WHITE HOUSE ENVIRONMENTAL JUSTICE
ADVISORY COUNCIL
Members:
August 16, 2022
Richard Moore,
Co-Chair
Peggy Shepard,
Co-Chair
Catherine Coleman
Flowers, Vice Chair
Carletta Tilousi,
Vice Chair
LaTricea Adams
Susana Almanza
Jade Begay
Maria Belen Power
Dr. Robert Bullard
Tom Cormons
Jerome Foster II
Kim Havey
Angelo Logan
Maria Lopez-Nunez
Harold Mitchell
Dr. Rachel Morello-
Frosch
Juan Parr as
Michele Roberts
Ruth Santiago
Dr. Nicky Sheats
Viola Waghiyi
Dr. Kyle Whyte
Dr. Beverly Wright
Hli Xyooj
Miya Yoshaitani
The Honorable Brenda Mallory, Chair
Council on Environmental Quality
Executive Office of the President
Washington, DC 20500
RE: Recommendations for the Climate and Economic Justice Screening
Tool
Dear Chair Malloiy:
We commend the hard work and deliberative process undertaken by the
Council on Environmental Quality (CEQ) to create the Climate and Economic
Justice Screening Tool (CEJST) to enable federal agencies to identify
communities "that are marginalized, underserved, and overburdened by
pollution" and to guide prioritization of investments for Justice40 initiatives to
address environmental justice challenges across the United States.1 The
WHEJAC takes seriously our charge to provide advice and recommendations on
the CEJST as CEQ revises the tool in anticipation of its Version 1.0 release and
updates and improves the CEJST as new data become available. Ensuring the
accuracy of the CEJST and improving the Tool, as new data become available,
will be critical to the successful and equitable implementation of Justice40.
Accordingly, CEQ will need to commit sufficient funding and staff resources to
this iterative process, and provide communities, particularly rural communities
and Tribes, capacity-building support that ensures that they can fully benefit
from this unprecedented federal initiative.
The following recommendations are based on our review of the February 2022
public beta form of the CEJST, as well as on feedback from our communities and
constituents across the country.
1. Integrate indicators of structural racism.
The CEJST does not include race as an indicator of a disadvantaged community.2
However, decades of environmental justice research justify the inclusion of
structural racism metrics in the tool. Examples of such measures include:
1. Council on Environmental Quality, "About," Climate and Economic Justice Screening Tool-Beta, accessed July
23, 2022. https://screeningtool.geoplatform.gov/en/about/.
2. Executive Office of the President, "Climate and Economic Justice Screening Tool: Frequently Asked
Questions," accessed July 23, 2022. https://www.whitehouse.gov/wp-content/uploads/2022/02/CEQ-CEJST-
QandA.pdf/.
-------
2
A. Redlining. Historical redlining3 is a well-documented discriminatory
and illegal practice that research shows continues to exert adverse
environmental and health impacts on redlined neighborhoods,
including worse air quality,4 a lack of greenspace,5 and higher heat
island risks,6 as well as elevated rates of cardiovascular disease,7 asthma
hospitalizations,8 poor birth outcomes,9 and other diseases.10
B. Segregation. Racial residential segregation has been significantly
driven by discriminatory political, social, and economic forces,11
coupled with patterns of industrialization and disinvestment that have
segregated people of color into neighborhoods, including immigrant
enclaves. Although these communities have developed strong
foundations of socioeconomic resiliency and cultural vibrancy, they
often have some of the poorest indices of environmental quality.
Accordingly, CEQ should consider including segregation metrics into the
CEJST that account for: (1) dimensions of evenness, which measures the
degree to which the proportion of a particular racial or ethnic group
living in a census tract approximates that group's relative percentage of
an entire county or metropolitan area; or (2) isolation and exposure,
which assesses the extent to which a member of a particular racial or
ethnic group is likely to have contact with members of the same group
(isolation) or, conversely, the degree to which different groups would be
exposed to one other by sharing common tracts (exposure).
3. See, for example, Robert K. Nelson, LaDale Winling, Richard Marciano, Nathan Connolly, et al., "Mapping
Inequality," American Panorama, ed. Robert K. Nelson and Edward L. Ayers, accessed July 23, 2022.
https://dsl.richmond.edu/panorama/redlining/ - loc=5/39.l/-94.58&text=about/.
