total Public Water Supply Population cnan?
YEAR 1989
~
~
Fluoridated
Non-Fluoridated
Public Water Supply Population = 220,179,000
CDC/CPS/DDPA
-------
Number of Public Water Systems charts
EPA DATA 1989
-------
Mummm ©f p^joridated f=w,s.
fluopjdat&n csmsus i§@@ - mmmmi
systems §5§m
eowgeeyiwE systems 2ss?i
SmTUSAL SYSTEMS 3,414
TOTAL FLUORIDATED SYSTEMS 1Ss874
-------
Type of P.W.S. Fluoridating
YEAR 1989
Chart 10
~
~
~
Adjusted
Natural
Consecutive
FSuoridating Systems = 12,874
CDC/CPS/DDPA
-------
Fluoridation Adjusted and Natural Chart 11
Fluoridation Census 1989 - Summary
D Adjusted
~ Natural
Fluoridated Population = 135,179,757
CDC/CPS/DDPA
-------
FLUORIDATION
STATISTICS
STATE SUMMARIES
-------
I
STATE SUMMARY DATA AS OF 12/31/89
ALABAMA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
56
30,905
261
121,000
1,001-5,000
114
275,989
265
648,000
5,001-10,000
52
382,539
71
526,000
10,001-50,000
49
939.402
53
995,000
50,001-100,000
5
352,470
5
352,000
>100,000
4
1,130,000
4
1,125,000
TOTAL
280
3,111,359
659
3,768,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
105
2,454,172
78.9
CONSECUTIVE
154
598,933
19.2
NATURAL
21
58,254
1.8
TOTAL
280
3,111,359
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
4
31,763
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
0
0
SODIUM SILICOFLUORIDE
8
53,852
HYDROFLUOSILICIC ACID
241
2,984,903
25
-------
STATE SUMMARY DATA AS OF 12/31/89
ALASKA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
177
43,323
469
85,000
1,001-5,000
11
29,193
24
58,000
5,001-10,000
6
45,805
8
64,000
10,001-50,000
2
43,000
2
43.000
50,001-100,000
0
0
0
0
>100,000
1
160,000
1
113,000
TOTAL
197
321,321
504
363,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
197
321,321
100.0
CONSECUTIVE
0
0
0
NATURAL
0
0
0
TOTAL
197
321,321
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
140
50,428
0
0
INDIAN SCHOOLS
5
484
0
0
MILITARY SYSTEMS
9
35,543
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
125
257,639
SODIUM SILICOFLUORIDE
0
0
HYDROFLUOSILICIC ACID
0
0
26
-------
STATE SUMMARY DATA AS OF 12/31/89
ARIZONA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
112
34,750
624
150,000
1,001-5,000
36
85,237
95
231,000
5,001-10,000
13
91,845
22
164,000
10,001-50,000
11
162,917
24
468,000
50,001-100,000
0
0
3
203,000
>100,000
2
243,000
5
1,875,000
TOTAL
174
617,749
773
3,092,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
71
212,586
34.4
CONSECUTIVE
0
0
0.0
NATURAL
103
405,163
65.6
TOTAL
174
617,749
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
67
60,816
15
6,070
INDIAN SCHOOLS
1
170
3
660
MILITARY SYSTEMS
0
0
5
19,200
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
61
56,386
SODIUM SILICOFLUORIDE
1
135,000
HYDROFLUOSILICIC ACID
1
12,000
27
-------
STATE SUMMARY DATA AS OF 12/31/89
ARKANSAS
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
59
31,555
411
179,000
1,001-5,000
71
170,019
240
558,000
5,001-10,000
24
178,335
37
266,000
10,001-50,000
20
411,550
26
526,000
50,001-100,000
1
64,000
3
240,000
>100,000
2
324,272
1
195,000
TOTAL
177
1,179,731
718
1,963,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
67
874,255
74.1
CONSECUTIVE
97
292,951
24.8
NATURAL
13
12,555
1.1
TOTAL
177
1,179j 731
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
2
14,170
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
6
7,514
SODIUM SILICOFLUORIDE
89
481,729
HYDROFLUOSILICIC ACID
69
677,248
28
-------
STATE SUMMARY DATA AS OF 12/31/89
CALIFORNIA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
23
5,027
2,736
510,000
1,001-5,000
9
18,761
415
1,025,000
5,001-10,000
2
14,000
149
1,059,000
10,001-50.000
26
708,756
248
6,198,000
50,001-100,000
7
487,816
70
4,890,000
>100,000
8
3,033,700
42
12,746,000
TOTAL
75
4,268,060
3,660
26,428,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
63
3,842,017
90.0
CONSECUTIVE
11
425,943
o
•
o
H
NATURAL
1
100
O
•
o
TOTAL
75
4,268,060
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
21
6,053
1
100
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
19
6,598
SODIUM SILICOFLUORIDE
0
0
HYDROFLUOSILICIC ACID
13
1,166,919
29
-------
STATE SUMMARY DATA AS OF 12/31/89
COLORADO
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1.000
285
71,079
557
133,000
1,001-5,000
100
228,089
117
258,000
5,001-10,000
22
163,718
29
228,000
10,001-50,000
31
678,422
24
559,000
50,001-100,000
5
348,000
6
463,000
>100,000
5
1,472,404
4
1,630,000
TOTAL
448
2,961,682
737
3,270,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
57
1,809,959
61.1
CONSECUTIVE
95
360,841
12.2
NATURAL
296
790,882
to
a\
•
TOTAL
448
2,961,682
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
1
1,400
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
27
83,260
SODIUM SILICOFLUORIDE
115
1,983,240
HYDROFLUOSILICIC ACID
3
82,500
30
-------
STATE SUMMARY DATA AS OF 12/31/89
CONNECTICUT
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
4
1,030
546
84,000
1,001-5,000
3
6,428
39
95,000
5,001-10,000
1
6, 000
12
92,000
10,001-50,000
20
592,504
28
696,000
50,001-100,000
7
429,549
5
281,000
>100,000
5
1,326,798
6
1,479,000
TOTAL
40
2,362,309
636
2,727,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
35
2 , 358,779
99.9
CONSECUTIVE
1
2,500
0.1
NATURAL
4
1,030
o
•
o
TOTAL
40
2,362,309
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
7
133,740
SODIUM SILICOFLUORIDE
5
559,500
HYDROFLUOSILICIC ACID
24
1,668,039
31
-------
STATE SUMMARY DATA AS OF 12/31/89
DELAWARE
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
3
1, 065
195
44,000
1,001-5,000
5
11,206
30
70,000
5,001-10,000
2
11,800
6
40,000
10,001-50,000
1
32,800
3
98,000
50,001-100,000
1
93,000
1
93,000
>100,000
2
290,000
2
280,000
TOTAL
14
439,871
237
625,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
9
432,700
98.4
CONSECUTIVE
0
0
0.0
NATURAL
5
7,171
1.6
TOTAL
14
439,871
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
2
6,400
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
5
43,400
SODIUM SILICOFLUORIDE
1
140,000
HYDROFLUOSILICIC ACID
0
0
32
-------
STATE SUMMARY DATA AS OF 12/31/89
DISTRICT OF COLUMBIA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
0
0
0
0
1,001-5,000
0
0
0
0
5,001-10,000
0
0
0
0
10,001-50,000
0
0
0
0
50,001-100,000
0
0
0
0
>100,000
2
604,000
2
604,000
TOTAL
2
604,000
2
604,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
1
884,000
100.0
CONSECUTIVE
0
0
o
•
o
NATURAL
0
0
o
•
o
TOTAL
1
884,000
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
0
0
SODIUM SILICOFLUORIDE
0
0
HYDROFLUOSILICIC ACID
1
884,000
33
-------
STATE SUMMARY DATA AS OF 12/31/89
FLORIDA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
8
1,752
1,377
329,000
1,001-5,000
29
93,262
293
682,000
5,001-10,000
24
174,109
81
583,000
10,001-50,000
43
1,088,386
132
2,994,000
50,001-100,000
13
849,164
26
1,858,000
>100,000
11
4,046,699
18
4,522,000
TOTAL
128
6,253,699
lj 927
10,966,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
98
5,381,616
85.9
CONSECUTIVE
3
0
0.0
NATURAL
27
881,756
14.1
TOTAL
128
6,253,372
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
2
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
12
109,127
1
1,072
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
5
9,412
SODIUM SILICOFLUORIDE
10
2,382,120
HYDROFLUOSILICIC ACID
66
2,709,456
34
-------
STATE SUMMARY DATA AS OF 12/31/89
GEORGIA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
38
20,373
1,289
261,000
1,001-5,000
127
349,023
204
507,000
5,001-10,000
54
383,386
54
379,000
10,001-50,000
51
1,111,540
55
1,183,000
50,001-100,000
9
611,400
8
553,000
>100,000
9
2,235,500
9
2,616,000
TOTAL
288
4,711,222
1 j 619
5,499,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
238
3,970,851
84.3
CONSECUTIVE
45
724,106
15.4
NATURAL
5
16,265
0.3
TOTAL
288
4,711,222
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
6
89,900
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
120
995,111
SODIUM SILICOFLUORIDE
38
863,150
HYDROFLUOSILICIC ACID
106
2,335,346
35
-------
STATE SUMMARY DATA AS OF 12/31/89
HAWAII
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
1
970
72
24,924
1.001-5,000
4
13,200
37
87,234
5,001-10,000
1
5,700
7
48,890
10,001-50,000
3
58,800
11
217,606
50,001-100,000
1
63,900
2
141,875
>100,000
0
0
1
592,243
TOTAL
10
142,570
130
1,112,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
7
121,470
85.2
CONSECUTIVE
3
21,100
CO
•
H
NATURAL
0
0
0.0
TOTAL
10
142,570
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
10
142,570
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
10
142,570
SODIUM SILICOFLUORIDE
0
0
HYDROFLUOSILICIC ACID
0
0
36
-------
STATE SUMMARY DATA AS OF 12/31/89
IDAHO
SYSTEM SIZE CLASSIFICATION
FLUORIDAT]
3D SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
27
8,400
729
123,000
1,001-5,000
17
42,533
62
158,000
5,001-10,000
3
19,016
11
80,000
10,001-50,000
6
125,078
11
235.000
50,001-100,000
0
0
0
0
>100,000
1
105,000
1
105,000
TOTAL
54
300,027
814
700,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
12
53,937
o
•
00
H
CONSECUTIVE
2
750
o
to
NATURAL
40
245,340
CO
•
T—1
CO
TOTAL
54
300,027
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
4
1,295
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
1
6,000
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
6
5,845
SODIUM SILICOFLUORIDE
8
48,842
HYDROFLUOSILICIC ACID
0
0
37
-------
STATE SUMMARY DATA AS OF 12/31/89
ILLINOIS
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
764
269,726
1,134
395,000
1,001-5,000
475
867,665
494
1,096,000
5,001-10,000
111
659,656
115
822,000
10.001-50.000
172
3,062,453
165
3,475.000
50,001-100,000
19
1,057,214
16
1,034,000
>100,000
7
4,688,285
6
3,782,000
TOTAL
1,548
10j605,000
1,930
10,605,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
948
7,440,835
58. 0
CONSECUTIVE
401
4,626,518
36.0
NATURAL
199
772,326
6.0
TOTAL
1,548
12,839,679
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
5
61,795
1
139
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
261
449,182
SODIUM SILICOFLUORIDE
86
661,298
HYDROFLUOSILICIC ACID
991
10,947,536
38
-------
STATE SUMMARY DATA AS OF 12/31/89
INDIANA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
220
121,605
543
173,000
1,001-5,000
196
472,744
241
535,000
5,001-10,000
54
384,737
56
383,000
10,001-50,000
46
1,005,637
48
997,000
50,001-100,000
5
337,695
5
349,000
>100,000
6
1,437,549
5
1,326,000
TOTAL
527
3,759,967
898
3,761,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
330
3,287,718
87.4
CONSECUTIVE
105
209,629
5.6
NATURAL
92
262,620
7.0
TOTAL
527
3,759,967
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
85
35,899
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
1
1,500
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
278
702,375
SODIUM SILICOFLUORIDE
44
1,278,753
HYDROFLUOSILICIC ACID
110
1,513,878
39
-------
STATE SUMMARY DATA AS OF 12/31/89
IOWA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
323
143,524
1,003
294,000
1,001-5,000
182
394,345
242
500,000
5,001-10,000
37
268,294
41
299,000
10,001-50,000
21
471,420
22
504.000
50,001-100,000
5
328,335
5
325,000
>100,000
3
431,884
3
440,000
TOTAL
571
2,037,802
1,316
2,361,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
259
1,627,189
79.9
CONSECUTIVE
92
100,683
4.9
NATURAL
220
309,930
15.2
TOTAL
571
2,037,802
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
1
286
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
1
250
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
10
18,747
SODIUM SILICOFLUORIDE
14
354,458
HYDROFLUOSILICIC ACID
318
1,350,754
40
-------
STATE SUMMARY DATA AS OF 12/31/89
KANSAS
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
101
40,195
624
215,000
1,001-5,000
55
123,194
221
469,000
5,001-10,000
8
51,847
19
138,000
10,001-50,000
21
419,105
38
816,000
50,001-100,000
1
54,013
0
0
>100,000
2
304,021
4
830,000
TOTAL
188
992,375
906
2,469,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
48
802,387
80.9
CONSECUTIVE
58
36,381
3.7
NATURAL
82
153,607
15.5
TOTAL
188
992,375
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
3
33,000
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
4
30,273
SODIUM SILICOFLUORIDE
64
615,321
HYDROFLUOSILICIC ACID
30
389,565
41
-------
