National Environment Justice Advisory Council (NEJAC) Virtual Public Meeting January 5 2022


U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA)
NATIONAL ENVIRONMENT JUSTICE ADVISORY COUNCIL (NE JAC)

VIRTUAL PUBLIC MEETING

JANUARY 5, 2022

1

-------
TABLE OF CONTENTS

NEJAC PUBLIC MEETING AGENDA 1/5/2022	6

NEJAC 1/5/2022 - PUBLIC MEETING AGENDA SLIDES 	8

PREFACE	9

MEETING SUMMARY	10

WELCOME, INTRODUCTIONS & OPENING REMARKS	10

WELCOME, EPA UPDATES & DIALOGUE	12

EPA SENIOR LEADERSHIP UPDATES	28

NEJAC STRATEGIC PLAN SUMMARY FEEDBACK 	35

NEJAC FORMAL RESPONSE AND DELIBERATION ON DRAFT FY 2022-2026
EPA STRATEGIC PLAN PRESENTATION (THIS IS A FOLLOW-UP FROM THE
NOVEMBER 10, 2021 NEJAC PUBLIC MEETING.)	35

PUBLIC COMMENT PERIOD	56

NEJAC WRITTEN PUBLIC COMMENTS SUBMITTED FOR 1.5.2022 MEETING.. 88

NEJAC ADDITIONAL WRITTEN PUBLIC COMMENTS CONT	101

CLOSING REMARKS & ADJOURN	102

NEJAC MEMBER LIST	103

2

-------
ATTENDEES LIST

SPI.AKLRS AM) FACILITATORS



FRED JENKINS, JR., PhD

DESIGNATED FEDERAL OFFICER (DFO)
ENVIRONMENTAL PROTECTION AGENCY
(EPA)

MATTHEW TEJADA, PhD

DIRECTOR, U.S. EPA OFFICE OF
ENVIRONMENTAL JUSTICE

MICHAEL REGAN

ADMINISTRATOR, ENVIRONMENTAL
PROTECTION AGENCY (EPA)

ALISON CASS AD Y

DEPUTY CHIEF OF STAFF,
ENVIRONMENTAL PROTECTION AGENCY
(EPA)

NATIONAL r.NMUONMr.N 1 AL.Il SI l( I.
ADVISORY COLNCII. (NLJAC) MIMIil.R
(HAIRS



SYLVIA ORDUNO

MICHIGAN WELFARE RIGHTS
ORGANIZATION

NEJAC MEMBER CHAIR - EPA REGION 5

NA'TAKI OSBORNE JELKS, PhD

WEST ATLANTA WATERSHED
ALLIANCE/PROCTOR CREEK
BOARD CHAIRPERSON
NEJAC MEMBER VICE-CHAIR
EPA REGION 4

MICHAEL TILCHIN

JACOBS ENGINEERING

NEJAC MEMBER VICE-CHAIR - EPA

REGION 3

ACADIMIA (jROl'P



JILL LINDSEY HARRISON, PhD

UNIVERSITY OF COLORADO BOULDER
NEJAC MEMBER - EPA REGION 8

APRIL KAREN BAPTISTE, PhD

COLGATE UNIVERSITY
NEJAC MEMBER - EPA REGION 2

SANDRA WHITEHEAD, Ph.D., M P. A.

GEORGE WASHINGTON UNIVERSITY
NEJAC MEMBER - EPA REGION 3

JAN FRITZ, PhD, C.C.S.

UNIVERSITY OF CINCINNATI
NEJAC MEMBER - EPA REGION 5

BENJAMIN J. PAULI, PhD

KETTERING UNIVERSITY
NEJAC MEMBER - EPA REGION 5

in sim:ss& industry croi p



3

-------
VENU GHANTA

DUKE ENERGY

NEJAC MEMBER - EPA REGION 3

VIRGINIA M. KING

MARATHON PETROLEUM
NEJAC MEMBER - EPA REGION 6

CO.M.Ml NITY BASKI) ORGANIZATIONS
GUOl P



REV. DR. AMBROSE CARROLL, SR.

GREEN THE CHURCH

NEJAC MEMBER - EPA REGION 9

LETICIA COLON DE MEJIAS

GREEN ECO WARRIORS
NEJAC MEMBER - EPA REGION 1

JEROME SHABAZZ

JASTECH DEVELOPMENT SERVICES INC.
AND OVERBROOK ENVIRONMENTAL
EDUCATION CENTER
NEJAC MEMBER - EPA REGION 3

CEMELLI DE AZTLAN

LA MUTER OBRERA

NEJAC MEMBER - EPA REGION 6

SOFIA OWEN

ALTERNATIVES FOR COMMUNITY &

ENVIRONMENT (ACE)

NEJAC MEMBER - EPA REGION 1

NOM.OVI.UNM KM A1 VKNYI UONM KM A1,
CUOl P



ANDY KRICUN

US WATER ALLIANCE
NEJAC MEMBER - EPA REGION 2

AYAKO NAGANO, JD

COMMON VISION

NEJAC MEMBER - EPA REGION 9

JEREMY F. ORR, JD

EARTH JU S TICE

NEJAC MEMBER - EPA REGION 5

JACQUELINE SHIRLEY

RURAL COMMUNITY ASSISTANCE
CORPORATION

NEJAC MEMBER - EPA REGION 6

BRENDA TORRES BARRETO

SAN JUAN BAY ESTUARY PROGRAM
NEJAC MEMBER - EPA REGION 2

TU1 HAL/lM) 1 (iKMOI S (iO V KKMM K.MS
andorganizations (;k«i p



JONATHAN PERRY

BECENTI CHAPTER, NAVAJO NATION
NEJAC MEMBER - EPA REGION 6

JOY BRITT

ALASKA NATIVE TRIBAL HEALTH
CONSORTIUM

NEJAC MEMBER - EPA REGION 10

SCOTT CLOW

UTE MOUNTAIN UTE TRIBE
NEJAC MEMBER - REGION 8

4

-------
ST.VITVLOCAI, (iOYKUN.MKNT (iKOl'P



FELICIA BELTRAN

ARIZONA DEPARTMENT OF

TRANSPORTATION

NEJAC MEMBER - EPA REGION 9

MILLICENT PIAZZA

WASHINGTON STATE DEPARTMENT OF
ECOLOGY

NEJAC MEMBER - EPA REGION 10

5

-------
NEJAC PUBLIC MEETING AGENDA 1/5/2022

FINAL AGENDA
UNITED STATES ENVIRONMENTAL PROTECTION
AGENCY

NATIONAL ENVIRONMENTAL JUSTICE
ADVISORY COUNCIL
FULLY VIRTUAL PUBLIC MEETING
January 5, 2022
1:00 P.M. - 5:30 P.M. EDT
Meeting Public Docket:
EPA-HQ-QA-2021 -0848
NEJAC Meeting Website:
https://www.epa, gov/envtronmentaliustice/n
ational-environmental-justice-advisory-
council-meetings

WEDNESDAY January 5, 2021

1:0Q pm -1:15 pirn

WELCOME INTRODUCTIONS, & OPENING REMARKS



o Fred Jenkins Jr., PhD. Designated Federal Officer -



U.S. EPA



o Matthew Tejada, PhD, Director, Office of



Environmental Justice - U.S. EPA



c Sylvia Ordufio, National Environmental Justice



Advisory Council Chair - Michigan Welfare Rights



Organization



o Na Taki Osbome J elks. PhD. National Environmental



Justice Advisory Council Vice Chair - West Atlanta



Watershed Alliance and Proctor Creek Stewardship



Council



o Michael Tilchin, National Environmental Justice



Advisory Council Vice Chair - Jacobs Engineering

1:15 pm - 2:00 pm

WELCOME EPA UPDATES, I DIALOGUE



o Michael Regan, Administrator - U.S EPA



/

J

-------
2:00 pm - 2:1 :• - 'oO pm

CLOSING REMARKS & ADJOURN

c- Sylvia Ordufio, National Environmental Met
Advisory Council Chair - Michigan Welfare Rights
Organization

o Fred Jenkins Jr., PhD, Designafed Federal Officer	

U.S. EPA.

Note; Please t>e advised Itiai agendo times are approximate: when the
discuss ton for one topic is completed, discussions for the next topic will begin,
For wither Information, please contact the Designated Federal Officer for this
meeifm Fred Jenkins Jr., PhD, of jenkircs.fred@epa.gov.

7

-------
NEJAC 1/5/2022 - PUBLIC MEETING AGENDA SLIDES

All EPA presentation materials for this meeting are available in the public docket of this
meeting. The public docket number for this meeting is EPA-HQ-OA-2021-0848. The public
docket is accessible via www.regulations.gov under its docket number, EPA-HQ-OA-2021-
0848.

8

-------
PREFACE

The National Environmental Justice Advisory Council (NEJAC) is a federal advisory committee
that was established by charter on September 30, 1993, to provide independent advice,
consultation, and recommendations to the Administrator of the U.S. Environmental Protection
Agency (EPA) on matters related to environmental justice.

As a federal advisory committee, the NEJAC is governed by the Federal Advisory Committee
Act (FACA) enacted on October 6, 1972. FACA provisions include the following requirements:

•	Members must be selected and appointed by EPA.

•	Members must attend and participate fully in meetings.

•	Meetings must be open to the public, except as specified by the EPA Administrator.

•	All meetings must be announced in the Federal Register.

•	Public participation must be allowed at all public meetings.

•	The public must be provided access to materials distributed during the meeting.

•	Meeting minutes must be kept and made available to the public.

•	A designated federal official (DFO) must be present at all meetings.

•	The advisory committee must provide independent judgment that is not influenced by
special interest groups.

EPA's Office of Environmental Justice (OEJ) maintains summary reports of all NEJAC
meetings, which are available on the NEJAC website at

httns://wn'n'.epa.L>ov/environmentaliustke/national-environmental-iustice-a(h'isorv- council-
meetings. All meeting materials are posted in the public docket for this meeting. The public
docket number for this meeting is EPA-HQ-OA-2021-0848. The public docket is accessible via
www.regulations.gov under its docket number, EPA-HQ-OA-2021-0848.

9

-------
NATIONAL ENVIRONMENTAL JUSTICE ADVISORY COUNCIL
VIRTUAL PUBLIC MEETING
JANUARY 5, 2022

MEETING SUMMARY

The National Environmental Justice Advisory Council convened via Zoom meeting on
Wednesday, January 5, 2022. This summary covers NEJAC members' deliberations during the
meeting and the discussions during the public comment period.

WELCOME, INTRODUCTIONS & OPENING REMARKS

Dr. Fred Jenkins, Designated Federal Officer (DFO), U.S. Environmental Protection Agency
(EPA), welcomed everyone to the meeting and introduced himself and his role in the NEJAC.
He explained the administrative details of the meeting. He invited the NEJAC leadership to give
their opening remarks.

Dr. Matthew Tejada, Director, U.S. EPA Office of Environmental Justice, thanked everyone
for joining the meeting. He hoped everyone had an enjoyable and relaxing holiday. He explained
that the EPA was very busy throughout the holidays given the unprecedented level of
opportunity and commitments and demands that were before them. The same went for the
members of the NEJAC both professionally and in their capacity as NEJAC members. A lot of
folks spent a lot of time over December getting ready for this meeting because there is a lot of
work to do. There is a lot of opportunities to help change the way the EPA and the federal
government operate and govern, to be more equitable and to be more just. So that is part of the
reason why there is such an early meeting, to make sure that the NEJAC can speak and give
them the advice and recommendations promptly so that they can be as influential and as
impactful as possible.

Ms. Sylvia Orduno, NEJAC Chair, introduced herself and explained that NEJAC has been
working over the holidays, but it was good work. She said she's excited to have the portion of the
meeting today where the Strategic Plan Workgroup will bring forward considerations to the full

-------
Council. She explained that the NEJAC planned for an early meeting to be ready for a running
start and make sure that the Council's feedback would be included in the strategic plan for the
next few years.

She stated that the NEJAC is excited to have the administrator at the meeting. It's been several
months since he's attended, but he has kept his commitment to making sure that the heads of this
administration would be regularly participating at the Council meetings here-

Dr. Na'Taki Osborne Jelks, NEJAC Vice-Chair, introduced herself. She stated that she's
excited about the dialogue happening and shared thoughts about the work that has been done in
the Agency. She thanked the Strategic Plan Workgroup for their hard work over several weeks to
dive into the strategic plan and to make a set of recommendations that will be shared.

Mr. Michael Tilchin, NEJAC Vice-Chair, introduced himself. He also thanked the public
commenters and reassured them that their input is truly what drives NEJAC's business. NEJAC
genuinely appreciates this opportunity to comment on EPA's strategic plan. This has been a
whole-of-NEJAC effort, to review and comment on the plan. He stated that NEJAC appreciates
Administrator Regan's presence. They note that he has followed up on the very important and
promising words and speeches that were given related to environmental justice when he first
came into office with action. That is extremely gratifying. He turned the meeting back to the
Chair.

Ms. Sylvia Orduno, NEJAC Chair, invited the rest of the NEJAC to introduce themselves.
Afterward, she invited Dr. Matthew Tejada to speak.

Dr. Matthew Tejada, Director, EOJ, gave some updates that can be expected from NEJAC in
the coming year, including a tentative meeting schedule for the remainder of the year. He then
introduced Administrator Regan.

-------
WELCOME, EPA UPDATES & DIALOGUE

Administrator Regan, EPA: Thank you and thank you for your leadership, Matt. It's great to
be here with you, and it's great to be here with everybody today. Happy new year to everybody.
It was important to meet with you at the start of the year, so I appreciate the invitation to join you
today. I'd also like to thank Deputy Administrator McCabe and so many of my leadership team
for speaking to NEJAC on my behalf while I was traveling during the last NEJAC meeting. I'd
also like to thank each and every one of you for your service. I recognize that you serve on this
committee in a voluntary capacity and that you have other pressing professional and personal
commitments. We are deeply grateful for your dedication, your leadership, and most importantly
your honesty as you engage with the EPA. You've never let up when it comes to fighting for
equity and justice. I can promise you that neither will I and neither will this EPA. As I told my
team last month, we're going to keep the pedal to the metal in 2022. People have been suffering
for a long time, and they're counting on all of us to get this right. So we have a responsibility to
get this right, and that means we have to get moving right out of the gate. I believe we laid a
strong foundation in 2021, and I'm proud of the progress that we're making, especially given how
much agency rebuilding we needed to do.

Shortly after I was sworn in last year, I directed my leadership team to embed environmental
justice into every aspect of our work, from our regulatory work to our permitting to our
enforcement activities. I asked my team to go further and faster than we've ever gone before,
which I recognize is immensely challenging in a government bureaucracy. Faster isn't typically
in the federal government's vocabulary. Then again, I felt like EPA wasn't starting from scratch.
We had the incredible benefit of building on nearly 30 years of EJ engagement,
recommendations, and guidance from NEJAC. As Matt mentioned earlier, now we also have the
political will. President Biden made it clear from day one that advancing racial justice and equity
requires a whole-of-government approach. EPA in many ways is at the heart of the president's
mission. You have my word that there is no higher priority for me than ensuring that all people
in this country have clean air to breathe, clean water to drink, and the opportunity to live a
healthy life. Our work to advance equity and justice will continue to be a central driver in every

-------
single thing we do at EPA.

That's why this past November we launched the Journey to Justice tour because we knew that
rebuilding trust is essential to this Agency making progress. Rebuilding trust requires that we
actually show up, see up close the injustices that people have endured for generations, hear
directly from the frontline communities, and then commit to working together with a sense of
urgency to fix these historic wrongs. I had the privilege of meeting with historically marginalized
communities in Jackson, Mississippi; in Mossville, New Orleans; St. James Parish and St. John
the Baptist Parish, Louisiana; as well as Houston, Texas. Every single stop along this journey
was driven by the community. We specifically relied on local communities to set the agenda, to
invite all the participants, and determine the focus of our time together. Let me tell you, that
made all the difference. Being on the ground, seeing it for myself, talking with community
members, I learned a great deal from these communities. And I committed to continuing to do
better, to leverage our enforcement, to work with Congress to get the toughest laws in place so
that we are adequate and protected and doing so in concert with community members who've
been fighting for their health and safety for decades.

There is a sense of urgency around a solution for how we move forward. So my team here at
headquarters and across Regions 4 and 6 specifically, as it relates to the Journey to Justice tour,
have remained in touch with the community leaders in the weeks after the tour to ensure that the
challenges they raised are being addressed either through our efforts directly or those of our
partners at the state and local levels. In the next few weeks, we will roll out a specific list of
actions that EPA will be taking in direct response to what I saw and heard on the ground. 2021
was a critical year because it set the tone and laid the groundwork for where EPA is headed in
the future. As you know, last year, thanks to the Biden Administration's leadership, we received
$100 million in ARP funding. We started putting $50 million towards projects that support the
priority needs of overburdened communities. In December, we launched a $20 million grant
program from our Air Office to fund air quality monitoring projects in communities all across
the United States.

One of the consistent things I heard while on the Gulf Coast was the need for more monitoring at

-------
all levels for all sorts of different pollutants, and that's why we've already allocated funding
through the ARP Rescue Plan for this need, to make sure that more official monitors provide
transparent, real-time information and actually put resources directly into the hands of
communities and their partners to do the monitoring alongside the EPA. It's also important to
note that in 2021 we pushed out more funding through our EJ Grants Program in one year than
EPA was able to make possible over the entire previous decade, over the past 10 years. I see
these grants as incubators for community-driven solutions, solutions that we must lift up and
replicate as we look to vastly larger resources in the bipartisan infrastructure law and other future
spending bills. Shortly before the holiday break, we made a couple of important announcements
that have significant environmental justice implications. We know that more than one in four
black and Hispanic Americans live within three miles of a superfund site, and thousands of these
contaminated sites exist nationally.

Thanks to the infrastructure law, the EPA is investing $1 billion to initiate cleanup and clear the
backlog of 49 previously unfunded superfund sites. We're also going to accelerate cleanup at
dozens of other sites all across the country. And listen to this; sixty percent of the sites receiving
funding for the new cleanup projects are in historically underserved communities. I want to
thank you for the years of guidance you provided to our Office of Land and Emergency
Management. It allowed for Assistant Administrator Waterhouse and his program to get a
jumpstart on issuing a thoughtful EJ plan, and it's helped to inform how we're approaching our
larger agency-wide plan and efforts as well. Earlier today, OLEM released its draft EJ action
plan, which follows through on both the ongoing work with the NEJAC and agency-wide efforts
to strengthen compliance, embed environmental justice considerations throughout EPA's
activities, and improve community engagement. It's my hope that the action plan will enable
stronger and faster progress in addressing contaminated land all across the country. Last month, I
also had the privilege of joining Vice President Harris to roll out the administration's actions on
lead and drinking water. The president and the vice president have made replacing lead pipes a
central part of the bipartisan infrastructure law.

At the event, EPA announced three things in particular. Number one, water utilities will be
required to develop Lead Service Line Inventories because, to remove lead pipes from the

-------
ground, we have to know exactly where they are. Two, EPA will develop a new proposed rule
that will strengthen the lead and copper rule. Three, we also announced $2.9 billion in bipartisan
infrastructure law funding for states, tribes, and territories to remove lead service lines. This
allocation is the first of five annual allotments that will provide $15 billion in dedicated funding
for lead service line replacements. We're going to work very closely with other federal partners,
state coregulators, and communities to identify their needs and provide them with critical
resources, including the creation of technical assistance hubs in regions with large concentrations
of lead service lines. Another priority area is ethylene oxide. I've spoken to community members,
and I've heard their concerns directly. As I reported in my response to NEJAC's 100 Day Letter
in the fall, EPA has committed to a timeline for new rule makings for several critical source
categories, and we're working to get those done as quickly as possible.

In that letter, I also told you about plans with ethylene oxide and the toxics release inventory.

Just last month, we expanded the scope of TRI reporting requirements to included certain
facilities that are not currently reporting on EtO releases. Companies that use the largest amounts
of EtO in this industry sector will be required to publicly report their releases of this chemical
and shed light on potential exposures from this use. This will also help EPA inform future
actions and empower communities to act at the local level as well. It's an important part of our
ongoing efforts to increase publicly available information on EtO releases and other waste
management activities. Listen, I recognize that impacts to the communities continue to happen
while organizations like ours are developing effective strategies and making the necessary
organizational changes to protect our people, so we also made it clear that this EPA will not
hesitate to use its authority to hold polluters accountable.

In the U.S. Virgin Islands, I ordered Limetree Bay refinery to cease its operations due to repeated
incidences that polluted the air and sickened members of the community. In South Carolina, we
issued an emergency order requiring the New-Indy paper mill to monitor and reduce hydrogen
sulfide air pollution from its facility. Just last week, we reached a million-dollar settlement that
ensures surrounding communities will be protected from the unlawful pollution from this facility
through mandatory long-term improvements. In Chicago, we voiced our concerns about a
proposal for a car shredding operation on the southeast side. Mayor Lightfoot promptly

-------
suspended the city's permit until a thorough environmental justice analysis is to be completed.

On the personnel side, I'm happy to report that we now have regional administrators in eight of
the ten regions. Their leadership is going to be critical to advancing our mission on
environmental justice, from building collaborative relationships with communities to engaging
our tribal partners in a nation-to-nation capacity to working closely with states and other levels
of government. We've selected proven regional administrators that have strong EJ track records,
like Earthea Nance in Region 6, Lisa Garcia in Region 2, Daniel Blackman in Region 4, among
others who are very accomplished as well. I know that NEJAC is already planning its 2022
meetings, and I'm hopeful that you will have plenty of time to engage with these new regional
leaders in addition to your ongoing engagement with those of us at headquarters.

What's next for 2022, you might ask. Well, we recognize that we're just getting started, and we
have a long way to go, especially when it comes to carrying out the work of our Justice40
initiatives. So far, the majority of the resources EPA has received through the infrastructure law
will go towards programs that were already a part of the White House-led Justice40 pilot. Our
goal is not only to meet but to exceed where needed the goal of the 40 percent of benefits
flowing to disadvantaged communities. As I already mentioned, our superfund program is
spending 60 percent of their new infrastructure dollars in these communities because that's where
the need is. It's also a great pace setter for our other programs at EPA and other federal agencies
as well.

I want to be clear. Having served as a state secretary for environmental quality in North Carolina,
I realized that deciding where the money goes in a state isn't always easy and is definitely not
driven in isolation by the federal government. So I'm committed to working closely with our
state regulatory partners and governors across the country on both sides of the aisle to ensure that
our resources find their way to those communities that urgently need them. That's why, in
December, I sent a letter to every governor of every state sharing detailed information about our
goals for using the water infrastructure money provided through the infrastructure bill.

I also committed to issuing guidance in the coming months that will have a greater level of detail

-------
to help ensure that these historic resources reach our most vulnerable communities. We're going
to have to rely on our governors, our state regulators, and our mayors, and I plan to continue to
partner with them as well. This is what I consider to be Justice40 in action. We're working in real
time, pulling together all of the streams from the executive orders, the American Rescue Plan
funds, and the infrastructure law to provide an example of the commitment to advancing equity
and justice right now at this moment by this Agency, but we're still listening. That listening, that
won't stop. We've held multiple national engagement calls to solicit more focused feedback
about how to implement Justice40 across a wide range of EPA programs, and specifically about
the six EPA programs that are part of the pilot Justice40 program. We'll continue to host these
opportunities and more to listen in 2022.

We also have ideas on how to calculate the benefits of EPA's Justice40 program, including
percent reduction of children's asthma-related hospital visits, tons of different pollutants reduced,
reductions in hospital visits and missed days of work or school, a number of health assessments
completed, and increased access to health providers, job trainings provided, technical assistance
given to tribal drinking water systems, and tracking the numbers of deaths prevented. While we
still have a lot of work to do to figure out which of these measures will work and which will be
most meaningful to hold us accountable to all the communities we serve, we continue to want to
get that input from you all. This is another example of where you all come in. This is another
example of where NEJAC comes in to help us figure these questions out as we continue to push
the implementation of Justice40. While measuring the benefits is important, I've heard loud and
clear that we also need to know where the actual dollars go. This is another commitment that I
will make to you. EPA will lead from the front to provide a transparent and meaningful way to
see where the actual funds wind up.

Again, another area where we're counting on NEJAC's support and guidance to ensure that we
get it right. Getting this right, we all know, isn't going to be easy. We know it's going to take
time. For many of you in NEJAC and many of you in the EJ movement, Justice40 has been a
long fight for promise and is a huge chance to change the way the government operates. I, too,
share those ambitions, and I hope for Justice40's promise, and I'm committed to pushing
Justice40 the way the President envisions. It's really great that leadership is coming from the

-------
president on down. You will see that our engagement with NEJAC over the past year on broader
topics, such as our draft strategic plan, has helped to inform the priorities and alignment of
actions that were taken in our draft equity action plan. This includes the alignment of the plan
with elements of the draft multi-year strategic plan and with the implementation of Justice40.
We've got a lot of plans, a lot of strategies, and Justice40 lining up. We want to be sure that it's
blending together very well. I look forward to hearing more of your feedback on the draft
strategic plan and its implementation.

We're in the final stages of crafting that plan, and your feedback and deliberations have already
made a difference, especially in terms of wanting to see decisive action and clear progress being
made before the year 2026.1 wholeheartedly agree with this idea, and we're working to make the
necessary changes. I also want to emphasize just how important and unprecedented it is that we
have placed equity and justice at the heart of EPA's strategic plan. The commitments we make
will drive action. It will drive accountability, and it will drive resources for years to come. But I
want to be clear that we're not waiting for these plans to drive our actions. I hope that some of
the examples I just shared with you clearly demonstrate that I mean business and that we mean
business about taking action right now and not missing the tremendous opportunity already in
hand to advance equity and justice across the United States. Over the coming months, when you
see the final strategic plan, when you see the equity action plan, our implementation of Justice40
and the infrastructure resources, EPA's first-ever National Program Guidance for Environmental
Justice and External Civil Rights Compliance and actions on our priority issues, you will clearly
see your fingerprints all across the board.

So in closing, I do want to remind you all that everything we do, everything I do, at EPA, will be
rooted in the realities and the demands and the aspirations of the communities disproportionately
impacted by environmental and public health threats. This engagement is a crucial part of how
we approach and think about these issues. It's also a powerful form of accountability to hold EPA
responsible for getting it right. I know that you all have an extensive agenda today, and I want to
leave some time for questions. So I'll end there. Thank you all, again, for having me. Thank you
all for your time, your energy, and your efforts. Thank you all for the advice and
recommendations that you provide because they are essential, and I and my team greatly

-------
appreciate them. Thank you all.

Ms. Sylvia Orduno, NEJAC Chair: Thank you so much, Administrator Regan. It is always a
pleasure to hear from you. You're very inspirational. We need that, too, these days when there is
so much difficulty in the world. We can't tell you enough how much your leadership, what you're
bringing to this Council, and the genuine seeking of our advice really matters. We believe that,
and we appreciate it. This meeting today was special because we wanted to make sure that we
had the time to get in adequate feedback about the strategic plan. We have been doing our due
diligence to make sure that we are going to provide that to you in a timely way.

One of the things that I'm sure that you probably already heard, too, when we had a more in-
depth discussion about Goal 2 during the November meeting was that, even beyond the long-
term planning goals and the strategies that have already been noted, we're very much interested
and concerned about the implementation. So what you're speaking there, too, about making sure
that we've got alignment with Justice40, is also something that we were looking to see in this
plan and are providing some feedback around. I think that you can anticipate our anxiousness
about really wanting to see how this will play out because it is important in the details
themselves.

As we've heard extensively from Director Attorney Dorka about the External Civil Rights
Compliance, we're excited about that too because, unfortunately, it does take the law to come in
sometimes and make these things enforceable. We know that there are a lot of violations across
our communities, unfortunately, that we want to see addressed. We're excited to see the
additional resources and intentionality around addressing those issues as well.