4. Haley M. Lane, Rachel Morello-Frosch, Julian D. Marshall, and Joshua S. Apte, "Historical Redlining Is
Associated with Present-Day Air Pollution Disparities in U.S. Cities," Environmental Science & Technology Letters
9, no. 4 (March 2022): 345-350. doi: 10.1021/acs.estlett.lc01012.
5. Anthony Nardone, Kara E. Rudolph, Rachel Morello-Frosch, and Joan A. Casey, "Redlines and Greenspace:
The Relationship between Historical Redlining and 2010 Greenspace across the United States," Environmental
Health Perspectives 129, no. 1 (Jan. 2021): 17006. doi: 10.1289/EHP7495.
6. Nadja Popovich and Christopher Flavelle, "Summer in the City Is Hot, But Some Neighborhoods Suffer More,"
New York Times, Aug. 9, 2019, accessed July 22.
https://www.nvtimes.com/interactive/2019/08/09/climate/city-heat-islands.html/.
7. Mahasin S. Mujahid, Xing Gao, Loni P. Tabb, Colleen Morris, and Tene T. Lewis, "Historical Redlining and
Cardiovascular Health: The Multi-Ethnic Study of Atherosclerosis," Proceedings of the National Academy of
Sciences 118, no. 51 (Dec. 2021). doi: 10.1073/pnas.211Q986118/.
8. Anthony Nardone, Joan A Casey, Rachel Morello-Frosch, Mahasin Mujahid, John R Balmes, and Neeta Thakur,
"Associations between Historical Residential Redlining and Current Age-Adjusted Rates of Emergency
Department Visits Due to Asthma Across Eight Cities in California: An Ecological Study," Lancet Planetary Health
4, no. 1 (Jan. 2020): e24-e31. doi: 10.1016/S2542-5196(19)30241-4.
9. Anthony L. Nardone, Joan A. Casey, Kara E. Rudolph, Deborah Karasek, Mahasin Mujahid, and Rachel
Morello-Frosch, "Associations between Historical Redlining and Birth Outcomes from 2006 through 2015 in
California," PLOS One 15, no. 8, (Aug. 2020): el-el8. doi: 10.1371/iournal.pone.Q237241.
10. Eun KyungLee, Gwendolyn Donley, Timothy H. Ciesielski, India Gill, Owusua Yamoah, Abigail Roche, Roberto
Martinez, and Darcy A. Freedman, "Health Outcomes in Redlined Versus Non-Redlined Neighborhoods: A
Systematic Review and Meta-Analysis," Social Science & Medicine 294, (Feb. 2022). doi:
10.1016/i.socscimed.2021.114696.
11. Rachel Morello-Frosch and Russ Lopez, "The Riskscape and the Color Line: Examining the Role of
Segregation in Environmental Health Disparities," Environmental Research 102, no. 2 (Oct. 2006): 181-96. doi:
10.1016/i.envres. 2006.05.007.
-------
3
Segregation measures should include residential segregation and, if data
are available, also include school-based segregation (K-12).
C. Racialized disparities of extreme wealth and deprivation. The
Index of Concentration at the Extremes measures the extent to which a
census tract's residents are concentrated into groups at the extremes of
deprivation and privilege: a value of -1 means that 100% of the
population is concentrated in the most deprived group, and a value of 1
means that 100% of the population is concentrated into the most
privileged group. This measure has been used to characterize tracts in
terms of their concentrations of low-income people of color versus high-
income white persons in relation to air quality (levels of black carbon)
and other health outcomes.
D. Foreclosures. Mortgage foreclosures resulting from historic and
ongoing racially discriminatory lending practices disproportionately
affect home owners of color,12 particularly Black residents living in
segregated neighborhoods.13 Foreclosures have also been shown to be
associated withdetrimental effects on community health14 and poor
environmental quality.15 Proprietary data sources, including
CoreLogic,16 have excellent data on this measure (defined as the final
transfer of a foreclosed property deed to a new owner), and it is likely
that the Treasury Department, Department of Housing and Urban
Development (HUD), or Department of Justice might be tracking this
information systematically across the country in ways that could be
used in the CEJST.