STATE SUMMARY DATA AS OF 12/31/89
KENTUCKY
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
95
37,070
202
67,000
1,001-5,000
111
289,360
231
559,000
5,001-10,000
39
279,399
69
483,000
10,001-50,000
43
776,380
50
921.000
50,001-100,000
2
121,450
3
174,000
>100,000
3
1,102,500
3
1,103,000
TOTAL
293
2,606,159
558
3,307,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
278
2,573,841
98.8
CONSECUTIVE
15
32,318
1.2
NATURAL
0
0
o
•
o
TOTAL
293
2,606,159
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
78
24,933
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
1
23,400
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
143
222,097
SODIUM SILICOFLUORIDE
51
649,679
HYDROFLUOSILICIC ACID
91
1,704,706
42
-------
STATE SUMMARY DATA AS OF 12/31/89
LOUISIANA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
67
26,477
1,043
258,000
1,001-5,000
41
93,965
275
600,000
5,001-10,000
14
101,131
43
303,000
10,001-50,000
14
264,906
45
822.000
50,001-100,000
7
461,860
8
494,000
>100,000
3
1,030,364
6
1,613,000
TOTAL
146
1,978,703
1,420
4,091,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
49
1,733,824
87.6
CONSECUTIVE
3
13.200
0.7
NATURAL
94
231,679
11.7
TOTAL
146
1,978,703
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
3
22,100
1
1,700
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
0
0
SODIUM SILICOFLUORIDE
0
0
HYDROFLUOSILICIC ACID
52
1,747,024
43
-------
STATE SUMMARY DATA AS OF 12/31/89
MAINE
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1.000
5
2,882
312
53,000
1,001-5,000
36
87,128
71
162,000
5,001-10,000
9
65,580
15
109,000
10,001-50,000
12
282,451
15
337,000
50,001-100,000
0
0
0
0
>100,000
0
0
1
158,000
TOTAL
62
438,041
414
819,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
60
415,765
94.9
CONSECUTIVE
2
22,276
5.1
NATURAL
0
0
o
•
o
TOTAL
62
438,041
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
2
1,225
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
2
10,200
0
0
NUMBER
POPULATION
SODIUM FLUORIDE
25
81,940
SODIUM SILICOFLUORIDE
2
72,500
HYDROFLUOSILICIC ACID
35
283,601
44
-------
STATE SUMMARY DATA AS OF 12/31/89
MARYLAND
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
82
14,018
403
96,000
1,001-5,000
41
123,601
104
287,000
5,001-10,000
4
34,800
12
97,000
10.001-50,000
21
470,870
21
512,000
50,001-100,000
3
195,000
2
130,000
>100,000
3
2,600,000
4
2,697,000
TOTAL
154
3,438^289
546
3,818,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
87
1,289,676
35.9
CONSECUTIVE
13
2,100,000
61.1
NATURAL
54
48,613
1.4
TOTAL
154
3,438,289
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
7
52,003
2
2,027
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
12
38,350
SODIUM SILICOFLUORIDE
7
130,353
HYDROFLUOSILICIC ACID
56
2,065,870
45
-------
STATE SUMMARY DATA AS OF 12/31/89
MASSACHUSETTS
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
4
1,147
217
40,000
1,001-5,000
6
23,457
83
249.000
5,001-10,000
11
73,319
56
395,000
10,001-50,000
47
1,041,738
124
2,765.000
50,001-100,000
6
448,213
17
1,215,000
>100,000
2
1,674,534
4
1,146,000
TOTAL
76
3,262,426
501
5,810,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
73
3,262,029
100.0
CONSECUTIVE
0
0
0.0
NATURAL
3
397
0.0
TOTAL
76
3,262,426
SCHOOLS. INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
2
8,000
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
46
617,711
SODIUM SILICOFLUORIDE
5
270,980
HYDROFLUOSILICIC ACID
22
2,373,338
46
-------
STATE SUMMARY DATA AS OF 12/31/89
MICHIGAN
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
120
51,368
1, 022
267,000
1,001-5,000
167
437,441
295
676,000
5,001-10,000
61
441,468
75
537,000
10,001-50,000
85
1,945,369
89
2,029,000
50,001-100,000
15
1,102,954
16
1,147,000
>100,000
8
2,208,761
8
2,209,000
TOTAL
456
61187,361
1,505
6,863,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
133
2,960,305
47.8
CONSECUTIVE
229
3,108,246
50.2
NATURAL
94
118,810
1.9
TOTAL
456
6,187,361
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
3
19,700
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
10
38,239
SODIUM SILICOFLUORIDE
46
609,621
HYDROFLUOSILICIC ACID
290
5,328,349
4 7
-------
STATE SUMMARY DATA AS OF 12/31/89
MINNESOTA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
383
170,554
713
219,000
1,001-5,000
198
448,352
209
473,000
5,001-10,000
38
276,518
32
239,000
10,001-50,000
57
1,249.453
53
1,136.000
50,001-100,000
3
232,548
2
151,000
>100,000
2
702,492
4
1,469.000
TOTAL
681
3,079,917
1,013
3,688,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
635
2,910,362
94.5
CONSECUTIVE
32
165,443
5.4
NATURAL
14
4,112
0.1
TOTAL
681
3,079,917
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
5
1,543
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
32
39,267
SODIUM SILICOFLUORIDE
17
201,461
HYDROFLUOSILICIC ACID
614
2,832,691
48
-------
STATE SUMMARY DATA AS OF 12/31/89
MISSISSIPPI
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
126
49,794
898
368,000
1,001-5,000
108
250,985
404
844,000
5,001-10,000
28
195,553
41
274,000
10,001-50,000
21
463,055
34
681,000
50,001-100,000
1
57,000
1
57,000
>100,000
1
220,027
1
194,000
TOTAL
285
1,236,414
1,379
2,417,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
147
1,091,768
88.3
CONSECUTIVE
69
48.556
3.9
NATURAL
69
96,090
00
•
r-»
TOTAL
285
1,236,414
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
3
2 ,378
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
3
32,497
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
196
746,541
SODIUM SILICOFLUORIDE
11
372,740
HYDROFLUOSILICIC ACID
7
20,665
49
-------
STATE SUMMARY DATA AS OF 12/31/89
MISSOURI
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
108
47,734
707
185,000
1,001-5,000
133
315,076
169
347,000
5,001-10,000
27
191,556
22
151,000
10,001-50,000
25
489,590
16
406.000
50,001-100,000
1
64,000
0
0
>100,000
4
2,020,500
3
1,581,000
TOTAL
298
3,128,456
917
2,669,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
152
2,812,024
89.9
CONSECUTIVE
71
169.597
•
in
NATURAL
75
146,835
4.7
TOTAL
298
3,128,456
SCHOOLS. INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
1
4,080
0
0
INDIAN SCHOOLS
0
0
1
400
MILITARY SYSTEMS
1
22,500
1
4,000
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
125
268,328
SODIUM SILICOFLUORIDE
18
168,618
HYDROFLUOSILICIC ACID
73
2,538,719
50
-------
STATE SUMMARY DATA AS OF 12/31/89
MONTANA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
76
20,022
714
101,000
1,001-5,000
14
27,158
48
101,000
5,001-10,000
4
27,905
13
87,000
10,001-50,000
1
22,000
6
150,000
50,001-100,000
1
72,000
2
142,000
>100,000
0
0
0
0
TOTAL
96
169,085
783
580,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
30
64,894
38.4
CONSECUTIVE
3
566
0.3
NATURAL
63
103,625
61.3
TOTAL
96
169,085
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
19
5,877
3
419
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
1
3, 000
2
7,602
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
28
25,196
SODIUM SILICOFLUORIDE
4
40,100
HYDROFLUOSILICIC ACID
0
0
51
-------
STATE SUMMARY DATA AS OF 12/31/89
NEBRASKA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
50
22,067
563
145,000
1,001-5,000
34
60,958
96
173,000
5,001-10,000
9
66,489
17
107,000
10.001-50.000
3
71,959
9
159,000
50,001-100,000
0
0
0
0
>100,000
2
567,637
2
522,000
TOTAL
98
789,110
687
1,106,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
51
750,591
95.1
CONSECUTIVE
4
6,470
0.8
NATURAL
43
32,049
4.1
TOTAL
98
789,110
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
3
2,930
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
1
8,787
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
2
4,079
SODIUM SILICOFLUORIDE
6
36,706
HYDROFLUOSILICIC ACID
43
704,637
52
-------
STATE SUMMARY DATA AS OF 12/31/89
NEVADA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
21
5,681
267
43,000
1,001-5,000
5
9,510
45
97,000
5,001-10,000
1
8,700
3
26,000
10,001-50,000
0
0
4
70,000
50,001-100,000
0
0
1
50,000
>100,000
0
0
3
824,000
TOTAL
27
23,891
323
1,111,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
11
2,409
10.1
CONSECUTIVE
0
0
o
•
o
NATURAL
16
21,482
89.9
TOTAL
27
23,891
SCHOOLS. INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
10
2,384
3
607
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
1
1,510
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
11
2,409
SODIUM SILICOFLUORIDE
0
0
HYDROFLUOSILICIC ACID
0
0
53
-------
STATE SUMMARY DATA AS OF 12/31/89
NEW HAMPSHIRE
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
66
2,125
696
82,000
1,001-5,000
1
2,025
48
106,000
5,001-10,000
4
36,000
15
119,000
10,001-50,000
4
107,217
13
256,000
50,001-100,000
0
0
1
65,000
>100,000
0
0
1
105,000
TOTAL
75
147,367
774
734,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
9
135,267
91.8
CONSECUTIVE
2
1,300
0.9
NATURAL
64
10,800
7.3
TOTAL
75
147,367
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
1
25
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
6
48,625
SODIUM SILICOFLUORIDE
0
0
HYDROFLUOSILICIC ACID
5
87,942
54
-------
STATE SUMMARY DATA AS OF 12/31/89
NEW JERSEY
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
2
1,650
408
102,000
1,001-5,000
13
32,406
134
339,000
5,001-10,000
6
41,939
62
438,000
10,001-50,000
18
388,524
116
2,368,000
50,001-100,000
1
100,000
11
692,000
>100,000
3
605,528
12
3,796,000
TOTAL
43
lj 170, 047
743
7,736,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
28
1,056,302
90.3
CONSECUTIVE
0
0
0.0
NATURAL
15
113,745
9.7
TOTAL
43
1,170,047
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
3
35^952
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
6
80,697
SODIUM SILICOFLUORIDE
3
317,600
HYDROFLUOSILICIC ACID
18
645,005
55
-------
STATE SUMMARY DATA AS OF 12/31/89
NEW MEXICO
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
107
35,787
563
124,000
1,001-5,000
28
60,458
60
136,000
5,001-10,000
7
57,680
17
130,000
10,001-50,000
13
314,661
18
455,000
50,001-100,000
0
0
2
112,000
>100,000
1
342,000
1
351,000
TOTAL
156
810,586
661
1,306,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
69
562,723
69.4
CONSECUTIVE
1
2 ,250
0.3
NATURAL
86
245,613
30.3
TOTAL
156
810,586
SCHOOLS. INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
46
51,520
30
8,978
INDIAN SCHOOLS
2
1,410
6
1,045
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
65
155,723
SODIUM SILICOFLUORIDE
1
10,000
HYDROFLUOSILICIC ACID
4
399,250
56
-------
STATE SUMMARY DATA AS OF 12/31/89
NEW YORK
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
374
141,461
2,742
575,000
1,001-5,000
159
410,992
434
1,015,000
5,001-10,000
48
356,326
98
723,000
10,001-50,000
58
1,336,931
119
2,760,000
50,001-100,000
8
510,466
13
854,000
>100,000
10
8,918,005
16
10,686,000
TOTAL
658
11,674,181
3 ,422
16,612,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
152
9,800,170
83.9
CONSECUTIVE
502
1,872,795
16.0
NATURAL
3
1,216
o
•
o
i
TOTAL
657
11,672,181
SCHOOLS. INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
3
9,600
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
39
156,160
SODIUM SILICOFLUORIDE
64
7,684,126
HYDROFLUOSILICIC ACID
538
3,644,761
57
-------
STATE SUMMARY DATA AS OF 12/31/89
NORTH CAROLINA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
124
50,633
2,542
457,000
1,001-5,000
61
171,476
279
678,000
5,001-10,000
28
205,496
67
486,000
10,001-50,000
41
913,231
59
1,176,000
50,001-100,000
5
370,000
9
603,000
>100,000
7
1,618,900
6
1,232,000
TOTAL
266
3,329,736
2,962
4,634,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
237
3,248,435
97.6
CONSECUTIVE
0
0
o
•
o
NATURAL
29
81,301
2.4
TOTAL
266
3,329,736
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
103
41,658
2
585
INDIAN SYSTEMS
5
1,761
1
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
10
120,200
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
126
343,607
SODIUM SILICOFLUORIDE
13
1,378,260
HYDROFLUOSILICIC ACID
58
1,156,172
58
-------
STATE SUMMARY DATA AS OF 12/31/89
NORTH DAKOTA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
139
44,582
284
75,000
1,001-5,000
58
104,414
58
103,000
5,001-10,000
6
43,088
7
52,000
10,001-50,000
10
221,709
8
162,000
50,001-100,000
1
61,281
2
121,000
>100,000
0
0
0
0
TOTAL
211
475,074
359