I want to also thank you so much for the detailed feedback that you gave us in the 100 Day
Letter. It's very useful for us, and our workgroups are continuing to go through them and see how
it is that we can better understand not only what is going on in your administration, but how it is
that we can be more reflexive even in our feedback back to the different programs and offices.
Thank you very much, again, for all of what you're offering and for the tour that you led and,
again, the members of your administration being willing to accept the critical feedback that we

-------
offer to make your tour even more successful based on some of the experiences in other places
and states before you get the tour underway. Thank you for that.

As you might recall, our last meeting in November we had several new members of the Council
join. I was thinking that maybe what we can do is start off any kind of questions that you folks
might have by beginning with our newer members of the Council and then opening it up to our
veteran members. So any new members of the Council have any kind of questions or comments
they want to offer to the administrator while we have him here for a couple more minutes?

Mr. Jonathan Perry, NEJAC Member: Thank you. I appreciate the time as well as the
discussion and report given today by our administrator. I appreciate it. I'm speaking from
northwestern New Mexico, Region 6, out of the Navajo Nation. One thing that I wanted to
maybe bring up or question is in regard to the regulations about in-situ leach [ISL] mining with
uranium extraction, if there are any efforts to address regulations, maybe updating regulations, or
an approach to bring further stability in terms of holding companies accountable in our local
communities. Again, thank you. That's my question.

Administrator Regan, U.S. EPA: Jonathan, thank you for that question. Yes, we are taking a
very close look at it. I think you may have seen that I was privileged to visit Navajo Nation last
year and spend some time with leadership there. We specifically focused on the abandoned
uranium mines and the obligation that this administration has to put some resources to look at
cleaning up there. Also, as a responsible partner with our sister agencies, as we look at mining
currently and moving forward, we apply some environmental rigor to how these operations move
forward and what those operations mean to our communities, many of our communities, black,
brown, and tribal communities. Yes, this is a priority of ours. It's a priority of this administration.
I think we have a combination of actions that we're perusing both at EPA and across the
administration to address the mining issues.

Mr. Andy Kricun, NEJAC Member: Thank so much, Administrator Regan, for your leadership
and to EPA for all that you're doing to protect the environment and especially to protect
underserved communities and disproportionately burdened communities. So appreciative and

-------
honored to be able to serve on the NEJAC. My comment only is that it's so wonderful to see the
additional infrastructure funding that is becoming available already, and hopefully, more will
come if there's some sort of reconciliation bill coming out of Congress this year. I see that, for
underserved communities, as like a buried treasure, but sometimes they lack the shovels to get
the funding. Sometimes because of lack of resources, underserved communities don't always
have the same opportunity to get the funding that more resourced and larger cities may have, or
better-funded cities may have. I'm wondering if there's a plan to try to assist EJ communities
with getting at least their fair share, if not more so, of this new infrastructure so they can close
the gap and ensure safe drinking water and clean water ways for themselves and their
community.

Administrator Regan, U.S. EPA: Thank you, Andy, for that question. Yes, we've given that a
lot of thought. We try to apply that level of thinking as we distributed the American Rescue Plan
dollars, both on the grant side for communities but also when we look at air quality monitoring.
When you look at the bipartisan infrastructure law and you look at the billions of dollars that will
go for water infrastructure, a lot of those resources are zero-interest or low-interest loans or
grants. That really is unprecedented because it gives certain communities opportunities to apply
for resources without having to have matching dollars. That opens up a different pool of folks
that are qualified for these resources. Then, in those resources, our Office of Water, being led by
Assistant Administration Radhika Fox, has been really thoughtful about how we also carve out
resources to provide technical assistance to these communities that are on the ground. We have
these grants and these low-interest to no-interest loans available, which increases the pool.

We've improved our ability to provide technical assistance with some of these resources as well.
Then, what I learned during the Journey to Justice tour and what I've been doing over the past
year is really developing a stronger relationship with our historically black colleges and
universities, our minority-serving institutions, and also with mayors on the ground. If we can
leverage these relationships with mayors on the ground who, quite frankly, have not been as
successful competing with these dollars, matching that with some of these NGOs that are the
ground, the technical assistance that we can provide, and again these grant dollars or low-interest
loans that are part of the bipartisan infrastructure law, I believe that we'll have a larger pool of

-------
applicants who will be really, really, really competitive for these resources. I think that's a game
changer, quite frankly.

Mr. Andy Kricun, NEJAC Member: Thank you so much, Administrator. That's so great to hear
because providing our communities with the shovels to get the buried treasure that can turn
things around will really be a game changer. Thank you so much for your thoughtful efforts.

Dr. Jill Lindsey Harrison, NEJAC Member: Great. Thank you so much, and thank you,
Administrator Regan, for being here. It's great to have this opportunity to talk with you and hear
about all of the wonderful work that the administration has been doing and that the Agency has
been doing. I just wanted to pass along a quick comment to you. My own research on
government agencies and environmental justice reform efforts over the past ten years has shown
that there has been some considerable unevenness within any given agency in terms of staff
members' support for environmental justice reforms to the ways that everyday decisions are
made in terms of permitting and rulemaking and enforcement. I guess a couple of things to say
about that are, one, as part of this broader effort that you're committed to around environmental
justice, I hope that it also includes some hard-hitting assessments of how well different offices
within the Agency have done in terms of environmental justice and to really honestly reflect on
how agencies have met their broader commitments in general and to EJ in particular and also to
hold offices and management at all different levels accountable for their responsibilities to
environmental justice.

Then, finally, in addition to rolling out these dollars for really important projects, also to fulfill
the commitment that's been made, that Janet McCabe mentioned in her previous visit to us, to
change the ways the decisions are made regularly in terms of permitting and rulemaking and
enforcement so that the agencies work broadly. Even in times when we don't have these big
influxes of funding for special projects, the Agency's decision-making can better support
environmental justice daily. Again, thank you very much. I appreciate your time and your
interest.

Administrator Regan, U.S. EPA: I appreciate that statement. I can say that, when I look across

-------
the administration, especially at the other cabinet agencies, I feel so fortunate because, number
one, we've got a dedicated workforce, folks like Matt who you all are so familiar with, who are
so passionate about not only holding our external partners accountable but holding all of us
accountable. I'm grateful to Matt, to Phil Fine, and to Vicki Arroyo, and all of those folks in OEJ
and OP because they are really providing some excellent leadership. I'm also fortunate because,
when I span out and look at all of our national program offices, whether it's Radhika Fox in OW
or Carlton Waterhouse in OLEM, we've got some leaders there who are just relentless and who
are really focused on ensuring that this is pushed down programmatically. When you add the
president's overlay of these strategic plans and the building in of Justice40,1 guess this is a long
way of me saying that many of us want to do this work, and we know the structural changes
required to get it done in an expedited way. But there are a lot of pressures that are driving all of
us to do it in a structurally sound way that doesn't let anybody off the hook.

We're trying to build in all of that as we move forward. I think with the guidance and support
from you all, I believe that this is a moment in time where we will be able to do this and do it in
a really impactful way. We're mindful that everyone won't get it at the same time, with the same
level of intensity. We're going to keep pushing, but we're also going to build a system that keeps
that pressure on all of us. I hope to soon announce a senior advisor to me on environmental
justice and equity. We are hopeful that, right now, our budget is held up in Congress with the
Build Back Better plan. Once we get our budget, there will be the ability to begin to build a
national program office dedicated to environmental justice and equity, which that advisor would
be very competitive to lead that office. That would be at a Senate-confirmed level to, again, add
even more accountability to all of these things that were started. I'm mindful that, yes, we want
to do all these things, but there's a point in time when many of us may not be in these seats. We
need to have the infrastructure in place so that this carries on long after each one of us serves.

Ms. Sofia Owen, NEJAC Member: Thank you, Administration Regan, for making time for us.
Dr. Jill made several of my points, so I'll try to be brief. I want to echo the need for greater
training and systems change in terms of how permitting and other decisions are made. Those
have equity and EJ implication, of course, as we all know. It's wonderful the amount of money
that is coming to communities, and I appreciate that that is unprecedented. I also want to make

-------
sure that, with that money, there is going to be a focus on guidance on Title VI and how to
ensure that accountability and transparency are built into those programs, as well, so that the
recipients of that money are going to be able to be held accountable to the community. Then, the
last thing that I'll say is that I acknowledge that the focus on equity and EJ for EPA and the
strategic plan is unprecedented. But as someone who represents a black-lead, black-staffed
community organization, our folks have been waiting for these changes to be made for 20, 50,
100 years. The moment is really now to make sure that we dig in and make these changes.

Thank you.

Administrator Regan, U.S. EPA: Thank you. Listen, I think that it's fair to say that we share
that sense of urgency on Title VI and civil rights. I think, in addition to ensuring that the funds
are distributed equitably, there are numerous commitments that we laid out in Goal 2 of our
strategic plan, and we've already started taking specific steps to strengthen civil rights
compliance and enforcement as well. Your point is well taken. What I'd like to say,
unfortunately, is we didn't get into this situation overnight, and we won't get out overnight. But
what you have from the president on down are individuals that are committed to getting things
right. We want to work as expeditiously as possible. We will continue to rely on all of you to
hold us accountable and to provide us feedback and guidance. Again, I'm optimistic that we can
right some of these wrongs sooner rather than later.

Dr. Na'Taki Osborne Jelks, NEJAC Vice-Chair: Thank you, Sylvia. Thank you so much,
Administration Regan, for your time and for, really, everything that you've shared. I'm very
encouraged by several things that you mentioned today in terms of the amazing work that is
happening at the Agency, from the work on expanding the scope of TRI reporting requirements
to the investments being made in the replacement of lead service lines to investments being made
in EJ communities through the superfund spending, et cetera. A few times in what you've shared
today, you talked about greater accountability. You also talked about getting eight of the ten
regional administrators onboard. That seems something that's really key to some of the
accountability that is needed in communities. In just a short time today, we're going to open up
the public comment period. Every time we have a NEJAC meeting, there are people representing
communities across this country who are coming to the NEJAC expressing concerns, in some

-------
cases feeling like they have issues and challenges that EPA has some purview over, but that
action hasn't necessarily been taken.

You mentioned, in terms of your Journey to Justice tour, that you're going to be responding, in a
very prompt manner it seems, to the many communities that you visited this summer. What I'm
wondering is if you could share a little bit about what in terms of, perhaps, your management
approach and how you have onboarded these new regional administrators to also think about
greater accountability to communities as they express their environmental justice concerns.

Time after time, we're hearing the same types of comments that seem to have lasted for an
extended period of time, often without clear responses, actionable responses, to those
communities. I think, in terms of EPA's reputation, everything that you've mentioned today is
wonderful in terms of the investments. The expansion of the EJ grants program is critical. But
the trust that you build in these communities is going to be tied to that responsiveness. Again,
just to shorten it, if you can talk a little bit about the strategies that you all are putting in place to
make sure that, from the regional level, there's more responsiveness to communities and their
concerns on the ground, I'd greatly appreciate it.

Administrator Regan, U.S. EPA: Yeah, and thank you for that question. When I spent time
interviewing all of our regional administrators in partnership with the White House,
environmental justice and equity were a key part of the interview conversation. Since these
individuals have been onboarded, we've spent a lot of time talking about how they plan to
execute our EJ initiatives in partnership with our headquarters office. They're developing plans.
The good news is that, while we were waiting to bring these RAs on board, we were already
building inventories of things that needed to be done or paid attention to. So that was part of their
initial briefings. The Journey to Justice tour is an example of if we have had RAs on board —
which we didn't, but we had strong VRAs on board. As I did these tours and as we engaged with
these communities in what I would call a historic manner, not only did we have the things that
we were aware of but we learned about things that we were unaware of.

It allowed for us to begin to engage the community in a way where we think about how we
prioritize solving some of these issues because, number one, we don't have an unlimited number

-------
of resources or an unlimited amount of people. But we can begin to agree on what needs to be
tackled first and what is most important. Those are the types of things that these new RAs are
armed with now. When you have in an individual like Earthea Nance who has been spending a
lot of time with people like Dr. Beverly Wright and Dr. Bob Bullard and thought very carefully
about how to approach these issues, they are now leading regional offices, and they have staff
that they can begin to push and prod and begin to tackle some of these issues. Many of these
folks have only been on the job two to three weeks.

I'm confident that, once they get their sea legs under them and as they continue to push our
agenda, we will see a level of partnership between our regional offices and headquarter offices
that we've never seen before. Couple that with the guidance that the president has given all of us,
I think it will just be a matter of how quickly we can tackle some of these complex issues and
how much can we all push the envelope together. I don't believe it will be a lack of will. I can
say that firmly from, again, Matt and his leadership and those here in headquarters all the way to
our regional offices. The political will is finally there. Now we just have to begin to roll up our
sleeves and do the work.

Ms. Felicia Beltran, NEJAC Member: Hello, Administration Regan. I'm Felicia Beltran serving
out of Region 9, representing state and local government. I wanted to thank you for the recap on
what the Agency has been up to and where it's headed to address equity. I want to make a
statement that hearing you say, "People have been suffering for a long time," was a strong and
reflective statement of really what's historically been happening to underserved communities
from the actions of governments and/or industries. I really appreciated that statement being said.
I also want to state that it's very exciting to hear the efforts of the external civil rights compliance
efforts because there is a lot of weight around Title VI and the Civil Rights Act of 1964.1
appreciate seeing this external enforcement effort as a priority from the administration. I always
say that agencies don't have to take federal funds, but if they do, there's going to be some strings
attached, and recipients are going to be held accountable to comply with civil rights laws. Again,
thank you.

Administrator Regan, U.S. EPA: Thank you. I'll say EJ's external civil rights program really

-------
shifted from being primarily reactive, responding only to complaints, to proactively initiating
compliance activities. We're also initiating proactive pre-award and post-award civil rights
compliance activities, including launching the first affirmative compliance reviews to address the
impacts of potentially discriminatory activities on overburdened communities soon. This year,
we will issue clear and strong civil rights policy guidance, and we'll deliver training and
technical assistance to increase the recipients' compliance with civil rights laws, including those
on adverse or disparate impacts. We've also committed to conducting timely and effective civil
rights complaint investigations and resolutions, including investigations and informal resolution
agreements that effectively address adverse, disparate, and cumulative impacts. We've already
begun enhancing our communication and engagement with these overburdened communities to
meaningfully inform EPA's civil rights work and to empower and increase their partnership, the
communities' partnerships, and participation with critical decision-making.

We launched our first-ever public listening session on external civil rights priorities this past
October. I'm excited about, again, what this team is doing. Listen, I'm delighted that I have such
a strong team. All of the things that we're talking about today and the things that we've done in
the past year, it really is because there are leaders at EPA, again, from myself all the way down
who have really shifted resources, begun to reorganize, began to outline strategic plans, and have
really put some actions in place that, quite frankly, are very impressive for a bureaucracy of this
size to be done in the amount of time that we've done it in. I'm really excited about 2022. I'm
excited about our partnerships. Again, I know we have a lot of work to do, but I believe that, if
we stay focused, we will get a lot done over this next year, especially with your guidance and
your suggestions.

Ms. Sylvia Orduno, NEJAC Chair: That is terrific. Thank you for also staying on here for a few
extra minutes with us. I know that we've got a couple other members who have questions, but I'm
going to ask if maybe they could just send them directly to you. We'll definitely capture it, too,
in our notes. Again, in this special meeting that we're having, especially to provide the feedback
from the strategic plan, one of the things I think, in case it wasn't already highlighted, was that
we're very much appreciative of what has been outlined in Goal 2. But the Council didn't believe
that the other areas of the report had enough emphasis on environmental justice issues, which is

-------
why we've also made the additional effort to provide more feedback throughout the report. We're
hoping that you'll take note of that when you do receive it and know that that was also part of our
purpose in the review. Thank you, again, so very much, Mr. Administrator. We're delighted to
have you here.

Administrator Regan, U.S. EPA: Thank you all. Again, thank you all for the hard work and
for all the guidance. We greatly appreciate it.

Dr. Matthew Tejada, Director, EOJ: Thank you all so much. Thank you, Administrator Regan,
so much for spending the time. I've been getting a lot of responses while you've been speaking,
how blown away a lot of folks are with the commitment of this administration and your
leadership. From my perspective of being here almost ten years as a career person, this is the
work and the opportunity I came to EPA for. You are making that possible for us. We are
absolutely waking up every morning to live up to your mandate and the possibility that you are
making possible through your leadership. Thank you, Administrator.

Administrator Regan, U.S. EPA: Thank you, Matthew, for your leadership and your
partnership.

EPA SENIOR LEADERSHIP UPDATES

Dr. Matthew Tejada, Director, EOJ, stated that behind the scenes, Alison Cassady has actually
been doing so much of the EJ leadership work for us at EPA, and she will speak soon. He
mentioned that several times in some of the previous NEJAC meetings and the administrator also
mentioned trying to bring together so many of these things happening — the strategic plan, the
National Program Guidance, Justice40, the infrastructure bill, the American Rescue Plan.

There's one that we have typically thrown in the mix every single time not just in NEJAC, just
more broadly, not that there's none, but there's just not as much focus on as so many of these
other initiatives. Maybe it's because it uses the work "equity" instead of "justice." Of the
executive orders the president signed on his first day in office, they didn't include Justice40.
Justice40 was signed on his seventh day in office if my counting is correct. On his first day of

-------
office, he signed Executive Order 13985 on advancing racial equity. That is one that was
implemented immediately back in February.

The leadership for that executive order is not coming from the Council on Environmental
Quality, CEQ, which is running Justice40 and so many other parts of what we're doing on EJ and
this administration. Executive Order 13985 on racial equity is being run out of the Domestic
Policy Council under the leadership of Ambassador Susan Rice. Again, they've been grinding
away on that since February. One of the things that are coming up is an Agency equity action
plan. That is something that they've engaged quietly in. Some of the things that they presented
and wanted to get feedback on back in the November meeting, they do so purposefully because
we knew we had this other action plan that we were tying into these things. They've been quietly
looking at a whole other effort going on as they're getting in more general feedback on strategic
planning and other things.

He invited Ms. Alison Cassady to give a little bit more insight in terms of where they are at and
where they're going to go, which will include more outright engagement with NEJAC in the
coming months around what they're doing with that Agency equity action plan.

Ms. Alison Cassady, Deputy Chief of Staff for Office of Policy, U.S. EPA: I'm Alison Cassady.
I'm the Deputy Chief of Staff. Thank you for letting me talk for a few minutes. I'll try to keep it
short so that you guys can move on. I really want to hear more about the strategic plan and your
comments on it. I thank you and reiterate the administrator's thanks for your engagement on that.
Strategic plans aren't necessarily always the sexiest thing, but it is really important because we
want to make Goal Two the top of the pyramid for the Agency's EJ and civil rights enforcement
work. Because you guys have spent so much time commenting on it and the public has
commented on it, we really want EPA's work to flow from it. That's where the equity action plan
comes in. We've been working on it quietly. One of the reasons is that your feedback on the
strategic plan is directly informing what we're doing on the equity action plan. We have been
trying to kill two birds with one stone here, first of all, out of respect for everybody's time
because we really want these two documents to be intertwined.

-------
As Matthew mentioned, the EO 13985 directed all agencies, including EPA, to plan to ensure
underserved communities benefit from EPA's programs, policies, and processes. That executive
order is much broader than environmental justice. It's talking about a whole range of underserved
communities from LGBTQ communities to rural communities. We focused on environmental
justice as really the crux of what we're doing in this equity action plan that we have to submit
because we want to use it as a starting point for actually implementing the strategic plan even
before it's finalized. We want to tie our commitment to implementing the executive order to our
commitment to implementing the strategic plan. We hope that this will provide multiple lines of
accountability to you as well as to the Office of Management and Budget and others within the
office of the president. It's a series of self-reinforcing accountability mechanisms in many ways.
I heard a lot in the questions you asked the administrator about, obviously, the importance of
implementation and the importance of accountability.

For the equity action plan, we're committing to several priority actions with clear metrics to
actually get started on implementing Strategic Plan Goal 2 now and chipping away at some of
the long-term performance goals in the strategic plan. I'll give you a couple of examples. First of
all, we're committing to developing a consistent and comprehensive framework for considering
cumulative impacts on populations and communities in our decision-making. That's a really
important part of implementing Goal 2 well. We're also committing to build the capacity of
communities to engage with EPA so that we can learn from you and manage community-led
projects to reduce pollution and improve outcomes on the ground. What do I mean by that? For
example, we're going to commit to provide more capacity-building grants and technical
assistance, funding. We need the funding. Hopefully, with no appropriations, we're going to
provide more capacity to build grants, more technical assistance to more communities. We also
want to provide more tailored grants training to underserved and under-resourced communities. I
can't remember if it was Andy who said, "This money is like buried treasure."

We want to provide more shovels, make sure that people have the right kind of shovels, and
understand what kind of shovels to use, to really help communities apply for these grant
opportunities. We're committing to ensure that all public meetings, stakeholder meetings,
external-facing materials provide crucial information in a nontechnical, actionable manner and

-------
really are more accessible for communities with disabilities, with limited English proficiency, et
cetera. In addition to trying to build external capacity in communities with EJ concerns, we are
committing to building EPA's internal capacity both to meaningfully engage these communities
in a way that is culturally sensitive and truly meaningful, but we also want to ensure that our
internal processes and way of doing business is set up in a way that we can actually take the
information we learn, apply it, and build it and take action on it. This requires changing the
regular course of doing business at EPA and building accountability, and it's about a systems
change. I think somebody said that earlier in the Q&A with the administrator. One thing, for
example, we're committing to do is requiring EPA's programs and regions to develop national
program guidance and implementation plans for achieving the objective of Goal 2 in the strategic
plan.

To be clear, that's not to be siloed. This is going to be across the Agency, not just an EJ program,
but across all our programs. Second, we're going to commit to integrating equity, environmental
justice, and civil rights benchmarks into our annual performance plans and reviews for the
relevant EPA staff. Again, this is about accountability, personal accountability as well as
programmatic accountability. Finally, we want to try to find a way to do ongoing assessments to
learn whether our programs really are delivering for our communities in the way that we hope
they are or think they are. I think Dr. Harrison raised this. These equity assessments or these EJ
assessments can be expensive. They can be time consuming, but we want to find a way to do
them right and do them strategically so that we know — this is the objective we want to achieve;
are we actually achieving it? In addition to the things I just mentioned, we are committing to
other priority actions on Title VI enforcement, being more proactive. We need more funding for
this, but there's a lot that we can do right now. We are committing to improving our procurement
processes and contracting processes to make sure we are reaching businesses in underserved
communities. We want to improve EPA's ability to integrate community science into our
decision-making, whether it's permitting, rulemaking, our research agenda, et cetera.

Again, all of your comments on the strategic plan are directly informing this equity action plan.
They really are related. We are trying to achieve our strategic plan objectives with this plan. It's
going to lay out clear next steps to make achieving Goal 2 and the strategic plan or hopefully

-------
make some progress on it as soon as possible. We look forward to continuing the conversation
with NEJAC and other EJ leaders as we finalize the strategic plan. I look forward to reading the
comments that I just received in my email. We really want to work with you to identify and
improve any implementations steps that we need to take to make Goal 2 a reality.

One last thing I wanted to say before I stop talking is I wanted to let you guys know about a
brand-new announcement, a brand-new thing that we did yesterday from the Office of Air. Just
yesterday, EPA took final action to find that 12 states and local air pollution control agencies
failed to submit state implementation plan revisions required by the Clean Air Act in order to
address excess emissions during periods of startup, shutdown, and malfunction of their facilities.
Obviously, these facilities are located in communities with EJ concerns, and these startups and
shutdowns could have significant EJ impacts. EPA's action triggers certain Clean Air Act
deadlines so EPA can impose sanctions when the state does not submit an adequate plan, or we
can impose a federal plan. This announcement affects Rhode Island, D.C., Alabama, certain
counties in North Carolina, Illinois, Ohio, Arkansas, South Dakota, San Joaquin Valley in
California, and Washington state. That's something new that happened yesterday that I thought
you all might be interested in, so I wanted to make sure you knew about it. With that, Matthew,
I'll turn it back to you.

Dr. Matthew Tejada, Director, OEJ: Thank you so much. I don't have anything to add except,
again, the first few months in this administration, I was like, whoa. All these things going on.
How are we going to do all these things? How are we going to tie them all together? It is
absolutely a huge credit to folks like Alison, who don't often get to spend a lot of time with you
all, doing a ton of work very quietly but very aggressively within the four walls of the
government, making these things actually happen and bringing them together and working in a
way that I've never experienced, again, in my ten years of government, of really engaging me,
engaging colleagues such as Lilian Dorka, who you see on the screen, engaging our staffs, really
listening and working hand in hand with trying to do this the right way and bring these things
home and bring them together so that they're meaningful; they're accountable; they're
transparent; they're responsive to what we hear from the NEJAC, from what the NEJAC hears
from members of the public. Huge credit to Alison and a lot of her colleagues that have come in

-------
in this administration for really making this happen. I think we have just a couple minutes
maybe, Sylvia, if anybody has any questions about this or questions for me or Alison before we
hand it back over to you all to get on with the business of the meeting.

Ms. Sylvia Orduno, NEJAC Chair: Thank you very much for that, Matt and Alison. It was a
pleasure to hear what you reported there. Maybe one thing that I'll offer towards this is that, yes,
very much measures matter. What EJ communities really need are those outcomes. I'm sure
you're regularly hearing it. Yes, we don't want to continue to be studied and researched. We want
to see the deliverables. You can keep that in mind too. I think that that's also what we try to hit at
in some of the strategic plan feedback. I'm glad that you'll be drawing from that document, as
well, as you're developing the equity action plan.

Ms. Alison Cassady, Deputy Chief, OP: Yeah, no problem. One thing I should note is that, in
terms of building accountability mechanisms, one thing we're trying to figure out is what are
those outcomes that we can start to measure. Some of them don't appear overnight, obviously,
like reducing blood lead levels. That's an outcome that we want to achieve that we need to figure
out what is the baseline we're starting from. How do we measure our progress? How do we hold
ourselves accountable for that? In addition, have we had five meetings or done these widgets?
Because I understand what you're saying. There's always that challenge of figuring out, what is
the right outcome to measure, and can we actually measure it in a short enough period of time to
figure out if we're actually making that progress even though it might take ten years? I look
forward to your comments because that definitely will inform how we can think about that better.
Thank you.

Mr. Andy Kricun, NEJAC Member: Thanks, Sylvia. One quick question or thought is that,
having worked in the public water sector for many years, one of the really helpful things was that
the public sector is really able and wants to share our best practices and knowledge. If a
McDonald's does something, they wouldn't let Burger King know necessarily, but the public
sector's glad to share information. So we often, in the drinking and wastewater side, would have
a compendium of best practices so that, if one utility had a good idea, others could learn from it
and replicate or adapt it. I'm wondering if the same kind of approach might work with the 50

33

-------
state departments of environmental protection, the 50 state EPAs, or even the 10 regional EPA
offices, to try to see if there are certain things that one regional office is doing, one innovation, or
one of the 50 states is doing that the other 49 could benefit or the other 9 regional offices to try to
bring about and gather all these best practices and successful ways of implementing
environmental justice, whether it be enforcement of odors or permitting or assistance to EJ
communities and see what those best practices are that some of the regional offices and state
offices have been able to come up with and then share them so that other states and other regions
could benefit as well. Thank you.

Ms. Sofia Owen, NEJAC Member: I am wondering if it is possible to have the information that,
Alison, you presented to us be shared in a written form, whether it's a presentation or a one
pager, so that we can share that back with our community members and constituents.

Ms. Alison Cassady, Deputy Chief, OP: We can work on pulling something together. Yeah.

Ms. Sofia Owen, NEJAC member: Thank you.

Ms. Sylvia Orduno, NEJAC Chair: That'd be terrific. Thank you, because I'm sure that this is
going to be on the mind of this Council for this year, at least. There's a lot that's related to equity
and I think ties in with Justice40. We'll be looking for it. Thank you for that.

Ms. Alison Cassady, Deputy Chief, OP: Yeah. We're trying to make it all, actually, sing
together. It's a little bit of a challenge.

Ms. Sylvia Orduno, NEJAC Chair: Loud like a beautiful choir. Thank you.