2. Include relevant indicators of Native American and tribal land.
Research shows that land dispossession and forced migration have displaced
Indigenous peoples to lands that are more exposed than their original lands to
climate change risks and other environmental hazards.17 Currently, the CEJST
"covers all U.S. census tracts, including those located within Tribal Nations, to
the extent that data is available."18 The CEJST states that decisions regarding
the inclusion of tribal land will be informed through "consultation and
12. Matthew Hall, Kyle Crowder, and Amy Spring, "Variations in Housing Foreclosures by Race and Place, 2005-
2012," The Annals of the American Academy of Political and Social Science 660, no. 1 (June 2015): 217-237. doi:
10.1177/0002716215576907.
13. Jacob S. Rugh and Douglas S. Massey, "Racial Segregation and the American Foreclosure Crisis," American
Sociological Review 75, no. 5 (2010): 629-651. doi: 10.1177/0003122410380868.
14. Janet Currie and Erdal Tekin, "Is There a Link Between Foreclosure and Health?" American Economic Journal:
Economic Policy 7, no. 1 (Feb. 2015): 63-94. doi: 10.1257/pol.2012Q325.
15. John I. Gilderbloom, Wesley L. Meares, and William Riggs, "How Brownfield Sites Kill Places and People: An
Examination of Neighborhood Housing Values, Foreclosures, and Lifespan," Journal of Urbanism: International
Research on Placemaking and Urban Sustainability 9, no. 1 (2016): 1-18. doi: 10.1080/17549175.2014.905488.
16. http://www.corelogic.com/.
17. Justin Farrell, Paul Berne Burow, Kathryn McConnell, Jude Bayham , Kyle Whyte, and Gal Koss, "Effects of
Land Dispossession and Forced Migration on Indigenous Peoples in North America," Science 374, no. 6567 (Oct.
2021). doi: 10.1126/science.abe493.
18. Executive Office of the President, "Climate and Economic Justice Screening Tool: Frequently Asked
Questions," accessed July 23, 2022. https://www.whitehouse.gov/wp-content/uploads/2022/02/CEQ-CEJST-
QandA.pdf.
-------
4
coordination with Tribal Nations."19 We encourage CEQ to follow through with
this critical consultation process and to ensure that the WHEJAC Indigenous
Peoples and Tribal Nations Workgroup is actively engaged in these
deliberations. In addition to depicting federally recognized tribal land, the
CEJST should include other associated federally recognized land (trusts,
restricted fee, or mixed ownership), as well as state recognized tribal lands,
Hawaiian homelands, and traditional hunting and fishing treaty areas. Data
sources on tribal land census tracts are available from the U.S. Census Bureau,
including the American Indian/Alaska Native/Native Hawaiian Areas National
Shapefile, which contains shapefiles for federally recognized American Indian
reservations and off-reservation trust land areas as well as state-recognized
American Indian reservations. The shapefile includes data such as the Oklahoma
Tribal Statistical Areas, Tribal Designated Statistical Areas, and State-
Designated Tribal Statistical Areas. It is important to acknowledge that many
tribes retain jurisdiction over treaty areas and ancestral homelands, including
remaining allotment lands, even though these are often held as private,
nontribal trust land. Data sources that depict the impact of land dispossession
and forced migration of Indigenous people are available online and could
potentially be used to augment this element of the CEJST.20
For Indigenous peoples, it is not always true that simply displaying more data
or making data more publicly accessible is automatically beneficial. Some
information in the CEJST may interfere with ongoing legal disputes and other
territorial conflicts in which some Indigenous peoples are embroiled. Or
information displayed in the CEJST could trigger other sensitive cultural, social,
and political issues with which some Indigenous peoples are grappling. Even
though the data in the CEJST tool are already public, the data gain further
visibility when curated in the tool. The increase in visibility is not always an
unalloyed good for some Indigenous peoples and can pose risks and threats.
This is why adequate consultation and feedback is needed to know whether and
how the CEJST can have beneficial relevance for Indigenous peoples.