513,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
106
407,111
85.7
CONSECUTIVE
28
41.393
8.7
NATURAL
77
26,570
5.6
TOTAL
211
475,074
SCHOOLS. INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
16
10,189
1
465
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
2
29,518
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
26
35,280
SODIUM SILICOFLUORIDE
15
256,628
HYDROFLUOSILICIC ACID
92
156,131
59
-------
STATE SUMMARY DATA AS OF 12/31/89
OHIO
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
333
116,648
1,040
296,000
1,001-5,000
175
437,857
335
770,000
5,001-10,000
74
544,644
82
603,000
10,001-50,000
95
1,970,872
111
2,213,000
50,001-100,000
16
1,081,210
17
1,141,000
>100,000
12
4,139,844
10
4,293,000
TOTAL
705
8,291,075
1,595
9,314,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
229
7,050,752
o
«
in
CO
CONSECUTIVE
168
997.504
12.0
NATURAL
308
242,819
2.9
TOTAL
705
8,291,075
SCHOOLS. INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
1
1,500
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
28
56,933
SODIUM SILICOFLUORIDE
85
3,148,770
HYDROFLUOSILICIC ACID
277
4,811,100
60
-------
STATE SUMMARY DATA AS OF 12/31/89
OKLAHOMA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
98
38,699
975
266,000
1,001-5,000
82
197,284
282
594,000
5,001-10,000
21
156,009
36
259,000
10,001-50,000
22
582,440
34
847,000
50,001-100,000
1
60,000
2
115,000
>100,000
4
588,800
4
641,000
TOTAL
228
1,617,232
1,333
2,722,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
78
1,362,484
84.2
CONSECUTIVE
95
145.586
9.0
NATURAL
55
109,152
6.7
TOTAL
228
1,617,232
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
2
540
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
5
16,224
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
21
220,232
SODIUM SILICOFLUORIDE
119
1,099,206
HYDROFLUOSILICIC ACID
34
188,642
61
-------
STATE SUMMARY DATA AS OF 12/31/89
OREGON
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
21
9,635
833
159,000
1,001-5,000
17
45,660
128
294,000
5,001-10,000
8
60,825
28
209,000
10,001-50,000
9
184.800
39
805,000
50,001-100,000
1
90,000
1
68,000
>100,000
1
116,000
3
653,000
TOTAL
57
506,920
1, 032
2,188,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
28
446,415
88.1
CONSECUTIVE
9
18.805
3.7
NATURAL
20
41,700
CM
•
00
TOTAL
57
506,920
SCHOOLS. INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
5
3,480
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
9
16,330
SODIUM SILICOFLUORIDE
26
426,090
HYDROFLUOSILICIC ACID
2
22,800
62
-------
STATE SUMMARY DATA AS OF 12/31/89
PENNSYLVANIA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
13
8,161
1,821
429,000
1,001-5,000
36
115,336
362
866,000
5,001-10,000
30
226,777
93
690,000
10,001-50,000
40
926,016
120
2,570.000
50,001-100,000
9
657,999
16
1,096,000
>100,000
7
3,218,767
16
4,504,000
TOTAL
135
5,153,056
2,428
10,154,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
94
4,953,894
96.1
CONSECUTIVE
41
199,162
3.9
NATURAL
0
0
0.0
TOTAL
135
5,153,056
SCHOOLS. INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
23
245,742
SODIUM SILICOFLUORIDE
28
513,269
HYDROFLUOSILICIC ACID
71
3,746,844
63
-------
STATE SUMMARY DATA AS OF 12/31/89
PUERTO RICO
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
2
1,404
301
92,000
1,001-5,000
5
10,368
116
265,000
5,001-10,000
3
24,791
26
179,000
10,001-50,000
22
533,441
48
1,083.000
50,001-100,000
3
202,572
4
302,000
>100,000
4
1,748,736
5
2,113,000
TOTAL
39
2,521,312
500
4,032,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
39
2,521,312
100.0
CONSECUTIVE
0
0
o
•
o
NATURAL
0
0
o
•
o
TOTAL
39
2,521,312
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
39
2,521,312
SODIUM SILICOFLUORIDE
0
0
HYDROFLUOSILICIC ACID
0
0
64
-------
STATE SUMMARY DATA AS OF 12/31/89
RHODE ISLAND
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
1
350
59
10,000
1,001-5,000
2
5,300
9
25,000
5,001-10,000
3
22,900
7
46,000
10,001-50,000
8
200,243
10
259,000
50,001-100,000
3
226,302
3
215,000
>100,000
1
277,891
2
388,000
TOTAL
18
732,986
90
942,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
8
510,357
69.6
CONSECUTIVE
10
222.629
30.4
NATURAL
0
0
0.0
TOTAL
18
732,986
SCHOOLS. INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
0
0
SODIUM SILICOFLUORIDE
15
639,487
HYDROFLUOSILICIC ACID
1
88,199
65
-------
STATE SUMMARY DATA AS OF 12/31/89
SOUTH CAROLINA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
128
45,526
677
127,000
1,001-5,000
85
233,769
143
359,000
5,001-10,000
39
261,222
49
345,000
10,001-50,000
46
1,007,371
47
960,000
50,001-100,000
3
212,912
5
324,000
>100,000
3
664,525
3
664,000
TOTAL
304
2,423,325
924
2,779,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
75
1,703,627
70.3
CONSECUTIVE
102
416,444
17.2
NATURAL
127
303,254
12.5
TOTAL
304
2,423,325
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
1
450
34
11,318
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
6
44,593
1
3,176
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
25
206,839
SODIUM SILICOFLUORIDE
85
918,879
HYDROFLUOSILICIC ACID
59
986,652
66
-------
STATE SUMMARY DATA AS OF 12/31/89
SOUTH DAKOTA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
234
82,245
338
94,000
1,001-5,000
78
171,312
77
167,000
5,001-10,000
8
50,035
8
48,000
10,001-50,000
9
161,353
9
164,000
50,001-100,000
1
81,232
1
81,000
>100,000
0
0
0
0
TOTAL
330
546,177
433
555,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
152
449,900
82.4
CONSECUTIVE
111
58.179
r-
•
o
H
NATURAL
67
38,098
7.0
TOTAL
330
546,177
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
65
23,949
1
84
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
1
5,000
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
68
106,436
SODIUM SILICOFLUORIDE
23
168,551
HYDROFLUOSILICIC ACID
141
210,250
67
-------
STATE SUMMARY DATA AS OF 12/31/89
TENNESSEE
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
19
13,121
182
70,000
1,001-5,000
113
297,386
224
531,000
5,001-10,000
60
435,565
80
562,000
10,001-50,000
60
1,273,228
66
1,408,000
50,001-100,000
4
266,495
4
265,000
>100,000
4
1,271,481
4
1,257,000
TOTAL
260
3,557,276
560
4,094,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
209
3,376,209
94.9
CONSECUTIVE
51
181,067
5.1
NATURAL
0
0
o
•
o
TOTAL
263
3,557,276
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
3
61,119
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
57
188,762
SODIUM SILICOFLUORIDE
157
1,852,268
HYDROFLUOSILICIC ACID
46
1,516,246
68
-------
STATE SUMMARY DATA AS OF 12/31/89
TEXAS
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
195
125,372
3 ,162
783,000
1,001-5,000
392
951,251
1, 081
2,426,000
5,001-10,000
88
614,301
199
1,146,000
10,001-50.000
109
2,115,366
181
3,506,000
50,001-100,000
18
1,301.471
23
1,588,000
>100,000
18
5,905,407
22
7,373.000
TOTAL
820
11,013,168
4,668
16,991,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
149
5,986,357
54.4
CONSECUTIVE
144
2.166.015
19.7
NATURAL
527
2,860,796
26.0
TOTAL
820
11,013,168
SCHOOLS. INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
12
116,927
2
5,500
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
38
362,981
SODIUM SILICOFLUORIDE
52
2,297,730
HYDROFLUOSILICIC ACID
201
5,478,061
69
-------
STATE SUMMARY DATA AS OF 12/31/89
UTAH
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
20
5,413
257
39,000
1,001-5,000
4
10,420
93
121,000
5,001-10,000
1
9,900
22
91,000
10.001-50,000
1
17,000
28
317,000
50,001-100,000
0
0
7
291,000
>100,000
0
0
4
848,000
TOTAL
26
42,733
411
1,707,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
9
35,609
83.3
CONSECUTIVE
2
1,100
2.6
NATURAL
15
6,024
14.1
TOTAL
26
42,733
SCHOOLS. INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
7
5,109
2
175
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
1
9,900
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
4
10,309
SODIUM SILICOFLUORIDE
1
17,000
HYDROFLUOSILICIC ACID
2
4,300
70
-------
STATE SUMMARY DATA AS OF 12/31/89
VERMONT
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
33
7,280
396
75,000
1,001-5,000
18
49,047
55
134,000
5,001-10,000
4
32,300
9
72,000
10,001-50,000
3
84,000
5
141,000
50,001-100,000
1
60,000
0
0
>100,000
0
0
0
0
TOTAL
59
232,627
465
421,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
51
232,627
100.0
CONSECUTIVE
8
0
0.0
NATURAL
0
0
o
•
O
TOTAL
59
232,627
SCHOOLS. INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
23
5,630
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
42
68,427
SODIUM SILICOFLUORIDE
1
50,000
HYDROFLUOSILICIC ACID
16
114,200
71
-------
STATE SUMMARY DATA AS OF 12/31/89
VIRGINIA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
210
54,825
1,327
257,000
1,001-5,000
51
134,820
155
360.000
5,001-10,000
21
148,473
35
247,000
10,001-50.000
33
741,217
51
1,115.000
50,001-100,000
3
246,441
3
232,000
>100,000
12
2,601,897
12
2,737,000
TOTAL
330
3,927,673
1,583
4,950,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
101
3,232,857
82.3
CONSECUTIVE
21
483.035
12.3
NATURAL
208
211.781
5.4
TOTAL
330
3,927,673
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
5
3,020
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
2
11,714
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
37
900,960
SODIUM SILICOFLUORIDE
29
885,770
HYDROFLUOSILICIC ACID
54
1,913,821
72
-------
STATE SUMMARY DATA AS OF 12/31/89
WASHINGTON
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
43
15,693
2,108
320,000
1,001-5,000
35
84,881
192
433,000
5,001-10,000
11
79,851
37
278,000
10,001-50,000
31
604,794
64
1,306,000
50,001-100,000
2
153,750
8
500,000
>100,000
3
846,000
4
1,026,000
TOTAL
125
1,784,969
2,413
3,861,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
66
1,222,747
68.5
CONSECUTIVE
43
501,923
rH
•
CO
CM
NATURAL
16
60,299
3.4
TOTAL
125
1,784,969
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
26
9,525
1
450
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
3
57,709
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
48
368,976
SODIUM SILICOFLUORIDE
18
263,654
HYDROFLUOSILICIC ACID
41
1,079,755
73
-------
STATE SUMMARY DATA AS OF 12/31/89
WEST VIRGINIA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
13
9,717
516
138,000
1,001-5,000
83
231,630
235
542,000
5,001-10,000
25
181,053
32
228,000
10,001-50,000
12
239,255
15
362,000
50,001-100,000
4
228,078
2
123,000
>100,000
2
296,000
2
286,000
TOTAL
139
1,185,733
802
1,679,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
135
1,170,524
98.7
CONSECUTIVE
3
14,550
1.2
NATURAL
1
659
0.1
TOTAL
139
1,187,533
SCHOOLS. INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
97
317,496
SODIUM SILICOFLUORIDE
16
350,232
HYDROFLUOSILICIC ACID
25
517,346
74
-------
STATE SUMMARY DATA AS OF 12/31/89
WISCONSIN
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
229
71,562
1, 045
220,000
1,001-5,000
161
383,738
219
487,000
5,001-10,000
34
258,856
39
295,000
10,001-50,000
42
832,601
41
859,000
50,001-100,000
10
639,731
7
459,000
>100,000
2
793,835
3
1,005,000
TOTAL
478
2,980,323
354
3/326,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
302
2,573,117
86.3
CONSECUTIVE
25
233,162
7.8
NATURAL
151
174,044
5.8
TOTAL
478
2,980,323
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
43
7,261
0
0
INDIAN SYSTEMS
11
8,137
0
0
INDIAN SCHOOLS
0
0
2
6,719
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
53
36,496
SODIUM SILICOFLUORIDE
26
570,744
HYDROFLUOSILICIC ACID
245
2,195,156
7 5
-------
STATE SUMMARY DATA AS OF 12/31/89
WYOMING
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
11
3,796
262
51,000
1,001-5,000
4
11,286
29
65,000
5,001-10,000
1
5,310
11
80,000
10,001-50,000
3
48,091
6
143,000
50,001-100,000
1
58,429
1
51,000
>100,000
0
0
0
0
TOTAL
20
126,912
309
390,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
7
105,065
82.8
CONSECUTIVE
1
359
0.3
NATURAL
12
21,488
16.9
TOTAL
20
126,912
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
1
1,668
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
1
1,668
SODIUM SILICOFLUORIDE
6
92,209
HYDROFLUOSILICIC ACID
1
11,547
76
-------
FLUORIDATION
STATISTICS
TERRITORY SUMMARIES
-------
STATE SUMMARY DATA AS OF 12/31/89
AMERICAN SAMOA
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
0