Ms. Alison Cassady, Deputy Chief, OP: Some of us are out of tune. Some of us you don't want
to hear sing. But we're working on it.

Ms. Sylvia Orduno, NEJAC Chair: We look forward to it. Thanks so much. Well, if there's
nothing else, Council, then we'll go into our next item. Appreciate very much that report from

-------
Matt and Alison.

NEJAC STRATEGIC PLAN SUMMARY FEEDBACK -

All materials presented at this meeting including the NEJAC's Strategic Plan Summary feedback
document are available in the public docket of this meeting. The public docket number for this
meeting is EPA-HQ-OA-2021-0848. The public docket is accessible via www.regulations.gov
under its docket number, EPA-HQ-OA-2021-0848.

NEJAC FORMAL RESPONSE AND DELIBERATION ON DRAFT FY 2022-2026
EPA STRATEGIC PLAN PRESENTATION (THIS IS A FOLLOW-UP FROM THE
NOVEMBER 10, 2021 NEJAC PUBLIC MEETING.)

Ms. Sylvia Orduno, NEJAC Chair, stated that this is the heart of the meeting. She stated that
Michael Tilchin made a document tying together the recommendations from the Strategic Plan
Workgroup, who met four times over November and December, and the feedback from the
public commenters. The Council will go through each goal and make suggestions for additions,
deletions, and changes. This document will eventually go to the Office of Environmental Justice,
not the administrator yet. (This document is currently available in the public docket for this
meeting at www.regulations.gov under its docket number, EPA-HQ-OA-2021-0848). Only the
Strategic Plan Group will report out at this meeting; the other workgroups will report out at
another meeting. She stated that the conclusion of the final document will also conclude the work
of this workgroup, which was a short-term workgroup. It can be decided later if there's a need to
pick up any part of what this work was. She thanked Michael and the workgroup for their hard
work.

Mr. Michael Tilchin, NEJAC Vice-Chair, thanked the group for their hard work. This is a work
in progress, certainly, in terms of clarity and spelling and punctuation. He reminded the Council
not to worry so much about the small mistakes; just focus on the big items. He reiterated that this
strategic plan is about establishing Agency-wide priorities and setting a direction for EPA and all
the national programs. It absolutely addresses long-term performance goals and the other more

35

-------
immediate performance goals that are highlighted in the strategic plan. It does not get into
implementation issues, which is not the purpose of the strategic plan. But the NEJAC knows that
those are the next steps, the downstream products that are developed from the strategic plan,
where plans get developed, and those plans and action plans are implemented. It does talk about
the vision for those actions that are needed. That's intentional, and hopefully, it is taken in the
spirit with which it is offered, to help the Agency do better with respect to serving overburdened
and underserved communities.

Ms. Sylvia Orduno, NEJAC Chair, reminded everyone that Aya Nagano is taking notes to
capture the additional feedback or edits to this document. She'll be the Council note taker on this
because the official notes from this meeting won't be received in time. She invited anyone else
who wants to help to contact Aya because those are the notes they'll be drawing from. She
reminded the Council that there are about eight or nine minutes allocated per goal. Some goals
will take longer, maybe 12 minutes. Others are shorter, maybe six minutes.

Mr. Michael Tilchin, NEJAC Vice-Chair, explained that the names written in the document
were the source of the comments. He asked that those persons named essentially address what's
on the page, clarify things if they're not written correctly, and potentially expand if there are any
revisions.

Mr. Andy Kricun, NEJAC Member, thanked Michael for pulling all of it together. He explained
that EJ communities are disproportionately burdened and vulnerable to issues of climate change.
As listed in the document, the first one would be requiring better enforcement of the existing
nine minimum controls for combined sewer systems, which are often in older EJ communities,
and making sure that these communities aren't impacted with combined sewage flooding, which
obviously is a public health issue, or combined sewer overflows, which results in contamination
of waterways. EPA needs to take the lead with the states and the regions to make sure that these
existing regulations are more rigorously enforced in EJ communities.

The Administrator alluded to comment number two. Additional funding should be pushed
toward combined sewer systems because there are two sides of the environmental injustice coin

-------
associated with the combined sewer systems, one being that they result in combined sewage
flooding and combined sewage overflow. Also, they're very expensive to fix.

There's a community in New Jersey, for example, the city of Perth Amboy, in which it's
supposed to take 40 years to fix their system to make it affordable. Yet, their rates will still go up
by a factor of four. They'll quadruple. The only thing that can break that is they either have to
deal with impaired waterways and combined sewage for a longer period of time or have their
rates go up even higher. The only thing that helps would be external funding and assistance.

Also, good begets good is comment number three. When green infrastructure is put in place to
capture stormwater and bring back a less impervious surface and more balance to a city and an
urban area, then this green infrastructure has to be maintained. It's an opportunity for green jobs
in EJ communities, like the Civilian Climate Corps idea that's now in the Building Back Better
plan. Some of that should be supported. Like a toolbox, you don't want to have eight hammers.
You need a hammer, pliers, a screwdriver, et cetera.

Comment four is that, in addition to additional funding and additional enforcement, also to give
some of our EJ communities some guidance, maybe some templates, for environmental justice
ordinances that would help to protect against cumulative impacts or stormwater ordinances so
that our EJ communities don't have to develop these ideas in 1,000 or 10,000 different siloes.
There could be templates, so they get them along the way more quickly, so it'll be easier for them
to implement such ordinances that are more protective.

Similarly on comment five, another thing that is a challenge, especially in the northeast or the
eastern half of the country, is flooding. I know that water scarcity is more of a problem on the
western side. On the eastern side, though, and in all parts of the country where there are more
storms, there are vulnerabilities to power outages. There are power outages on either side of the
eastern-western continental divide. Maybe provide some more guidance and also funding on
how to implement green energy initiatives so that safe drinking water and clean waterways can
be preserved even if there are power outages, getting our water utilities off the grid, for example.

Similarly, in comment six, we deal with the river level rise, which is another serious problem in

-------
areas where flooding is more of an issue. Then, lastly, on the drought side, to help address
drought and low-flow conditions as well. The thing is that — and the administrator really
addressed this earlier — often in the past, EPA and the states have been reacting to problems. But
it would be great to see them also, especially in environmental justice communities, acting as a
proactive champion in the environment and providing additional resources and funding and also
bringing partners in, like nonprofits, community groups, that would assist the EPA and the states
in bringing more resources and knowledge to the EJ communities.

Mr. Michael Tilchin, NEJAC Vice-Chair stated that the next set of comments is related to that
connection that Andy just made. Many of them focused on the connection between resilience.
These next comments address issues related to, specifically, a focus on energy and energy
education. Several people had comments along these lines.

Ms. Leticia Colon de Mejias, NEJAC Member stated that these comments are related to
feedback that was heard from communities and also witnessed. It's very difficult for people to be
engaged in a conversation or directing or having any agency in decision-making or accessing
opportunities if they're unaware of the issues or causes of those problems or potential resources
that are available or how to apply. It's very important to understand that there's been systemic
racism throughout history. Therefore, certain communities have had no access or little access to
information regarding energy impacts, climate change, and the implications on their health or
their economic development in their communities, nor are they prepared to make the necessary
changes to become resilient based on the climate science that's available at the EPA and the
DOE.

So this suggests that, for those communities to be appropriately engaged, they would need to
have access to that information. That wasn't in the plan, and so it's remiss to imagine that
someone would know how to address something if they didn't know the problem exists or the
causes of the problem. Likewise, this then rolls into the idea that equitable electrification would
also require that same shift, that overburdened communities may not be aware of the
implications of the choices that are made by government agencies. Thus, it would be critical to
ensure that they understand the ways. Some of those ways are more protective to underserved

-------
and vulnerable communities. Therefore, this plan must note that intentionally and that it be a
specific goal in the plan.

Ms. Sofia Owen, NEJAC Member, noted that in that first objective there's no reference to
environmental justice or equity, which is a problem. Place-based emissions reductions are critical
in terms of addressing the climate crisis for EJ populations and other frontline communities,
especially where they're relying on market-based solutions like the regional greenhouse gas
initiative in the northeast. We haven't seen place-based emissions reductions at the same rates in
both the northeast and in California where we have solutions like that. She just wanted to
highlight that EPA needs to ensure that those reductions are being made.

Ms. Leticia Colon de Mejias, NEJAC Member, followed up on Sofia's comment. It's often
remiss in many of the discussions about climate change that the largest emitter is electric
demands, generation of electricity. It's important to understand that that is both at the generation
site but also at homes and buildings across America. So it's critical to understand that, to reduce
that, several acts have to happen. The first one is that people need to be educated. There has to be
retrofitting of all of the homes and buildings across our nation. Then there are entire
communities that have no access to any type of renewable resource because they're often, again,
in underrepresented communities, renters, and can't even adopt some of the opportunities that
exist today. There needs to be a direct environmental justice focus and a civil rights focus on the
importance of access to clean energy and demand reductions services, which have additional
benefits beyond climate because they also impact air, water, food, and resilience in general, as
well as career opportunities.

The other thing that is important in environmental justice concerning climate resilience is that,
again, in underserved and under-represented communities, we find a very high rate of barriers to
even accepting retrofitting of homes. So these are nob and tube, asbestos vermiculite, lead, mold,
and heating failures which would exempt their homes, either single-family or multiple-family,
from becoming resilient and energy-efficient or from connecting to resources like solar. Again,
there's an issue with flood resilience because many of these communities that are low-income
and communities of color are in low-lying communities, and they're not in the areas in the

-------
FEMA maps that were originally put out for flooding. There has unfortunately been, even in just
this past year, flooding that has occurred in unexpected places. Because basements are where we
house our heating, cooling, and hot water equipment, it leaves them without access to heating
and hot water, making it an unsafe living condition.

There's been increased mold all across the nation, again, in unexpected areas. So they're not often
in the plans or looked at as places to provide support. This is going to be along the rivers, along
the wetlands. Then, the other thing is that, again, it's very important to ensure that, when they're
talking about water, they educate people on ways to avoid getting toxins. Water is going to rise,
and so the toxins are going to be closer to those low-lying communities. Then, the last one is
about information and resources, ensuring that they provide people information to take action in
more than one location: at home, at work, at school, in their community. Making them heroes
versus victims will help move people to the frontlines to play a role in decision-making and have
agency in protecting the things that they love, like their family homes and places they live.

Mr. Michael Tilchin, NEJAC Vice-Chair, stated that next are the long-term performance goals.

Ms. Sofia Owen, NEJAC Member, stated that, unless these broader goals commit to reducing
emission in EJ and frontline communities, they run the risk of overall reductions, which is a good
thing, without ensuring that the most burdened folks are actually seeing the benefit of cleaner air.
Concerning the reference to Executive Order 13990, there should be a priority for holding state
and partner agencies accountable, tracking and measuring enforcement performance, and
intervention when states are not taking action or responding to community concerns. For electric
vehicles, the analysis of benefits should consider the full spectrum of electric vehicles, not only
individually owned cars but public transit and fleets. If at all possible, programs directed at
reducing emissions from wood-burning appliances should reach beyond the residential context,
and the generation of energy from biomass should not be considered a renewable energy source
or subsidized.

Mr. Michael Tilchin, NEJAC Vice-Chair, moved on to Objective 1.2, accelerate resilience and
adaptation to climate change impacts. He read a comment from John Doyle, who was not able to

-------
join the meeting. John noted that the critical role that the tribal colleges play in researching tribal
lands is at the core of being able to address issues. He cited some very specific and somewhat
unique things that are happening in often very rural tribal lands. Those institutions, those
academic institutions, on tribal lands really play a vital role in protecting the community through
the research they perform, and that is something that ought to be highlighted as a priority for the
Agency in this area of technical assistance.

This is an issue that they have talked about in numerous contexts over multiple NEJAC public
meetings, and that is the establishment of regional EJACs. Picking up on what the administrator
said in the Journey to Justice, it's important to have access to decision-makers through NEJAC.
They do serve an important conduit, but the conduit is too narrow. The establishment of regional
EJACs is going to essentially create the circumstances for the kind of communications between
communications and the regions that are really critical to achieving the goals of environmental
justice. That's what this is about. They also addressed this issue in a previous report that came
out in 2018 on youth perspectives related to climate change.

Ms. Sylvia Orduno, NEJAC Chair, explained that there was a report that was done in July of
2018 by youth from across the country that had been invited to respond to a charge about youth
perspectives on climate change and how to best engage youth. There were several
recommendations that they had in there, specifically around engagement and how it could be
done better paying attention to generational issues and so on. She extracted from that report some
things here that are relevant to strategic planning. A lot of it, again, is about when they're looking
at how to implement programs and how to seek participation in them. There were some specifics
there that they can all do better by way of ensuring that youth are not only informed but that
there is respectful space for them to participate. This also means making sure that there are
adequate resources that are also employed for that kind of participation.

Mr. Michael Tilchin, NEJAC Vice-Chair, invited the Council to make comments on Goal 1.

Dr. Sandra Whitehead, NEJAC Member, asked a specific question going back to 1.6. Is there a
reason that river level rise was focused on and not intermittent flooding or sea-level rise?

-------
Mr. Andy Kricun, NEJAC Member, stated that he meant all three were important. He didn't
mean to cite just one area.

Dr. Sandra Whitehead, NEJAC Member, wanted to be clear that all three need to be included
so all communities are covered.

Ms. Ayako Nagano, NEJAC Member, didn't know if this was the place to state her concerns or
not. She got an email from Fred Jenkins late last year that the EPA's Office of Land and
Emergency Management and the Office of Resource Conservation and Recovery recently
focused on a recycling strategy for a circular economy. The goals were to increase recycling to
50 percent. Truthfully, the strategy should be to eliminate the creation of things that are not part
of the circular economy. They need to stop the production of these pollutants at the source. Why
focus on recycling when they need to stop production? There's no discussion about curbing the
production of new disposable plastic products. It increases the use of fossil fuels and it's
growing.

From source to production to its afterlife, disposable plastic is a pollutant that the United States
produces in large amounts. It's an injustice of grand proportions that those who profit from the
creation and sale of these unrecyclable substances market them with a greenwashed lie that it is
somehow okay to pollute the earth and its inhabitants in this way continually. It's only getting
worse. The production of disposable plastics is on an upward trajectory. The problem is not
whether we are recycling better or not. She doesn't see the EPA pushing against the production.
They really need to be focusing on the production, to stop it. We just don't need these poisons
any further. Maybe objective 1.4 is to curb the production of disposable plastics somewhere in
this plan because there's no end in sight right now. There's a new facility being planned. It
needs to stop, and somebody needs to put their foot down.

Ms. Sylvia Orduno, NEJAC Chair, suggested that as a new recommendation and asked Aya to
add it to the notes.

-------
Mr. Michael Tilchin, NEJAC Vice-Chair, stated that it is relevant to Goal 6.

Ms. Jacqueline Shirley, NEJAC Member, had a clarification about the biomass comment. It's
on number 11 where it says, "As part of that, current practices for generating energy from
biomass should not be considered a renewable resource and should not be subsidized." That
seems pretty broad because are you trying to talk about logging. There is a benefit as a fuel
reduction because of the drought. A lot of biomass programs are going into these overgrown,
dried-out forests and using those biomass products as energy and also at the same time reducing
their fuel reduction program. She didn't understand that whole thing because it seems like they're
saying biomass is something that shouldn't be considered a renewable energy source and
shouldn't be subsidized when there are so many aspects to biomass. She said she was having
trouble with this sentence.

Mr. Michael Tilchin, NEJAC Vice-Chair, stated that he's not an expert in this, but his initial
reaction to this is there are clearly going to be regional, geographic, biogeographic differences.
A blanket statement like this that seems to be applied to the country as a whole probably needs to
be reworded to reflect those details. Because the Council doesn't have time to dive deep into
biomass at that moment, it will address that issue in the coming days to make sure it's straight in
what ultimately gets submitted at the end of the week.

Ms. Sylvia Orduno, NEJAC Chair, reminded the Council that the meeting needs to stay on track
for time.

Mr. Michael Tilchin, NEJAC Vice-Chair, suggested that the member identified on the
document comments focus on areas where the words are simply misdirected or there's a key
point that hasn't been made. He acknowledged that it's challenging given the timeframe, but
that's what they'll need to do to speed up the process.

Dr. Na'Taki Osborne Jelks, NEJAC Vice-Chair, wanted to underscore another comment that
was made earlier about singling out rivers. They also have to consider creeks and streams that

-------
flood communities out as well. She wanted to make that distinction in terms of looking at
waterways and not just focusing on rivers. Then, to the recommendation that was focused on
providing some guidance on adopting stormwater fees, that could be applied to large owners of
impervious surfaces, et cetera. There must be guidance that is provided that can help
municipalities who are perhaps looking to adopt a stormwater utility and making sure that there
are models that they can look at in terms of equity for low- to moderate-income homeowners
who might be impacted by such a policy. Just wanted to add that, that there are models out there
and that that guidance should also be shared.

Dr. April Karen Baptiste, NEJAC Member stated that one of the things that she would like to
see strengthened in the strategic plan is perhaps encouraging the EPA to either list or prioritize
those areas that are most vulnerable to climate change. For example, on page three, there is a
mention of low-lying areas or areas located around rivers. We know that everyone is going to be
impacted by climate change, but some areas are going to be much more vulnerable than others.
For example, our small and developing states that are part of the United States are prone to
typhoons in the Pacific as well as hurricanes in the Atlantic. How is the EPA going to list and
prioritize those areas that are the most vulnerable of the vulnerable? Then, not only prioritizing
those but then developing a clear plan for adaptation, resilience, capacity building, and
addressing those that already can address climate change?

Ms. Leticia Colon de Mejias, NEJAC Member, suggested that, on biomass, there are types of
biomasses that are actually made from byproducts of other products. There's also hemp biomass.
It actually absorbs carbon while growing. She understands the need to be focused on the
particulates released when burning biomass, but some climates are going to need backup heat
because they just don't currently, and won't for a while, have resources to do it otherwise.
Additionally, some of them have benefits while growing. That's something to be investigated.
For low-lying areas, it's very important to make sure that we focus on all low-lying areas,
wetlands, streams, rivers, creeks, and flooding in those areas.

Later on in the document, there's talk about benefits, how to delineate environmental justice and
ensure that it's equity-based when you're planning for infrastructure changes. That would be, like

-------
April was saying, looking at which communities currently are going to be most hard hit,
understanding that those communities need resources first. The other thing, which is really
important and isn't in here, is ensuring that resources go to areas that already are not resourced.
She reiterated what April just said because that is historically how it happens; people who have
resources leverage those resources to get more resources. Thus, those without stay without. If
there's any way to get that into this document, it would be very important.

Ms. Sofia Owen, NEJAC Member, hoped that, as a group, it can be narrowed appropriately to
focus on the technologies and situations that may be beneficial and flag those that are not. She
noted that one theme that came up repeatedly is there are a lot of references to EPA working to
have programs in place to ensure that state agencies are fully compliant with their obligations
under environmental law and Title VI. She knows that this is meant to be high-level, but she did
question how and whether that goal is achievable given that they hear over and over again from
community members that their state agencies right now are not in compliance and are not
receptive to their needs. She hopes that there will be more specificity regarding how and what
those plans will look like and more emphasis on enforcement.

Mr. Scott Clow, NEJAC Member, stated that his comment was regarding nuclear power and the
front end and the tail end of that energy production. There are a lot of people in this world that
think that nuclear is a great solution to climate change and energy production, and it's certainly a
tool in the toolbox. What they've seen, like his colleague from Navajo pointed out earlier
regarding ISL uranium production, is that, on the front end, a lot of rural, especially native
American, communities out west have been impacted by uranium poison. We're also poised to
receive the high-level nuclear waste at the tail-end of the cycle. The middle part's great, but the
front and the tail end are very poisonous and hazardous and create environmental justice issues.

Mr. Michael Tilchin, NEJAC Vice-Chair, went on to Goal 2.

Ms. Sylvia Orduno, NEJAC Chair, stated that for the sake of time, they should just highlight
anything new.

45

-------
Ms. Jacqueline Shirley, NEJAC Member, stated that NEJAC and EPA spent considerable time
back in 2014 with the charge on the EPA policy for environmental justice working with federally
recognized tribes and Indigenous peoples. She suggested that they should use language that's
already in place instead of having to reinvent the wheel on specific language. It should say
Indigenous people because Indigenous people are very broad for our country, for state-
recognized tribes, non-recognized tribes, our Hawaiian brothers and sisters, and even other
migrants, other Indigenous peoples from other countries who live in EJ communities. The
working group addressed those. Those Indigenous peoples even from other countries who live in,
predominantly, our U.S. EJ communities are also recognized.

Ms. Sylvia Orduno, NEJAC Chair, noted a couple of other things. On page seven of this
document, one of the things in that second bullet was related to investment in EJ organizations.
Again, they've talked about this several times, about the need for additional resources at the
regional level. They've heard repeatedly from staff that there is not enough staff and that those
that are EJ coordinators are oftentimes really stretched out. She wanted there also to be real
specific intentionality and resources devoted to making it so that the regions can have the
resources that they need to be effective because it only frustrates the effort when they're talking
about how it is that the regions engage with state and local groups.

Objective 2.2 about embedding environmental justice and civil rights, they had a considerable
conversation about that and appreciate what Matt and Ms. Dorka shared last time in how to
enforce civil rights in EJ communities.

Mr. Jonathan Perry, NEJAC Member, commented on that section. It would be really beneficial
if we look at EPA having reference to maybe internal training on how to coordinate and work
with different tribes and different Indigenous people. There's a great need for that within our area
here in the Navajo Nation. The reason is that you get different regions, like Region 9 or Region
6, working with the Navajo Nation. The other approach is that the influence of jurisdiction, like
different land status that we encounter, there's a need of training between the EPA staff and how
they can coordinate and work with the different tribes.

-------
Ms. Millicent Piazza, NEJAC Member, clarified that back on page five; the second and third are
from the NEPA workgroup.

Dr. April Karen Baptiste, NEJAC Member, commented on the second point. I would like to
see the EPA do an audit on all the cases that have been brought to them already and what has
been accomplished, as that's been something that has been brought up constantly. What has been
accomplished so that they can see that? That should fall under Goal 2, perhaps developing a clear
protocol for how cases will be addressed when they are brought to the EPA and making that
transparent. They may need to have new staff or a new office. If there is one, maybe that office
needs more resources. Then, finally, there needs to be a clear sense of any outstanding or
pending Title VI claims that are pending to determine what speedy action is going to be taken.

Finally, there needs to be resources provided for communities so that they can write up their
complaints so that they are successful because lots of people don't have those resources. I just
wanted to reflect those on the record.

Ms. Jacqueline Shirley, NEJAC Member, wanted to make sure how important it is that they do
not use "Indian country" because there is no Indian country in Alaska except for Metlakatla.
There are 239 federally recognized tribes, but we're not considered Indian country. Indian
country is a very inappropriate term.

Ms. Sylvia Orduno, NEJAC Chair, thanked Ms. Shirley for flagging that. She reminded
everyone to keep Goal 3 short. It enforces environmental laws and ensures compliance. Within
that, there's an objective 3.1, holding environmental violators and responsible parties
accountable.

She flagged line Item 31 about fence-line communities and wanted to make sure, as well, that
there is something that is being done to protect frontline communities and that they need a truly
protective risk management plan. There have been calls for the NEJAC to write a letter about
this and take the information that has been shared so that they can actually see about getting this

-------
incorporated. She hopes that what we can do is make sure that they've got that specificity in this
strategic plan for that. Then, when they have our next public meeting, they can look at the
potential development of a letter specifically on that to enforce it because it is something that
some of our public commenters have been trying to drive home.

She moved onto Goal 4, which is to ensure clean and healthy air for all communities.

Ms. Cemelli De Aztlan, NEJAC Member, wanted to emphasize that, throughout this whole
strategic plan, she had noticed there is no mention specifically of the environmental effects in
border communities. She addressed the Clean Air Act's loophole, 179B, which allows for an
exemption on clear air because of our international boundaries. Often, people want to blame
Mexico for our poor air quality. But the United States is not only responsible for a huge
percentage of that on the U.S. side of the border, but they're also responsible for a huge
percentage. Almost 70 percent of maquilas in Ciudad Juarez are U.S.-owned companies. She
didn't include that emphasis in regard to how do they hold U.S. companies that choose to
manufacture in countries such as Mexico that have lax or less environmental laws. She didn't
know if that's overlapping some of the updated NAFTA environmental requirements with the
EPA. The only way to hold those new NAFTA requirements responsible is if the U.S. has some
standards regarding that business exchange. Unfortunately, that has a lot of negative effects on
the population here on both sides of the border.

She emphasized the Section 179B loophole of the Clean Air Act. It's on Goal 4, going into the
second page, the second point. Essentially, about 70 percent of the maquilas in Juarez are U.S.
owned. They go to run their factories in Juarez because of the lessened environmental and labor
laws. She suggested that there needs to be some sort of threshold in that assessment, that
loophole. It's too big of a loophole that keeps allowing the contamination and polluting of our
community here. The international loophole, I think, should have some sort of amendment that
says, if more than 40 percent of the U.S.-owned company is in Mexico, what sort of regulations
we could apply to them?

Mr. Michael Tilchin, NEJAC Vice-Chair, noted that it's his understanding that they will have a

-------
chance to edit and add to this between now and the end of the week. They can have a mechanism
for getting critical issues like the one that Cemelli just raised into this document before
submission.

Ms. Sylvia Orduno, NEJAC Chair, stated that they've captured the essence of it in the notes.
She moved on to Number 41. It is wanting to make sure that there is incorporation in the
strategic plan about the Justice40 pilot areas that are under EPA. She moved on to Goal 5 which
is to ensure clean and safe water for all communities. She noted that some of the previous goals
overlap with these sections. They even get back to some of the comments from the administrator
as well.

Mr. Jonathan Perry, NEJAC Member, asked, for this section, would it be best to also make a
clarification or distinction with the aquifers? It would be very crucial to include a language of
aquifers and have that outlined specifically because, in some cases, that would be more adequate
in terminology.

Ms. Sylvia Orduno, NEJAC Chair: I think that's completely appropriate. The aquifers would be
important to include.

Ms. Joy Britt, NEJAC Member, wanted to touch on incinerators as many of the rural
communities, most especially in Alaska, only use incineration and trash burning as means of
disposing of waste. There is much research about the injustice of incineration in smaller
communities.

Ms. Sylvia Orduno, NEJAC Chair, stated that she had gotten some additional feedback from
Ms. Crawford with the District of Columbia Department of Energy and Environment related to
objective 4.2, as well, again saying the EPA needs to move looking only at radon and that natural
gas consumption in the home leads to dangerous nitrogen dioxide and carbon monoxide levels.
While EPA doesn't regulate them from the indoor perspective, residential natural gas use is one
of the larger sources of precursors and also must be regulated. She will make sure that they get
that incorporated, as well, as something else to note.

-------
She went on to Goal 6, which is to safeguard and revitalize communities. With no comments, she
went on to Goal 7, to ensure the safety of chemicals for people and the environment. Most of
these comments were from the farmworker and pesticides workgroup. It is needing to ensure that
there's an emphasis on the protection of vulnerable workers, that it's not enough just to provide
for training. There has to be an emphasis on human life and their experience as workers as well
as children that are exposed to chemicals as well, even in the communities in which they live.

She went on to the summary on page 19, which is the section on cross-agency strategies. There
are four. The first one is to ensure scientific integrity and science-based decision-making. There
are comments from Dr. Harrison as well as some additional feedback in cross-agency Strategy 2,
which is consider the health of children at all life stages and other vulnerable populations. There
was no specific feedback that we received on Strategy 3, which is to advance EPA's
organizational excellence and workforce equity, but there was some on Strategy 4, strengthen
tribal, state, and local partnerships and enhance engagement.

Ms. Cemelli De Aztlan, NEJAC Member, stated that there was a recent Supreme Court case
that, using science-based and percentages, essentially, looks at minority communities and says,
"Well, if it's only affecting a small amount, it's okay." I love science, but when we talk about
percentages and statistics, it's very much skewed.