Given that for many Indigenous peoples the CEJST tool does not feature relevant
data, Indigenous representatives, leaders, officials, managers, and staff
members may question how they can use the CEJST tool. A consultative and
feedback process for Indigenous peoples must be orchestrated in a way that
does not run afoul of known guidance for engaging Indigenous peoples,
including the avoidance of overwhelming Indigenous people with requests for
consultation or feedback with little offer of capacity-building support to ensure
meaningful participation. For the CEJST tool to be effective, it has to be able to
be used in combination with what Indigenous peoples know about their own
communities and lands. It has to be a tool that is worth the time of Indigenous
persons who already wear many hats in order to manage multiple jobs,
programs, and responsibilities, given the dearth of overall needed support for
Indigenous peoples in the Justice40 investment areas. There should be
19. Ibid.
20. See, for example, the Native Land Research Initiative, https://www.nativelandresearch.org/.
-------
5
additional opportunities and resources for Tribal officials as well as the staff of
Indigenous organizations and community representatives to undertake
consultative and participatory activities that can supplement the CEJST with
Indigenous data, information, and knowledge (such as Indigenous traditional
ecological knowledge) of relevance to Justice40 and other initiatives that the
CEJST serves.
3. Address missing income data and ensure that the low-income
threshold is not prioritized over all other indicators in a way that
precludes DAC designation when thresholds for other indicators are
met.
Income data may not be available in some census tracts with small numbers of
residents, particularly tracts in rural areas. For tracts missing income data, we
recommend that CEQ undertake income imputation by using income
information from neighboring tracts. Alternatively, census tracts that are
missing income data and therefore cannot be assessed for disadvantaged
community (DAC) status but that are surrounded by tracts with a DAC
designation could simply be categorized as DACs. We also recommend reducing
the higher education and income thresholds so as not to exclude tracts that
house Historically Black Colleges and Universities. In addition, we believe that
there may be opportunities to use a more parsimonious and consistent set of
metrics for income and education. Currently, the CEJST uses two separate
education variables ("high school degree attainment" and "enrollment in higher
education") and three different variables to measure income ("low income,"
"poverty," and "median household income"). Further, consideration should be
given to providing a pathway for communities that would qualify as
disadvantaged were it not for the income requirement. Such a pathway might be
appropriate since these communities could be environmentally and socially
burdened in ways that still justify DAC classification.
4. Enhance the climate change vulnerability category.
Current indicators used to assess climate change vulnerability in the CEJST are
limited to expected agricultural loss, building loss rate, and expected population
loss rate. However, there are additional high-quality national data related to
other climate change impacts that would make this category more robust. Other
elements of climate change vulnerability that are critically relevant to
environmental justice include heat island risks,21 which disparately affect
environmental justice communities. Studies show, for example, that the adverse
perinatal effects of heat waves combined with poor air quality can
disproportionately impact people of color.22 Metrics could assess trends in the
number of extreme warm degree days or nights (e.g., number of days that daily
or nightly dry-bulb temperatures exceed the historical [1971-2000]
21. Bill M. Jesdale, Rachel Morello-Frosch, and Lara Cushing, "The Racial/Ethnic Distribution of Heat Risk-
Related Land Cover in Relation to Residential Segregation," Environmental Health Perspectives 121, no. 7 (July
2013): 811-817. doi: 10.1289/ehp.l205919.
22. Bruce Bekkar, Susan Pacheco, Rupa Basu, and Nathaniel DeNicola, "Association of Air Pollution and Heat
Exposure With Preterm Birth, Low Birth Weight, and Stillbirth in the US: A Systematic Review," JAMA Network
Open 3, no. 6 (June 2020): e208243. doi:10.1001/iamanetworkopen.2020.8243.
-------
6
summertime 99th percentile), neighborhood green space,23 tree canopy,24 and
impervious surface (using USGS National Land Cover Database^ or Normalized
Difference Vegetation Index - Enhanced Vegetation Index26 data). Additionally,
metrics related to flooding due to sea-level rise27 in low-lying coastal areas
should be added to the CEJST, given current and projected threats to potentially
hazardous facilities and legacy clean-up sites that are disproportionately
located in environmental justice communities.28
5. Integrate metrics of physical and social infrastructure.
Justice40 programs will include significant infrastructure investments, which
should be guided by more diverse infrastructure measures in the CEJST. We
recommend developing a more robust infrastructure category that includes
indicators related to transportation infrastructure and affordability (data could
be secured from the Department of Transportation); digital infrastructure, such
as internet and broadband access; banking services; food security (available
from data sources such as PolicyMap29 and Simply Analytics30); and affordable
housing (data could be acquired from HUD and/or the National Housing Trust).