0
50
15,000
1,001-5,000
0
0
4
8,000
5,001-10,000
0
0
0
0
10,001-50,000
0
0
1
18,000
50,001-100,000
0
0
0
0
>100,000
0
0
0
0
TOTAL
0
0
55
40,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
0
0
0
CONSECUTIVE
0
0
0
NATURAL
0
0
0
TOTAL
0
0
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
0
0
SODIUM SILICOFLUORIDE
0
0
HYDROFLUOSILICIC ACID
0
0
78
-------
STATE SUMMARY DATA AS OF 12/31/89
NORTHERN MARIANAS
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
0
0
2
2,000
1,001-5,000
0
0
2
3,000
5,001-10,000
0
0
0
0
10.001-50,000
0
0
0
0
50,001-100,000
0
0
0
0
>100,000
0
0
0
0
TOTAL
0
0
4
4,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
0
0
0
CONSECUTIVE
0
0
0
NATURAL
0
0
0
TOTAL
0
0
SCHOOLS. INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
0
0
SODIUM SILICOFLUORIDE
0
0
HYDROFLUOSILICIC ACID
0
0
79
-------
STATE SUMMARY DATA AS OF 12/31/89
GUAM
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
2
1,000
2
1, 000
1,001-5,000
3
7,000
3
7,000
5,001-10,000
2
14,000
2
14,000
10.001-50,000
2
25,000
2
25,000
50,001-100,000
1
62,000
1
62,000
>100,000
0
0
0
0
TOTAL
10
109,000
10
109,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
10
109,000
100. 0
CONSECUTIVE
0
0
o
•
o
NATURAL
0
0
o
•
o
TOTAL
10
109,000
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
2
41,000
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
8
68,000
SODIUM SILICOFLUORIDE
1
25,000
HYDROFLUOSILICIC ACID
1
15,000
80
-------
STATE SUMMARY DATA AS OF 12/31/89
REPUBLIC OF PALAU
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
0
0
31
7,000
1.001-5,000
0
0
0
0
5,001-10,000
0
0
0
0
10.001-50.000
0
0
0
0
50,001-100,000
0
0
0
0
>100,000
0
0
0
0
TOTAL
0
0
31
6,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
0
0
0
CONSECUTIVE
0
0
0
NATURAL
0
0
0
TOTAL
0
0
SCHOOLS. INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
0
0
SODIUM SILICOFLUORIDE
0
0
HYDROFLUOSILICIC ACID
0
0
81
-------
STATE SUMMARY DATA AS OF 12/31/89
TRUST TERRITORIES
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
0
0
165
36,000
1,001-5,000
0
0
8
19,000
5,001-10,000
0
0
4
35,000
10,001-50,000
0
0
0
0
50,001-100,000
0
0
0
0
>100,000
0
0
0
0
TOTAL
0
0
177
89,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
0
0
0
CONSECUTIVE
0
0
0
NATURAL
0
0
0
TOTAL
0
0
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
0
0
SODIUM SILICOFLUORIDE
0
0
HYDROFLUOSILICIC ACID
0
0
82
-------
STATE SUMMARY DATA AS OF 12/31/89
VIRGIN ISLANDS
SYSTEM SIZE CLASSIFICATION
FLUORIDATED SYSTEMS
PUBLIC WATER SYSTEMS
NUMBER OF
SYSTEMS
TOTAL
POPULATION
NUMBER OF
SYSTEMS
TOTAL
POPULATION
=<1,000
0
0
140
20,000
1,001-5,000
0
0
1
1,000
5,001-10,000
0
0
2
19,000
10,001-50.000
0
0
0
0
50,001-100,000
0
0
0
0
>100,000
0
0
0
0
TOTAL
0
0
143
41,000
FLUORIDATED SYSTEM CLASSIFICATION
NUMBER
POPULATION
PERCENTAGE (POP.)
ADJUSTED
0
0
0
CONSECUTIVE
0
0
0
NATURAL
0
0
0
TOTAL
0
0
SCHOOLS, INDIAN AND MILITARY SYSTEMS
ADJUSTED
NATURAL
NUMBER
POP.
NUMBER
POP.
TOTAL SCHOOLS
0
0
0
0
INDIAN SYSTEMS
0
0
0
0
INDIAN SCHOOLS
0
0
0
0
MILITARY SYSTEMS
0
0
0
0
CHEMICAL USAGE OF FLUORIDATING SYSTEMS
NUMBER
POPULATION
SODIUM FLUORIDE
0
0
SODIUM SILICOFLUORIDE
0
0
HYDROFLUOSILICIC ACID
0
0
R 1
-------
Shalanda D. Young, Director, Office of Management and Budget
Brenda Mallory, Chair of the Council on Environmental Quality
Gina McCarthy, National Climate Advisor
CC:
Richard Moore, Chair, White House Environmental Justice Advisory Council
Peggy Shepherd, Chair, White House Environmental Justice Advisory Council
White House Environmental Justice Advisory Council Members
April 6, 2022
Dear Director Shalanda Young, Chair Brenda Mallory, and Advisor Gina McCarthy,
Thank you for your commitment to carrying forward President Joe Biden's Justice40 Initiative. The
United Frontline Table submits the following comments in support of strengthened and robust
implementation of this Initiative as outlined in Executive Order 14008 and the Interim Guidance
issued by the Office of Management and Budget on July 20, 2021.
The United Frontline Table1 is a national network of Black, Indigenous, Asian, Pacific Islander, Latinx,
and working class-led organizations representing hundreds of grassroots groups and communities
across the US. Our membership collectively represent hundreds of thousands of people in frontline
communities across the country, who face the brunt of historic racism, poverty, pollution, climate
change and other inequities, and who work together towards a regenerative future that repairs historic
harms and inequality and invests in the resilience of the most impacted communities.
We look forward to a robust Justice40 program, and offer the following comments to strengthen the
initiative and achieve the full breadth of its envisioned impact:
Meaningful Access and Impact
1. Ensure that the program application process does not inhibit access. For example,
consider creating application processes where eligible entities including community based
organizations, small businesses, and local governments, where applicable, can apply for
multiple grants from across federal departments through one application. Such a process can
facilitate communities with limited capacity and the greatest need to participate fairly and
meaningfully.
1 Visit www.unitedfron.tlinetable.org for more information about the United Frontline Table.
1
-------
2. Devote a portion of federal Justice40 resources to technical assistance from agencies on
proposal development, application process, implementation and long-term governance,
especially for those communities with greatest environmental justice burdens, to facilitate
maximum access to programs by eligible entities, and lasting impact from Justice40
investments.
3. Ensure a maximum proportion of project dollar amounts are contracted with local
Black, Indigenous, and People of Color and worker-owned businesses, or if they lack
capacity to take on Justice40-funded projects at scale, require that winning contractors
subcontract with otherwise-eligible Black, Indigenous, and People of Color and worker-owner
contractors, and allow them to shadow the lead contractor onsite to develop experience and
skill.
4. Require all implementing agencies to undertake robust stakeholder and community
engagement at every stage of project development and implementation, including via
direct outreach to frontline and environmental justice communities, hearings or listening
sessions in targeted geographies, field liaisons, and attention to language justice and access.
5. Develop a transparent auditing framework to track progress toward and beyond the
40% of funding to be invested in disadvantaged frontline communities.
Do No Harm
6. Ensure that all federal climate investments have clear requirements to explicitly
prohibit increases of harmful burdens on disadvantaged communities. Require agencies
to conduct and publicly report impact assessments that project potential harms of investments,
programs, rules, and other program activities before issuance of any project or program funds.
7. No federal funding should be allocated to any projects, programs, or investments that
will harm any frontline constituency. For Justice40 to keep its promises, funding decisions
must be required to respect and balance the interests of all frontline constituencies, rather than
forcing them into competition. This requires diverse stakeholder engagement and ensuring
investments do no harm in any community.
A Comprehensive Approach
8. Develop funding criteria that require investments to support development and
investment in collective community ownership of essential assets, such as affordable
housing, microgrids, worker-owned businesses, community land trusts, and community
development finance institutions, in order to build the resilience of frontline communities over
the long term.
2
-------
9. Create separate programs and funding mechanisms responsive to the specific needs of
the Gulf South, Native American Tribes and communities, and US territories including Puerto
Rico, the Northern Mariana Islands, American Samoa, and Guam. Undertake comprehensive
outreach across communities in these areas, with attention to appropriate language access, to
ensure awareness and equitable deployment of Justice40 funds and programs.
10. OMB should exercise oversight of agencies in the designation of Justice40 covered
programs beyond those named in the pilot program, first with a focus on formally
designating as part of Justice40 specific relevant programs of the Infrastructure Investment and
Jobs Act and any relevant provisions from the Build Back Better Act that pass into law, and
broadly seeking to expand the scope of Justice40 into additional specific areas including in
public health, education, immigration, housing, open space, lands conservation, ecosystems
protection and restoration, and other areas with clear climate impacts. All implicated agencies
should be responsible for developing plans detailing how each of their covered programs will
be tailored to achieve Justice40 investment goals, including targeted investment for the most
vulnerable communities and engagement with stakeholders to determine programmatic
priorities.
11. Agencies should issue rules or policies to accompany formula funding in all Justice40
policy areas instructing a broad range of recipients, including states, counties and tribal
governments, about their obligations to adhere to Justice40 in the allocation of formula funds,
such as the use of mapping tools like the Climate and Economic Justice Screening Tool
(CEJST), to ensure that funding is targeted to reach the most vulnerable communities.
12. Require competitive grant programs that fall within Justice40 utilize the Climate and
Economic Justice Screening Tool in rating proposals. Proposals benefiting the most
vulnerable communities should receive higher consideration, all other things being equal as to
proposal requirements. The CEJST should also be incorporated as a decisional factor in
oversight of formula funding, as well as in impact assessments of rulemakings, permitting and
other Justice40 actions bearing on frontline communities.
Lasting Legacy
13. Ensure to the greatest extent possible that Justice40 efforts are embedded in long-term
guidance, rules and policy of implementing agencies so progress to achieve Justice40
targets continues regardless of political changes in the administration:
a. The Administration should work with Members of Congress to advance legislation
that codifies the Justice40 Initiative into law.
3
-------
b. Ensure agencies, GAO, CEQ, and OMB have adequate levels of funding and staffing
for long-term implementation and oversight of Justice40.
c. Give guidance for agencies to develop clear multi-year targets and timetables to meet
Justice40 targets.
d. To the greatest extent possible, ensure uniform uptake of the Justice40 initiative across
agencies, leveraging the advisory role of the WHEJAC and the inter-agency efforts of
the WHEJIC.
We strongly recommend that any further Justice40 guidance from the Biden administration to
implementing entities include direction that conforms to the above recommendations. We look
forward to continuing to work with your offices and directly with departments and agencies to ensure
robust and equitable implementation that fulfills the transformative potential of Justice40.
Sincerely,
Member Organizations of the United Frontline Table:
Asian Pacific Environmental Network
Center for Economic Democracy
Climate Justice Alliance
Grassroots Global Justice Alliance
Gulf Coast Center for Law and Policy
Indigenous Environmental Network
Kentuckians for the Commonwealth
Labor Network for Sustainability
New Economy Coalition
People's Action
Right to the City
Trade Unions for Energy Democracy
UPROSE
4
-------
Hi
I
Statement to the White House Environmental Justice Advisory Council
Jamie Banks, President, Quiet Communities Inc
March 30, 2022
EJScreen 2.0 is intended to protect public health and the environment, yet does not include noise as an
indicator, putting EJ communities at risk for noise-related health and environmental harms.