Ms. Leticia Colon de Mejias, NEJAC Member, noted that on Item 84, on Strategy 3, no one
commented. She wondered if no one commented because no one knows what the EPA's
organizational excellence and workforce strategy is. She suggested that black and brown
communities are underrepresented in the clean energy industry and the energy efficiency
industry, making up a maximum of 12 percent of all people working across the nation in that
area. There is more than 12 percent of us in the United States. They're underrepresented in many
of these things. Maybe there should be something there about ensuring that whatever this
excellent workforce equity strategy is has some metrics around engagement of communities of
color in the workforce initiatives. I can tie a report to that that was done by the DOE. Then, on
the next one down, with partnerships, what they're trying to say is, what are the metrics on

-------
ensuring that there is maybe a small group of representatives?

Ms. Sylvia Orduno, NEJAC Chair, noted in the point about Strategy 3 is there is a pretty good
description of how EPA is trying to be more mission-driven in its workplace but also in its hires.
Also, she noted that a lot of communities of color oftentimes might not have the education to be
able to apply to jobs in the federal government, then how to improve on that to reduce barriers
and increase opportunities. That is something that they are conscious of. That would be
important to learn about in this equity action report that is being developed.

Mr. Jonathan Perry, NEJAC Member, stated that, for this section on the discussion, would it be
good to also maybe outline a section where EPA can coordinate with the tribal governments to
maybe have the tribal governments establish programs to allow for their people to get educated
or get the skills they need to take up some of these roles? It would be good to have EPA try and
set up communication that way. It would help support getting these Indigenous people into these
positions because a lot of times the actions are taking place on tribal lands or on reservations or
other areas. A lot of the communities would feel more appropriate that their people are engaged
and working in these different positions.

Ms. Sylvia Orduno, NEJAC Chair, stated that there are multiple points across this plan that the
questions relate to implementation, about how do they ensure that these job force development
and training opportunities are built into these programs, but also whether resources are going to
drive the economic needs of those communities as well. That's very appropriate there.

Ms. Jacqueline Shirley, NEJAC Member, stated that her question was going to be out of
ignorance because she saw other vulnerable populations, especially when we're talking about
pesticides and other environmental negative impacts on some of our farmworkers, our migrant
workers. A lot or maybe a majority or maybe a few may be undocumented citizens for this
country, but how does NEJAC protect them and how does EPA work with cross-agencies,
maybe, with whoever's involved making sure that they're protected. Because whether they're
documented or not, they're part of our society. They're part of the economic drive in our society.

-------
There's money exchanged. There's food exchanged. I don't know how we can protect
undocumented citizens in our country from the devastation that they receive by making sure that
we have food on our plates. How would EPA work with other agencies? Do they have a
whistleblower program for those migrant workers, those farmworkers? How can we allow them
to speak up? That whole area needs to be addressed in this country.

Ms. Sylvia Orduno, NEJAC Chair, answered that where it probably applies the best is in that
cross-agency Strategy 2, about considering the health of children at all stages and other
vulnerable populations. There's definitely more that could be and should be said around how to
provide those not only workplace protections but human rights needs that are issues of violations
that need a cross-agency response. She will try to maybe get that more in that strategy.

Ms. Cemelli De Aztlan, NEJAC Member, suggested that it should be worded like Title 1
schools and HUD require air monitoring and implementation of mediation and strategies with the
community. Also, in just looking at the language here and how children and vulnerable
populations are ignored, she would like to repeat or reiterate here that many of the standards are
based on an adult male, which has been very frustrating when they're trying to address lead and
high levels of copper in the soil. The EPA still has its standard assessing from adult males. So
having children or children-specific standards should be added.

Ms. Sylvia Orduno, NEJAC Chair, stated that it was time for a break and that they will resume
where they left off followed by the public comment period.

[BREAK]

Ms. Sylvia Orduno, NEJAC Chair, welcomed everyone back and continued where the meeting
left off.

Mr. Scott Clow, NEJAC Member, commented on cross-agency Strategy 1. It's important for
the scientific integrity to also connect with traditional ecological knowledge and that there's
often this perception that those things are fundamentally different when I think what we really

-------
need to accomplish is connecting the two of them. This also relates to Strategy 4 as far as public
engagement and trying to learn how local people interpret the goals and how to engage the
public with local knowledge as opposed to while we're communicating with you, but we're really
understanding you. So, I just wanted to throw some traditional ecological knowledge [TEK] of
concepts from there.

Ms. Sylvia Orduno, NEJAC Chair, stated that it reminded her of something that's come up, too,
like, with the Great Lakes Advisory Board about making sure that they're using the document
from Indigenous communities around the TEK, right? So maybe that's something that will be
noted and put a link to where that's accessible to incorporate in the report as well.

Ms. Felicia Beltran, NEJAC Member, commented about the term "citizen." In the U.S., that
term does mean something, and Title 6 is the foundation really of a lot of the civil rights laws
here that are being implemented. Title 6 specifically says protections for those who are
documented or undocumented. So, she noted that overall that usage of that term could be
discriminatory just by the usage regardless of if it's intended or not.

Ms. Sylvia Orduno, NEJAC Chair, suggested that they use the word "resident" instead so, this
way, they're not qualifying what the relationship is.

Mr. Andy Kricun, NEJAC Member, wondered if there could be another cross-agency goal to
make sure that other federal agencies are implementing environmental justice practices, for
example, FEMA or the Department of Transportation. Often, the highways cut across
environmental justice communities, and they're very high air emissions from mobile vehicles
from those highways that are going forth. So, there's sort of a way for there to be a cross-agency
strategy where EPA could work with its sister and brother federal agencies to try to look for
opportunities to inject or imbed environmental justice and those agencies in the same way that
EPA is doing it itself.

Ms. Sylvia Orduno, NEJAC Chair, wanted to note that the strategic plan talks about citizen
science. It appreciates the citizen science work that a lot of NEJAC communities do.

-------
Oftentimes, this is the work that they've got to do because they're overlooked or ignored and try
to figure out who they can partner with that will get them the more sort of formal research that
needs to happen in the work that a lot of groups are doing around their EJ grants. This is going to
be oftentimes citizen science.

She moved on to the Draft Learning Agenda. Within that area, there's also the piece on Learning
Priority Areas: Workforce Planning. She stated her concerns about it. It echoes some of the
things that some of the folks that had been talking about issues of water and infrastructure might
also be concerned about. In particular, there is a proposal in there about how the Office of Water
might be engaging with environmental groups to try to look at how to decide our noncompliance
systems, such as a proposal to develop an algorithm that can assess how it is that a system gets
into compliance or factors that put it into noncompliance.

She noted a troubling trend that there's a rush to try to figure out how to take noncompliant
systems and consider them for consolidation, a regionalization without looking at those factors
that will put them into noncompliance to begin with. When someone looks closely at those
communities, especially in EJ communities of color that are low income, in many instances,
they've been allowed to fail. This is where she gets into some serious disagreements with how
EPA's relationship with the states is not working. It's not providing the resources or support or
technical capacity building for these small communities. These vulnerable water utilities are now
being considered for consolidation without really looking at the issues around this investment
and racism and all kinds of issues that have contributed to why the system is in this state to begin
with.

She wants to make sure that there is due diligence and consideration of the environmental justice
factors that contributed to a system's noncompliance and not just sort of making the appearance
that this is an objective analysis when there's much more subjectivity that needs to be part of the
assessment.

Mr. Scott Crow, NEJAC Member, thought that this also plays out significantly in Indian
country because the EPA's relationship with the Indian Health Service is very regionalized, and

-------
so different regions have different mechanisms for infrastructure development in parts of the
country. Making it consistent across the whole nation would not be necessary, but the system
that they're using to evaluate failures of systems — water and wastewater and solid waste —
continues to underserve Native American and Indigenous populations. They need to get together
with the Indian Health Service to fix this.

Ms. Sylvia Orduno, NEJAC Chair, noted some feedback at the end of the document. One of
them is some short-term goals that can be incorporated as opposed to not just the long-term
goals, but also ways to look at more interim or incremental steps.

She relayed a comment from Brenda Torres Barreto related to Goal 1 around climate justice.
She says, "As a federal agency, the EPA has a responsibility to lead the development and
implementation of policies and regulations that are inclusive and relevant to all American
citizens. We, therefore, respectfully request that EPA recognize and include "island
communities" when listing fellow communities that are disproportionately affected by the
effects of climate change that is low-income communities, children, the elderly, communities of
color, tribunal communities, and Indigenous people." Then she adds, "If you can mention the
need to incorporate island communities as one of the categories of disproportionately affected
communities during your remarks, that would be great."

Mr. Jonathan Perry, NEJAC Member, suggested that, for the tribes that have treaties
acknowledged, is there a way that EPA can not only provide training to their staff but
acknowledge those treaties that are in existence? That would go in with the relationship with the
different tribes. Knowing that not all tribes have those treaties in place, but for those that do, it
would be good to have those incorporated into the strategic plan.

Ms. Sylvia Orduno, NEJAC Chair, asked that the Council turn on their video so they can do a
simple vote for consensus that the strategic plan meets their satisfaction, that they've had the
opportunity to make additions, that the Council feels that this is something they can move
forward on, knowing that between now and Friday, they will be working on the details to get the
document cleaned up incorporating the feedback. There was a consensus. She asked if there was

-------
any opposition.

Ms. Cemelli De Aztlan, NEJAC Member, noted the mention of ozone. She suggested that they
clarify with the Montreal Protocol that addresses stratospheric ozone but also include ground-
level ozone in the strategic plan.

Ms. Sylvia Orduno, NEJAC Chair, asked again if there were any objections to this project
moving forward. There were none.

Ms. Sylvia Orduno, NEJAC Chair, thanked everyone who worked on the document.

ORAL PUBLIC COMMENT PERIOD

Dr. Fred Jenkins, DFO, stated the announcements regarding the public comment period.

Dr. Na'Taki Osborne Jelks, NEJAC Vice-Chair, reminded the public speakers to make sure
that the Council is clear on what their ask is.

Ms. Alice Sung, Public Commenter: Great. Thank you so much. I'd like to thank you for this
opportunity to make a public comment and listen in on my first NEJAC meeting. I'll try and
make this succinct. I guess my first ask to be direct, Sylvia, to your request, is that we find some
way to improve general public and meaningful community engagement in a two-way
conversation. Quite often, in these, you get two minutes or three minutes to comment, and then
they move on to the next comment. There needs to be some other meaningful period of time
where we could actually have meaningful conversations and a public portal or website that
maybe could be expanded on EPA's website to hold and record these conversations and make
sure that every public comment is addressed.

So, we avoid feedback or commenting falling into the black holes, which is really frustrating for
us on the public end. And so along that line, I'd love to also ask that you publicly share your
documents before your meetings. It would've been helpful to give you more feedback, for

56

-------
example, on your feedback survey and comment on your strategic plan motion. So, I'll do that in
writing afterward.

Second, I'd like to urge you to pay attention to all of the earnest public comments that will
follow me.

Third, when defining your budget or developing your programs for implementation, I'd like to
encourage you to think differently, other than traditional means of competitive grants as a
mechanism and avoid the whole notion of competition because, as I think it was mentioned,
those that already have the resources and capacity and means to actually compete or even rely on
market-based solutions, those often perpetuate in equities already.

Lastly, I'd like to have you consider looking hard at that — looking at root causes and sources of
pollution and toxics. It seems as though a lot of the discussion this afternoon was on solutions to
solving and remediating pollution and toxins in waterways and so on, so forth. Look at root
causes in tackling the climate crisis, number one, stop the subsidies to fossil fuels. Stop the new
permits and let existing permits wane for extraction. Stop the pollution and toxics at the source.
I thank you again for your time, and I will put these into the written comments. Thank you.

Mr. William Patterson, Public Commenter: I am William B. Patterson, and on behalf of the
East Bay Municipal Utility District, I'm providing comments on the draft 2226 United States
EPA Strategic Plan. As a member of the Board, I represent Ward 6 in East Bay MUD, which
includes portions of Oakland, including East Oakland, and this area I have represented since
1997, and one I care about deeply. My comments today focus on Goal 2, take decisive action to
advance environmental justice and civil rights. That is my background since the '50s.

East Bay MUD is a special district that provides drinking water to 1.4 million people and
wastewater treatment services to 740,000 people in 20 cities and in 15 unincorporated
communities in the east bay San Francisco Bay, including numerous disadvantaged
communities. Over the decades, we have planned and invested in our infrastructure, developed a
reliable high-quality water supply — number one in the nation — and led the industry in

-------
innovating to meet the growing challenges our industry faces. This planning and these
investments were done to ensure that our operations are sustainable and resilient by also
ensuring we're able to support our customers who are most in need.

East Bay MUD has a long history of helping its customers, including those in need. Easy Bay
MUD was among the first public utilities to establish a customer assistance program and helped
low-income customers pay their water bills and wastewater bills. We invested $500 million in
the Freeport Regional Water Facility to improve our drought resiliency. We also sponsored
legislation to minimize lead in household faucet and pipe fasting in California in 2010 and
signed into action by, then, President Obama, in 2011.

To cut to the chase, I really want to say regional facilities such as ours, regional government
entities, such as ours, should be inclusive. As you work with our state water board, we want to
have input to you directly so that you understand the ground floor. Unfortunately, our state
water resources control board doesn't always have the science, and I can give you more specifics
on that. My time has run out, but if we just look at the management for the past hundred years
of our Mokelumne River, you will see investments made up there in the millions of dollars in
fish hatcheries. This river has the greatest return of salmon of all the rivers of California, and
the management of flows and how we handle that for the past hundred years have really been at
the expense of East Bay MUD.

Any changes that are made in that really need to have environmental input into, especially to
justice issues, and our repairs shouldn't be burdened with additional costs as a result of any
changes because they've already paid their dues. We don't want to push them into gentrification,
and some of that will be explained in my written comments. If you have any questions, I'd be
happy to answer them.

Ms. Sylvia Orduno, NEJAC Chair: So, thank you very much both of you for the comments that
you offered here. I think that they're very salient to what you're saying is related to this strategic
plan. Also, just to the overall process, I can tell you that as Council members, we're very much
interested in trying to figure out how this Council can be more available in a way. Even with

-------
technology, we know that it's very much so that a lot of people are still not able to participate,
and we recognize that. Even in person, we know that there are limitations in terms of even
travel.

I think that what we're interested, too, with the EPA is trying out how NEJAC, in particular, can
better be made available, both in the way that we're accepting public comments. I think that
there have been some pretty good strides in that, that the Office of Environmental Justice has
really tried to make in terms of how it is that they're communicating with folks and getting
people prepared for comments. And we're really looking at how to have the follow-up with
regions. So, there is kind of like some pilot efforts that Council members are working on with
regions with OEJ staff to try to figure out how with what you all share here. We're not only
doing our best to try to incorporate through our work groups where we've got issues specific
kinds of work that we're continuing to follow up on with EPA programs and offices. Then,
when the issues are very local, we're figuring out how to create better opportunities for
conversation and advocacy with the regions.

So, a lot of this really touches back to the communities themselves. So, your feedback is really,
again, important to us and just want you to know that it is something that we are taking to heart.
Thank you.

Ms. Alice Sung, Public Commenter: Thank you, Chair Sylvia. I'd love to see that we could
have some follow-up mechanism, and I don't know how to do that. Do you have my email?
How do we follow up on this?

Ms. Sylvia Orduno, NEJAC Chair: As a private citizen for my organization, I can follow up
with you. I can get your email. Thank you.

Ms. Alice Sung, Public Commenter: Thank you.

Ms. Ayako Nagano, NEJAC Member: I just wanted to add for Mr. Patterson, thank you for
your comment. I live in Berkeley. I drink your water. I use your facilities. I attend the classes

59

-------
you give on water quality, and I'd like to follow up with you. So I will look for that information
in the written comments. Thank you.

Mr. William Patterson, Public Commenter: Thank you.

Ms. Alice Sung, Public Commenter: I neglected to say I, too, live in East Bay MUD territory.
Mr. William Patterson, Public Commenter: Thank you.

Ms. Leticia Colon de Mejias, NEJAC Member: I wanted to thank the commenters for their
comments. It's so important that these issues be raised and say that as a Council member, I
personally am very interested in addressing the root causes of the pollution and the causes of
environmental justice working on addressing cumulative impacts on communities and not just
continuing to approve polluters in those communities that are already overburdened, but in fact,
to make genuine efforts to ensure that the EPA stops those polluters at the source, even from the
point of extraction of fossil fuel to production of products that don't have a closed-loop cycle.

So, please know that there are lots of us here on this Council who have those same interests and
would like to address them and work diligently on your behalf to do so. And your comments are
very important. They inform the work that we do. So, thank you.

Ms. Sabina Perez, Public Commenter: Well, thank you. I really appreciate this forum. This is
my first time as well. I haven't had the opportunity to look at the strategic plan, but I would like
to provide comments at a later time. I didn't formulate any formal comments at this time, but I
would like to just maybe ask a couple questions and just to give you a little bit of background
about Guam itself.

So, Guam is an unincorporated territory. So we often are left out of many of the decisions that
really matter to our environment. So, I don't know how many of you know, but we're
undergoing one of the largest militarization in our region, and so basically, it's a huge military
buildup that's occurring right now. So, we've had a long history of militarization during both

-------
world wars and including up until today. With that comes a lot of environmental issues from
legacy issues to current problems.

One of the projects that I'm involved with is seeking safer, cleaner alternatives to open burn and
open detonation. So, we do have that here on Guam, and, considering there's a huge buildup
that's occurring, my concern is that it could be used for a lot of munitions that are coming into
our island. So, we have no control over what's coming in, and I think this is a really huge
concern of our community. The leading cause of mortality on our island has been heart attacks
and cardiac disease; the second leading cause is cancer.

So, I think, for me, I would like to see EPA incorporate some of these concepts of restorative
justice precautionary principle free and prior informed consent for indigenous people. So the
Chamorros are the Indigenous people of the island, and we've been here for over 3,000 years.
So, since President Obama adopted the Declaration of Rights of Indigenous Peoples, I think it's
really important to incorporate a lot of these principles. Being that I'm here today, I didn't hear
about the meeting directly. I had heard it from a third party. And so it's very difficult to be at
the table for many of the meetings that really can address the environmental issues. There are so
many things I want to say, but I will include them in my written comments. I hope you have any
suggestions on how to incorporate these ideas. Thank you. Much appreciate this opportunity.

Ms. Sylvia Orduno, NEJAC Chair, inquired about public commenters being allowed to use
their video if they choose for the next meeting.

Mr. David Publow, Public Commenter: Great. So my name is Dave Publow. I'm with an
organization called Lights Out Norlite, and, just to put that organization in context, one of our
key members is Judas Anke, who is the former regional EPA administrator for Region 2. I'm
basically here to comment on some of the specifics not in the document that you guys have been
working on today, but in what's happening in this region. Specifically, Norlite, LLC, which is a
hazardous waste incinerator that is located and operates about two miles away from where I live.
It uses rotary kilns to convert shale to aggregate but uses hazardous waste as a fuel.

-------
Norlite has the rotary kilns approximately 300 feet away from a public housing complex, which
has already been declared an environmental justice site. I've been working on a documentary
about this for the last year and a half. I have documented many children being exposed to
silicates, also from hazardous waste that is piled in massive piles in the open air because
neurologists use something called the bevel exemption to do this. Also, Norlite had a contract
with the DOD that was not disclosed to the public and burned more than two million pounds of
AFFF containing PFAS chemicals in 2017 through 2019.

So, all of this is in play and our local administrator, the DEC, the current situation is the BEP
allows them to administer things like the Title 5 permit structure and things like that. Norlite's
Title 5 permit expired more than a year ago, but Norlite is allowed to continue to operate. Also,
when the PFAS incineration process came to light and it was national news, the DEC
deliberately did not test for PFAS in the locations on the Norlite plant, most likely to show a
high concentration of PFAS contamination.

So, we do not have adequate representation. We have people who are exhibiting adverse health
impacts, like, right now in real time, and none of this is being addressed. And unfortunately,
New York seems to have embraced hazardous waste incineration in general. So, a lot of what
I'm saying would also apply to the Lafarge Cement Plant, which is just down the river, and the
Hudson River in Ravenna where they've been trying to burn tires right next to two public
schools. So, we need this type of stuff to be addressed, and I would invite the EPA to send a
representative to our area, and I would give them a full tour of what's happening.

Dr. Millie Piazza, NEJAC Member: Yes. I just wanted to just express my gratitude to Sabina
Perez for the comment she provided today. I just really appreciate, first of all, taking the time to
join us and bring into this NEJAC space concerns from Guam. We haven't had a lot of
discussions as a Council about the history of environmental justice in the Pacific Islands U.S.
territories, former trust territories, and in particular, the military legacy and the ongoing military
activities.

So, a huge appreciation and would love the NEJAC, my co-members to be thoughtful about this,

-------
particularly in linking what we're hearing today with our previous two meetings where the
nuclear legacy and uranium mining were also brought forward as public comments. So, it's an
area that I don't believe that we've dug into, and I would love to elevate that within NEJAC and
just greatly support those comments. Thank you.

Dr. Na'Taki Osborne Jelks, Vice-Chair: For Mr. Publow, can you tell me again, you're in
region, was that one or two?

Mr. David Publow, Public Commenter: It was Region 2.

Dr. Na'Taki Osborne Jelks, Vice-Chair: Region 2. Okay. Thank you so much.

Mr. William Patterson, Public Commenter: I just wanted to make a quick clarification. I'm a
different Mr. Patterson. My dad was also named William Patterson. He spoke previously. He's
with East Bay MUD. My name is also William Patterson. I represent a number of community-
based organizations in Region 9 and really quickly just a couple of points.

The first one is the point that I heard mentioned before about local engagement is not only
critical and key for making residents understand what's going on with environmental justice, but
also it's important in building trust because what we're seeing here at the community based and
faith-based level is still a lack of trust between the people who are affected at the grassroots level
and the government. So, that trust factor is going to be really important as you carry out your
plans for environmental justice and continue to implement your programs and resources.

The second point that I wanted to make is actually defining what a disadvantaged community is.
Here, out here in Region 9, specifically in cities like Seattle, Portland, Los Angeles, San
Francisco, and the Oakland Bay area, the demographic has changed quite a bit in where
previously many black and brown folks have resided in the community, they are no longer parts
of those communities because those communities have now been gentrified. So, what we're
looking at is a new demographic. So, I just hope that EPA within your framework and
engagement practices are really looking at the scope of disadvantaged communities and how far

-------
outward they've extended. I mean, we're talking about disadvantaged communities, men,
women, and children living in tents underneath the freeway.

So, it is very important that we understand the makeup of when we talk about a disadvantaged
community. We see these folks all the time because, in one of the organizations, we operate a
40-station computer lab. If we didn't have those resources, these folks would have no way to be
connected at all. I'm hoping that I can be able to share your strategic plan, take feedback, take
questions, take their concerns directly to the EPA because, to be quite honest with you, as was
mentioned previously by a couple of speakers, our local, county, and state elected officials have
been very ineffective in doing that. Thank you.

Mr. John Mueller, Public Commenter: Okay. Good afternoon. I am John Mueller in Tulsa,
Oklahoma. I'm a retired civil engineer having practiced mainly in water resources engineering
for public water and wastewater utilities. Albeit ostensibly, I represent a very large
environmental justice community. The community of citizens who depend on public tap water
that has been artificially fluoridated. That is reportedly about 70 percent of the U.S. population.
I have attended NEJAC public meetings last year, in addition to the WEJAC public meetings. I
have also attended several environmental justice community engagement calls hosted by Matt
Tejada. Thank you, Matt, for those additional opportunities.

Through all of this, I have submitted additional scientific and other materials supporting the fact
that artificial water fluoridation is an egregious environmental injustice formulated more than 75
years ago under claims of science seriously lacking the integrity so desperately needing attention
today. The EPA has regulatory authority over contaminants in public drinking water and fluoride
is a regulated contaminate. When the harmful effects of fluoride exposure are well documented
as they have been as a developmental neurotoxicant, then any proclaimed benefit of fluoridation
for preventing or treating tooth decay becomes very insignificant.

Tooth decay can be repaired. Brain damage and early brain development is a lifetime mental
health issue. I have also proposed that the most meaningful and speedy remedy is for this agency
to concede to the petitioners, the plaintiffs, in the current TSCA, Toxic Substance Control Act,

64

-------
the current lawsuit, food and water watch versus environmental protection agency now pending
in the federal district court in the northern district of California in which the plaintiffs and EPA
to rightfully ban the addition of fluoridation chemicals to public water supplies.

The administration's Justice40 initiative is the perfect platform for shifting the paradigm of
community water fluoridation to a system of locally instituted oral health care programs, where
they are needed most. The disadvantaged and underserved black and other minority communities
are disproportionately harmed by fluoride exposure, and that disproportionate harm is well
documented by the CDC's National Center Statistics.

My request today is for a status update from NEJAC chair, Ms. Orduno, in an email to me
regarding my submitted additional materials about fluoridation. Specifically, has NEJAC
acknowledged that fluoridation is an environmental injustice, and if not, then why not? What
must I do differently? Thank you very much for these important opportunities to help enact
change where needed most. I will be submitted more written comments. Thank you.

Dr. Jill Lindsey Harrison, NEJAC Member: Thanks so much for those comments to both of
you. I just wanted to respond briefly to Will Patterson. I realize that you made comments on
several different matters. Just in particular, I really appreciate your reminding us about the need
to recognize the particular vulnerabilities experienced by those who are currently unhoused and
also the need for NEJAC but also EPA and all of its various scientific work to recognize that
particular set of vulnerabilities and to recognize how population changes in recent years have
really grown that population and that it's very difficult to track.

So, we welcome your comments further about that including how it relates to EPA's draft
strategic plan, but just so you know, I've added some specific language about unhoused status as
a particular form of vulnerability that we are encouraging EPA to specifically recognize. So,
right now in the draft strategic plan, it's got this language about different cross-agency strategies,
and it talks about children and then other vulnerable populations. One of my comments has been
to encourage EPA to specify some of those other forms of vulnerability, including racism, food
insecurity, undocumented status as some of our Council members mentioned earlier when I

-------
think we should also add unhoused status and others.

We can add others, too, and part of that is to also kind of train EPA staff to recognize those
different forms of vulnerability. So, that's my comment to you, and then to Sylvia, I guess, my
question is, is that okay just as a matter of kind of process? Is that okay that I put that as a
comment in that Google doc, or is there a different place that we could add comments under
what our public commenters are providing us right now?

Ms. Sylvia Orduno, NEJAC Chair: Thank you for that questions, Dr. Jill. I'm going to take the
interpretation from the Council's support of the strategic plan work that we did that as long as it's
within the realm of the issues that we've noted of concern that we can go ahead and incorporate
things like that. I think if it's really an outlier, that's probably where it's more of a problem, but to
me, this seems like it's within the areas that we've discussed. So, it'd just be a matter of, I think,
as Mike was noting earlier is that we would need any additional specific feedback or
recommendations to get to us by tomorrow afternoon so that we can get them in by Friday.

Dr. Jill Lindsey Harrison, NEJAC Member: Great. Thank you. I just put it in the Google doc.

Ms. Sofia Owen, NEJAC Member: Thanks. Thank you both for your comments. To Will
Patterson, as someone who is representing a community-based organization that is in a
community that is one of the hot spots for gentrification and displacement in our area, I hear
you. As Dr. Jill noted, we have been trying to find ways to strengthen EPA's consideration of
what it means to be a disadvantaged population or however you want to define the term. I'll also
just say that one of the things that I think we're hoping to see in the strategic plan is more
interagency cooperation. So, we can't have environmental justice without housing justice, and in
terms of housing, there is an obligation under the Federal Fair Housing Act not for recipients,
not further segregation and that goes hand in hand with some of the dynamics you're describing.

So, I'm hoping to see more cross-agency work with EPA, DOJ, HUD, and other agencies. In
terms of the trust building, I also very much appreciate your comments on that, and we'll be
continuing to push both the NEJAC and in my capacity as an attorney at my organization for that

-------
work to be done as someone who's seeing that day in and day out. So, thank you for your
thoughtful comments.

