Kudo’s to Corrine Greenberg, of Carbide Industries, who presented at this month’s Kentuckiana Chapter of Hazardous Material Managers’ meeting. She did a great job of introducing the group to EJScreen. EJScreen is EPA’s environmental justice screening and mapping tool. EPA describes EJScreen as a tool to help understand environmental and health burdens in communities.

According to their website, EPA’s EJ2020 program goal #1 is to deepen EJ practice within EPA programs to improve the health and environment of overburdened communities. This includes rulemaking, permitting, compliance and enforcement, and science. The EJ 2020 webpage claims that EPA will “improve on-the-ground results for overburdened communities through reduced impacts.”

Concepts of environmental justice (EJ) seem simple, but solutions are very complex. For this tool, EPA has chosen environmental indicators which are based upon estimated health risks, potential exposure, proximity to and density of surrounding industry. They also have identified demographic indicators such as income, minority, education, and age. The EJ Index uses the concept of “excess risk” by looking at how far above the national average the block group demographics are. Blocks with high indices are identified as “overburdened” or “vulnerable.” EPA admits that this is a screening tool and not a definitive assessment. Measuring and comparing actual risk versus the distance to an industrial facility is an onerous task.

I encourage you to check out EJScreen. Many of my clients, especially those in urban areas, face EJ review during permitting for their upcoming projects. EPA’s EJ agenda is anticipated to lead to more scrutiny and potentially could result in project delays or even permit denials. It remains to be seen how relaxed implementation may become due to the upcoming administration change. The concept of environmental justice is unlikely to disappear. Reviews will typically be part of permit review for larger projects and those with NEPA review, but may also include smaller projects. EPA’s FAQ about their EJ air permitting agenda provides some useful information about air permitting implications. The Environmental Law Institute published a one page summary of Environmental Justice Hooks with citations for air, water and waste code which they claim include environmental justice provisions. At a minimum, it will be helpful for environmental managers to have a basic understanding of how their facility is represented in EJScreen and to be able to discuss perceived versus actual risks to the community. Additionally, for equipment upgrades and plant expansions which trigger permitting be prepared to address environmental justice questions.

If you need assistance in managing environmental justice concerns, please contact me at PattyM@SmithManage.com or 502-587-6482 extension 211.