Noise was first recognized as a public health hazard in 1968. The need to address it is described in the
Clean Air Act of 1970. The Noise Control Act of 1972 states "it is the policy of the United States to
promote an environment for all Americans free from noise that jeopardizes their health or welfare."
Noise causes hearing loss and tinnitus, contributes to various health problems, and impairs children's
learning and work productivity. It comes from transportation, industry, construction, mining, blasting,
and so forth. There is a nexus between noise and fossil fuels. Chronic noise, even at low levels, can cause
annoyance, sleep issues, and stress that contribute to cardiovascular and cerebrovascular disease,
metabolic disturbances, worsening of psychological disorders, and early death. It threatens the health of
more than 100 million Americans, with children among the most vulnerable and environmental justice
communities affected disproportionately.
Measures can be taken. For example, installing sound insulation and relocating noise sources have been
shown to reduce noise and reverses its adverse impacts on learning and cardiovascular health. Quieter
equipment are available.
In its recent policy statement, called Noise as a Public Health Hazard, the American Public Health
Association calls on the federal government to:
1. Ensure that reduction of noise exposures is part of all environmental and health efforts;
2. Acknowledge the disparate impacts of noise on communities of color and low-income communities;
and,
3. Implement programs and policies across all federal agencies, including the Environmental Protection
Agency, Departments of Labor, Transportation, Defense, Health and Human Services, Education, and
Housing and Urban Development, and the Federal Aviation Administration, National Institute of
Standards and Technology, and the Consumer Product Safety Commission.
The Bipartisan Infrastructure Law will allocate funds to build safer and more sustainable airports,
highways, and transportation infrastructure. Including noise as an indicator in EJScreen 2.0 will help
reduce the impacts of noise and related air pollution from these projects on the health and well-being of
EJ communities. Failure to include it exposes those communities to potential harms to health, learning,
and well-being.
Thank you for your work and your time.
Jamie Banks
iamiegquietcommunities.org
Quietcommunities.org
3/30/22
-------
Contact info : Karen L. Martin at wheiac@epa.gov or by phone 202-564-0203
Objective: Provide comments relevant to the performance scorecard that is being developed by
the White House Environmental Justice Advisory Council to assess the progress of federal
agencies in addressing current and historic environmental injustice.
On behalf of The Chisholm Legacy Project, we offer the following recommendations to the
White House Environmental Justice Advisory Council and the Council on Environmental
Quality regarding development of the Justice40 Scorecard:
We agree with White House Environmental Justice Advisory Council's (WHEJAC)
concerns around use of the term "disadvantaged community." Terms that might be more
appropriate to consider include overburdened, underinvested in, or historically
disenfranchised/marginalized. We advocate for language that assigns a level of culpability to
government actors for historical and ongoing neglect and outright abuse. We also advocate for
framings that acknowledge that while these communities may be overburdened and historically
marginalized, they do not lack agency. Interventions must first and foremost recognize a
community's right to self-determinism. For the sake of this written comment, we will be using
the phrases "frontline and fenceline communities" and "EJ communities." In addition, we will
be referencing the WHEJAC Recommendations and EO 12898 Revisions Report, dated May 21,
2021, hereafter called the May 2021 Report.
In the development of a Justice40 scorecard, input throughout the entire process must
be driven primarily by stakeholder representatives, such as BIPOC communities, Black femmes
from frontline and fenceline communities, those living in public housing, communities that
were excluded from the REAP Program, etc. In the process of data collection in EJ communities,
research entities should engage in just models of collaborative relationship and mutually
beneficial partnership led by affected communities. The Chisholm Legacy Project will be
publishing a guiding document for this relationship in the coming months. Additionally, when
seeking collaborations, partnerships, and mentorship opportunities, nontraditional indicators of
success and leadership must be considered to meaningfully incorporate the lived experiences of
BIPOC/Black femme voices in frontline and fenceline communities.
Frontline and fenceline communities are often distrustful of government engagement.
In order to rebuild trust, government actors must authentically transfer power to communities
rather than simply consulting after decisions have been made. To this end, we find the
following graphic from Facilitating Power useful. True, meaningful, and transformative change
happens when communities own the changes to their own circumstances. It is imperative that
the Justice40 Scorecard create requirements for agencies to defer to community decision-
making.
1
-------
THE SPECTRUM OF COMMUNITY ENGAGEMENT TO OWNERSHIP
$ % Facilitating
Pow«r
STANCE
TOWARDS
COMMUNITY
I COLLABORATE I DEFER TO
> 5>
Marginalization
community Deny access to
engagement decision-making
goals processes
message to Your voice, needs
community & interests do not
matter
Closed door
meeting
Misinformation
Systematic
resource 100%
allocation Systems Admin
Provide the
community with
relevant information
IVe will keep you
informed
Fact sheets
Open Houses
Presentations
Billboards
Videos
70-90%
Systems Admin
10-30%
Promotions and
Publicity
Tokenization
Gather input from
the community
We core what you
think
Public Comment
Focus Groups
Community Forums
Surveys
60-80%
Systems Admin
20-40%
Consultation
Activities
Ensure community
needs and assets
are integrated into
process & inform
planning
You are making
us think, (and
therefore act)
differently about
the issue
Community
organizing &
advocacy
House meetings
Interactive
workshops
Polling
Community forums
50-60%
Systems Admin
40-50%
Community
Involvement
Delegated
Power
Ensure community
capacity to play a
leadership role in
implementation of
decisions
Your leadership
and expertise are
critical to how we
address the issue
MOU'S with
Community-based
organizations
Community
organizing
Citizen advisory
committees
Open Planning
Forums with Citizen
Polling
20-50%
Systems Admin
50-70%
Community
Community
Ownership
Foster democratic
participation and equity
through community-
driven decision-
making; Bridge divide
between community &
governance
It's time to unlock
collective power
and capacity for
transformative
solutions
Community-driven
planning
Consensus building
Participatory action
research
Participatory budgeting
Cooperatives
80-100%
Community partners
and community-driven
processes ideally
generate new value and
resources that can be
invested in solutions
WHEJAC must more clearly expound on its commitment to "do no harm." Immediate
direct effects of any action or lack of action are not the only effects that should be considered.
Medium- and long-term outcomes, especially in continued or emerging disparities, should be
monitored. In addition, consideration should be given to "loss and damage" in frontline and
fenceline communities in the form of reparations (e.g., payments to BIPOC who developed
health conditions as a result of living in HUD financed homes that were built on toxic sites).
Pollution and toxins in the air, water, and soil are among the most immediate threats to these
communities and must be addressed in a holistic, intersectional manner to alleviate the
disproportionate burden that is experienced. For instance, coal ash is a major threat to public
health. The recommendation and metric guidelines outlined in the May 2021 Report for clean
up in the Tennessee Valley Authority region should include the monitoring and evaluation of
key performance indicators with mechanisms of measurement developed through community-
led, democratic decision-making processes. These guidelines and metrics should also be applied
to a|l toxic coal ash regions, including those outside of TVA territory, and should include
equitable compensation for victims.
Additionally, because Black and other communities of color are disproportionately
exposed to PM2.5 and other air pollutants in vehicle exhaust, we recommend direct funding
towards the installation of green barriers between EJ communities and transportation
2
-------
corridors, with air monitors that can measure improvement in air quality installed in all
metropolitan and suburban areas. These communities should be the first considered for
accelerated transition to electric public transportation, with the requirement that the electricity
is not derived from dirty energy sources.
In addition to WHEJAC's goal of replacing lead water pipes, we should be ensuring that
everyone in the United States has reliable access to safe and clean drinking water. Citizen
science opportunities can help ensure progress. While expanding criteria to the Drinking Water
State Revolving Fund (DWSRF), WHEJAC should also incentivize states to include
unincorporated townships, specifically freedmen's settlements such as Sandbranch, Texas. The
Sandbranch community and many other freedmen's settlements like it, currently have no
running water or wastewater infrastructure.
There is an immense amount of energy democracy work already occurring at the
community level. We recommend WHEJAC catalog action taken to localize energy and uplift
energy democracy and justice in marginalized communities through mechanisms such as
microgrids, solar coops, etc. WHEJAC should also measure the degree of interdisciplinary,
intersectional solutions by monitoring engagement of diverse community members to ensure
climate action does not lead to further subsequent inequities. Additionally, the Department of
Energy needs to take a more active stance in making clean energy resources accessible to
communities by partnering with community members in the expansion of renewable energy.
Application processes for grant programs require time and technical expertise to participate.
The burden should not be on the most affected and least resourced communities.
Divestment and investment must be utilized to equitably transition to a living economy
away from dirty energy. Therefore, WHEJAC must more clearly define the threshold of
divestment from fossil fuels, plastics, dangerous chemicals, and nuclear energy by 2030 that is
addressed in the May 2021 report. Updated language from most recent IPCC report about
divesting from so-called "clean" solutions that are neither clean nor in the best interest of
frontline communities must be adopted by WHEJAC. Furthermore, there must be more clearly
outlined mechanisms and oversight in place to make sure banks are investing 40+% in frontline
and fenceline communities. These may require a separate team to track and analyze the
monitoring and enforcements. This should include requirements and metrics for community
ownership, asset ownership, and overall lending and investing practices being non-extractive.
Additionally, with regards to green bank financing, we recommend including "no interest" loans
to increase community participation and mitigate the risk of default.
Finally, we have significant concerns regarding gaps in data acquisition and coverage in
the Climate Economic Justice Screening tool. These gaps will lead to too many communities
falling through the cracks, which points to an incomplete commitment to Justice40, and
therefore they must be addressed while the screening tool is still in beta. These concerns are
(but are not limited to) the following:
3
-------
Clean energy and energy efficiency:
Affordable and sustainable housing:
-Urban Heat Island is not accounted for
-Ignores community planning
-Ignores Radon
Clean transit:
-Ozone (03) not accounted for
-Focus seems to be on pass through vehicles not community access to multimodal transit
-Percentage of roads improved with bicycle lanes
-Percentage of roads improved with sidewalks
-Number of bus routes
-Number of bus shelters
Reduction and remediation of legacy pollution:
-Leaking underground storage tanks are more than likely going to be missed
-RMP facilities cover a lot but facilities can also have TRI and NPDES but not be RMP facilities
Health Burdens:
-Access to medical facilities
-Food deserts
Additionally, datasets used for the scorecard and the mapping are not well designed to address
wealth gaps. Income and household value are both accounted for, but with so many people -
especially in EJ communities - renting or living in public housing or living with little to no
income, not including non-housing assets as another economic indicator can misrepresent the
economic situation of many communities (including high net wealth communities as well).
We look forward to continuing to engage with WHEJAC and CEQ and hope that our
recommendations on behalf of the equity of frontline and fenceline communities will be
integrated into the development of the Justice40 Scorecard. Thank you.
4
-------
NEW YORK
CITY BAR
March 28, 2022
The Honorable Brenda Mallory
Chair
Council on Environmental Quality
Executive Office of the President
Washington, DC 20500
Re: Support for a United Nations General Assembly Resolution Recognizing the Right to
a Healthy Environment
Dear Chair Mallory:
On behalf of the New York City Bar Association (the "City Bar"), we write to request that
the Biden Administration support a United Nations General Assembly resolution recognizing the
right to a healthy environment. The City Bar, founded in 1870, is an independent, non-
governmental organization with approximately 24,000 members including lawyers, judges, law
professors, law students and government officials from the United States and over 50 countries.
We have a long history of dedication to promoting the rule of law, reform of the law and access to
justice in support of a fair society.
In September 2020, the City Bar issued a report supporting the formal recognition by the
United Nations of the human right to a healthy environment.1 As set forth in the report, the
recognition of this right is imperative in an era where the harrowing effects of human activities on
the natural world are increasingly palpable as a result of climate change, loss of biological
diversity, air, water, and land pollution. As the report acknowledges, the current coronavirus
pandemic is greatly exacerbated by environmental conditions. Vulnerable groups, who frequently
bear the brunt of environmental injustices and suffer their consequences, are affected most by the
pandemic. Further, the right to a healthy environment has been developing at international,
regional and national levels, as treaty bodies, regional tribunals, special rapporteurs, and other
international human rights bodies have elaborated on the fundamental importance of a healthy
1 "Support for the Formal Recognition by the United Nations of the Human Right to a Healthy Environment" Sept.
14, 2020, https://www.nYcbar.org/member-and-career-services/committees/reports-listing/reports/detail/liuman-
right-to-a-healthv-environment-un-formal-recognition.