Mr. Scott Clow, NEJAC Member: Yes. Thank you both for your comments today. I would like
to chime in on what Dr. Jill was saying, I think that people with mental health issues also fall
into a vulnerable population and then some of the other realms so that you were describing there
with homelessness and stuff. So, I think maybe I'll add that to the Google doc also if it's
appropriate.

Mr. Mueller, I really want to express my appreciation for your comments. I think that this issue
of fluoridation is one that it's clear, it's tangible, and it's something that we can make a concise
recommendation to EPA on. So, thank you. I think we could follow through on that and am
happy to work with you beyond that.

Ms. Sylvia Orduno, NEJAC Chair: Thank you, Scott. I appreciate that. Also, I just want to
echo what folks have raised about our public commenters and thank you, Mr. Mueller, in
particular. So, I think what helps us as a Council is when you've come back again to share your
serious meaningful concerns because it helps us when we hear things from more than one
commenter and more than one community. So, I think that, in part, I can say that I don't recall
anyone else coming to talk necessarily about concerns with fluoridation, although I know that it
is an issue, but I have heard members, residents of the City of Flint raised.

So, it just hasn't necessarily come here at that point specifically. I think that what we can do is
what we've been trying to do as a council is take as many of the public comments as we can and
incorporate them within the work of our work groups. And so I know that last time we discussed
taking what you shared to the water infrastructure work group. I can say that I will commit to
follow through on that and see what more we can learn from the Office of Water along with
what Scott is noting to see what we can find out in terms of where the EPA is around that in
terms of an issue. Then we'll see if there's anything more that perhaps other regions might be
able to share or that the Office of OEJ to the Office of EJ may know. So, I can at least commit to
follow through. Thank you.

-------
Dr. Na'Taki Osborne Jelks, Vice-Chair: Thanks, Sylvia. I also just wanted to appreciate both
of the public commenters. I can relate, Mr. Patterson, concerning the forces of gentrification
displacement. It is alive and well, unfortunately, in my community in Atlanta. So, Mr. Mueller,
we definitely hear you. I heard you saying how do I have to phrase this so that you all will look
into this? So, as Sylvia mentioned, we'll definitely take this to the water infrastructure work
group and come back with something, but first really just understanding how EPA is dealing
with or addressing this, what's happening in other regions and where there perhaps some
inconsistencies. On one hand, there is evidence of harm. On another hand, there is a lot out
there that talks about the good.

So, how do we really get to the core of the issues and how they are impacting real people in
communities today? So, you have our commitment to looking into that issue more and being
responsive to it.

Mr. John Mueller, Public Commenter: Thank you.

Ms. Jacquelyn Drechsler, Public Commenter: Okay. Thank you very much. I'm really happy
and delighted to have participated, at least in hearing about the strategic plan. As the very first
commenter said, it would have been great to have that kind of in my hand before your meeting,
but it looks like you're doing a lot of good.

So, my ask is maybe bigger than some other people's asks, and I will start with this. I don't see a
time thing on my phone, but on January 4th in 1979, President Jimmy Carter issued Executive
Order 12114, "Which was issued solely for the purpose of establishing internal procedures for
federal agencies to consider the significant effects of their actions on the environment outside of
the United States, its territories and possess..." So President Biden's order expands upon the
former Presidents Carter and Clinton updating the Executive Order 12898 of 1994 prioritizing
and adjusting historical injustices and encouraging a whole of government approach. It
formalizes a commitment to make environmental justice a part of every agency of the
developing programs and policies to address disproportionate environmental, socioeconomic,

-------
and climate impacts on disadvantaged communities.

So, when we talk about policies to protect all people, that is only for all people in the United
States. There's nothing in the policies to actually protect all people. For instance, the people
where dirty energy is actually produced — for instance, in Canada where Hydro-Quebec floods
Indigenous lands — people suffer the consequences of our energy needs. Many of the people
living in substandard housing do not have running water or electricity themselves. This is an
injustice. They suffer breathing dirty air for construction projects for hydroelectricity and the
consequences of having their land taken, abused, poisoned, and unfit for the life systems they
rely on for food and water.

There's the loss of the carbon capture Boreal forests, greenhouse gas emissions, poison toxin,
methylmercury, which is created. So, President Biden has said that he wants us, the United
States and himself, to be considered an international leader in the fight against global warming
and climate change. And the only way to do this is to go further than what we have at the local,
state, and national levels. It is to create an international policy that states that no one can be hurt
by environmental injustice that all people deserve clean air, water, and clean energy, not just us.

So, my ask is that we go beyond. We shouldn't be hypocritical here, and I know that we have so
much work to do to protect our own people here, but we cannot be hypocritical and allow
indignities and injustice to be happening somewhere else for our needs and ignore that. I do
believe that we need to have an international policy that is just as strong as what you are creating
for the United States. It needs to be international. It needs to go over borders. I live in Rockland
County, by the way, and I've been very involved in the fight against the Indian Point nuclear
power facility, which has finally been shut down.

A horrible company named WholeTech has the decommissioning and part of their plan is to take
the radioactive waste to New Mexico. Now, I've been listening to Jonathan, and I've known for a
long time about the horrible situation there with uranium mining and the poisoning of their land
and waters. We've just got to get our federal agencies all on the same page to be saying no to
these things, to these injustices. All federal agencies have to work together, please, to stop these

-------
horrible injustices from continuing. Thank you very much.

Ms. Daisha Williams, Public Commenter: My name is Daisha William. I'm from Region 4.1
am an environmental justice manager for an organization called Clean AIRE NC here in the state
of North Carolina. There are so many issues that I could bring up not only across my state, but
the nation. Today, specifically, I wanted to bring up the issue of CAFOs, or concentrated feeding
animal operations, because it poses perhaps the greatest civil rights violation in our state. Not
only does Administrator Regan have roots in the eastern part of our state plagued by these
facilities, but it also has been on the EPA's radar recently.

So, in 2017, the EPA's external Civil Rights Compliance Office wrote to our Department of
Environmental Quality expressing its deep concern on the possibilities that communities of color
have been subjected to discrimination related to our state's oversight of hog farms. And EPA
also recognized that industrial hog farms have a negative impact on residents' quality of life and
health. Looking at the year, it's now 2022, and the situation has remained unchanged, if not
worse, especially with the new prospect of biogas projects, which will contribute to cumulative
impacts due to the industry operating with substandard systems and practices still to this day.
Technically, these CAFOs fall under federal regulations overseen by the EPA, as well as our
state laws, but our state has a long-standing failure to provide relief for residents suffering from
CAFO pollution.

In fact, recently, the North Carolina Court of Appeals ruled that our government has the power
to limit nuisance lawsuits against hog farms, which is obviously just going to further silence our
communities. So, it's just for this reason that I hope NEJAC will guide the EPA in setting a
precedent within the strategic plan towards better practices and regulations and enforcements of
the CAFO industry in North Carolina as well as across our nation because I know that this is not
just an issue impacting our state.

So, just some recommendations I had starting off would be to address the cumulative health and
environmental impacts of the 2000-plus CAFOs in our state. They're literally right on top of
each other. I don't even know how this was allowed to happen. People breathe this air. They

-------
drink this water. It literally has feces in it. It's just really troubling to work and to hear the stories
of what these communities are going through. But I also recommend that you hold agencies
accountable within the strategic plan and ensure that environmental justice outcomes in
communities like this are pushed programmatically and effectively.

Then lastly, I just wanted to recommend that you increase reliable ways to measure emissions so
that the EPA can better enforce federal environmental laws and also use citizen science data,
which can really help to bridge meaningful participation between citizens on the front line and
with government agencies, such as yourself. Thank you for your time today.

Dr. Na'Taki Osborne Jelks, Vice-Chair: Thank you both Ms. Drechsler and Ms. Williams. I
can just really appreciate what you've both mentioned, Ms. Drechsler in terms of the impact of
our actions on the territories outside of the sort of the standard kind of 50 states. Ms. Williams,
really bringing this long-standing challenge of CAFOs and health-related issues in North
Carolina and other places in the south. Thank you both for bringing that. I do want to just kind of
emphasize that I'm really hoping and will be pushing to see how EPA is looking at its use of
citizen and community science data whether it's around CAFOs or other issues and challenges,
especially in the air quality in air monitoring space

Mr. Michael Tilchin, NEJAC Chair: Thank you, Dr. Na'Taki. And I want to thank both public
commenters for their excellent comments. I do want to respond specifically to Ms. Drechsler,
who I think raised some outstanding points about the fact that pollution knows no boundaries,
and we live in a very globalized world. I have some ideas about how the Council can address a
related issue, but international environmental treaties come from the U.N. environmental
program. There are not very many of them.

I think what maybe one of the most recent ones was the Minamata treaty, which the U.S. is a
signatory, too, so there are international mechanisms, but what I was thinking about during your
comments was this is also a global supply chain issue, and as you noted for major sources of
pollution, it's not just what happens at the literal point of views. It's the extraction. It's the
synthesis. It's the transport. Many of those things are happening as you noted, outside of U.S.

-------
boundaries, and I'm thinking as something for our Council to consider is a deeper dive into the
impact of really dirty supply chains, whether that supply chain is happening within the
boundaries of the U.S. or outside of it. I don't have a solution, but I think it's a really important
issue that we may want to tackle in the future. Thank you.

Ms. Maya Nye, Public Commenter: Good evening. My name is Maya Nye. I'm the federal
policy director for Coming Clean, which is a network of over 150 organizations working to
reform the chemical industry so that it's no longer a source of harm. I'm also a former fenceline
resident who grew up and went to school about a mile away from a high-risk chemical
manufacturing site that's located in Institution, West Virginia and institutes of the predominantly
black community with a historically black land grant university, and they both existed before the
facility was there.

On top of the cumulative threat of daily emissions from the plant, we lived under the constant
threat and occurrences of chemical disasters because of inadequate prevention measures like
those that need to be provided under EPA's risk management program or RMP. For decades,
members of my community have been asking for additional protections, many of which EPA is
considering including in a new RMP rule, and now the community faces additional cumulative
threats because a facility converts natural gas into methanol, which is highly explosive is also
located on the same site, but it's not covered under the RMP.

So, EPA really needs to address this as well as several other threats like increased climate risk.
Back in July, the NEJAC wrote the first 100 Days Letter to the EPA administrator where you
included the need for a fully implemented and enforced risk management program, and I thank
you for this as I mentioned in my public and written comments for the last two NEJAC
meetings. This information that was included in your letter, unfortunately, is outdated, and it
doesn't go far enough to protect communities that are at disproportionate risk of chemical
disasters, many of which are also located in areas of increased climate risk.

I requested, as did other commenters, that the NEJAC send the new letter calling on
Administrator Regan and the CPA to prioritize a preventative and protective new RMP rule on

-------
the fastest timeline possible. So, I'm here with that same request today as the EPA must be
guided in the right direction as they develop this new rule so that it's not another couple of
decades that fenceline communities, like mine, go without the protections that they need. It
sounded like in the last two meetings that you would be revisiting this or moving forward on
drafting a new letter, and I was hoping to hear if there was any movement.

I think it was mentioned earlier. I'm sorry I missed a bit of the business meeting, but otherwise, I
hope that we can count on you to send this new letter, and I'll resubmit my previous comments
outlining some specific requests for that letter. So, thanks for your attention to this, and thanks to
all of you for your volunteer commitment. I know that you all have a number of obligations to
your communities outside of this. So, I thank you for any attention you can provide. Thanks.

Ms. Kelly Crawford, Public Commenter: Good evening, everyone. My name is Kelly
Crawford. I'm the associate director of the Air Quality Division and chair of the Equity
Committee at the D.C. Department of Energy and Environment. I hail today from the District of
Columbia, which occupies the unseeded ancestral lands of Nacotchtank and the sacred site of
Anacostan and Anacostan people, and the unseeded ancestral land of the Piscataway people.
EOEE appreciates the opportunity to comment on EPA's efforts to address environmental justice
in its work as part of NEJAC's process, specifically, on EPA strapped FY22 to 26, EPA's
strategic plan.

Thank you, Chair Orduno and members of the Council for already incorporating our comments
into your recommendations. I'm so appreciative of the care and consideration that you have all
went in this process, and I'm eager to see the outcomes from this strategic plan as well as the
Agency's rational equity action plan, which we heard about earlier today. I'm especially
encouraged by most of the conversation that I've heard here today, including the explicit
consideration of addressing the inequitable exposure to ground-level ozone pollution. While the
work over the last 50 years of air quality regulation has contributed to tremendous reductions
and air pollution overall in the United States, the same communities that fought this harm
decades ago continue to face the greatest public health threats associated with long-term
exposure to air pollution today.

-------
Although persistent, these health inequities are neither natural nor habitable. I'll refer you to my
previous testimony to EPA regarding the ozone standard, but in brief, the ozone standard must
be revisited to account for the protection of our most vulnerable populations. But that one size
fits all approach does not bring justice. The evaluation of ozone in regard to health-based
standards must do more to take into account the disparate impacts on vulnerable populations,
and in particular communities of color. DOE's Equity Committee together with the mayor's
Office of Racial Equity has been working to develop new training tools and strategies while
we're finding existing ones to work towards a more sustainable and equitable D.C. We are happy
to share our experiences and initiatives with EPA in developing their own tools.

We are painfully aware of how critically important the pre-work is to ensure agencies are
adequately prepared to move from conception to true operation through thorough and timely
training, which is needed urgently to ensure EPA staff are prepared for the work ahead. I won't
take any more of your time today. Again, I just want to thank you for the opportunity to speak
and for the careful consideration of our written comments that you spoke of today earlier. Thank
you.

Dr. Na'Taki Osborne Jelks, Vice-Chair: Thank you so much to both our commenters, Ms. Nye
and Ms. Crawford. Thank you, Ms. Nye, for elevating the comments that you've made
previously and for pointing out the important information about some outdated information,
perhaps being used in some of what NEJAC has produced in the recent past. That's definitely
something that we will look into, and we appreciate you giving us specific recommendations that
you wish to be shared specifically as the agency is looking at the RMP rule.

Thank you, Ms. Crawford, for your comments as well. I'm glad that we hit a sweet spot in terms
of incorporating some of that feedback already into the feedback that we will be sharing with
respect to the strategic plan.

Ms. Sylvia Orduno, NEJAC Chair: I appreciate the comments that you added to what we heard
there. So, thank you, Ms. Nye, too. I think that you're right. We've been hearing also from

-------
members of the EJ Health Alliance that this Council is overdue for really trying to lean in
heavier to this administration about what we see as a need for providing more help essentially,
for frontline communities that have been suffering for a long time and with the need for a new
RMP rule.

So, I could also commit that by the next public meeting, this will be something that we will
bring forward in our agenda, and that we will work with the Council to not only better update
our own information, but that we're incorporating which you all are sharing as well. I think we
can make sure that we get some urgency around that over to the administrator.

Then similarly, Ms. Crawford, thank you so much, too, for the written comments that you
suggested. They're really helpful, both for the strategic plan and then also what you're sharing
here around ground-level ozone pollution as well and the need for better standards based on
health. So, admittedly, this is less in my wheelhouse of knowledge, but I know we've got
Council members that understand this better. So, we will work on making sure that we're getting
this better incorporated as well. So, thank you both for your feedback.

Ms. Stephanie Herron, Public Commenter: My name's Stephanie Herron. I'm the national
organizer with the Environmental Justice Health Alliance for chemical policy reform or EJHA.
First, I would like to express my deep gratitude and sincere appreciation to each member of the
NEJAC. I know this is a big job put on some already very busy people and an unpaid one at that.
We really do appreciate all your service and dedication to EJ communities.

A recurring theme that I think we've heard today in the public comment is about accessibility. I
would direct NEJAC members and particularly newer Council members are folks who missed
the last meeting, to a comment submitted on behalf of the EJHA by my colleague Katie Super.
We have several procedural and accessibility recommendations, some of which I think would be
pretty easy to implement, which haven't been necessarily implemented in today's meeting. For
example, calling on public commenters in the order of the list that was sent out in advance or
displaying that list on the screen. And some others, perhaps a work group or a meeting focused
specifically on these and other ideas to make NEJAC more accessible would be helpful. I know

75

-------
it's hard over Zoom, and we're all kind of over being online all the time.

To get quickly to my substantive ask, as you may be able to predict, I'm asking for the NEJAC
to write a letter to Administrator Regan and to EPA Office of Land and Emergency Planning,
calling on them to issue a strong risk management plan rule to protect frontline communities on
the fastest timeline possible. I really appreciate the commitment and the previous comments of
Chair Orduno during the strategic plan conversation and just now. I do appreciate that earlier
reference, and I really do also appreciate and am sensitive to the need for NEJAC to balance
your finite capacity with the Council's very large and very important charge. I just wanted to
reiterate that now is a really crucial time on this RMP rule.

The EPA has publicly stated that they plan to issue a proposed draft rule later this year in
September, and I'm afraid that if the NEJAC doesn't send their letter in the next couple of
months, we might, unfortunately, miss the window to substantively impact the EPA's rule. I
would direct the Council to my previous comments that I've submitted at the last couple of
meetings. In the November meeting docket, I submitted my last couple of meeting comments, as
well as some supporting materials. I'd be glad to address either right now or offline any
questions, concerns, or requests for more information that any Council members have.

Just for the benefit of new Council members, a few examples of what a strong role would
include to us are addressing the cumulative hazard to communities located near multiple RMP
facilities or facilities close to other polluting and dangerous land uses requiring facilities to
assess and go with safer alternatives or less dangerous chemicals when they're available. I have a
longer list, but I'll submit that in writing in the interest of time. I just want to also emphasize
that, as I've mentioned previously, the NEJAC does have a long history of engaging in chemical
disaster prevention, and has sent letters about this in the past, which we really appreciate and
look forward to continuing to engage with you all on. Thank you.

Ms. Cozetta LaMore, Public Commenter: I am with Choices Interlinking. We are a nonprofit
organization based out of East Texas, Kilgore, Texas. We own property. It's in a community
that's been impacted by an ejection fracking operation, and specifically, it's been severely

-------
polluted. We submitted some documents on this, I think, at one of the last previous sessions.
We've been involved in a problem-solving committee, which had been suggested by this
Council.

Despite three years of involvement, nothing has happened. Properties have been severely
damaged and poisoned. And today, I wanted to just kind of talk about the connection between
environmental justice or injustice and social injustice. Social injustice is composed of structural
disasters such as mass incarceration and homelessness, and they are linked to incompetent
systems that target especially black folks. Environmental injustice is such as exposure to poison.
Also, they are positioned so that they're targeting black and brown communities who are being
disproportionately harmed. These disasters create greater and greater barriers that exclude and
ostracize Afro-Americans from equitable opportunities that are offered to others.

So, what we are seeking today is a shift and decision-making processes and power as one
measure for undoing these blatant acts of institutional racism. As you know, institutional racism
equals racial inequity. We know policies, practices, and procedures currently work better for
white people than for people of color and especially for black people. We are also seeking a
reckoning what the reality of structural racism. It involves institutional racism across all
institutions. It's complicity that combines to create and strengthen barriers and come and
cumulative disadvantages for especially black people.

So, we want to be equitably included in evaluating and determining standards for health and
safety. This has not happened in the problem-solving committee we have been a part of. It is our
people who are dying. It is our intergenerational health and safety that is being jeopardized due
to unchecked environmental harm. These life-threatening decisions should not be left solely to
those who are far removed from harm who monopolize institutionalized power and control. I
think the term citizens science has been referred to today. And so maybe that's what we're asking
for. We need to be heard so, despite involvement in committees, nobody seems to be listening
because everything's the same.

We want to be included with equitable decision-making power and systemic support in

-------
determining restitution, reparations, and access to opportunities for resiliency and safe, healthy
environments. Current systems and structures rely almost exclusively on structures and
authorities that do not equitably value the loss and suffering of those most harmed. The people
who are being harmed need to be heard and responded to equitably. Thank you.

Dr. Na'Taki Osborne Jelks, Vice-Chair: Thank you so much both Ms. Herron and Ms.

LaMore. Ms. Herron, I definitely hear you. I think we hear you. Thank you again for elevating
your comments and for also giving us a warning in terms of the time frame and possibly missing
a window of opportunity to, I guess, reform the risk management plan rule. So, thank you for
that. We definitely hear you, and we'll take that under advisement with the appropriate
workgroup.

Also, Ms. LaMore, definitely we hear what you're saying. I'm not as up to date on this problem-
solving committee and what NEJAC may have suggested being done in the past concerning that,
but we definitely hear you concerning the need to have those who are most impacted be a part of
decision making. So, I'd love to better understand how we can help at this point. Thank you for
your comments.

Ms. Leticia Colon de Mejias, NEJAC Member: Thank you so much. Just wanted to respond to
Ms. LaMore in her fracking example of injustice and just really address her comments overall.
First of all, thank you so much for making such cognizant representations of the issues that
you're experiencing in your communities. It is very real that social injustices have been long-
standing, and that we really need to apply an equity lens relationship to having multiple facilities
in one place, or the idea that we should clean it up versus not make the mess in the first place. I
also agree with you that institutional racism is often unaddressed and results in far-reaching
disparities in resources, supports, opportunities, and information that would allow our
communities to engage with agency and have a true voice in changing to create decent living
conditions in the communities where we reside.

Decision-makers are often detached from those who are suffering in frontline communities. Just
want you to know, I 100 percent hear you, and I feel your pain. I believe that the work that we're

-------
doing to submit comments to the EPA's plans and strategic plans specifically have areas and
comments that will focus on some of those concerns that the idea of measuring something is not
the same as addressing the problem or concern directly. Just wanted to thank you for taking the
time to submit your comments and encourage you to continue doing so, so that we can elevate
your voice. Thank you.

Mr. Scott Clow, NEJAC Member: Thank you for both of your comments. I especially wanted to
home in on Ms. LaMore in the fracking issue. This is one that the EPA has sort of had stops and
starts on over the years. When I was first asked to represent tribes and their relationship with the
EPA on the National Tribal Caucus, there was a fracking workgroup when fracking was the big
new thing in the Bush administration. Pavilion, Wyoming was being polluted on the Wind River
Reservation, and we had this really awkward meeting at EPA headquarters where they invited
some representatives from tribes to participate in a meeting with their fracking workgroup, and
then we were quickly ushered out of the group and it was odd, to say the least.

I think it's about time that EPA revisits the fracking workgroup and really gets a handle on this
instead of dodging it. So, I really appreciate you bringing this to the forefront again. It hasn't
gone away. Obviously, the industry had a downturn, and so that sort of took eyes and ears off
from it. It certainly is booming in the Permian Basin in West Texas, so thank you for that. I
think we need to follow up.

Mr. Jerome Shabazz, NEJAC Member: I want to thank both the testimony of Herron and
LaMore. The latter presentation really, really touched me in the sense that immediately what
came to mind was the old quote that injustice anywhere is a threat to justice everywhere. I really
appreciated how she was able to make the connection between environmental injustice and
social injustice and that this is very interesting work. Oftentimes, we realize that there is an
environmental injustice because of how it's impacting people's lives.

I live in a state where there's a great deal of fracking taking place, and I hear the horror stories.
We just wanted to elevate your message and your point around your testimony and to let you
know that whatever we can do to look at this fracking issue and to bring greater support to these

-------
areas, I think it will be a well-advised initiative. So, thank you very much for your comment and
we do hear you.

Mr. Tom Neltner, Public Commenter: Thanks for the opportunity to provide public comments
to the Council today. I'm the senior director for safer chemicals at the Environmental Defense
Fund, and I've been working on lead poisoning prevention at the local, state, and federal levels
for more than 25 years. I focus my comments on lead service lines. Those are the lead pipes
connecting drinking water mains under the streets to homes that made Flint unfortunately so
prominent, such national attention. The environmental justice implications of those lead service
lines for the all-too-common-practice by utilities of expecting customers to pay to replace the
portion of the lead pipe on their property.

My primary concern is that when these utilities are replacing the water main attached to the lead
service lines, they force low-wealth customers to choose between finding the money to pay for
the full replacement or risk significantly more exposure to lead and the harm that it brings
because the utility will end up only replacing only part of the lead service line. Renters in
particular are often at greater risk because the landlord may choose not to pay without even
seeking their input. Zero-interest loans to customers offered by some utilities may soften the
financial impact, but the reality is far too many families lack the funds to take on another
monthly payment for three or ten years. Three states — Michigan, Illinois, and New Jersey — in
some communities have prohibited partial lead service line replacements. These states have an
estimated 25 percent of the nine million lead service lines in the country. They can show it's
possible.

However, the vast majority of the 11,000-plus water utilities with lead service lines engage in
this practice. In communities that have a history of racial segregation, lead lining, and
underinvestment in neighborhoods predominantly comprised of people of color, the practice of
requiring customers to pay to replace lead pipes can raise significant civil rights concerns. We
want to alert the Council to two recent events that address the issue and reinforce the excellent
efforts that we have seen from both the Biden administration and EPA under Administrator
Regan.

-------
First, last week, Dr. Karen Baylor and her team at American University published a peer review
case study finding that Washington D.C. residents in low-income neighborhoods between 2009
and 2018 were significantly less likely than those in wealthier neighborhoods to pay for full lead
service line replacement, and therefore, had an increased risk of harm from lead exposure due to
the partial lead service line. It seems obvious, but by documenting it in a statistically
representative manner, it should be useful to decision-makers like you and EPA.

Second, earlier this afternoon, five groups, the Childhood Lead Action Project, the South
Providence Neighborhood Association, Direct Action for Rights and Equality, the National
Center for Healthy Housing, and EDF submitted a civil rights complaint to EPA alleging the
Providence Water Supply Board's LSL replacement practices violate Title 6 of the Civil Rights
Act. It disproportionately increases the risk of lead exposure to black, Latinx, and Native
American residents because it expects residents to pay.

We ask that the Council monitor these developments and these complaints closely, but also to
encourage EPA to send guidance to state revolving loan fund program administrators that are
funding this work and make it clear to them to describe their obligations to proactively ensure
compliance with the Civil Rights Act of 1964 regarding lead service lines. Then, most
importantly, EPA needs to audit compliance at the state and local level for projects that disturb
drinking water mains. Thank you.

Mr. Michael Tilchin, NEJAC Vice-Chair: Thank you.

Ms. Ngozi Nwosu, Public Commenter: My name Ngozi Nwosu. Thanks everyone for the
opportunity to be part of this wonderful program. My comment is, for those of us that advocate
or run programs for communities that could be affected by environmental justice programs, is
there a database that is being created that could be used for future reference in terms of how
things should be handled or evaluated to best represent their interest?

Mr. Andy Kricun, NEJAC Member: I did want to reply to Mr. Neltner, the first commenter

-------
about the lead service lines. I agree with what he says completely. I think, even in a sense, the
risk is somewhat understated, but not only is there a disproportionate economic burden to people
of color who have less of a chance to be able to replace their lead service lines, but there's also a
chemical perspective. When you do a partial replacement and replace the part of the service lines
when it's on the public side and not replace the part that goes on the private side that goes from
the, say, the curb into the house, it actually accelerates the leaching of the lead into the water.
So, it actually makes it worse than leaving it alone, and so it is really critical that this be uplifted
to come by the EPA.

I'm from New Jersey, and I serve on the New Jersey Environmental Justice Advisory Council. I
had been advocating, and we're very grateful that the governor put a ten-year deadline for the
elimination of all lead service lines on both the public and private sides. I hope that can be
replicated across the nation. I think it's critical to increase SRF funding. It's critical to provide
that, but another thing we need to do is some utilities in some states are actually prohibited from
going on private property.

So, even if a utility is right thinking and wants to do the right thing, it may be prohibited by law.
So we have to come up with not only information for EJ communities but also templates for
communities to address these laws and how these laws change and maybe make drinking water
funding contingent upon that. It could be an issue, or it could be an opportunity. But the
problem with that is, when we do that, we might be actually adding another layer of injustice to
environmental justice because then they may not be able to get other kinds of water
infrastructure funding that they need. So, we do need to address this, but I feel that we have to
have a holistic approach on how to address the problem without harming the EJ community even
further. Thank you.

