NPS Rim of the Valley Draft Study Best Practice for Expanding Green Access, Health, and Environmental Justice for AllMay 26th, 2015
The National Park Service has released its 2015 Rim of the Valley draft study on expanding the Santa Monica Mountains National Recreation Area and increasing the presence of NPS in the greater Los Angeles area.
This study is a best practice for improving access to healthy green land use for underserved communities in Los Angeles. NPS recognizes that there are disparities in access to green space for low-income communities and communities of color, that those disparities contribute to health disparities, and that environmental justice requires agencies to address those disparities. 
Analysis of Green Access and Health
NPS addresses environmental justice and equal access to park and recreation programs for all. NPS relies on Executive Order 12898 on environmental justice and health, which “requires all federal agencies to incorporate environmental justice into their missions by identifying and addressing disproportionately high and adverse levels of human health or environmental effects from their programs and policies” on people of color and low income people (ROTV Study, page 278).
The draft study cites The City Project’s work on green access, including our policy reports and mapping and demographic analysis, to document that there are disparities in access to green space for low income communities and communities of color in the Los Angeles region.
“Many nearby local communities are currently deficient in providing adequate parks and recreational opportunities for residents. This is particularly true of communities in the City of Los Angeles. Neighborhoods around downtown Los Angeles have the highest population density within the study area and the greatest concentration of residents that lack adequate access to park resources. In addition, most of these residents are from predominantly minority and lower income communities (The City Project 2011).” (page 211)
NPS also cites the related health disparities, documenting that “children in communities that do not have adequate access to outdoor recreation tend to have higher rates of childhood diseases related to obesity, such as diabetes” (page 250).
Map of Park Poverty, Income Poverty and People of Color Throughout the Study Area (Figure 2-14, page 127)
Transportation is a significant barrier for many low income communities and communities of color in accessing the existing green space in the region. “Though large open space areas such as SMMNRA and the Angeles National Forest give the appearance of high per capita available recreation space in the Los Angeles area, there is a major issue with equitable access to these areas. As demonstrated in The City Project’s work in Los Angeles, many families in the low income neighborhoods of the region often do not have cars nor live near public transportation systems that allow for access to regional parks. Few, if any sites, within SMMNRA and the Angeles National Forest can be accessed by public transportation, a major barrier for urban residents without a car.” (page 128)
One purpose of the ROTV study is to provide “close-to-home recreational opportunities for urban residents living in areas that currently do not meet standards for access to parks and recreation areas” (page 278). NPS recommends expanding the boundaries of the SMMNRA as the best option to accomplish this, as it will provide more open space and recreational opportunities for all, and can lead to long-term beneficial impacts on underserved communities. Realizing these goals will require long-term commitments to working with public transportation providers, cities, and communities (page 329).
There are several best practice examples in addition to the NPS 2015 Rim of the Valley study on how to use civil rights and environmental justice tools. These include the NPS San Gabriels study  and the US Army Corps of Engineers L.A. River study.  NPS’s national work on its Healthy Parks, Healthy People Community Engagement eGuide is also a valuable resource. 
The Department of Housing and Urban Development (HUD) provides another best practice example. 
Andrew Cuomo, as Secretary of HUD, would not issue federal subsidies for a proposed warehouse project in downtown L.A. unless there was a full environmental study that considered the impact on people of color and low-income people, and considered the park alternative. HUD cited Executive Order 12898 on environmental justice and health, and Title VI of the Civil Rights Act of 1964 and its regulations in reaching that decision. HUD’s action led to the creation of the Los Angeles State Historic Park and the greening of the L.A. River.
In addition, the Federal Transit Administration articulates these compliance and planning principles in its guidance on Title VI and Executive Order 12898.  The United States Department of Agriculture has articulated these compliance and planning principles as well. 
The Values at Stake
The values at stake in expanding the Santa Monica Mountains National Recreation Area include:
- Fun, health, and human development.
- Conservation values including climate justice, clean air, water, and land, complete green streets with transit, biking, hiking, and safe routes to schools, and saving habitat.
- Economic values include meaningful work and wealth creation, and avoiding displacement.
- Art, culture, history, and spiritual values, including Native American values.
- Equal justice, democracy, and livability for all.