In addition, we believe the CEJST should assess the availability of data to
generate metrics that would identify severely deprived areas where
communities are living in housing that lacks electricity, plumbing, or sewerage,
particularly in rural areas, unincorporated areas, and colonias along the US-
Mexico border (HUD may have such data). CEO should also assess whether
national data sources are avt grate industrial zoning information.
6. Enhance metrics of relevance to community health status.
We encourage use of perinatal and maternal health outcomes, including low
birthweight, small-for-gestational age, preterm birth, and severe maternal
morbidity in the CEJST. The Centers for Disease Control and Prevention or the
U.S. Department of Health and Human Services should be able to share these
data. In addition, an indicator of a community's health insurance status could be
developed by using the percentage of people receiving Medicaid compared with
its total Medicaid-eligible population. This metric can be obtained from the U.S.
Census Bureau.
7. Expand or enhance environmental hazard indicators.
We encourage including a wider array of environmental hazards in the CEJST.
As examples, national scale data sources exist for the following hazards:
23. Nardone, et al. "Redlines and Greenspace." doi: 10.1289/EHP7495.
24. American Forests, Tree Equity Score, accessed July 23, 2022. https://treeequitvscore.org/.
25. https://www.mrlc.gov/data/nlcd-2019-land-cover-conus/.
26. https://modis.gsfc.nasa.gov/data/dataprod/modl3.php/.
27. Climate Central, Surging Seas Maps and Tools, accessed July 23, 2022.
https://sealevel.climatecentral.org/maps/.
28. See Toxic Tides: Sea Level Rise, Hazardous Sites, and Environmental Justice in California, accessed July 23,
2022. https://sites.google.com/berkeley.edu/toxictides/home/.
29. https://www.policvmap.com/features/access-data/.
30. https://simplvanalvtics.com/.
-------
7
A. National Air Toxics Assessment (aka AirToxScreen)31 or the Risk-
Screening Environmental Indicators Model32 that more
comprehensively characterize potential cancer and non-cancer hazards
related to hazardous pollutants emitted into air, water, and soil.
B. Concentrated animal feeding operations (CAFOs) from EPA's Facility
Registry Service database, as these facilities are of great relevance for
community health and environmental justice,33 particularly for rural
communities. CEQ should collaborate with EPA to push for better data on
the location, size, and types of multiple CAFOs across the country.
C. Oil and gas extraction activities, including unconventional methods
(such as hydraulic fracturing) pose significant environmental justice
threats34 in rural and urban communities throughout the country and
should therefore be included as a hazard. Enverus35 is a private service
that aggregates data on oil and gas development activity from operators
and state agencies across the United States that is also made available for
research purposes.
D. Mining sites from the Abandoned Mine Land Inventory System36 as
well as data on formerly used defense sites37 from the US Army Corp of
Engineers should be added to the CEJST.
8. Integrate measures of sensitive populations and receptors.
We recommend that CEJST include metrics of sensitive receptors of critical
relevance for environmental justice, starting with K-12 schools38 (for which
data are likely available from the Department of Education) and prisons39 (data
are likely available from the Department of Justice).
9. Add indicators of drinking water quality and sanitation.
While there is a paucity of high-quality spatial data on community and public
water systems, the Environmental Policy Innovation Center has created the first
comprehensive national dataset of drinking water service area boundaries for
community water systems.40 We encourage CEQ to work with EPA and consider
31. https://www.epa.gov/AirToxScreeri/2017-airtoxscreeri/.
32. https://www.epa.gov/rsei/.
33. Ji-Young Son, Rebecca L. Muenich, Danica Schaffer-Smith, Marie Lynn Miranda, and Michelle L. Bell,
"Distribution of Environmental Justice Metrics for Exposure to CAFOs in North Carolina, USA," Environmental
Research 195, (April 2021): 110862. doi: 10.1016/i.envres.2021.110862.
34. David J. X. Gonzalez, Anthony Nardone, Andrew V. Nguyen, Rachel Morello-Frosch, and Joan A. Casey,
Historic Redlining and the Siting of Oil And Gas Wells in the United States, Journal of Exposure Science and
Environmental Epidemiology (April 2022). doi: 10.1038/541370-022-00434-9.