Dr. Benjamin J. Pauli, NEJAC Member: Andy essentially said what I was going to say. So, in
the interest of time, I withdraw my comment. Thank you.

Mr. Michael Tilchin, NEJAC Vice-Chair: Okay. Thank you. I just want to also note how much
we appreciate both Mr. Neltner's and Ms. Nwosu's comments. I think Ms. Nwosu raised a very

82

-------
interesting concept for us that there be essentially some formation of a database that can
demonstrate where disadvantaged communities have tackled similar environmental problems
that are prevalent in other communities and be able to kind of use that as a network to identify
best practices. So, very constructive and we thank both of you.

Mr. John Beard, Public Commenter: Good afternoon to the Council. My name is John Beard,
and I am the chairman and founder and CEO of the Port Arthur Community Action Network in
Port Arthur, Texas. I've listened to what you all have said and that some very good things have
come out of it. I'm going to do a little bit more exploratory work in the summary that you gave
concerning your EJ plan, and there are some very good elements in it. However, I want to bring
to you as quickly as possible an American horror story right here in Port Arthur, Texas, when we
talk about environmental justice and social justice and those issues and pollution.

My city, a city of about 53,000 was declared an environmental showcase community by the EPA
in 2010, whatever that meant because we are unduly burdened by industrial pollution. We are at
the nexus of what I call climate change. Hurricane Harvey hit in this area, dumping 60 inches of
rain. Can you imagine that? Over 5 feet of rain in this city where that morning after the storm,
when it did abate, people's homes were so flooded, the boats going down the street were
stepping off the boat onto the rooftops of homes. That is a direct result of climate change.
Because we're so close to the gulf, storm surges from these hurricanes affect us mightily.

We've had in the last 15 years five major hurricanes and at least that many smaller hurricanes,
two of which occurred last year almost back-to-back in August, which was Laura and Delta in
October. So, we are directly affected by the very things you're talking about in terms of climate
change, but we're also overburdened by pollution. Oxbow Calcining, a company of the Koch
brothers puts out 11,000 tons of S02, S03 particulate matter a year. If you go out on our
environmental justice website, you'll see that on a clear, beautiful blue day, going across the sky.
That's the air we breathe, as well as Valero with over 600 air quality violations in five years. We
are disproportionately affected by those floods because we have an almost 30 percent poverty
rate, and two-thirds of our citizens are economically disadvantaged.

-------
We are also home to the largest refinery in the country and several other smaller ones and a port
and many other industrial facilities. So, we're at the heart of all of this that's going on. What we
definitely need to come here is a sense of environmental justice to be restored in its effects on
our community. We have some of the highest unemployment in the state even with all of this
growth and development. That's only exceeded by those down in the valley, who have only
tourism, but we have heavy industry. Yet, our unemployment is twice the state national average.
From a health standpoint, we're affected because we have twice the state and national average
for cancer, heart, lung, and kidney disease. So, definitely, we are a horror story, and we've been
unduly impacted.

What I'm glad to hear you all talk about is also having local oversight over the initiatives that
you're proposing and one of those that you're going to have to have very great oversight over is
the justice for the initiative. If we're going to rebuild communities such as mine to improve the
flooding which I think in large part is caused by some forms of environmental injustice and also
social injustice because the whiter community surrounding Port Arthur remained high and dry
while we were underwater, over 80 percent of the city. So, we have got to find ways to use that
Justice40 initiative to not help companies that are Oreo or black on the outside but white on the
inside, but actually go help and grow and develop companies that are minority-owned and
operated that are going to put minorities that live here to work with whether that's chronic high
unemployment to help rebuild communities that get rid of the disparity, but also we depend on
the EPA to help clean up the air by stricter enforcement of those rules and laws.

If you go on our website, you will also see that we have information where we've used Title 6 of
the Civil Rights Act to help our communities, and the EPA has taken up that fight for us. We
expect good things to come from that because we have been unduly and overly impacted. It's
been said that Port Arthur has sacrificed so America could have oil and gas, but we should not
have to be sacrificed because everyone has a right to clean air and clean water and to live in a
clean, safe environment. So, I ask and beset this Committee, this Council to look into those
issues and one other thing as I close.

Director Regan took his so-called environmental justice tour of the South recently, but he

-------
skipped Port Arthur. He went right there less than 60 miles away from us in Moss Bluff and
went to Houston, which we're just 90 miles away from. But he didn't come through here where a
large portion of America's refining capacity is. What he said at the nexus of climate change I
find to be very puzzling. If it's about justice, then those who need and seek justice most need to
be addressed and need to be helped. So, once again, I thank you for your work.

I thank you for your input, and I want to also say that if there's anything that you will want or
need or require, come and visit Port Arthur, and I'll take you on the toxic tour and let you see
these things for yourself, and you can see what I'm talking about how it affects communities like
mine up and down the Gulf Coast and other parts of Texas and across America, but Port Arthur
is definitely and should be a focal point. So, I am my organization PACAN, Port Arthur
Community Action Network, stand ready to work with you to help make justice possible and
make justice reap. Thank you.

Ms. Nayyirah Shariff, Public Commenter: I'm Nayyirah Shariff. I'm the director of an
organization called Flint Rising, which is in Region 5, EPA Region 5, Flint, Michigan or the
traditional Anishinaabe lands, and this has been a very fruitful conversation. I enjoy listening to
the public comments. One of the things that I will say, we in Michigan have been struggling with
our state environmental regulatory agency, the Michigan Department of Environment. Great
Lakes Energy is a hot mess. We really need action for it not to be a hot mess, and it is, I will say
across agencies. Organizationally, we've been assisting with the recovery, the Flint water crisis,
and other crises around the date, and we're also part of this local coalition.

One of my many, many jobs is I used to be a trainer through all of the different fads. I think
when I started, it was diversity, then it became racial equity, now it's diversity, equity inclusion,
and we have to make sure that policies are in place, instead of just fads because you can't just be
in the heat of the moment, and it just feels good. It has to be matched with policy to ensure that
they're a success. With the Justice40 and —

Mr. Kurd Ali, NEJAC Support: She's completely dropped off.

-------
Dr. Fred Jenkins, DFO: If we can't get her back on or if she can hear me, can you please send
your comment in writing if you can on our website?

Mr. Anthony Paciorek, Public Commenter: I just wanted to say thank you, the NEJAC
Council, and thank you for taking the time to hear every one of our comments. My name is
Anthony Paciorek. I am an environmental justice organizer with Michigan United in Flint,
Michigan, Region 5 and also a coalition member with the same coalition that Nayyirah was
mentioning regarding a Stop Ajax Asphalt Plant currently in Flint, Michigan. It is being put up
near a predominantly minority community, and it is quite troublesome. I was really glad to hear
that you guys are increasing your work on your civil rights department and upholding those sorts
of actions as our community has been predisposed to numerous environmental injustices. We
had an incinerator that took years to get rid of. We have the ongoing lead crisis that we're
dealing with.

We have the discrepancies of our health system that are blatantly against minority communities,
and then we have a clean air crisis that will be certainly developing because, as Nayyirah
mentioned, our state agencies are trashed. They do not hold up the protective measures for
people. They haven't seen a permit that they don't like. So, we don't have faith in Michigan
because a lot of these processes are seven years ongoing, and we still haven't seen results I'm
afraid. So, unfortunately, it seems that a lot of these issues are going to be revolving around civil
rights violations as they are mainly for predominantly minority and poor communities.

So I'm glad that you're sticking to your guns and increasing that. I wanted to say thank you for
that. I also wanted to say thank you for having EPA Region 5 director Regina Clark and
Deborah Short show up on December 19th to have a conversation with residents of Flint. While
it was reassuring to have these conversations, I saw unfamiliar faces in that room. So, that made
me think that there were the right voices in the room. However, that meant there was a problem
with those voices being heard. I was thanked for my activism, but I had to ask Deborah Short if
she would be willing to be brave and to have conviction because the tools the agencies need to
ensure long-term health and access to the recovery we need, it needs to be a long-term
commitment, and it just can't rely necessarily on the goodwill of one ministry or another.

-------
You, as an Agency, must and should advocate for your own power to push these issues further as
you're seeing more and more, the state agencies are not doing what they need to, to protect the
citizens that they should. So, I want to say thank you for that. We're looking forward to having
continual communications with Ms. Short in a month or so as she agreed to have a follow-up
conversation. Ideally, I want to end this real quick here. I heard so many smart and wonderful
comments on all of you citizen scientists. I want to air quote that. I know you guys are doing
amazing work and just to say that you're a citizen scientist is underselling the work that we all
do. I didn't want to say that — I'm just about done. Sorry.

I do want to encourage you to be brave and to have that same conviction to find a way to commit
to these communities in the long term. As I stated, I am from Flint, Michigan. We are still in a
lead crisis. We still have to deal with this, even though state agencies have said that it's good and
it isn't. These communities that face these problems often need the commitment of such an
agency to get these processes done to take seven-plus, eight-plus years before we see justice.
So, I am very pleased with a lot of the work and efforts I've heard today and heard from the plan
for 2022 to 2024 or 2026, and I can't wait to be part of more of these meetings. Again, I can't
help but stress that you guys push for as much advocacy and agency, your own agency as well.
I just wanted to make certain that we remember our current administration. He said nothing will
fundamentally change. We need to push back against that hard.

-------
NEJAC WRITTEN PUBLIC COMMENTS SUBMITTED FOR 1.5.2022 MEETING

Region 1: Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont

Full Name (First and Last): Karen Spencer

Name of Organization or Community: None

City and State: Gloucester, MA (population size 30,162)

"New evidence questions existing policies about the safety of fluoride for babies' developing
brains. Given that safe alternatives are available and that there is no benefit of fluoride to
babies' teeth before they erupt or appear, it is time to protect those who are most
vulnerable." - Bruce Lanphear MD, PhD; Christine Till PhD; & Linda S. Birnbaum PhD in "It
is time to protect kids' developing brains from fluoride. " Environmental Health News (October
7. 2020)

"I would advise them (pregnant women) to drink bottled water or filtered water..." -

Dimitri Christakis, MD, MPH, editor in chief of JAMA Pediatrics on "Association Between
Maternal Fluoride Exposure During Pregnancy and IQ Scores in Offspring in Canada " (Ausust
19. 2019)

"(Fluoridation) is a civil rights issue I am calling for Fluoridegate hearings...." -

Ambassador Andrew Young, civil rights activist (Compilation of Civil Rishts Opposition 2016)
NEJAC -1 understand that many of you are still unaware that fluoridation policy damages the
health of millions of Americans with heightened susceptibility to harm in environmental justice
communities - scientific and medical facts which are supported by countless studies, many NIH
funded and published in recent years. This is not unexpected, as: 1) EPA scientists documented
that fluoride (a regulated water pollutant) is a 'gold standard' developmental toxicant with
substantial evidence of harm to humans (Mundy et al. 2009 & 2015). 2) LULAC identified
fluoridation as a civil rights violation in 2011, and 3)The 2006 National Research Council
recommended then that the MCLG be lowered as it was not supportive of health. Moreover, the
NRC chided the EPA that there was no evidence of safety to any population, let alone
susceptible subpopulations that included pregnant women & their fetuses, bottle-fed babies and
young children, the elderly and any with chronic conditions such as low-thyroid, kidney disease
or diabetes. Sixteen years later, and the EPA has failed to do address these gaps. Frankly, I am
appalled that the EPA continues to avoid admitting that evidence, ethics, environmental factors
and economics all are against fluoridation policy. I am attaching an annotated bibliography with
dozens of peer-reviewed published studies published since 2015 that support this statement.
I am also attaching a one-page handout that I prepared some years ago specific to environmental
injustice. For more on me, see my signature. I ask that you do whatever is in your power to
rectify this injustice, including, if possible, taking actions regarding the EPA position in the
ongoing TSCA lawsuit brought against it by the Food & Water Watch, et al. in U.S. District
Court, California Northern District (Food & Water Watch. Inc. et al v. Environmental Protection
Agency et al. Docket No. 3:17-cv-02162) BOTTOMLINE: If an individual doesn't believe
topical use of fluoride in dental products is sufficient for their needs, it is cheap to buy a gallon
of fluoridated drinking water. However, for low-income populations, many with circumstances
putting them at heightened risk of toxicity which include diabetes and CKD that
disproportionately affect EJ populations, it is very costly to have to purchase bottled water for all
consumption and in some cases topical use to prevent even more costly harm to bodies, bones

-------
and brains.

Full Name (First and Last): Jack Crowther
Name of Organization or Community: None
City and State: Rutland, VT (population size 15,398)

Dear National Environmental Justice Advisory Council: Our experience as a society beset with
problems points to a truism: When systemic problems develop, when numbers of people suffer
injury, the less advantaged suffer disproportionately. This is injustice. My specific concern is
fluoridation of public water supplies, a practice that science, ethics, and common sense
increasingly discredits. Fluoridation is known to have negative health impacts across a wide
spectrum that includes brain damage to infants, tooth mottling, bone fractures, harm to thyroid
and kidney function, gastric distress, and chemical sensitivity. Others will have provided the
peer-reviewed science to support these claims. What we all know by now is that economic
privilege can reduce the harm of health stresses. We know that the profiles of the certain
minority populations, notably Black, may include generally lower income, health vulnerabilities,
and toxic exposures driven by lack of housing choices. Ending fluoridation of public water
supplies will greatly reduce exposure to a protoplasmic poison, a developmental neurotoxin, and
an endocrine disruptor — all potentially harmful to people in general and particularly to those
whose environment, broadly speaking, makes them particularly vulnerable.	

Full Name (First and Last): Paul Connett

Name of Organization or Community: Fluoride Action Network

City and State: Exeter, NH (population size 14,306)

In 2015 I co-authored a 135-page paper entitled Water Fluoridation and Environmental Justice.
This paper was written in response to a request for public comment from the newly formed US
government Environmental Justice Interagency Working Group. Despite the many hours of work
I and other members of the Fluoride Action Network (FAN) put into this paper we received
neither acknowledgement nor a thank you from those who solicited public comment.
Nevertheless, some 6 years later much of what we wrote stands up well today and I encourage
Council members to give it a read. In particular, section 9 points out the lack of U.S. studies up
to that time (2015) which had seriously investigated fluoride's potential to cause harmful health
effects. There have been some very important developments since 2015. Two FAN initiatives in
2016 In 2016, FAN did two things which focused on fluoride's neurotoxicity, an issue FAN has
followed closely since its formation in 2000.

1)	FAN requested the National Toxicology Program (NTP) to undertake a systematic review of
all the studies (animal, human and cellular) pertaining to fluoride's potential to damage the brain,
and

2)	FAN petitioned the EPA under provisions in the TSCA law to ban the deliberate addition of
fluoridation chemicals to the drinking water supply because it poses an unreasonable risk to the
developing brains of children. A game-changing development in 2017 Both these initiatives have
yielded very important results as I will discuss below. Both were enhanced by a dramatic game-
changing development. Even though many fluoride-IQ studies have been published in China,
India, Mexico and Iran since the late 1980s, in 2017 the first of four US government-funded

89

-------
studies (Bashash, 2017, 2018; Green, 2019 and Till, 2020) were published in major journals
including Environmental Health Perspectives and JAMA Pediatrics. The earlier studies
(particularly from China), while yielding very consistent results, were of an ecological design
(exposures were based on community water levels not individual measurements) and a number
were at a higher concentration (2 to 11 ppm, see the 2012 Harvard meta-analysis of 27 studies,
Choi et al., 2012) than used in water fluoridation programs in the USA (0.7 to 1.2 ppm). The
very rigorous high-quality US government funded studies were based on individual
measurements of both exposure and outcome, controlled for a large number of confounding
variables and were conducted either in fluoridated communities at 0.7 ppm (Green, 2019 and
Till, 2020) or in communities with exposures (from other sources) in the same range as
fluoridated communities (Bashash, 2017 and 2018). Moreover, these US government funded
studies for the first time examined in utero exposure. Fetal exposure was measured via
examining the pregnant women's urine fluoride levels. Such measurements indicate total
exposure to fluoride from all sources, which allows comparisons between communities and
countries regardless of water fluoridation status. From the results obtained in both the Bashash
and Green studies it is clear that the most sensitive period as far as fluoride impacting brain
development is concerned (at least for boys) is during the fetal stage. However, Till's research in
2020 also showed that early infancy is another very vulnerable period. Till found a large
significant lowering of IQ for children who were bottle-fed in fluoridated communities in
Canada (F level = 0.7 ppm) compared to those who were bottle-fed in non-fluoridated
communities.

So while the water fluoridation debate has framed the issue of whether or not we should add
fluoride to the drinking water, maybe a better frame would be should we add fluoride to the
amniotic fluid of the fetus from its first day of existence! Based on the findings in the Bashash
and Green Studies the shocking conclusion is that today water fluoridation is causing a greater
overall loss of IQ points to America's children than any other factor including lead exposure and
preterm birth. This has been the most thorough review of fluoride's neurotoxicity ever
undertaken. Their final report is due in March 2022. Draft versions have indicated that of 29
High Quality (i.e. low risk of bias), 27 found a lowering of IQ. Of these 13 were conducted at 0.7
ppm or lower; another 5 conducted between 0.7 and 1.5 ppm and 5 at 1.5 ppm or higher. In other
words, the claim by fluoridation promoters that the lowering of IQ only occurs at much higher
concentrations than used in artificial fluoridation programs is false.

Please Note: finding a lowering of IQ at 1.5 ppm offers no adequate margin of safety when you
are exposing a large population of children to 0.7 ppm of fluoride in their drinking water. There
are two reasons for this a) children drink different amounts of water and b) there is a wide range
of sensitivity to any toxic substance among a large population. Typically, regulatory agencies
like the EPA would like a margin of safety of 10, in this case 1.5 ppm only offers a margin of
safety of 2. The TSCA lawsuit against the US EPA. In 2017, the EPA rejected our TSCA petition
on scientific grounds which allowed us to take the matter to Federal court (Region 9, San
Francisco). Our case was held in June 2020 (via Zoom - with 500 observers). FAN was able to
obtain expert testimony from Howard Hu (director of the ELEMENT cohort in Mexico City
which was used in the Bashash, 2017 and 2018 studies; Bruce Lanphear, a world-renowned
expert on lead's neurotoxicity and co-author of the Green, 2019 and Till, 2021 studies and
Philippe Grandjean, a world-renowned expert on mercury's neurotoxicity and author of a risk
assessment (BMD analysis) on fluoride's neurotoxicity (LINK). One couldn't imagine a more
qualified team to have available for establishing that the addition of fluoride to public drinking
water poses an unreasonable risk for the brain development of America's children. To almost

-------
everyone's surprise (including our own) for its experts the EPA lawyers chose not to use
scientists from the agency, but instead used experts from the firm Exponent, Inc. This firm is
notorious for being highly industry-friendly defending the safety of such chemical villains as
dioxins, PCBs, PFOS and Monsanto's glyphosate.

The judge in this case (Judge Chen) is following the science very closely and this trial offers the
world a rare opportunity to examine the science of this matter on a level playing field. In this
situation the EPA cannot expect any deference based on its regulatory authority. The Judge will
rule on the scientific merits of our case. One important concession made by Exponent's experts
is that the four US government-funded studies (Bashash, 2017, 2018; Green, 2019 and Till,
2020) included as evidence in our case, are the highest quality human studies on fluoride
conducted to date. The Judge has delayed his ruling on this case until he has been able to read the
final report of the NTP's review of fluoride's neurotoxicity) expected in March 2022,

Grandjean's BMD analysis, a study from Spain and possibly other studies which have been
published since June 2020 (of which there are several). Unless the EPA concedes the case, it is
anticipated there will be another round of expert testimony probably sometime in the fall of
2022. The glaring irony in this case, however, is that the science being presented as evidence for
the plaintiffs comprises the essential science EPA needs to revise its regulatory limits for fluoride
in drinking water (currently the Maximum Contaminant Level Goal (MCLG) and the Maximum
Contaminant level (MCL) are both currently set at 4 ppm, based on crippling skeletal fluorosis as
the most sensitive end point!) The need for such revision was the overarching conclusion in the
NRC's 2006 landmark report on fluoride in drinking water, a need EPA has not been able to
properly address since that report was published at their own (EPA's) request. A victory in our
lawsuit would most likely necessitate setting the MCLG at zero (like lead and arsenic) and the
MCL (an enforceable standard) no higher than 0.1 ppm, based on protecting children's brains.
Such an MCL would doubtless trigger opposition from states with high natural levels of fluoride
who would probably fight spending money to remove the natural fluoride from their water
supply. The beauty of FAN's TSCA lawsuit is that it begs that debate by simply calling for a ban
on the deliberate addition of fluoride to drinking water. So what has all this cutting edge science
have to do with the Environmental Justice community? In our 2015 paper we drew attention to
the many ways that communities of color are disproportionally impacted by fluoride. This is
especially true of fluoride's impact on the brain because inner city children are known to have
been historically exposed to higher levels of other neurotoxic substances in their air, water and in
local soils. Knowingly, adding to this burden is unconscionable. Fluoridation has been promoted
as closing the gap in dental care between rich and poor, which is certainly a noble intention but
whether that has been achieved or not is debatable (see the Cochrane Review of 2015 which
found "insufficient evidence to determine whether water fluoridation results in changes in
disparities in caries levels across socio-economic status" ) it is time a safer way be found to bring
better dental care to low income families. Childhood tooth decay notoriously remains at
epidemic levels in the inner cities and other disadvantaged areas. The quickest and simplest way
of achieving better dental care as well as improving the overall health of communities of color.
In our 2015 paper we provided some very positive suggestions on how better dental care could
be delivered to low income families and communities of color, which would not only improve
dental care but also improve overall health and community well-being. I urge you to review
section 22, on page 64 of our 2015 paper. Finally, on behalf of all the disadvantaged and
disproportionately harmed environmental justice communities who have no choice but to drink
fluoridated tap water, FAN hereby requests that WHEJAC recommend, in strongest terms

91

-------
possible, that EPA leadership resolve to concede in the referenced TSCA lawsuit. Thank you for
this opportunity to contribute to your valuable mission during these challenging times.

Full Name (First and Last): Rick North

Name of Organization or Community: None

City and State: Wellesley, MA (population size 28,747)

My name is Rick North. I'm the former executive vice president (CEO) of the Oregon American
Cancer Society and former project director for the Oregon Physicians for Social Responsibility.
Now retired, I have over 30 years' experience in nonprofit health and environmental
management. Most of my life I believed the CDC's and American Dental Association's
assertions that water fluoridation was "safe and effective." When I actually examined the
science, I was taken aback. Fluoridation's effectiveness was minimal, at best, and there were
numerous associated health risks, as identified by the National Academy of Science's (NAS)
authoritative 2006 review, Fluoride in Drinking Water

(https://www.nap.edu/catalog/11571/fluoride-in-drinking-water-a-scientific-review-of-epas-
standards). Since its publication, hundreds of other peer-reviewed, published studies have added
even more evidence of these risks. My main purpose in writing is to document the evidence that
fluoridation harms, not helps, low-income families. First, please consider fluoridation's lack of
effectiveness and clear evidence that fluoride's preventive actions are mainly topical, not
ingested. The Cochrane Collaboration is considered the gold standard for evaluating
effectiveness of medical interventions. Its 2015 report on fluoridation
(https://www.cochranelibrarv.com/cdsr/doi/10.1002/14651858.CD01Q856.pub2/fuin found
4,677 published studies in its exhaustive literature search. Of those, only 277 studies qualified
for the first round of review, with 155 meeting Cochrane's highest quality criteria for inclusion
in the study.

The report concluded "There is insufficient evidence to determine whether water
fluoridation results in a change in disparities in caries levels across socio-economic status."

(https://fluoridealert.org/articles/fan-brochure-fluoridation-efficacv-one-pager/) CDC itself has
said .. fluoride prevents dental caries predominately after eruption of the tooth into the
mouth, and its actions primarily are topical for both adults and children."

(http s: //www, ede. gov/mm wr/previ ew/ mm wrhtml/ mm4841al. htm) Even CDC's belief that
fluoridation results in a 25% reduction of caries, which in itself is highly questionable, only
equates to half a cavity per child. Finally, World Health Organization data clearly show that
cavity rates in children have dropped as much in nations that don't fluoridate as in nations that
do. (https://fluoridealert.org/issues/caries/who-data/) Then consider ingested fluoride's health
risks, which, as cited in NAS's Fluoride in Drinking Water, include brain damage,
hypothyroidism, kidney damage, diabetes and fluorosis. To take just one example, neurotoxicity,
please note the National Toxicology Program's 2020 systematic review
(https://fluoridealert.org/wp-content/uploads/ntp.revised-monograph.9-16-2020.pdf). which
found compelling data linking fluoride to IQ loss in children. Several of the most recent studies
were on pregnant women consuming fluoride or babies being fed formula mixed with fluoridated
water: - 25 of 27 of the studies determined to be the highest quality linked higher fluoride levels
to substantially lower IQs - 11 of 11 studies detected this IQ loss at levels found in fluoridated
water. Low-income families also use more infant formula. A 2019 high-level Canadian study
funded by the U.S. National Institutes of Health determined that babies fed formula mixed with
fluoridated water averaged 4 IQ points less than those mixed with non-fluoridated water, 9 points

-------
lower in non-verbal IQ.

(https://www.sciencedirect.com/science/article/pii/S01604120193261457via%3Dihub)
The chances for academic achievement for low-income children and future success as adults are
already diminished by poor nutrition and other environmental pollutants, such as lead in pipes, as
shown in Flint, MI and other cities. It is not right to expose them to another toxic substance
further reducing their capabilities. Cheap water filters don't eliminate fluoride. Low-income
families can't afford expensive filters (typically at least $300/$400) or bottled water to avoid the
health risks of fluoridated water. They have no choice. And since Black and Hispanic families
are more likely to be below the poverty level, they are disproportionately harmed. Such notable
Black civil rights leaders as former U.N. ambassador Andrew Young, Rev. Gerald Durley and
Rev. Bernice King, daughter of Martin Luther King, Jr., have publicly opposed fluoridation. And
LULAC, the nation's oldest and largest Hispanic advocacy organization, is also formally
opposed. (http://fluoridealert.org/wp-content/uploads/FAN-Environmental-Justice-Brochure-
Final.pdf) If people want fluoride, they can get it very inexpensively in toothpaste or mouthwash
and apply it topically, where it's most effective. But no one should have the right to force anyone
else to ingest a drug that they don't want in their drinking water. This is clearly a social and
environmental justice issue. Fluoridation is unethical for low-income families and should be
ended immediately. Thank you for your consideration.

Region 2: New Jersey, New York, Puerto Rico, US Virgin Islands

Full Name (First and Last): Raveendran Narayanan

Name of Organization or Community: Air Conditioning the Mother Earth

City and State: Jamaica Queens, NY (population size 109,495)

Brief description about the concern: FAR CASE- 2021-016/ AIR CONDITIONING THE
MOTHER EARTH (Climate Change Third Group by Raveendran Narayanan USA) EARTH
SCIENCE CONFERENCE COMMITTEE Zurich Switzerland awarded certificate during
September 2018 "Air Conditioning the Mother Earth ".

What do you want the NEJAC to advise EPA to do? : NOT C02 & GHG, C02 is FOOD
AIR CONDITIONING THE MOTHER EARTH (Climate Third Group by Raveendran
Narayanan USA)

"Why Raveendran Narayanan USA is different from 31, 847 CLIMATE AND GLOBAL
WARMING SCIENTISTS?

Region 3: Pennsylvania, District of Columbia, Maryland, West Virginia, Virginia,

Delaware,

Full Name (First and Last): Judith Robinson

Name of Organization or Community: Susquehanna Clean Up/Pick Up, Inc.

City and State: PHILADELPHIA (population size 1,603,797)

Brief description about the concern: Issues of Environmental Justice are a close as one nose
and lungs but are often overlooked in an urban setting. Climate Change, sustainable, concerns
only become real when we discuss " Green Jobs." Air Quality - Post Demolition in a gentrifying
community make these issues relative. The way we reach the discussion of the benefits of tree
canopy is really different in an urban community wronged in the past. Funding is important...as
much of this work is done on a shoestring budget.

