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ECC to EPA: State 111(d) Plans Must Ensure Environmental Equity for Low-Income Neighborhoods

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Washington, D.C., December 2, 2014 – State plans for reducing carbon emissions must ensure equity for low-income communities of color, the Emerald Cities Collaborative (ECC) said in comments to the U.S. Environmental Protection Agency (EPA) on proposed regulations for section 111(d) of the Clean Air Act.

EPA and numerous advocacy organizations have documented that each year, pollution from coal-fired power plants causes hundreds of thousands of premature deaths, heart attacks, cases of asthma and other adverse health consequences.  

Disproportionate Consequences
While carbon emissions adversely affect all American communities, communities of color in disadvantaged urban neighborhoods suffer more than their share, given their frequent proximity to coal-fired power plants, freeways and factories, all spewing harmful emissions.

Coupled with the inordinate amount of waste incineration on public housing properties and in municipal incineration plants, those emissions create toxic environmental “hot spots” with higher than average asthma rates among children of color and a growing rate of respiratory disease and cancer among neighborhood senior citizens.

“Every American has the right to breathe clean air irrespective of his/her ZIP code,” asserted ECC President and CEO Denise Fairchild. “The final 111(d) rule should acknowledge these environmental and health inequities and require state plans to assess and mitigate the impacts of carbon emissions on the most vulnerable communities.”

Convening of Enviro Justice Groups
ECC recently convened a group of 16 organizations concerned with environmental justice and energy savings to explore the need for equity in the 111(d) state plans. The discussion led ECC to call on EPA to emphasize renewable energy and energy efficiency as paths to carbon reduction that also stimulate jobs and economic development.

ECC also invited EPA to meet with the organizations for “a candid conversation about the importance of an equity dimension in the 111(d) rules.”

As a result of the discussion, ECC’s comments call on EPA to include in its final regulations:

  • A requirement for states to include local leaders from impacted “hot spot” communities in the development and execution of state 111(d) plans.
  • A directive for states to make long-term community benefit investments in the communities disproportionately burdened with pollution.
  • A requirement to identify “impacted communities” for inclusion in planning and targeted investments, using existing federal government-derived instruments (e.g. EPA’s Environmental Justice View or the CDFI Fund’s CIMS Mapping Tool) to define target areas.
  • A requirement that states conduct an “equity” analysis of their carbon reduction plans. 

Additionally, ECC called for the following steps to reduce carbon emissions: 

  • Absolute reduction of greenhouse gas and co-pollutant emissions from facilities located in/within 30 miles of impacted communities.
  • Absolute reduction of greenhouse gas and co-pollutant emissions from existing coal plants located in/within 30 miles of impacted communities.
  • Ensuring that carbon-trading mechanisms employed do not adversely effect impacted communities or export negative consequences to other low-income communities of color, domestically or internationally.
  • No use of carbon capture, sequestration and/or other large-scale “clean coal” technology.
  • No expansion of nuclear energy and no cancellation of scheduled closures of nuclear facilities.

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