About the Association
The mission of the New York City Bar Association, which was founded in 1870 and has approximately 24,000
members, is to equip and mobilize a diverse legal profession to practice with excellence, promote reform of the law,
and uphold the rule of law and access to justice in support of a fair society and the public interest in our community,
our nation, and throughout the world.
The Association of the Bar of the City of New York
42 West 44th Street, New York, NY 10036
212.382.6600 | www.nycbar.org
-------
environment for the full enjoyment of other human rights, such as the rights to life, health, food,
water, and sanitation.
On October 8th, 2021, the United Nations Human Rights Council adopted Resolution
48/13, which recognizes the right to a healthy environment as a human right.2 Additionally, in
November 2021, in New York State, a statewide voter referendum passed an amendment to the
New York State Constitution guaranteeing that "each person shall have the right to clean air and
water, and a healthful environment.As the City Bar report states, the time has come for the
United Nations to acknowledge and amplify existing global efforts, and to explicitly advance the
right to a healthy environment. A United Nations General Assembly resolution would advance this
important notion that each and every human being has the right to live in an environment that
supports a dignified and fulfilling life.
For all these reasons, we urge the United States to vote in favor of a resolution recognizing
the right to a healthy environment when it is considered at the United Nations General Assembly.
We appreciate your consideration of this request.
Sincerely,
Bret Parker, Executive Director Susan Kath, Director
New York City Bar Association Environment Program, Cyrus R. Vance Center
for International Justice
Scott Caplan, Co-Chair Michael A. Fernandez, Chair
Doris Toyou, Co-Chair Inter-American Affairs Committee
African Affairs Committee
Viren Michael Mascarenhas, Co-Chair
Irit Tamir, Co-Chair
Business & Human Rights Working Group
Kenneth Rivlin, Chair
International Environmental Law Committee
Margaret Barry, Co-Chair
Bethany Davis Noll, Co-Chair
Environmental Law Committee
Ramya Jawahar Kudekallu, Chair
International Human Rights Committee
Clayton T. Cheney, Co-Chair
Catherine E. Van Kampen, Co-Chair
United Nations Committee
2 See https://documents-dds-nY.un.org/doc/UNDOC/GEN/G21/289/50/PDF/G2128950.pdf7QpenElement.
3 NYS Const. Art. 1, Sect. 19, https://dos.nv.gov/svstem/files/documents/2022/01/Constitution-Januarv-l-2022.pdf.
2
-------
Cc:
Hon. Antony Blinken, Secretary of State
Hon. Debra Anne Haaland, Secretary, Department of Interior
Hon. Thomas J. Vilsack, Secretary, Department of Agriculture
Hon. Michael S. Regan, Administrator, Environmental Protection Agency
Hon. Richard W. Spinrad, Administrator, National Oceanic and Atmospheric Administration
Hon. Richard Moore, Co-Chair, White House Environmental Justice Advisory Council
Hon. Peggy Shepard, Co-Chair, White House Environmental Justice Advisory Council
Contact
Elizabeth Kocienda, Director of Advocacy | 212.382.4788 | ekocienda@nycbar.org
Mary Margulis-Ohnuma, Policy Counsel | 212.382.6767 | mmargulis-ohnuma@nycbar.org
3
-------
March 31, 2022
WHEJAC Councilors,
In follow-up to my oral comment yesterday, already submitted in writing with close to 100 scientific
references attached, I wanted to take a moment to reflect on what was said by councilors and
others that are relevant to two issues, only one of which I mentioned before this, fluoridation, and
one of which I would like to bring up today, wireless technology.
1. Dr. Kimberly Leary eloquently spoke to the need to critically re-examine "policies, programs
and services" that we have assumed to be right, but in fact may include baked in systemic
inequities. This is absolutely applies to fluoridation. Not only do the marketing mantras
continue to be used in order to suppress 21st century scientific evidence, all but forgotten are
the truly appalling decision that persisted until not that long ago to fluoridate water supplies in
Indigenous school systems with six times the "safe & effective" amount recommended based
on the rationale that water in reservation homes was not fluoridated. This action undoubtedly
caused kidney disease and diabetes in countless children. These life-long afflictions leave a
multi-generational scar on indigenous families, as will the damage from wireless technology.
2. Tom Cormons' admonition that Justice40 will only be as good as its implementation for
achieving transformative justice, and focusing on the "right incentive structures" to deploy
funds also resonated. If we believe marketing slogans, we can believe we are doing right when
in fact we are doing wrong. This will always be a challenge. Again, I refer you to my earlier
submission with its scientific citations relevant to fluoridation policy. I'll include a few more
references with this article relative to wireless technology.
3. Maria Lopez-Nunez hit the nail on the head when she worried about the perversion of funding
and advocated for a more humble government. There are many people who knowingly do the
wrong thing because it serves their agenda, but there are many more who are ignorant of what
they do. Disciplined study, a curious and open mind, professional integrity and personal
courage are required for good decision-making, as well as humility.
4. Radhika Fox's comments worried me a great deal. Making millions and billions of dollars
available to states for "infrastructure" or any other reason, even with memos regarding
obligation and expectations, is rife for misuse. In 2016, Erin Brockovich said, "Regulatory gaps
are lobbyist created Grand Canyons designed to cheat the system." We need to be very careful
and thoughtful about how we manage money.
Finally, the comment that will always resonate with me, as I expect it will with you, came from the
public. A woman gave voice to the exhaustion she feels from constantly fighting the power brokers
in service of her community where her friends, family and neighbors are relentlessly being
poisoned, suffering and dying.
We are all entitled to clean and safe food and medicine, yet government allows those necessary
products to be contaminated, and I suspect WHEJAC is as powerless to affect change there as
any single exhausted environmental health activist.
We are all entitled to clean and safe water and air, and although government has allowed them to
be polluted, too, WHEJAC has power here.
As I said yesterday, using its tool to track fluoride concentrations in water, preventing monies from
being used in service of any artificial fluoridation scheme, and working towards ending fluoridation
are concrete actions WHEJAC can take independently and in concert with IAC to achieve
environmental justice.
1 of 4
-------
Additionally, I suggest WHEJAC take a stand against the spread of wireless technology, especially
Smart Meters and 5G because the inescapable 24/7 bombardment with electro magnetic
frequencies (EMF) and radiofrequency radiation (RF) cause endocrine disruption, anxiety and
depression, cardiac irregularities, blood disease, cardiac disease, and cancers.
Consider: A group of EMF scientists have petitioned the United Nations several times to address
this as an air pollution problem that poses a planetary threat to life. Telecom workers protested 5G
rollouts in the streets in France in concert with mayoral protests. The National Toxicology Program
validated cardiac tumors associated with wireless exposure. Smart Meter rollouts are being
protested across the country. In August 2021, a federal court ruled that, the FCC has miserably
failed in its mission:
"...the FCC completely failed to acknowledge, let alone respond to, comments concerning the
impact of RF radiation on the environment...The record contains substantive evidence of
potential environmental harms." - The U.S. Court of Appeals for the D.C. Circuit
"The court's decision exposes the FCC and FDA as captive agencies that have abandoned
their duty to protect public health in favor of a single-minded crusade to increase telecom
industry profits." - Plaintiff Attorney
Communities all over the country, like in Pittsfield MA, are fighting the telecoms to remove wireless
stations that are causing illness in their communities - an uphill battle as telecom lobbyists
managed to get Congress to pass an act in 1996 declaring wireless technology safe and outlawing
the use of either human health concerns or environmental damage as valid objections to
expansion of these profitable technologies. This arrogant display of systemic injustice, like
fluoridation policy, puts us all at risk. It puts me in mind of this trope: Environmental equity is
poisoning everyone equally. Environmental justice is don't poison anyone.
I suggest that WHEJAC allocates some time for studying the harms of wireless technologies
and takes action to prevent EJ communities from becoming targets for the Telecom expansion
of their latest technologies.
Best of luck in achieving your goal of environmental justice.
Sfcettcen
WIRELESS TECHNOLOGY REFERENCES:
EMF Scientists Appeal: https://www.emfscientist.org/
Smith-Roe SL, et al. Evaluation of the genotoxicitv of cell phone radiofrequency radiation in male and
female rats and mice following subchronic exposure. Environ Mol Mutagen. 2020 Feb;61(2):276-290
Ronald L. Melnick. Commentary on the utility of the National Toxicology Program study on cell phone
radiofrequency radiation data for assessing human health risks despite unfounded criticisms aimed at
minimizing the findings of adverse health effects. Environmental Research
Volume 168, January 2019, Pages 1-6.
'Historic Win': CHD Wins Case Against FCC on Safety Guidelines for 5G and Wireless. Children's Health
Defense Team. Aug. 14, 2021.
Employees at France's Biggest Phone Company Undermine Country's 5G Push. Dafna Tachover. 9/22/20.
Peter Hensinger, Isabel Wilke. (2016) Wireless communication technologies: New study findings confirm risks
of nonionizing radiation. New Technologies - New Risks.
Pittsfield. MA Board of Health Unanimously Votes to Issue Cease and Desist for Verizon Cell Tower.
Environmental Health Trust. Feb. 3, 2022
2 Of 4
-------
Cardiac Disorders
Environmental Impact
Health References
Environmental References
Electrosmog can disrupt
heart rhythms due to the
nature of the different
signatures and the sum
of the broadcasts
causing anxiety, anger,
depression and disease.
Despite presumptuous
language in the 1996
Telecom Act declaring
there is no environmental
risk from EMR, we have
scientific proof that
plants and animals suffer.
If J«
Technician repairs cell phone tower. Photo: Loren
Holmes/Alaska Dispatch News/Zuma Press
DNA Damage
Even low levels of microwave frequencies used in
telecommunication networks have been confirmed
in multiple studies across the world to cause cell
death and cell degeneration. Cell damage can be
mitigated by avoidance of WiFi networks. However,
the damage depresses our immune system, triggers
biochemical reactions, and impacts sperm and
fetuses leading to life threatening and multi-
generational health effects.
Less visible than 20th century smokestacks and
pollution, 21st century electrosmog is an even more
deadly threat to people and planet.
Wireless communication
technologies: New study findings confirm
risks of nonionizing radiation. Peter
Hensinger, Isabel W i I k e . New
Technologies - New Risks. May 29, 2016;
translated by Katharina Gustavs, May
2017.
Biological effects from exposure to
electromagnetic radiation emitted by cell
tower base stations and other antenna
arrays. Blake Levitt and Henry Lai,
Environ. Rev. 2010. Vol 18: 369-395.
How does long term exposure to base
stations and mobile phones affect human
hormone profiles? Eskander EF, et al.
Clinical Biochemistry, Volume 45, Issues
1-2, January 2012, Pages 157-161.
Radiation from wireless technology
affects the blood, the heart, and the
autonomic nervous system. Havas, M.
Reviews on Environmental Health. 2013,
28(2-3), pp. 75-84.
A Review on Electromagnetic Fields
(EMFs) and the Reproductive System.
Asghari, Ali et al. Electronic Physician.
2016 Jul; 8(7): 2655-2662..
"It makes little sense to keep denying
health symptoms that are being reported
in good faith... Effects reported include:
genetic, growth, and reproductive;
increases in permeability of the
blood-brain barrier; behavioral;
molecular, cellular, and metabolic; and
increases in cancer risk."
- Blake Levitt and Henry Lai (2010)
Radiofrequency radiation injures trees
around mobile phone base stations.
Waldmann-Selsam C, Balmori-de la
Puente A, Breunig H, Balmori A. Sci Total
Environ. 2016 Dec 1 ;572:554-569.
Anthropogenic radiofrequency
electromagnetic fields as an emerging
threat to wildlife orientation. Balmori A.
Sci Total Environ. 2015 Jun 15;518-519,
Magnetoreceptiori. Gould JL.Current
Biology. 2010, Vol 20, Issue 10.
The effect of the nori ionizing radiation on
cultivated plants of Arabidopsis thaliana
(Col.). Aikaterina L.Stefi, et al. Flora -
Morphology, Distribution, Functional
Ecology of Plants. Volume 223, August
2016, Pages 114-120.
Websites
Biolnitiative.org
EHtrust.org
SmartGridAwareness.org
Just Prove It net
NaturalScience.org
Whatls5G.info
Building-Biology.org
Facebook ©Citizens for Safe Technology
"The entire earth turns more and
more Into a huge laboratory...
only we cannot clean up this
laboratory quite as easily when we
realize the experiment went wrong."
- Neitzke et al. in "Electrosmog - A
Risk?" (1994)
-------
Neurological Damage Carcinogenicity
Headaches, brain fog
and sleep disturbance
are associated with
radio frequencies.
Electromagnetic hyper-
sensitivity (EHS) is a
recognized functional
disability in Sweden.
The carcinogenic impact
of electrosmog cannot
be overstated. Blood,
breast and brain
cancers may be most
documented, but the
impact of EMR on
biology is all inclusive
CJ
JAN
GEF
4
)
Environment v. Economy
The 1996 Telecom Act was designed to stimulate
the economy. It assumed radio frequencies (RF) had
no impact other than thermal based on incomplete
and suspect science, a model that prohibited any
zoning objections due to health or environment.