-------
What do you want the NE JAC to advise EPA to do? : Please consider funding in urban
settings. Air quality, Land Use, Flooring, Heat Islands, Tree Maintenance

Full Name (First and Last): Carolyn White

Name of Organization or Community: Pughsville Civic League and Community
City and State: Chesapeake and Suffolk Virginia (Pughsville - population size 30,626)

Brief description about the concern: The two cities we are comprised of have funding for our
drainage from VDOT (began in 2006 with the Devolution Road Takeover for Suffolk Va.)
Chesapeake gets funding no contract but all Hampton Roads cities were given funding then to
make our streets the VDOT Urban System with drainage, gutters and sidewalks. Both cities
continue to receive yearly funding from VDOT, now the American Rescue Plan and Biden's
Infrastructure funds. Chesapeake now says $886,000 in the account for Pughsville. Suffolk has
more than $5 million supposedly for Pughsville. The work has not begun. Now Suffolk says $7
million is needed. They plan to put pipes down one street and develop a retention pond. The
CASA Investment developer said he has already piped the street and built two houses on the
main drainage in which Suffolk permitted him to do. Now, since they are planning this "big lie"
to pipe the same street, they have recently " Stopped Order for CASA Investments company and
stated a possible violation. They have him doing the work the city should have done in 2006 and
now it makes them look bad to the residents, so they stopped him from completing the work.
Suffolk and Chesapeake need to be audited and looked into. We have paid storm drainage fees
on our taxes since 2006. We have a letter from Council of the City of Suffolk stating they have
never put any storm water management work in the Nansemond taxing district. The CASA
Investment Developer (Scott Dovenspike) stated Suffolk should return the communities' funds as
there is no storm water management in the area. We have stated this to the cities and to the DEQ
of Norfolk, VA (David Taylor). We are not asking EJA for more money; we need help getting
the two cities to let go of our funding in order to get drainage, sidewalk for Townpoint Road and
Wise St (two major thoroughfares) and guttering to carry the water out of the area. They have
built new developments all around and in Pughsville and yet refuse the African Americans
Communities any relief. We need help. We have documents, pictures, emails, letters,
everything to show what is happening here. The lawyers need money and Pughsville has no
funds to pay lawyers such magnitudes of dollars to have them side with the big bucks the cities
will give them to keep quiet. As the song goes "Come see about Me" (Us)! The bogus plan is
going to Suffolk Council on Jan. 12 at 6:00p.m. in which their plan is to tear up the same John
Street CASA Investments has completed Suffolk's work. They also plan to buy out two older
homes (families live in) to place the retention pond. This is not for Pughsville drainage, but the
other developers have looked at those properties to build. They have an auction to get the other
properties across from the two homes. We see the PLAN!!!!

What do you want the NEJAC to advise EPA to do? : We ask that an investigation, audit, or
look at our documents to Seek how we can get the government and VDOT to provide mandates
to get our drainage taken care of. Suffolk says it will be 2023 before they do anything. They do
not clean the ditches to have the water to flow. Help is urgently needed. The walk thru the area
like you mentioned at the last meeting to see the complaints listed here. If I need to speak at the
meeting I will. Your list of speakers is extensive and three minutes is not enough time to discuss
the matter at hand. Thanks for your consideration in this matter.

-------
Full Name (First and Last): Dave Arndt

Name of Organization or Community: Self

City and State: Maryland, Baltimore (population size - 583,923)

Brief description about the concern: Hello. My name is Dave Arndt, a Baltimore Maryland
resident and a Climate, Environmental and Social Justice advocate. These three areas have a lot
of overlap and I am going to focus on topics at the intersection of these areas. Unfortunately, by
plan, all of this injustice is burdened on Black, Brown and low-income areas. Today I am going
to focus on a neighborhood in Baltimore called Curtis Bay. About a week ago, there was a
thunderous explosion at the CSX Coal Terminal there. Surrounded by mountains of black coal,
the tall metal silo routinely emits acrid odors and leaves a coating of particulates on windows,
cars and lawn furniture. For years community leaders have been trying, without success, to get
federal, state and local officials to do something about the facility and others in their industrial
waterfront community. Maybe now, with this catastrophic event, someone will pay attention,
but probably not. Afterall, CSX's air quality permits are all in compliance with state and federal
environmental regulations. In addition to the coal terminal, this area is home to a medical waste
incinerator, a trash incinerator, a major interstate highway, a rendering plant, various chemical
factories, a sewage treatment plant and the city's Landfill site. All in compliance. Something is
wrong here; The Baltimore region ranks among the worst in the U.S. for air pollution. Baltimore
City has asthma at twice the rate of the rest of the country, and the hospitalization rate for
pediatric asthma is one of the highest in the nation. Residents are dying and everything is in
compliance. There are three major reasons for this: 1) Individual regulations are not strict
enough, they put profit and jobs over the health of residents, 2) Regulations are done
individually, there are no cumulative effects. When people breath, they can't choose which
pollution source they are breathing in, they get it all, 3) Environmental injustice. This was all
done by design. If this was a wealthy white neighborhood, this would not be happening. I have
heard hundreds of stories like this all across this nation.

What do you want the NEJAC to advise EPA to do? : It is time for the EPA to act like an
agency for all the people and a healthy environment.

Region 4: Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South

Carolina, Tennessee,

None

Region 5: Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin,

Full Name (First and Last): Dr. Jim Van Keuren

Name of Organization or Community: College of Education, Ashland University, Ashland,
Ohio

City and State: Brook Park, Ohio (population size 18,617)

Brief description about the concern: Add a Performance Goal: by September 30, 2024, Create
a Study Group to Review the Presumptive List of Conditions for those Individuals who were
exposed to Toxins at Superfund and other like sites.

-------
What do you want the NEJAC to advise EPA to do? : This performance goal would be added
to: Cross Agency Strategy 2: Consider the Health of Children at All Life Stages and Other
Vulnerable Populations.

EPA Superfund detailed data on populations between 1 and 3 miles of Superfund sites make up
approximately 22% of the population of the United States. It appears that this data fits with the
Cross Agency Strategy 2 which centers on children and vulnerable populations.

I couldn't stay for the public comment period. I would like a copy of the document before
today's comments are incorporated. And I assume I will automatically receive the document
that includes today's edits. In Goal 7, the wording should include ... Chemicals and
radioactive isotopes.... Radioactive waste remains on site after a nuclear power plant is
dismantled. What to do with this waste has flummoxed scientists, politicians and military
minds for about 75 years, and it's still at the sites where it was created — nuclear power
plants. The history of ideas and frustrations in this regard is a story of scientific/engineering
failures in the attempt to find a "use" for it, or — barring that it can be made "useful" — a
place to put it. But the only "use" leaders have been able to figure out is a more-waste-
producing process for separating the extremely dangerous bomb-generating isotope 235Pu
(Plutonium 235) and the also deadly Uraniums 235U, also "useful" for bombs (Hiroshima) and
238U, called Depleted Uranium; but, it's just uranium, not depleted at all. 238U has a very high
mass and thus is used to harden bullets and tank bodies. So nuclear waste is "useful" — for
war. But war only uses a small portion of the waste so the rest of it is stranded. "Where to put
it" is truly a saga in the political sense because it's a decades-old story of grassroots resistance
supported by Nevada politicians (and now New Mexico and Texas politicos). Few of us (I
mean the people, mostly white, who took over this land) are able to psychologically access
the wisdom of those who lived here for thousands of years, who understand this terrible
situation, and who see what must be done. "We" think there will be a way to dump it and
forget it, like we do our garbage, our plastic gee gaws, our out-of-fashion clothing, the
products of combustion (CO2), and our sewage. Maybe you've noticed a salient fact: all that
stuff is still here. FORGOTTEN BUT NOT GONE. We won't be able to dispose of and
forget about spent fuel from nuclear power plants. We'll have to develop a system for dealing
with it for as many generations as it remains dangerous. Unfortunately, it is very dangerous,
it lasts a long time and it's all ours. The Anishinabek/Iroquois along with a Canadian, Dr.
Gordon Edwards, have a plan for doing this. It won't be easy and certainly not cheap. The
alternative is unthinkable if we care about communicating with and protecting future
generations.

Region 6: Arkansas, Louisiana, New Mexico, Oklahoma, Texas,

Full Name (First and Last): Coz Lamore

Name of Organization or Community: Choices Interlinking Inc-Alliance
City and State: Kilgore, Tx (population size 14,962)

Brief description about the concern: Environmental disasters such as chemical spills &
industry-caused poisoned air & water are manmade pollutions that intentionally target Black and
brown people.

Structural disasters such as mass incarceration and homelessness are linked to incompetent
systems that target especially Black people. Environmental, climate and social injustice all create

-------
greater & greater barriers that exclude and ostracize Afro-Americans from equitable
opportunities that are offered to others.

What do you want the NEJAC to advise EPA to do? : We seek: A shift in decision-making
processes and power as one measure for undoing institutional racism. EJ. communities want to
be equitably included in evaluating and determining standards for health and safety. It is our
people who are dying, and it is our inter-generational health and safety that is being sacrificed
due to unchecked environmental harm. These life-endangering decisions should not be left solely
to those far removed from harm, who monopolize institutionalized power and control. We
further want: To be included with equitable decision-making power and systemic support in
determining restitution, reparations, and access to opportunities for resiliency in safe and healthy
environments. Current systems & structures rely almost exclusively on structures and authorities
that do equitably value the loss and suffering of Black and brown people who have been most
harmed. The people who are being harmed need to be heard and responded to.

Full Name (First and Last): Cemelli de Aztlan

Name of Organization or Community: Centro Fronterizo del Obrero (dba) La Mujer Obrera
City and State: El Paso, TX (population size 963,000)

Brief description about the concern: EPA finally designated El Paso County as an ozone
nonattainment area in Nov. 2021. This is a major victory for air quality and environmental
justice in our community, to hold polluting industries accountable. The EPA, Texas Commission
on Environmental Quality (TCEQ), and others will be making decisions over the next year that
will determine whether this victory is transformative in terms of reducing pollution in our
community, or not. TCEQ has already stated, on record, that it disagrees with the EPA's
designation, and they are seeking to reverse this victory and return to the status-quo. El Paso-Las
Cruces is currently classified as a "marginal" nonattainment area. That means it is subject to the
lowest level of regulation. In marginal areas, new industrial sources are required to install
additional emission controls and purchase offsets, and infrastructure projects that receive federal
funding must undergo additional environmental review, but there are no requirements for
existing industrial sources. TCEQ is not required to develop a plan to reduce emissions from
existing industrial sources unless El Paso-Las Cruces is reclassified as a "moderate"
nonattainment area. Under the Clean Air Act, an area is ordinarily reclassified as moderate if it
fails to attain the ozone standard within 3 years. Though, the complication is that Section 179B
of the Clean Air Act provides that an area is not reclassified from marginal to moderate if a state
can show that it would attain the standard "but for emissions emanating from outside of the
United States." Section 179B was actually written specifically with El Paso in mind, which is the
largest binational community in the world and has the largest concentration of maquiladoras
along the border, a majority of them (63%) are US based Fortune 500 companies producing
pollution and highly toxic waste. Recent data modeling showed Mexico contributing about 7
parts per billion to ozone levels in our community, which is reporting an ozone value of 78 parts
per billion. If you subtract the 7 parts per billion attributable to Mexico, you still have an ozone
value of 71 ppb, which is above the standard. We ask the EPA to reclassify the El Paso/Las
Cruces area from "marginal" to "moderate," which would result in regulation of existing sources.

What do you want the NEJAC to advise EPA to do? : We ask that the EPA reject the 179b
exemption, which is based on a dangerous and exploitive loophole. The reality is: US industries

-------
have been and are currently violating the ozone standard even if emissions from Mexico are
excluded.

Full Name (First and Last): John Mueller
Name of Organization or Community: None
City and State: Tulsa, OK (population size 402,324)

Dear NEJAC Leadership and Members, please know how much I appreciate, as the sixth public
speaker in last Wednesday's public meeting, that my brief presentation this time clearly got some
very real and important traction for the road ahead. My thanks especially go to NEJAC Chair
Orduno and Vice Chair Jelks for confirming the assignment of the fluoridation issue to the Water
Infrastructure Workgroup. Cutting to the chase, I suggest again that the road ahead leads to
finally ending the allowed addition of a treatment chemical, fluoride, to the public drinking
water, whose sole purpose is not to treat the water for safe consumption, but to indiscriminately
treat the consumers of that water for a medical condition, whether the consumer has the treatable
condition or not. The most commonly added fluoridation chemical is a persistent environmental
pollutant, fluorosilicic acid (FSA), as confirmed in the attached letter from the EPA's Office of
Water, hanmerl983.pdf. Please share this with the current Office of Water when contacted in
the future as mentioned in Wednesday's meeting in partial response to my presentation. You
may wish to also consider and mention during that contact the more recent (2015) nearly $2
billion settlement with Mosaic Fertilizer LLC for future remediation of its unlawful discharge of
hazardous wastes produced in its phosphate mining and fertilizer manufacturing operations in
Florida and Louisiana, https://www.justice.gov/opa/pr/major-fertilizer-producer-mosaic-
fertilizer-llc-ensure-proper-handling-storage-and-disposal. The identified hazardous wastes
include FSA, as seen listed with other specified hazardous wastes, for example, in the consent
decree with the Florida DEP,

https://www.justice.gov/sites/default/files/enrd/pages/attachments/2015/10/02/mosaic_consent_d
ecree_appendices_florida.pdf

Also attached is the current TSCA lawsuit, originally filed April 18, 2017, which I have
mentioned previously in earlier public comment submittals. EPA can initiate the paradigm shift
away from promoting the CDC's Community Water Fluoridation (CWF) program toward a new
paradigm with proven alternatives, developed under Justice40 directives, entirely apropos for
building the capacity of localized and targeted oral health care programs where needed most - the
disadvantaged communities where fluoridated tap water has been their only affordable option,
but without their informed consent or other public approval. By conceding to the plaintiffs via
an express directive from Administrator Regan, EPA is conveniently afforded the simplest and
most plausible and expeditious means to initiate the needed paradigm shift. Most of the rest of
that shift, of necessity, will be on the shoulders of the CDC in response to EPA's eventual
regulatory rulemaking, absent a more desirable executive order to impose an immediate
moratorium on any further CWF promotional activity. I fully realize and acknowledge the
existence of obstacles and challenges that multiple powerbrokers and decision-makers will run
up their respective flagpoles, metaphorically speaking, with far reaching, vested interests in
continuing the promotion of the CWF program. Not only does the CDC's Division of Oral
Health appear to rely on CWF as its life-blood business activity, but numerous groups who have
long supported and promoted CWF will have vast and daunting public relations challenges to

98

-------
work through with a paradigm shift to alternative programs for promoting oral health. Certain
segments of the mining and manufacturing industry, for example the Mosaic Company, will have
to start incurring costs to properly dispose of their hazardous fluorosilicic acid (FSA) instead of
selling it to fluoridating drinking water utilities. I am well aware of all of this. But I also know
what we all know, that protecting the developing brain is far more important than protecting
teeth. Obviously, the benefits of fluoridation cannot possibly not outweigh the risks. Thank you
again for your attention to this important matter and the opportunity to make it available to you.
I plan to share much of it at the next WHEJAC public meeting later this month.

Region 7: Iowa, Kansas, Missouri, Nebraska,

None

Region 8: Colorado, Montana, North Dakota, South Dakota, Utah, Wyoming,

None

Region 9: Arizona, California, Hawaii, Nevada, the Pacific Islands,

Full Name (First and Last): Piper Perreault
Name of Organization or Community: Freebirds
City and State: Novato, CA (population size 55,642)

Brief description about the concern: Fluoridation of water

What do you want the NEJAC to advise EPA to do? : We need to remove fluoride from our
public water supplies. It is a known neurotoxin. The only studies that cite the good of
fluoridation is outdated, and not rigorous studies. People who think fluoride is good are simply
uninformed. And poorer communities do not have access to information about the harms of
fluoride and are often unable to afford filters that filter fluoride out, such as reverse osmosis
systems (which are expensive and create a lot of wastewater). This is an actionable clear issue
that EPA can solve...clean water now. It is hypocritical to not have taken toxic fluoride out of
water systems already as it has been a known neurotoxin for decades.

Full Name (First and Last): Jose Flores

Name of Organization or Community: Comite Civico del Valle
City and State: Imperial County, Ca. (population size 181,215)

Good afternoon, I am Jose Flores and currently work with Comite Civico del Valle in
Brawley, Imperial County, Ca. I was happy to hear the uplifting messages from Administrator
Regan and EJ Director Tejada. Having had the pleasure to meet the Deputy Administrator a
few years back when she visited Comite Civico and also meeting Administrator McCarthy as
well at a visit to the White House in 2016, it is good to hear how the new administration has
been taking action. My public comment is in regard to the critical mineral [lithium] that has
been found by geothermal companies in our region. We hope if lithium extraction really
takes off it is truly done with minimal carbon footprint. The possibility of this great venture is
something our county is keeping an eye on, since Imperial County in SE California by the
Arizona/Mexico border is the most economically/environmentally impacted out of
California's 58 counties. Since the lithium is literally adjacent to the Salton Sea we envision
how possibly the environmental issues in this largest lake in California may also be mitigated.
We understand time is of the essence and EPA Administrator made reference to speed dealing

-------
with initiatives, but we want to ensure community stakeholders being included in
conversations dealing with equity. This in reference to that old saying " if you want to go fast
go alone but if you want to go far go together". The inclusion of people of color that are
grassroots and traditionally don't engage in such discussions is our priority; it should not be
only with the "status quo' stakeholders that already have platforms to voice their opinions.
Also I want to highlight the discussion in your meeting in regard to safeguarding agricultural
workers whether documented or not. In our county we have hundreds of young men brought
from Mexico with visas that stay in our local hotels for months. On the surface it looks like a
win/win for both parties, but the reality is these workers cannot really voice concerns (like
pesticides) if they arise.	

Region 10: Alaska, Idaho, Oregon, Washington,

None

100

-------
NEJAC ADDITIONAL WRITTEN PUBLIC COMMENTS CONT.

Additional written public comment materials are available in the public docket of this meeting.
The public docket number for this meeting is EPA-HQ-OA-2021-0848. The public docket is
accessible via www.regulations.gov under its docket number, EPA-HQ-OA-2021-0848.

101

-------
CLOSING REMARKS & ADJOURN

Dr. Fred Jenkins, DFO, thanked everyone for their hard work. He reminded everyone that the
final meeting minutes and the meeting summary will be made publicly available within 90 days
after the close of the meeting. He adjourned the meeting.

[WHEREUPON THE MEETING WAS ADJOURNED]

102

-------
NEJAC MEMBER LIST

November 2021

National Environmental Justice Advisory Council
Contact List - November 2021

U,S. Environmental Protection Agency

Matthew Tejada, PhD

1200 Pennsylvania Avenue, NW

Washington, OC 20460

Director

Office of Environmental Justice
U.S. Environmental Protection Agency

Work.; |202j 564-S047

Email: teiada.matthew®erM.pov

I1 red Jenkins., PhD

1200 Pennsylvania Avenue, NW

Washington, QC 20460

DESlCiNAIED FEDERAL OFFICES
Office of Environmental Justice

Work; (202)566-0544
Email: ien*ins .fred (Sicca,eov

George QE Ward, MPA
1200 Pennsylvania Avenue, NW
Wash ngton, OC 2Q460

NEJAC Program Manager
Office of Environmental Justice

Work: (202) 564-3339
Emaif: wa rd.treorEeiWeoa.Bov

National Environmental Justice Advisory Council

Chair & Vice Chairs

EPA Region 5
¦Sylvia Orduiio {Chair)

Detroit, Michigan

Organizer

Michigan Welfare Hights Organization

EPA Region 4

Na'T.ikl Osborne Jellts, PtiO <[vke
Chair)

Atlanta, Georgia

Board Chairperson/Co-Chair

West Atlanta Watershed Alliance/Proctor Creek

EPA Region ?

Michael Tllchiii (Vke-Chair)
Betheida, Maryland

Senior Consultant
facobs engineering



National Environmental Justice Advisory Council Members

Academia (5)

EPA Region 2

April Karen RapTiste, PhD

Hamilton, New York

Professor

Environmental Stud)??, and Africa no and latin American Studies
Colgate University

FPA Region 4 & 5

Jan Marie Fritz, Phu, CX.S

Palm City, Florida

Professor

School of Planning

University of Cincinnati

FPA RegicMi«

Jill Lindsey Harrison, PhD

Boulder, Colorado

Associate Professor
University of Colorado Boulder

EPA Region S
Benjamin J. Pauli, Phu

Flint, Michigan

Assistant Professor
¦Deportment of Literal Studies
Kettering university

LPA Region J

Sandra Whitehead, PhD, MPA

Washington, OC 200O2

Assistant Professor & Program D rector
Sustainable Urban Planning
GeotQe Washington University

1

103

-------
Noverrber 2021

Business / Industry (4)

EPA Region 4
Jabari 0. Edwaidv

Columbus, Mississippi

Chief Executive officer
J5 GBij. UC

EPA Region 3
Venu Ghanta

Washington, DC

Vice President

Federal Regulatory Affairs and Environmental Policy
Duke Energy

EPA Region 6
Virginia King

fnendswood, TX

Director

Sustainability and Stakeholder Engagement
Marathon Petroleum LP

EPA Region 3

Michael Tilchin (see Vice -Chair)





Community-Based Organlmloinj jS]

EPA Region 9

Rev. Dr. Ambrose Carroll, Sr.

Oakland, California

Senior Pastor
Green The Church

EPA Region l
Letida Colon de Mejlas
Windsor, Connecticut

President and Founder
Green ECO Warriors

EPA Region e
CemeM De Aitian
0 Paso, Texas

Community Organizer
iff Mu/er Obrera

EPA Region A
Midred Mcclain, PhD

Savannah,. Georgia

Executive Director

Citizens for Environmental Justice and Harambee House, Inc.

EPA Region 1
Sofia Owen, JD

Roxbury, Massachusetts

Staff Attorney & Director

Environmental Justice Legal Services (EJLS)/Aiternatives for Community &
Environment {ACE)

EPA Region 3
Jerome Shabazz

Philadelphia, Pennsylvania

Executive Director

JASTECH Development Services Inc. and Overbrook Environmental Education
Center

EPA Region 7
Pamela Talley

St. Louis, Missouri

Executive Director

Lewis Place Historical Preservation, inc.

EPA Region 4

Na'Taki Osborne lelks, PhD (see Vice-
chair)





Non-Government Organizations (6)

EPA Region 2
Brenda Torres Barreto
San Juan, Puerto Rico

Executive Director

Son Juan Day Estuary Program

EPA Region 2
Andy Kikun

Erial, New Jersey

Senior fellow
US Walter Alliance

EPA Region 9

3oaid Member

2

104

-------
November 2021

Ayako Nagano, JO

Berkeley, California

Common Vision

EPA Region 5
Jeremy F. Orr, JD

Chicago, Illinois

Safe Water Initiative

Natural Resources Defense Council

EPA Region 6

Jacqueline D. Shirley, MPH

Albuquerque, New Mexico

Rural Development Specialist

Rural Community Assistance Corporation

EPA Region 5

Sylvia Orduiio (see Chair)





State and local Government (4)

EPA Region 9
Felicia Beltran

Phoenix, Arizona

Civil Right? Compliance Manager
Arizona Department of Transportation

EPA Region 7
Charles Bryson

St. Louis, Missouri

Director, Civil Rights Enforcement Agency
City of St Louis Civil Rights Enforcement Agency

EPA Region 10
Millie Piazia, PhD,

Olyrnpia, Washington

Environmental Justice Manager
Washington State Department of Ecology

EPA Region 4
Karen Spray berry

Columbia, South Carolina

Advisor to the Director of Environmental Affairs

South Carolina Department of Health and Environmental Control



Tribal/ Indigenous Government and Organizations (4)

EPA Region 10
Joy Britt

Anchorage, Alaska

Alaska Native Tribal Health Consortium

EPA Region 8

Scott Clow (EPA NTC Member)

Tcwaoc, Colorado

Environmental Programs Director
Ute Mountain Ute Tribe

EPA Region 8
John Doyle

Crow Agency, Montana

Water Quality Director
Little Big Horn College

EPA Region 6
Jonathan Perry

Crownpoint, New Mexico

Presid«nt
Becenti Chapter

105

-------
NEJAC Public Meeting Attendee List

First Name

Last Name

Organization

Bridget

Coyle

US EPA Region 9

Jennifer

McDonnell

New York City Department of Sanitation

Carolyn

Dick Mayes

U.S. EPA

Nettie

McMiler

U.S. EPA

Erin

Broussard

AEPCO

Jenna

Brinkworth

Tobacco Free RoswellPark

Jane

Kloeckner

Kansas University

Emily

Benayoun

U.S. EPA- Region 6

Cynthia

Peurifoy

None

J.

Herkimer

Housatonic Environmental Action League, Inc.
(HEAL)

Renee

Kuruc

HBK Engineering

Emily

Ryan

U.S. EPA

Marnese

Jackson

Midwest Building Decarbonization Coalition

Ronald

Ross

Northwood Estates Community Org

Adesuwa

Erhunse

U.S. EPA

Janice

Horn

Tennessee Valley Authority

Ashley

Oleksiak

Alaska Dept. of Environmental Conservation

Natasha

DeJarnett

University of Louisville

Patrick

Beckley

EPA

Ugbaad

Ali

EDF

John

Tocornal

Amazing Science Parties (A Family Company)

Taaka

Bailey

MDEQ

Adrienne

Gossman

LDEQ

Suzanne

Yohannan

Inside EPA's Superfund Report

Michele S

Paul

City of New Bedford, MA

Sofia

Benito Alston

ACCD

Hannah

Humphrey

MODNR

Jenn

Clarke

City of Richmond

Matthew

Greene

U.S. Fish and Wildlife Service

Stacey

Dwyer

U.S. EPA

Kathleen

Deener

U.S. EPA

Patrick

Bigsby

Iowa Department of Natural Resources

Natalie

Shepp

Pima County Department of Environmental
Quality

Alyse

Rooks

Environmental Defense Fund (EDF)

Rusty

Hazelton

U.S. EPA

Sims

Brad

Exxon Mobil Corporation

Reginald

Harris

U.S. EPA Region 3

Osmond

Lindo

Environmental Protection Agency

106

-------
Denisse

Diaz

U.S. EPA

Cynthia

Sanchez

IEPA

Elder

Jacqueline

V

Norris

WomEnviro Climate Social Justice Marginalized
Communities Collaboration

Haley

Ilg

Marathon Petroleum

Judith

Kendall

U.S. EPA

Brian

Holtzclaw

U.S. EPA

Jackie

Toth

Good Energy Collective

Courtney

Cooper

UCSF Program on Reproductive Health & the
Environment

Tina

Davis

U.S. EPA

Kiana

Courtney

Environmental Law & Policy Center

David

Publow

Lights Out Norlite

Mary Claire

Kelly

GASP

Kearni

Warren

Energy Justice Network

Genevieve

Gadsden

US EPA/LCRD/RCB/Chemical Safety Section

Chrislyn

Means

EPAR7

Pamela

Brandy

Pughsville Chesapeake/Suffolk Civic League

Yolanda

Allen

U.S. Environmental Protection Agency

Bonita

Johnson

U.S. EPA

Sharron

Porter

United States Environmental Protection Agency

Keilly

O'Reilly

Plains All American

Keisha

Long

DHEC

Lin

Nelson

Evergreen State College

Benita

Best-Wong

U.S. EPA

Loaela

Hammons

GSAPBS

Tim

Kirchgraber

NYS Empire State Development

Lindsay

McCormick

Environmental Defense Fund

Jennifer

Valenstein

Brightwater Strategies

Richard

Stoker

POWER Engineers, Inc.

