Diverse allies have submitted public comments to improve the Department of Interior’s (DOI) draft Environmental Justice Strategic Plan.
We commend the National Park Service (NPS) for addressing park and health disparities in its recent Healthy Parks, Healthy People US Strategic Action Plan (the HP/HP Plan). As the HP/HP Plan explicitly recognizes, “People of color and low income populations still face disparities regarding health and access to parks.” ”In regard to obesity, 36 percent of black and 35 percent of Hispanic high school students nationwide are overweight or obese, while 24 percent of non-Hispanic white high school students suffer from these conditions.”
We urge DOI and NPS to build on the strengths of the HP/HP Plan and NPS’s recent Call to Action as DOI finalizes the Environmental Justice Strategic Plan. The Plan should explicitly address the values that green space promotes to improve health and quality of life for all, including people of color and low-income people. DOI and NPS should thoroughly address the significance of the park and health disparities in the final Plan under equal justice principles and laws, including the 1994 President’s Order 12898 on Environmental Justice, and Title VI of the Civil Rights Act of 1964 and its regulations.
DOI and NPS need to educate the recipients and beneficiaries of their financial assistance about these requirements. Each of their recipients must comply. Beneficiaries need to know of these protections. The draft Plan does not adequately provide such information and guidance.
Thus, for example, the draft Plan, in discussing Title VI, states that NPS will foster civic dialogue about the stories of the civil rights movement, and commemorate significant 50th anniversaries of the civil rights movement, such as the passage of the Civil Rights Act of 1964 and Martin Luther King’s “I Have a Dream’ speech.” Of course we support celebrating the civil rights movement. But this example, and the draft Plan as a whole, do not provide adequate guidance.
The President’s Order 12898 requires each covered federal agency to “make achieving environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations.” Title VI and its regulations prohibit recipients of federal financial assistance from discriminating on the basis of race, color, or national origin.
Latino Coalition for a Healthy California; Community Health Councils; John J. Reynolds, Retired Deputy Director of the National Park Service; Jack K. Shu, Park Superintendent (Ret.), California State Parks, Office of Community Involvement; The City Project; Public Advocates; Center on Race, Poverty and the Environment; Prof. Nina Roberts of San Francisco State University, and Earthwise Productions submitted the public comments.
Read the November 30, 2011, Public Comments on DOI’s draft Environmental Justice Strategic Plan here.
Read the follow up December 20, 2011, Public Comments here.
Click on the links below for additional information discussed in the public comments:
National Park Service Healthy Parks, Healthy People US Strategic Action Plan.
National Park Service, Call to Action Report.
Detailed Environmental Justice and Title VI recommendations in Public Comments by 30 Diverse Allies to Federal Transit Administration.