Specific outcomes related to Rim of the Valley include getting people of color and low-income people to the parks now through Transit to Trails and other community engagement and public health programs; protecting some of the region’s last wild lands, open spaces, and historic sites, including habitat for threatened species; diversifying the NPS and park agency work force; educational materials on art, culture, and history; and providing multilingual rangers and signs. The expanded presence of NPS will facilitate new partnerships with schools, local governments, and community-based organizations to improve outreach and interpretive programs, better connect youth and families to the outdoors, and build a new generation of national park enthusiasts.
The Planning Process
The following planning process applies to federal agencies and recipients of federal funding to help ensure compliance and equity under environmental justice and civil rights laws and principles.
- Describe what you plan to do
- Analyze the benefits and burdens on all people. This includes demographic mapping and analysis.
- Analyze the alternatives.
- Include people of color and low-income people in the planning and decision-making process.
- Develop and implement an equity and compliance plan to distribute the benefits and burdens fairly and avoid discrimination.
The NPS Rim of the Valley draft study provides a best practice framework to address environmental and health disparities. This can be done through a planning process that ensures voluntary compliance with civil rights and environmental justice laws and principles. Federal agencies provide a framework (a) to address such evidence of disparities, (b) to promote the values at stake, (c) through voluntary compliance with those laws and principles, and (d) through the planning process. Applying NPS’s best practice framework to expand the Santa Monica Mountains National Recreation Area will ensure access to healthy green land use and promote health and environmental justice values for all.
 NPS, Rim of the Valley Corridor: Draft Special Resource Study and Environmental Assessment, April 2015, (ROTV Study). Click here to view relevant excerpts from the study. The full report is available at: http://parkplanning.nps.gov/rimofthevalley_draftreport.
The City Project and the following diverse alliance committed to health and environmental justice submitted public comments in 2013 to NPS to diversify access to and support for the expanded National Recreation Area: Robert Bracamontes, Acjachemen Nation, Juaneño Tribe; Amigos De Los Rios; Anahuak Youth Soccer Association; Asian and Pacific Islander Obesity Prevention Alliance; Asian Pacific Policy & Planning Council; California Black Health Network, Inc.; California League of United Latin American Citizens (LULAC); Concerned Citizens of South Central Los Angeles; Latino Coalition for a Healthy California; National Parks Conservation Association; PolicyLink; Santa Clara River Watershed Conservancy; Search To Involve Pilipino Americans; Sierra Club; Social Justice Consultancy; and SPARC (Social & Public Art Resource Center).
 NPS, San Gabriel Watershed and Mountains Special Resource Study & Environmental Assessment, p. 231 (Newsletter #5, Nov. 2011) (San Gabriel Study). Click here to view relevant excerpts from the study. See The City Project’s blog post, San Gabriel Mountains Best Practice Environmental Justice Framework for Parks, Health, and Conservation Values.
 USACE, Los Angeles River Ecosystem Restoration Integrated Feasibility Report. Relevant excerpts of the study are available here. The complete draft study is available at http://www.spl.usace.army.mil/Portals/17/docs/publicnotices/DraftIntegratedReport.pdf. See The City Project’s blog post, US Army Corps of Engineers Study Best Practice Framework for Revitalizing L.A. River
 NPS, Healthy Parks, Healthy People Community Engagement eGuide. The complete eGuide is available at www.nps.gov/public_health/hp/hphp/press/HealthyParksHealthyPeople_eGuide.pdf.
 See The City Project’s blog post, Best Practice HUD Los Angeles State Historic Park Healthy Green Land Use for All
 Federal Transit Administration, Environmental justice policy guidance for Federal Transit Administration recipients, Circular (FTA C 4703.1) (Washington, DC: Department of Transportation, Aug. 15, 2012); FTA, Title VI Requirements and Guidelines for Federal Transit Administration Recipients, Circular (FTA C 4702.1B) (Washington, DC: Oct. 1, 2012); Letters from FTA to Metropolitan Transportation Commission and San Francisco Bay Area Rapid Transit District (Jan. 15, 2010 and Feb. 12, 2010), available at www.cityprojectca.org/blog/archives/4468.
 Office of Civil Rights, U.S. Dep’t of Agric., DR 4300-4, Civil Rights Impact Analysis (2003), available at www.ocio.usda.gov/sites/default/files/docs/2012/DR4300-4.pdf.