Although U.S. radio frequency exposure limits are
much higher than limits in China, Russia and
Europe, no politically determined current legal limit
offers adequate protection per scientific evidence.
See inside for recent 21st century scientific citations
and reviews for evidence of adverse impacts to
environment and health. This science is dismissed
as irrelevant under the law by the U.S. government
in its decision making.
Organizational Objections
U.S. Department of Interior memo to the
National Telecommunications and
Information Administration (NTIA)
regarding environmental damage from
Cell Phone Base Stations and other WiFi
technology. 7 Feb 2014.
International EMF Scientist Appeal to
United Nations, Member States & WHO.
May 11, 2015 updated January 29, 2017.
• American Academy of Environmental
Medicine (AAEM). Recommendations
Regarding Electromagnetic and
Radiofrequency Exposure. July 12, 2012.
International Association of Firefighters:
Division of Occupational Health, Safety
and Medicine. Position Statement
Opposing Cell Phone Base Stations at
Firehouses. March 2005.
• Texas House State Affairs Interim Report
re Public Utility Commission of Texas
processes, procedures and problems.
August 15, 2016.
• French National Assembly law to reduce
exposures to wireless radiation from
electromagnetic fields. January 29, 2015.
"In May 2011 the World Health Organization
elevated exposure to wireless radiation,
including WiFi, into the Class 2b list of
Carcinogens...The AAEM strongly
supports the use of wired Internet
connections, and encourages avoidance
of radiofrequency such as from WiFi,
cellular and mobile phones and towers,
and 'smart meters."'
- AAEM Position Statement (2013)
Safe Technology
Our future is our
responsibility!
"...the electromagnetic
radiation standards used by
the Federal Communications
Commission (FCC) continue to
be based on thermal heating, a
criterion now nearly 30 years
out of date and inapplicable
today."
- U.S. Department of the Interior (2014)
For information on pending
Massachusetts EMF legislation, visit:
tinvurl. com/MA-EMF-Bills
Also critical pending national legislation:
S.19-MOBILE NOW Act
S. 88 - DIGIT Act
Dec 2017
-------
APPENDIX B:
Attendee List
Astrika
Adams
SBA OA
Sara
Adelsberg
Deloitte
Rebecca
Adler
Miserendino
Lewis-Burke Associates
David
Ailor
American Coke and Coal Chemicals Institute -
Olugbenga
Ajilore
USD A
Jose
Almanzar
Seyfarth Shaw LLP
Rudaina
Alrefai-
Kirkpatrick
Food and Drug Administration
Shanika
Amarakoon
ERG
Donald
Ami
DOE/NNS A/Los Alamos
Valerie
Amor
Private Citizen
Scott
Andrews
Aclima Inc.
Peggy
Anthony
Private Citizen
Francisca
Aparicio
Alianza Nacional de Campesinas
Karol
Archer
FAA
Gabriel
Arellano
STEMSign
Jo Ann
Armenta
Purpose Focused Alternative Learning
Mily
Arreola
Alianza Nacional de Campesinas
Brian
Ashton
AREDLLC
Joseph
Baietti
HUD
Taaka
Bailey
MDEQ
Sabrina
Bailey
Illinois Environmental Protection Agency
Louis
Bailey
WE ACT For Environmental Justice
Sandra
Baird
MassDEP
Jamie
Banks
Quiet Communities
Erica
Bannerman
Government
Chelsea
Barnes
Private Citizen
Xavier
Barraza
Los Jardines Institute
Catie
Bartone
VTDEC
Krystyna
Bednarczyk
FAA
Hormis
Bedolla
Alianza Nacional de Campesinas
Samantha
Beers
US EPA
Marlene
Begay
Walker River Paiute Tribe
Funmilola
Belie
Southern Connecticut State University
Emily
Benayoun
EPA
Agatha
Benjamin
EPA
Arielle
Benjamin
EPA
Crystal
Bergemann
HUD
91
-------
Lily
Black
EPA
Michael
Blair
Innovate Inc
Molly
Blessing
Household & Commercial Products Association
Nik
Blosser
White House
Lyndsey
Bloxom
The Water Research Foundation
Conrad
Blume
MODNR
Terri
Blunk
EPA
Coline
Bodenr eider
PHASC
Kofi
Boone
NCSU
Victoria
Bortfeld
American Public Health Organization
Terry
Bowers
Department of Defense
Joelle
Bowers
USD A
Randa
Boy kin
NCDEQ
Laura
Bretheim
University of Minnesota
Marcia
Briggins
Re-Right the Culture
Olivia
Blister
Progressive Leadership Alliance of Nevada
Emily
Brooks
U.S. Geological Survey
Erin
Broussard
Arizona Electric Power Cooperative
Aiden
Browne
University of California, Irvine
Kelsey
B rugger
E&E News/POLITICO
Sharunda
Buchanan
CDC/ATSDR
Khrystle
Bullock
HipHop Caucus
Omari
Burrell
EPA
Jeff
Burright
Oregon Department of Energy
Stan
Buzzelle
EPA
April
Byrne
ORISE
Stacey
Callaway
Ecology
Charles
Callaway
WE ACT
Hailey
Campbell
City and County of Honolulu
Morgan
Capilla
EPA
Ari
Caramanica
USDA-NIFA
James
Carlton
Private Citizen
Maria
Carnevale
Western Pacific Regional Fisheries Management Council
Adam
Carpenter
American Water Works Association
De'Lisa
Carrico
DOE
Oscar
Carrillo
EPA
Reba
Carruth
Private Citizen
Kim
Carter
Private Citizen
Elvira
Carvajal
Alianza Nacional De Campesinas
Ester
Ceja
Idaho Transportation Department
Audelia
Cervantes
Lideres Campesinas
Audelia
Cervantes
Lideres Campesinas
Brian
Chalfant
Pennsylvania Department of Environmental Protection
92
-------
Mark
Chambers
Stony Brook University
Kevin
Chang
Kua'aina Ulu Auamo
Amelia
Cheek
IERG
Lauren
Childs-Gleason
NASA
Eric
Choi
GHGSat Inc.
Stephanie
Coates
EDF
Majidah
Cochran
Beveridge & diamond
Deborah
Cohen
USEPA
Kimberlie
Cole
Strata-G LLC
Bob
Collin
Private Citizen
Rachel
Connolly
UCLA
Jasmin
Contreras
EPA
Cara
Cook
Alliance of Nurses for Healthy Environments
Farrah
Court
TCEQ
Kelly
Crandall
Colorado Public Utilities Commission
Bria
Crawford
Environmental Protection Agency
Brandi
Johnson
EJ Activist
Jace
Cuje
EPA/ORD
Anita
Cunningham
NC Disaster Survival and Resiliency School
C
Cunningham
DOI
Rebecca
Curry
Earthjustice
Diana
Cutt
EPA
Lew
Daly
Roosevelt Institute
Rachel
Davis
Waterspirit
William
Davis
Emr
Shanell
Davis-Bryant
Groundwork Jacksonville
Cemelli
De Aztlan
La Mujer Obrera
Marian
Dean
USACE
Tamara
DeRidder
TDR & Associates - Land Use Planning
Chris
Dobens
WE ACT for Environmental Justice
John
Doherty
IUPAT
Ali
Dominguez
Deloitte
William
Donnelly
IncrediBlocks LLC
Cecelia
Donovan
EcoLogix Group, Inc.
Lori
Dowil
Corteva
Melinda
Downing
Department of Energy
Charlotte
Keys
JPAP/MTAC
Rebecca
Dudley
Columbia University
Grace
El am
EPA
Tania
Ellersick
USD A Forest Service
Nora
Elmarzouky
Emerald Cities Collaborative
Marcus
England
FAA
Lena
Epps-Price
EPA
93
-------
John
Esch
Michigan EGLE
Jorge
Escobar
USDS/EOP
Monica
Espinosa
EPA
Mirella
Estrada
Alianza Nacional
Cynthia
Ferguson
US Dept. of Justice/ Environment
Ni colette
Fertakis
EPA
Timothy
Fields
MDB, Inc.
Stephanie
Fiorenza
setwnv
Robin
Forman
Independent Environmental Advocate
Kailea
Frederick
NDN Collective
Denise
Freeman
U.S. Department of Energy
Sarah
Froman
EPA
Kari
Fulton
Climate Justice Alliance
Juana
Garcia
Alianza Nacional de Campesinas
Carlos
Garcia
Bloom Energy
Josefina
Garcia
Alianza Nacional de Campesinas
Sergio
Garcia Meji a
Bureau of Ocean Energy Management
Danny
Garza
Mexican American Political Association
Sierra
Generette
UCOR
Andrew
George
UNC Chapel Hill Institute for the Environment
Venu
Ghanta
Duke Energy
Robert
Gibbs
USD A
Ora
Giles
Transcription, Etc., LLC
Linda
Giles
Transcription, Etc.
Kristin
Gimbel
Metropolitan Group
Alicyn
Gitlin
Sierra Club - Grand Canyon Chapter
Sonya
Goines
Department of Energy
Dewayne
Goldmon
USD A
Leo
Goldsmith
ICF
Rachel
Gonsenhauser
EPA
Catalina
Gonzalez
Center for Progressive Reform
Vanessa
Gordon
USD A
Eve
Granatosky
Lewis-Burke Associates LLC
running
Grass
Three Circles Center
Lena
Green
Community Advocate/NAACP
Matthew
Greene
U.S. Fish and Wildlife Service
Joy
Grewatz
Meguire Whitney
Ardie
Griffin
Emerald Cities Collaborative
Tyneshia
Griffin
New Virginia Majority
Ebony
Griffin
Earthjustice
Emily
Gulick
Jacobs Engineering
Rose
Gutowski
FEMA
Betsy
Hale
KCPS
94
-------
Yvonka
Hall
Northeast Ohio Black Health Coalition
Richard
Hamel
ALL4, LLC
Graham
Hamilton
Break Free from Plastic
Stephanie
Hammonds
WVDEP-DAQ
Rose
Hanks
LSU
Christine
Harada
Federal Permitting Improvement Steering Council
Linsey
Haram
USD A
Angela
Harris
Southeast care
Jill
Harrison
University of Colorado Boulder
Sherrie
Hart
NDN Collective
Betsy
Harvey
Boston Region MPO
Jenny
Heeter
National Renewable Energy Laboratory
Joshua
Helms
FEMA
Norrel
Hemphill
We the People of Detroit
Carey
Hengstenberg
Environmental Justice Coordinator
Tyler
Hepner
NYSDEC
Sinthia
Hernandez
Lideres Campesinas
Stephanie
Herron
EJHA
Brian
Holtzclaw
EPA
Courtney
Hoover
Department of the Interior
Janice
Horn
Tennessee Valley Authority
Melissa
Horton
Southern Company
Thomas
Hudson
Weyerhaeuser NR Company
Donald
Hui singh
Univ. of TN
Jennifer
Huser
EPA
Naadiya
Hutchinson
Congressman Donald McEachin
Patricia
Iscaro
Politico Agency IQ
Shakenya
Jackson
City of Apopka
Justin
Jackson
BlueGreen Alliance
Marnese
Jackson
Midwest Building Decarbonization Coalition
William
James
U.S. Army Corps of Engineers
Sarah
Jareczek
Intermountain Fair Housing Council
Tyler
Jenkins
Senate EPW
Julie
Jimenez
Private Citizen
Katherine
Jimenez
Southern Connecticut State University
Sabrina
Johnson
EPA
Brett
Johnson
NYSACC, Gorham Conservation Board.
Bonita
Johnson
EPA
Stephanie
Johnson
DelDOT
Marian
Thompson
NC DEQ EJE Advisory Committee
Lena
Jones
Minneapolis College
Sean
Joyner
U.S. Department of Housing and Urban Development
Miriam
Juarez
Alianza Nacional de Campesinas
95
-------
Darren
Kaihlanen
USD A
Cheryl
Kelly
Department of the Interior
Kameron
Kerger
USDS
Sonia
Kikeri
Emerald Cities Collaborative
Lee
Killinger
Florida Crystals
John
Kinsman
Edison Electric Institute
Bob
Kitchen
Virginia Clinicians for Climate Action
Amy
Klusmeier
US DOE
Trish
Koman
EPA
Renee
Kramer
North Carolina Department of Environmental Quality
Gretchen
Kroh
USD A
Emma
Kurnat-Thoma
Georgetown University NHS
Elyse
Kutsche
Private Citizen
Yukyan
Lam
NRDC
Kim
Lambert
U.S. Fish and Wildlife Service
Katie
Lambeth
EGLE
Tiffany
Landry
USD A
Peiley
Lau
EPA
Diane
Lauricella
Norwalk Zero Waste Coalition
Sharon
Lavigne
Rise St. James
Aine
Lawlor
HCNR
Matthew
Lee
EPA
Stephen
Lee
Bloomberg
Jada
Lee
Washington University
Rachel
Lekanoff
Aleutian Pribilof Islands Association, Inc.
