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


State plans for reducing carbon emissions under section 111(d) of the Clean Air Act must ensure equity for low-income communities of color, ECC said in comments on the U.S. Environmental Protection Agency’s (EPA) proposed 111(d) regulations. EPA will issue final regulations June 1, 2015, and individual or multi-state plans are due by June 30, 2016. (See timetable here.)

ECC national and local staff will work with state officials and allied organizations over the coming 18 months to include representatives of low-income communities of color in the development of state plans. The ultimate goal is to ensure that these communities share equally in the benefits of reduced carbon emissions, including a share of any jobs created as states implement those plans.

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 Senior Policy Advisor Felipe Floresca. “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 resulted in a “consensus platform” and a collaborative effort to submit a number of recommended rule modifications by the December 1 comment deadline.  Among the positions was the need to emphasize renewable energy and energy efficiency as paths to carbon reduction and economic development. 

The discussion led ECC to call on EPA to emphasize renewable energy and energy efficiency as paths to carbon reduction that also stimulate economic development. 

ECC 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 recommended that the final regulations include:

  • A requirement for states to include local leaders from impacted 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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