35. https://www.enverus.com/.
36. https://eamlis.osmre.gov/.
37. https://fudsportal.usace.armv.mil/.
38. Manuel Pastor, Jr., James L. Sadd, and Rachel Morello-Frosch, "Who's Minding the Kids? Pollution, Public
Schools, and Environmental Justice in Los Angeles," Social Science Quarterly 83, no. 1 (March 2002): 263-280.
doi: 10.1111/1540-6237.00082.
39. Adam Mahoney, "America's Biggest Jails are Frontline Environmental Justice Communities," Grist, April 15,
2021, accessed July 23, 2022. https://grist.org/equitv/toxic-iails-environmental-iustice-los-angeles-new-vork-
chicago/.
40. See https://www.policvinnovation.org/technology/water-utilitv-service-area-boundaries/.
-------
8
linking these boundaries with the federal Safe Drinking Water Information
System data to enable the development of a national drinking water layer that
could be added to the CEJST. These boundaries could also be used to estimate
areas where communities are not likely to be served by community water
systems and that are therefore reliant upon domestic wells. A method to
estimate the location of these domestic well areas has been used in California41
and could be scaled up nationally through a collaboration between CEQ, EPA,
and researchers working on water justice projects. To our knowledge, there are
currently no national data available that identify where communities lack of
access to sewerage and sanitation services—a significant environmental justice
challenge in both urban and rural areas. We therefore strongly recommend that
CEQ collaborate with US EPA, HUD, and USDA to address this critically
important data gap.
10. Provide a cumulative impact metric.
Advancing environmental justice in policy and regulatory decision-making
requires assessment and characterization of the cumulative impacts of
environmental and social stressors that drive health disparities across racial,
ethnic, and class lines. Although several state screening tools have valid
methods for assessing cumulative impacts, the CEJST currently lacks such an
approach. We recommend that CEJST address this critical data gap and derive a
cumulative impact metric. Such an approach could adapt validated and peer-
reviewed approaches that are used in existing screening tools, such as
CalEnviroScreen.42 Any cumulative impact methodology should be developed
with significant input from and in consultation with communities.
11. Provide a more transparent and accessible interface for timely user
and community feedback on the CEJST.
The CEJST currently provides an online survey43 to solicit feedback from users
and collect suggestions for additional data sources for the tool. However, we
think this feedback element should be enhanced by allowing users to provide
specific information about potential errors or data gaps on the site and by
clarifying and making more transparent the process and timeline by which CEQ
staff will respond to user queries, particularly when data errors have been
identified. In addition, given common errors in large administrative datasets,
CEQ will likely need to dedicate resources that enable its staff to engage directly
with community organizations that identify data accuracy or data gap problems
that could be collaboratively addressed through targeted ground-truthing of
CEJST results, identification of additional or better data sources that improve
accuracy of metrics, and other strategies. Finally, although the CEJST is
41. Clare Pace, Carolina Balazs, Komal Bangia, Nicholas Depsky, Adriana Renteria, Rachel Morello-Frosch, and
Lara J. Cushing, "Inequities in Drinking Water Quality Among Domestic Well Communities and Community
Water Systems, California, 2011-2019," American Journal of Public Health 112, no. 1 (Dec. 2021): 88-97, doi:
10.2105/AJ PH. 2021.306561.
42. Lauren Zeise and Jared Blumenfeld, CalEnviroScreen 4.0, Oct. 2021,
https://oehha.ca.gov/media/downloads/calenviroscreen/report/calenviroscreen40reportf2021.pdf/.
43. The survey is available at https://www.survevmonkev.eom/r/ceist-survev.
-------
9
currently available in Spanish, CEQ needs to do more to enhance the
accessibility of the tool for other non-English speakers.
We welcome an opportunity to discuss our recommendations with you, CEQ
staff members, and members of the White House Environmental Justice
Interagency Council.
Sincerely,
cc: Members of the WHEJAC
Michael S. Regan, EPA Administrator
Jalonne White Newsome, Senior Director for Environmental Justice, CEQ
White House Environmental Justice Interagency Council
Victoria Robinson, Designated Federal Officer
Richard Moore, WHEJAC Co-chair
Peggy M. Shepard, WHEJAC Co-chair
------- |