Justin
Leon
Native American Fish & Wildlife Society
Jake
Li
EPA
Christopher
Lindsay
IAPMO
Colleen
Litkenhaus
Dow
C
Liv
HHS
Tasha
Lo Porto
USD A Forest Service
Anna
Loizeaux
The JPB Foundation
Keisha
Long
SC DHEC
David
Lonnberg
shift7
Victoria
Loong
We the People of Detroit
Olivia
Lopez
Ocean Conservancy
Ysabel
Lopez
Mujeres Divinas
Sara
Lovtang
Oregon Dept of Energy
Jade
Lu
Massachusetts Clean Energy Center
Sonrisa
Lucero
DOE - Office of Economic Impact and Diversity
Lauren
Lurkins
Illinois Farm Bureau
Khali
Abdegeo
UMASS Medical School/Bay state Hospital Community
Jolene
Mafnas
Climate Justice Alliance
96
-------
Mark
Magana
GreenLatinos
Sam
Mardell
RMI
Larissa
Mark
EPA
Karen
Martin
Private Citizen
Anna
Martin
House Natural Resources Committee - Majority
Akilah
Martin
USACE
Marva
King
Retiree
Brendan
Mascarenhas
American Chemistry Council
Arsenio
Mataka
HHS
Shifali
Mathews
AECOM
Beth
Mattern
USDS
Henry
Mayer
CRESP - Vanderbilt University
Eileen
Mayer
US EPA
Catherine
Mazzocchi
Rockland County Environmental Management Council
Bud
McAllister
Partners in Healthy Communities
Mary
McCarron
Ohio EPA
Caitlin
McHale
National Mining Association
Roland
McKee
FAA
Dean
McMath
FAA
Rachel
Meidl
Baker Institute for Public Policy
Li at
Meitzenheimer
Fresh Air Vallejo
Trisha
Mejia
The Surfrider Foundation
Danielle
Mer curio
VNF
Hunter
Merritt
U.S. Army Corps of Engineers IWR
Debbie
Michel
East Bay Municipal Utility District (EBMUD)
Emily
Miller
Food & Water Watch
Mike
Miller
TCEQ
Kelly
Miller
Private Citizen
Vernice
Miller-Travis
Metropolitan Group
Melissa
Minor
General Services Administration
Katherine
Mlika
U.S. Digital Service
Lena
Moffitt
Evergreen Action
Jasmine
Moll
Healthy Gulf
Monica
Montejo
Alianza Nacional de Campesinas
Morgan
Moore
National Audubon Society
Chris
Moore
Eastman Chemical Co. - Kingsport, TN
Danilo
Morales
CSNDC
Olivia
Morgan
LSU
Sandra
Morse
Aegis Environmental Inc.
Brandon
Morton
Dallas College
Bridget
Moss
Private Citizen
John
Mueller
Private Citizen
Conor
Mulderrig
Grove Climate Group
97
-------
Phyllis
Mullenix
Private Citizen
Melissa
Muroff
Delaware County District Attorney's Office
Knowledge
Murphy
Multnomah County/Office of Sustainability
Sharmila
Murthy
CEQ
Olga
Naidenko
ENVIRONMENTAL WORKING GROUP
Tina
Ndoh
EPA
Emma
Nechamkin
USDS
Jonathan
Nelson
EPA
Lin
Nelson
Evergreen State College
Anuli
Njoku
scsu
Wendy
Norena
Deloitte
Marven
Norman
CCAEJ
Avriel
Null
Tennessee Valley Organization
Yamiles
Nunez
Alianza Nacional de Campesinas
Leanne
Nurse
The Nature Conservancy
Onyemaechi
Nweke
EPA
Maya
Nye
Coming Clean
Carlos
Ochoa
Azul
January
O'Connor
Raven's Group LLC
Teraine
Okpoko
Teraine Okpoko P.C.
Laura
01 ah
Citizens for Safe Water Around Badger (CSWAB)
Ashley
Oleksiak
Alaska Dept. of Environmental Conservation
Sarah
01 sen
The Missouri Department of Natural Resources
John
Oluwaleye
Gender-Based Violence as a Public Health Issue
Danielle
O'Neil
Environmental Protection Agency
Gail
Orendorff
USDOT
Elyse
Osterweil
EPA
Kelsey
Owens
U.S. Department of Transportation
Anthony
Paciorek
Michigan United
Anthony
Pahnke
Alianza Nacional de Campesinas
Monica
Palmeira
Greenlining Institute
Kai
Palmer-Dunning
Home Energy Efficiency Team
Alex
Papali
Center for Economic Democracy/ United Frontline Table
George
Parra
Socially Immersed
Bryan
Parthum
EPA
Regan
Patterson
Congressional Black Caucus Foundation
Rachel
Patterson
Evergreen
William
Patterson
EBMUD (East Bay Municipal Utility District)
Charles
Pearson
Syngenta Crop Protection, LLC
Katharine
Pelzer
Aclima
Jodie
Peotter
Wisconsin DNR
Nestor
Perez
Earthjustice
Brett
Perlman
Center for Houston's Future
98
-------
Hannah
Perls
Harvard Environmental & Energy Law Program
Chris
Perrigan
Brightwater Strategies, PLLC
Rebecca
Perrin
EPA
Kandyce
Perry
New Jersey Department of Environmental Protection
Julie
Petersen
U.S. Department of Energy
Lucia
Petty
HUD, FHEO
Sarah
Phillips
Waste Connections
Lori
Pierce
USDOT
Andrew
Pike
Virginia Department of Transportation
Paul
Presendieu
New York State Association of Conservation Commissions
Reginald
Harris
USEPA
Lee Ann
Racz
ToxStrategies, Inc.
Carmita
Thompson
USD A, RD-Civil Rights
Maria
Rahim
Chevron
Betseygail
Rand
Private Citizen
Elise
Rasmussen
Washington State Department of Health
Amee
Raval
Asian Pacific Environmental Network
Shantha
Ready Alonso
Interior
Tony
Reames
DOE
Leslie
Reed
Brightwater strategies
Dawn
Reeves
Inside EPA
Mayra
Reiter
Farmworker Justice
Liz
Rettenmaier
Private Citizen
Monica
Reyes
Rancho Vista/Redwood Community Organization
Cinthia
Reyes
Private Citizen
Annette
Rich
WE ACT for Environmental Justice
Pinkham
Richard
Booz Allen Hamilton
Charissee
Ridgeway
CEQ
Marelyn
Rivera
NJDEP
Sarah
Rizvi
NYU Law
Washington,
Robert
FHWA
Christina
Robichaud
EPA
Donovan
Robinson
OMB
Phillip
Rodbell
CEQ
Alex
Rodriguez
Conduit Government Relations
Julie
Roemele
EPA
Marlene
Rojas
Alianza Nacional de Campesinas
Theresa
Romanosky
AAR
Angila
Romious
Otis College of Art and Design
Anne
Rosenblatt
EPA
Abigail
Ruskey
University of California - Merced
Naveena
Sadasivam
Grist
Kirstin
Safakas
EPA
99
-------
Adrien
Salazar
Grassroots Global Justice Alliance
Dulce
Salgado
Alianza Nacional de Campesinas
Allison
Sanborn
AECOM
Cynthia
Sanchez
IEPA
Steven
Sander
California Department of Resources Recovery and
Recycling
Denise
Sarchiapone
B&D Environmental Consulting LLC
Mily
Sauceda
Alianza Nacional de Campesinas
Marisol
Saucedo
Alianza Nacional de Campesinas
Oral
Saulters
Tribal TAB
Hassanatu
Savage
Deloitte
Stephanie
Schlea
Association of State Drinking Water Administrators
Isabel
Segarra Trevino
Harris County Attorney (Texas)
Action
Service
MDEQ
Monisha
Shah
20024
Sachin
Shah
USGS
Vim
Shah
USDS
Preeti
Shankar
Center for Neighborhood Technology
Nayyirah
Shariff
Flint Rising
Natalie
Shepp
Pima County Department of Environmental Quality
Gina
Shirey
Alaska Department of Environmental Conservation
Jacqueline
Shirley
NEJAC and RCAC
Dave
Shukla
Long Beach Alliance for Clean Energy
Sarah
Sieloff
MFA
Jose
Silva
PLAN
Rachael
Singer
Private Citizen
Ross
Smith
North Carolina Manufacturers Alliance
Megan
Smith
shift7
Christopher
Smith
Interstate Natural Gas Association of America
Sheldon
Snipe
Smart Set
Jessica
Snyder
EPA
Dan
Solitz
Private Citizen
Karen
Spencer
None
Ramsey
Sprague
Mobile Environmental Justice Action Coalition
Isabela
Blackburn
Washington Unversity in St. Louis
Joanna
Stancil
USDA-Forest Service
Anastasia
Standrik
The JPB Foundation
Lucy
Stanfield
EPA
Erik
Stanfield
Navajo Nation
Rebecca
Stearns
Southern CT State University
Claire
Still
AECOM
Craig
Stroman
USDA-Civil Rights Office
Callie
Struby
Deloitte
100
-------
Asher
Sullivan
Private Citizen
Kate
Sullivan
Great Plains Institute
Mitchell
Sumner
EPA
Katy
Super
Environmental justice health alliance
Feleena
Sutton
Aera Energy
Constance
Sutton
Private Citizen
Kristy
Swartz
DOI -OWF
Sandra
Talley
NRC
James
Tanner
DOE-Savannah River
Philip
Tannian
US Ecology Inc.
Patricia
Taylor
Environment and Human Health, Inc.
Theresa
Taylor
US Dept. of the Interior - Bureau of Reclamation
Romona
Taylor Williams
MCUP
Andrea
Thi
Federal Government, Department of JUSTICE
Ron
Thomas
EPA
Susan
Thomas
Just Transition NWI
Tami
Thomas-Burton
EPA
Suzanne
Thornsbury
USD A
Demi
Tighe
DOT/FAA
Amber
Tilley
EPA
Analisa
Toma
NACD
Jackie
Toth
Good Energy Collective
Samantha
Tremaine
General Services Administration
Kathy
Triantafillou
EPA
Rebecca
Truka
Hexion Inc
Liz
Upchurch
TVA
Karen
Utt
TVA
Venus
Uttchin
Private Citizen
Enrique
Valdivia
texas rio grande legal aid, inc
Angie
Vandell
USD A RD
Cynthia
Garcia
Alianza Nacional de Campesinas, Inc.
Gloria
Vaughn
EPA
Cristina
Villa
Department of the Interior
Ashley
Voskuhl
ASDWA
Rachel
Vranizan
California Environmental Justice Alliance
Carla
Walker
World Resources Institute
Maria
Wallace
EPA
Margaret
Walls
Resources for the Future
Charlene
Wang
DOT
Michelle
Ward
Private Citizen
Phillip
Washington
USD A
Michon
Washington
FAA
Melissa
Schutten
Puget Sound Partnership
101
-------
Cheryl
Watson
Blacks In Green
Eric
Werwa
Department of the Interior
Sue
Westerberg
Southern CT state university
T'Shari
White
UNC Greensboro
Chad
Whiteman
U.S. Chamber of Commerce
Jalonne
White-Newsome
Empowering A Green Environment and Economy, LLC
Devlin
Whiteside
Owens Corning
Kevin
Wicker sham
Hudson Center for Community and Environment Inc
Wesley
Wiggins
EPA
Adam
Wilke
USD A NIF A
Jane
Williams
California Communities Against Toxics
Keisha
Williams
State of Michigan
Clarence
Williams
Tecolote Perch
Deborah
Williams
CWLP
MJ
Wilson
FEMA
Michele
Witt
USD A Rural Development
Leah
Wood
Washington State Department of Health
D
Wu
NYS OAG - EPB
Timothy
Wu
USD A
Zach
Yamada
WPRFMC
naomi
yoder
Healthy Gulf
Suzanne
Yohannan
Inside EPA's Superfund Report
Dondre
Young
Office of U.S. Senator Debbie Stabenow
Rachel
Young
EOP/CEQ
Matthew
Young
BeechWood Inc.
Tariq
Zahran
EVHybridNoire
Rachel
Zander
Department of Natural Resources
Hilary
Zarin
DOI
Steven
Zuiss
Koch
Ariel a
Zycherman
NO A A
102
-------
I, Richard Moore, Co-Chair of the White House Environmental Justice Advisory Council, certify
that this is the final meeting summary for the public meeting held on March 30-31, 2022, and it
accurately reflects the discussions and decisions of the meeting.
Richard Moore
I, Peggy Shepard, Co-Chair of the White House Environmental Justice Advisory Council, certify
that this is the final meeting summary for the public meeting held on March 30-31, 2022, and it
accurately reflects the discussions and decisions of the meeting.
103
------- |