Alan

Walts

U.S. EPA Region 5

Kim

Tucker-
Billingslea

GM

Jacquelyn

Drechsler

None

Ashley

Greene

U.S. EPA

Olga

Naidenko

ENVIRONMENTAL WORKING GROUP

Karol

Archer

FAA

John

Mueller

Independent activist to ban fluoridation

Stephanie

Flaharty

U.S. Environmental Protection Agency

Valincia

Darby

DOI

Leo Matteo

Bachinger

NYSDEC

Eliza

Alford

City of Philadelphia

Kandyce

Perry

NJ Department of Environmental Protection

107

-------
Meghan

Ernes

National Fuel

Rosemarie

Nelson

U.S. EPA

I-Jung

Chiang

U.S. EPA

Alex

Rodriguez

DCG Public Affairs

Rebecca

Shell

AECOM

Alexandra

Olson

US EPA R6

Heather

Navarro

St. Louis Board of Aldermen

Katherine

Egland

EEECHO and NAACP

John

Oluwaleye

Gender-Based violence as a public Health Issue

Chanese

Forte

UCSF

Lome

Norton

RUPCO, Inc.

Elaine

Tanner

Friends For Environmental Justice

Shane

Palmer

Peter Damon Group

Susannah

Tuttle

NC Council of Churches / NC Interfaith Power &
Light

Sabina

Perez

Guam Legislature

Kira

Kaufmann

USFS

Lorraine

Reddick

U.S. EPA

Angus

Welch

U.S. EPA

Kurt

Temple

U.S. EPA

Shelly

Lam

U.S. EPA

Jennifer

Ortega

Environmental Defense Fund

Nayyirah

Shariff

Flint Rising

Carl a

Walker

World Resources Institute

Rich

Evans

GES, Inc.

Ellen

Manges

U.S. EPA

John

Kinsman

Edison Electric Institute

Cecelia

Donovan

EcoLogix

Lawrence

Martin

U.S. EPA

Lynn

Fowler

Housatonic River Commission

Alayna

Martin

U.S. EPAR4

Tatiana

Eaves

NWF

Lakota

Ironboy

Leech Lake Division of Resource Management

Troy

Hill

U.S. EPA Region 6

Rebecca

Huff

U.S. EPA

Ni colette

Fertakis

U.S. EPA

Dave

Arndt

None

Michael

Troyer

U.S. EPA

Marilynn

Marsh-Robinson

EDF

Russ

Casenhiser

Creation Care Collective

Kathy

Triantafillou

U.S. EPA

Eileen

Mayer

U.S. EPA

Carrie

Brown

HCPA

108

-------
Kay

Nelson

Northwest Indiana Forum

Gabriel

Bellott

House Committee on Science, Space, and
Technology

Bruce

Lin

U.S. EPA

Christina

Lovingood

U.S. EPA-OIG

Darryl

Malek-Wiley

Sierra Club

Richard

Moore

Los Jardines Institute

Susan

Olavarria

Stericycle

Amanda

Strawderman

Clean Water for NC

Jeremy

Bratt

Dogwood Alliance

Corbin

Darling

U.S. EPA Region 8

Stephanie

Rambo

Tejon Indian Tribe

Navis

Bermudez

US Environmental Protection Agency

Bob

Varney

Normandeau

Daniel

Gogal

U.S. EPA/Office of Environmental Justice

Monica

Espinosa

U.S. EPA Region 7

Matt

Klasen

U.S. EPA

Victoria

Flowers

Oneida Nation

Tanisha

Edwards

Foley Hoag, LLP

Siobhan

Whitlock

EPA Region 4 Superfund & Emergency
Management

Sheldon

Snipe

U.S. EPA

Raina

Rippel

Halt the Harm Network

Vanessa

Simms

U.S. EPA

Alex

Guillen

POLITICO

Carolyn

White

Pughsville Chesapeake & Suffolk Civic League

Lori

Simmons

PROC

Elyse

Salinas

U.S. EPA

Jennelle

Crane

TCEQ

Diedre

Lloyd

U.S. EPA

Chandra

Taylor

Southern Environmental Law Center

Michael

Bloom

R. G. Miller Engineers, Inc.

Joanna

Stancil

USDA-FS

Mario

Sengco

U.S. EPA

Kate

Friedman

Louisiana Department of Health

Joe

Foote

Florida Department of Environmental Protection

Martha

Kelly

Connecticut Coalition for Environmental Justice,
GPUS EcoAction Committee

Annamarie

Romero

U.S. EPA R7

Will

Patterson

Scotlan Youth and Family Center

Tyler

Jenkins

Senate EPW

Leonardo

Wassilie

Salmonberry Tribal Associates

Shannon

McNeeley

Pacific Institute

109

-------
Anthony

Rogers-Wright

New York Lawyers for the Public Interest

Earthea

Nance

U.S. EPA

Doretta

Reaves

U.S. EPA

Francisco

Donez

U.S. EPA

Tynechia

Marshall

ADEM

Belinda

Joyner

Concern Citizen of Northampton County

Steve

Zuiss

Koch

Paul

Lee

Los Angeles Mayor's Office

Kim

Balassiano

U.S. EPA

Brittany

Whited

DOEE

Alane

Herr

IEPA

Emily

Kroloff

U.S. EPA

Alice

Sung

Greenbank Associates

Betsy

Lawton

Network for Public Health Law

Michael

Snyder

Dow

Eve

Granatosky

Lewis-Burke Associates LLC

Dora

Johnson

U.S. EPA

Angela

Chalk

Healthy Community Services

Leslie

Vishwanath

National Grid

Olivia

Rodriguez
Balandran

U S EPA Region 6

Christina

Chiappetta

GSA

Brandi

Hall

ADOT

Edith

Pestana

CTDEEP

Stephanie

Hammonds

WVDEP-DAQ

Ashley

Bullock

Public Health - Seattle & King County

Angela

Zhong

None

Kent

Benjamin

U.S. EPA

Kim

Lambert

U.S. Fish and Wildlife Service

Charles

Mason

Pacific Gas and Electric

Chris

Pressnall

Illinois EPA

David

Ailor

American Coke and Coal Chemicals Institute -

ORA

GILES

Transcription, Etc., LLC

Alessandro

Molina

U.S. EPA

Leel

Dias

EJN

Michael

Gange

City of Denton

Lori

Dowil

Corteva

Eric

Dessen

Con Edison

Alexis

Rourk Reyes

U.S. EPA

Gracie

Kennedy

Florida Department of Environmental Protection

David

Casales

SRMT Transfer Station

Elizabeth

Ross

Gunster

Kaitlin

Toyama

US DOJ, Civil Rights Division

110

-------
Dave

Pavlich

Phillips 66

Anhthu

Hoang

U.S. EPA

Sandra

Meier

Environmental Energy Alliance of New York

Krystina

Parker

Plains All American

Elizabeth

Evans

US EPA

Charles

Lee

US Environmental Protection Agency

John

Tsun

Groundwater & Environmental Services, Inc.

Danielle

Mercurio

VNF

Robert

Houston

U.S. EPA

Timothy

Gray

Housatonic River Initiative

Cecil

Rodrigues

U.S. EPA

Katie

Hoeberling

Open Environmental Data Project

Jeremy

Hancher

EMAP - Widener University SBDC

Victoria

Oliver

U.S. EPA/OCSPP/OPP/HED

Tami

Thomas-Burton

U.S. EPA

Carolyn

Yee

California Environmental Protection Agency,
Department of Toxic Substances Control

Adriane

Busby

Friends of the Earth

Whitney

Skeans

National Grid

Melissa

Vatterott

Missouri Coalition for the Environment

Maya

Nye

Coming Clean

Dawn

Reeves

Inside EPA

Michael

Blair

Innovate Inc

Camille

Moore

Peter Damon Group

Piper

T

Non-profit

Sheryl

Good

U.S. EPA Region 4

Sabrina

Johnson

U.S. EPA

Sarah

Knapp

GAEPD

Tom

Neltner

Environmental Defense Fund

Jordan

Gougler

NYSDEC

Anthony

Paciorek

Michigan United

Yassen

Roussev

Judicial Council of California

Michael

Mai com

The People's Justice Council

Jamie

Gobreski

U.S. EPA

Robin

Jacobs

U.S. EPA

Amanda

Hauff

U.S. EPA

Marva

King

None

Samantha

DiMeglio

NJDEP

Rev.Carlene

Thorbs

Community Board 12/QSWAB

Kelly

Crawford

DC Department of Energy and Environment

Arsenio

Mataka

Department of Health and Human Services

Lea Anne

Burke

Puget Sound Partnership

Ayodele

Jibowu

H-GAC

Ill

-------
Elena

Hawkins

Michigan Poor People's Campaign

Adler

Miserendino

Lewis Burke Associates

Michael

Hansen

GASP

Jenelle

Hill

U.S. EPA-OWM

Kathryn

Clay

International Liquid Terminals Association

Kurt

Conner

Southern Environmental Law Center

Ginger

Wireman

WA Dept. of Ecology, Nuclear Waste Program

Amy

Miller

U.S. EPA

Heather

Collins

U.S. Environmental Protection Agency

Riddhi

Patel

Center on Race, Poverty, & the Environment

Kristin

Aldred Cheek

Stericycle

Andrew

Geller

U.S. EPA

Tamara

Freeman

U.S. EPA R7

Megan

Kohler

ADEC

Cynthia

Ferguson

US Dept. of Justice, Environment and Natural
Resources

Gregory

Lovato

Nevada Division of Environmental Protection

Adriene

Weaver

NC Dept. Environmental Quality Division of
Water Resources

Kelsey

B rugger

E&E News

Hannah

Ashenafi

DOEE

Karen

Menetrey

New Mexico Environment Department

Bruno

Pigott

U.S. EPA

Carly

Sincavitch

A&P

Katy

Hansen

EPIC

Scott

Sherman

U.S. Army

Mike

Ewall

Energy Justice Network

Carolyn

Slaughter

APPA

Haley

Lewis

GASP

Michelle

Madeley

U.S. EPA

Stephanie

Bilenko

none

LINDA

GILES

Transcription, Etc.

Susan

Gordon

Multicultural Alliance for a Safe Environment

Victor

Zertuche

U.S. EPA

Beth

Graves

ECOS

Veda

Reed

EPA

Lakendra

Barajas

Earthjustice

Mike

Ripley

Chippewa Ottawa Resource Authority (CORA)

Doris

Betancourt

U.S. EPA

Jay

Hoskins

MSD

Latasha

Lyte

USD A - Forest Service

Xavier

Barraza

Valle de Oro National Wildlife Refuge

Rebecca

Chu

U.S. EPA

112

-------
Cara

Simaga

Stericycle

Cristina

Villa

Department of the Interior

Abu

Moulta Ali

US Environmental Protection Agency

Jennifer

Reynolds

CO Dept of Public Health & Environment

Erica

Brown

Assoc. of Metropolitan Water Agencies

Jan

Boudart

Nuclear Energy Information Service

Stephany

Mgbadigha

Air Alliance Houston

Chad

Whiteman

U.S. Chamber of Commerce

Michael

Smith

Interstate Natural Gas Association of America

Lilian S.

Dorka

U.S. EPA

Telly

Lovelace

ACC

Dr. Jim

Van Keuren

Ashland University, Ashland, Ohio/Author

Randa

Boy kin

NCDEQ

Travis

Voyles

Senate EPW

Chad

Larsen

Environmental Protection Agency

Mathilde

Saada

Baker Institute

Daniel

Blackman

US Environmental Protection Agency

Anthony

Nevicosi

VHA

David

Magdangal

U.S. EPA

Morgan

Capilla

U.S. EPA

Griselda

Gonzales

https://grisengineering.com

John

Beard

PACAN

Sabrina

Bailey

Illinois Environmental Protection Agency

Daniel

Morales

Northern Arizona University - ENG 530 Student

Macara

Lousberg

U.S. EPA

Coz

LaMore

Choices Interlinking Inc

Lela

Shepherd

HCFCD

Sarah

Miller

LSU

Alison

Ruttenberg

Healthy Gulf

Linsey

Walsh

U.S. EPA

Deborrah

Miller

Arizona Department of Transportation

Kacy

Manahan

Delaware Riverkeeper Network

Heidi

LeSane

Environmental Protection Agency

Nalleli

Hidalgo

Texas Environmental Justice Advocacy Services

Emily

Gulick

Jacobs Engineering

Brenda

Watson

Operation Fuel

Annie

Wilson

NYELJP

Bryan

Davidson

Tennessee Department of Environment and
Conservation

Caitlin

McHale

National Mining Association

Cassandra

Johnson

MDEQ

Luis

Lopez

Comite Civico del Valle

Kathy

Koon

OK DOT

113

-------
John

Blevins

U.S. EPA

Louis

Baer

Portland Cement Association

Will

Patterson

Scotlan Youth and Family Center

Olivia

Glenn

NJDEP

Patrick

Rogers

None

Sandra

Morse

Aegis Environmental

Doris

Johnson

DEEP

Emily

Bitalac

U.S. EPA

Ntale

Kajumba

U.S. EPA Region 4

Melissa

Watkinson-
Schutten

Puget Sound Partnership

Monique

Hudson

U.S. EPA/ORC/R4

Catherine

Villa

Environmental Protection Agency

Charles

Maguire

U.S. EPA Region 6

Nia

Rock

BlueSuite Solutions, Inc.

Josh

Tapp

U.S. EPA R7

Debra

Tellez

U.S. EPA

Ericka

Farrell

U.S. EPA

Dylan

Meagher

NYC Department of Environmental Protection
(NYC DEP)

Feleena

Sutton

Aera Energy

Richard

Pinkham

Booz Allen Hamilton

Alyssa

Millikin

Dept. of Natural Resources- Environmental
Protection Division

Amanda

Aspatore

National Association of Clean Water Agencies

Anna

van der Zalm

PETA Science Consortium International

Gina

Shirey

Alaska Department of Environmental
Conservation

Larry

Smith

Memphis

Roberta

Ezike

U.S. EPA

Jane

Mantey

Ceres

David

Thomas

Nearby Nature Milwaukee

Carlos

Claussell

Institute for Sustainable Communities

Molly

Blessing

Household & Commercial Products Association

Rafael

DeLeon

Environmental Protection Agency

Carol

Bergquist

Hannahville Indian Community

Colin

Wright-Pruski

FTI Consulting

Mary

Ross

U.S. EPA

Sheela

Lai

Blue Conduit

James

Courtney

Arnold & Porter, LLP

Samantha

Beers

U.S. EPA

Kelly

Poole

Environmental Council of the States

Geri

Freedman

Organized Uplifting Resources & Strategies

Jasmin

Contreras

U.S. EPA

114

-------
Madeline

Middlebrooks

Great Rivers Environmental Law Center

Forest

Replogle

Mid-Region Council of Governments

Sherrell

Byrd

SOWEGA Rising

Rochelle

Gandour-Rood

Tacoma Water

Lorrie

Davis

USD A

Roberta

Benefiel

Grand Riverkeeper Labrador

Maria

Gabriela Huertas
Diaz

San Juan Bay Estuary Program - ESTUARIO

Leslie

Ritts

NED A/CAP

Saachi

Kuwayama

Environmental Defense Fund

Nizanna

Bathersfield

U.S. EPA

Leanne

Nurse

The Nature Conservancy

Elizabeth

Foster

Minnesota GreenCorps

Aimee

Boucher

U.S. EPA

Trayce

Thomas

MDEQ - Office of Restoration

Maricela

Perryman

San Juan Bay Estuary Program

Rosty

Caryk

Davey Resource Group, Inc.

Kathryn

Super

EJHA

Debbie

Michel

East Bay Municipal Utility District (EBMUD)

Alan

Bacock

U.S. EPA Region 9

Theodore

Hilton

U.S. EPAGMD

Alexis

Williams

Louisiana Department of Health Office of Public
Health

Katie

Lambeth

EGLE

Daisha

Williams

Clean AIRE NC

Alice

Wright-Bailey

CEP

Gloria

Vaughn

U.S. EPA

Amelia

Cheek

IL Environmental Regulatory Group

Debra

Coffel

Environmental Protection Agency

Tommy

Landers

Harvard Law School

Michael

Seavey

CGI Federal

Dean

Scott

Bloomberg

Toshia

King

OLEM/ORCR

Deborah

Williams

CWLP

Gerardo

Acosta

Office of Communities, Tribes and
Environmental Assess.

James-
Lewis

Free

NO A A

Chitra

Kumar

U.S. EPA

Caroline

Emmerson

U.S. EPA

Andrea

Thi

DOJ

Stephanie

Herron

EJHA

Cathy

Waxman

National Grid

Ngozi

Nwosu

City of Dallas

115

-------
Taylor

Parks

Florida Department of Environmental Protection

Monika

King

New York State Dept. of Health

Tamela

Trussell

TLC Foundation/Move Past Plastic

Kimberlie

Cole

Strata-G LLC / UCOR LLC

Trey

Hess

PPM Consultants, Inc.

Virginia

Vassalotti

U.S. EPA Region 3

Sarah

Doran

Corning Inc.

Christopher

Mishima

U.S. EPA Region 9

Kyle

Boone

Pokagon Band of Potawatomi

Carl

Sivels

U.S. EPA

Jose

Flores

Comite Civico

Scott

Schlief

U.S. EPA Region 10

Jake

Rosenberg

POWER Engineers

William

Nichols

U.S. EPA

Lorna

Withrow

NCDHHS, DPH, OSWP

Lena

Epps-Price

U.S. EPA

Kamilah

Carter

Environmental Protection Agency

Morris

Azose

Stericycle

Michael

Bryant

Texas Department of Transportation

Tomeka

Nelson

U.S. EPA

Candace

Lewis

U.S. EPA

Melissa

Horton

Southern Company

Grace

Tuttle

Protect Our Water Heritage Rights (POWHR)

Rebecca

Brenner

Cornell University

Mark

Fite

U.S. EPA-Region 4

John

Shoaff

U.S. EPA

Gulan

Sun

Motiva

Brandi

Jenkins

U.S. EPA

Andrew

Daffern

City of Albuquerque

Lael

Goodman

North Brooklyn Neighbors

Tracy

Brown

Riverkeeper, Inc.

Stephen

Donnelly

U.S. EPA

Horace

Strand

CEP

Chelsea

Spier

CA Department of Water Resources

Cheryl

Watson

Blacks In Green

Hollis

Maye-Key

Environmental Protection Agency

Parisa

Norouzi

Empower DC

John

Byrd

Miller/Wenhold Capitol Strategies

Travis

Voyles

Senate EPW

Dione

Price

Keweenaw Bay Indian Community

David

Brewster

PARS Environmental

Steve

Whelan

Citizens Climate Lobby

Milford

Muskett

Southwestern Indian Polytechnic Institute

116

-------
Phylicia

Allen

Brownfields at TCEQ

Tamira

Cousett

U.S. EPA

William

Patterson

EBMUD (East Bay Municipal Utility District)

Joanne

Burton

None

Pam

Eaton

Green West Strategies

Allison

Smart

Little River Band of Ottawa Indians

Catalina

Gonzalez

Center for Progressive Reform

Kent

Benjamin

U.S. EPA

Megan

Smith

shift7

Brielle

Meade

Eastern Research Group, Inc.

Karin
Ursula

Edmondson

Karin Ursula Landscapes

Bo

Park

U.S. EPA

D.

Wu

NYS OAG - EPB

Karl a

Raimundi

VT Agency of Natural Resources

Jean

Mendoza

Friends of Toppenish Creek

Alex

Rodriguez

Save the Sound

Maria

Rahim

Chevron

Jamie

Flood

USD A National Agricultural Library

Mike

Schuster

Hannahville Indian Community

Leslie

Orloff

ASDL

Annie

Chen

OEHHA

Bridget

Weir

U.S. EPA

Julie

Simpson

Nez Perce Tribe - Air Quality Program

Brian

Chalfant

Pennsylvania Department of Environmental
Protection

Mindy

Comangane

None

Dana

McClure

NYS DEC

Kathryn

Walker

Center for Sustainable Materials Manag. at
SUNY ESF

Stacia

Bax

Missouri Department of Natural Resources

Evelyn

Mayo

Paul Quinn College

Bridget

Walsh

Superfund News

Meghan

Wahlstrom-
Ramler

U.S. EPA

Roya

Pardis

POWER Engineers Inc

Stan

Buzzelle

U.S. EPA

John

Parker

GNOICC/zen peacemakers

Angela

Seligman

ND Department of Environmental Quality

Colleen

Makar

Buffalo Sewer Authority

Roddy

Hughes

Sierra Club

Sara

Guiher

Toledo Metropolitan Area Council of
Governments

Timonie

Hood

U.S. EPA Region 9

117

-------
Stephanie

Lai

CA Dept of Justice

Emily

Gerhardt

Southern Company Services, Inc.

Shannon

Broome

Hunton Andrews Kurth

Megan

McBride

Choctaw Nation of Oklahoma

Michael

Fitzgerald

Finger Lakes Times

Scott

Hebner

bureau of reclamation

Alexandra

Campbell-Ferrari

The Center for Water Security and Cooperation

Eleftheria

Kontou

University of Illinois at Urbana-Champaign

Michael

Egnor

WV DEP

Daniel

Bagby

Dallas Water Utilities

Evan

Baylor

Babst Calland

David

Dunlap

Harsco Corp.

Lee

11 an

NYC Mayor's Office of Environmental
Remediation

Jeffrey

Norcross

U.S. EPA Region 1

Serene

Gauthier

Tribal

Jesse

Deer In Water

Citizens Resistance at Fermi Two (CRAFT)

Earthjustice

Brown

Earthjustice

Shanika

Amarakoon

ERG

Brian

Holtzclaw

U.S. EPA

Elise

Rasmussen

Washington State Department of Health

Lindy

Lowe

ERG

Jenna

Dodson

WVU

Khadija

Kamara

NYU

Leatra

Harper

FreshWater Accountability Project Ohio

Amy

Minor

Southwest Research Institute

Judy

Abbott

NYSDOH

Sharon

Pope-Marshall

CIVITAS

Kathy

Andrews

Blue Ridge Environmental Defense League

Erica

Bates

WA Department of Ecology

Paloma

Pavel

Earth house center

Maureen

Mulcahy

Eagle County

Vanessa

Zahora

GSA

Laura

Berloth

National Fuel

Sally

Kniffen

SCIT

Heather

Croshaw

St. Croix Environmental Association (St. Croix,
USVI)

Sarah

Lobe

Nixon Peabody

Ruben

Camacho

U.S. EPA

Collin

Yarbrough

Southern Methodist University

Renee

Panetta

City of Troy - Troy, NY

AK

Will

McCarthy Building Companies

Haley

Lewis

GASP

118

-------
Julie

King

Baylor University

Michael

Perrin

U.S. EPA

Keisha

Sedlacek

Chesapeake Bay Foundation

Dallas

Conyers

SCEN

Tracy

Corley

Conservation Law Foundation

Sonja

Stark

Clean Air Coalition of Greater Ravena/Coeymans

James

Brady

State of Vermont

Linda

Giles

Transcription, Etc. LLC

Mari

da Silva

NAACP NYS CONFERENCE

Ashley

Fisseha

U.S. EPAR5 SEMD

Susan

Alzner

shift7

Aurora

Aparicio Collazo

The Packard Foundation

Vincent

Martin

V Martin Environmental Justice LLC

Valerie

Blank

U.S. EPA ORD

Tyler

Lites

U.S. EPA

Kay

Anderson

SSDRA

Emily

Joynt

North Dakota Department of Environmental
Quality

Evan

Mulholland

MCEA

Bill

Burns

Environmental Awareness Foundation Inc

Renee

Kramer

North Carolina Department of Environmental
Quality

John G.

Andrade

Old Bedford Village Development, Inc.

Shaun

Auckland

SPEER

Catherine

Lutz

Brown University

Samantha

Harden

U.S. EPA

Lauren

Godshall

Tulane University

Valerie

Rangel

nmelc.org

Enrique

Valdivia

Texas Rio Grande legal aid, Inc

Raymond

Wayne

Heritage

William

Hannemann

Aqualete Industries

Timothy

Fields

MDB, Inc.

Shayne

del Cohen

SDC consulting

Chikara

Mb ah

U.S. EPA

James

Tillman

CGI Federal

Danilo

Morales

CSNDC

Erin

Stanforth

Mecklenburg County

Roxanne

Groff

BEN

Eric

Ruder

IEc

Diana

Umpierre

None

Holly

Young

U.S. EPA

Susan

Stilson

U.S. EPA

Patricia

Donohue

Dept of Defense

119

-------
Adrianne

Yang

None

Naomi

Yoder

Healthy Gulf

Christian

Holmes

Boston Consulting Group

Christine

Primomo

Clean Air Coalition of Greater Ravena Coeymans

Katie

Darr

Lake Champlain Basin Program

Kristina

Torres

U.S. EPA

Carl

Anthony

Earth House Center

Prakash

Kashwan

UConn

Melanie

Meade

VCAN

Eduardo

Martinez

City of Richmond, California

Alexis

Stabulas

U.S. EPA

Desi

Santerre

DOLA

Matt

Small

U.S. EPA

James

Brunswick

Depart, of Natural resources and Environmental
Control

Astrika

Adams

SBA OA

Jane

Curtis

Community advocate

Janene

Yazzie

Sixth World Solutions

David

Lonnberg

shift7

Tana-
Isabela

Anulacion

U.S. EPA

Conrad

Geiger

Student @ University of Colorado

Diana

Abadie

Clean Air Coalition of Coeymans and Greater
Ravena

Simone

Sagovac

Southwest Detroit Community Benefits Coalition

Nichelle

Taylor

GNOHA

Latoya

Miller

U.S. EPA Region 4

Patricia

Taylor

Environment and Human Health, Inc. (EHHI)

LesLee

Jackson

Northside Green Zone

Li at

Meitzenheimer

Fresh Air Vallejo

Gail

Lobin

FTI Consulting

R

Hill

St Albans Chamber

Colleen

Baublitz

U.S. EPA

Vanessa

Gordon

USD A

Krista

Mclntyre

Law Firm

Kate

Shackford

Independent Consultant

Emily

Larson

Appalachian Power Company

Alicia

Daniels-Lewis

U.S. EPA

Helen

Serassio

U.S. EPA

Mohsen

Fatemi

University of Kansas

Chante

Davis

Sunrise Movement Houston

David

Lonnberg

shift7

Lauren

Lurkins

IL Farm Bureau

120

-------
Monique

Tate

Coosa Nation-State of North America (USA)

Adam

Cole

RCO

Matt

McGarry

ToC

Kyle

Crider

The People's Justice Council

Pamela

Harris

MDE

Catharine

Bartone

VTDEC

Jackie

Spryshak

FTI Consulting

Gregory

Norris

A.C.E.S. 4 Youth

Gilbert

Sabaterf

Becket, Inc

Damon

Watson

None

Melissa

McCoy

U.S. EPA

Debbie

Madden

Gunster

Danielle

O'Neil

U.S. EPA

Kerry

Hicks

U.S. EPA-Region 8

LaKeshia

Robertson

U.S. EPA

Mary

McCarron

Ohio EPA

Jennifer

McCord

Alabama Dept of Environmental Management

Kim

Gaddy

South Ward Environmental Alliance

Sarah

Abdelghani

Louisiana Department of Health

John

Valinch

Groundwork USA

Chris

Lewicki

U.S. EPA OW

Lisa

Perry

City of Rock Island

Shannon

Ansley

Portneuf Resource Council

Isabel

Segarra Trevino

Harris County (Texas)

Christine

Noonan

Reed Smith

William

Patterson

East Bay Municipal Utility District

Matt

Ellis-Ramirez

University of Miami

Earl

James

EKI Environment & Water, Inc.

Allison

van Pelt

Des Moines Area MPO

Jessica

Terlikowski

City of Portland

Amy

Beatie

Colorado Attorney General's Office

Amruta

Sakalker

UT Arlington

121

-------
I, Sylvia Orduno, Chair of the National Environmental Justice Advisory Council, certify that this
is the final meeting summary for the public meeting held on January 5, 2022, and it accurately
reflects the discussions and decisions of the meeting.



Date: April 4, 2022

122

-------