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San Gabriel Mountains Best Practice Environmental Justice Framework for Parks, Health, and Conservation Values

Diverse allies working with the San Gabriel Mountains Forever (SGMF) coalition seek to diversify access to and support for the San Gabriel Mountains and Watershed through (1) proposed legislation for a national recreation area, and for wilderness and wild and scenic river designations; (2) national monument designation; and (3) compliance with environmental and health justice laws and principles.

The comprehensive Special Resource Study completed by the National Park Service has served as a helpful precursor to potential legislation or administrative action for the San Gabriel Mountains and Watershed, as has NPS’s national work on Healthy Parks, Healthy People. We often refer to these resources to inspire and inform our own work. This provides one strong framework to sustain environmental quality, health and environmental justice commitments over the long-term, spanning administrations.

nps eguide

The Values at Stake

We believe that engaging stakeholders by promoting the diverse values at stake will enhance the San Gabriel Mountains region. The NPS Healthy Parks, Healthy People eGuide summarizes these values as follows.[1]

  • Fun and human development: Children who are physically fit tend to do better academically, and parks can create community and drive out vandalism and crime.
  • Conservation values: This includes clean air, water, and land, complete green streets with transit, biking, hiking, and safe routes to schools, saving habitat, and climate justice.
  • Economic values: This includes jobs and apprenticeships for youth, diversification of government contracts to involve local workforce, the ramifications of gentrification and potential displacement of lower income residents and businesses as greening improves their communities, and increasing home ownership and support for small business.
  • Art, culture, and spiritual values: At monuments like those that celebrate Martin Luther King, Jr., Cesar Chavez, Manzanar, and Mesa Verde, people are apt to connect on a cultural level and the health and well-being message can be included.
  • Equal justice, democracy, and livability for all. “Ultimately, we can appeal to the values that we strive to achieve as a community and democracy and emphasize the inherent democratic nature of public spaces.”

In addition, we recommend that, whenever possible, federal agencies in the San Gabriel Mountains region “identify opportunities to develop partnerships with Tribal governments, consistent with mission needs to provide necessary technical assistance to enhance tribal capacity to address environmental, health, and welfare concerns,” as noted in the NPS San Gabriel Study.[2]

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.

  1. Describe what you plan to do.
  2. Analyze the benefits and burdens on all people, including people of color and low income people.
  3. Include people of color and low income people in the decision making process.
  4. Analyze the alternatives.
  5. Develop an implementation and monitoring plan to distribute benefits and burdens fairly.

There are several best practice examples implementing this planning process. The noted NPS San Gabriels study is one, as discussed below. The U.S. Army Corps of Engineers (USACE) draft 2013 study for the revitalization of the Los Angeles River is another. This USACE study recognizes there are unfair disparities in access to green space for people of color and low-income people in Los Angeles, that those disparities contribute to unfair health disparities, and that environmental justice requires agencies and recipients of federal funding to address those disparities. The Department of Housing and Urban Development (HUD) provides a third 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 L.A. 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.[3]

The United States Department of Agriculture has articulated these compliance and planning principles as well.[4] United States Forest Service staff have played a leading role analyzing management alternatives to address how diverse people engage with natural green space and recreation differently based on their own values, cultures, histories, and traditions.[5] USDA and USFS would manage a national monument in the San Gabriels.

Environmental Quality, Health, and Justice

The following considerations help inform work around environmental quality, health and environmental justice both locally and nationally, and help inform the planning process.

“Environmental justice must be considered in every major federal action by assessing environmental factors that negatively or disproportionally affect minority populations” and low income populations. San Gabriel Study at 231. NPS cites the President’s Executive Order 12898 on environmental justice and health, and related laws and principles. Id. and Errata p. 11-12.

We are all well aware that “Los Angeles County is one of the most disadvantaged counties in terms of access to parks and open space for children of color and people of color.” P. 219. “[C]ounty averages can mask dramatic disparities in access to green space within the county.” P. 218. Non-Hispanic “[w]hites currently have disproportionately greater access to parks and open space, compared to Latinos and African-Americans. These groups are 12-15 times more likely to have less park acreage per capita when compared to [non Hispanic w]hites.” P. 219. Further, “the communities with the least amount of access to parks and open space tend to have higher rates of childhood diseases related to obesity such as diabetes.” Id.


And we are also cognizant that “Economically disadvantaged populations in the study area lack access and the ability to partake of existing opportunities due to lack of close-to-home open space, lack of effective transportation, lack of culturally advantageous facilities or opportunities, and lack of knowledge about recreation and natural resources. . . . Youth corps and job corps partnerships provide a solid environmental learning experience for the youth involved, while at the same time leaving a legacy of work which significantly benefits the parks and community.” P. 231.

And “[M]any families in the low income neighborhoods of the region often do not have cars nor are near public transportation systems that allow for access to regional parks.” The Transit to Trails program provides opportunities for park poor, income poor communities to learn about water, land, wildlife, and cultural history, and engage in physical activity through recreation. It also helps reduce traffic congestion, improve air quality, and reduce polluted water run-off into rivers and the ocean by providing accessible public transportation. San Gabriel Study, p. 179. Transit to Trails is a best practice both in the eGuide (p. 17) and in the San Gabriels study (p. 93).

Secretary of the Interior Sally Jewell with children from Anahuak Youth Sports Association, Raul Macias from Anahuak, and Robert Garcia from The City Project at Los Angeles State Historic Park.

We know that health concerns in the San Gabriel region reflect concerns and disparities across the nation. For example:

  • Nationally, 49% of American adults report that they do not engage in the Surgeon General’s recommended 30 minutes of physical activity for most days of the week.
  • 18% of the US Gross Domestic Product goes to health care costs.
  • Health disparities remain widespread among members of racial and ethnic minority populations.
  • Minorities or Populations of color are far more likely than non-Hispanic whites to suffer from chronic conditions, many of which are preventable.
  • Heart disease is the leading cause of death for people of most ethnicities in the United States.
  • Non-Hispanic blacks have the highest rates of obesity (44.1%) followed by Mexican Americans (39.3%).
  • Compared to non-Hispanic whites, the risk of diagnosed diabetes is 18% higher among Asian Americans, 66% higher among Hispanics/ Latinos, and 77% higher among non-Hispanic blacks.
  • People of color and low income populations still face disparities regarding health and access to parks.
  • Proximity to parks and other green spaces has benefits for health and health-related behavior, especially of urban residents, and aids in reducing health disparities among populations.

eGuide, p. 9-10.

Human health includes a state of complete physical, mental and social wellbeing, and not merely alleviating chronic diseases including obesity and diabetes, according to the World Health Organization and NPS’s Healthy Parks, Healthy People U.S. Strategic Action Plan.[6] NPS’s Healthy Parks, Healthy People Science Plan (2013) compiles extensive social science, evidence-based research that identifies relationships between socio-economic status and participation and access to green space and outdoor recreation.[7]

The National Recreation Area Legislation

San Gabriel Mountains Forever Environmental and Health Justice for All

Congresswoman Judy Chu emphasizes public health and environmental justice as two of the main reasons for her bill for the San Gabriels National Recreation Area. “Los Angeles is the most park-poor region in the United States. New York City has more park space than L.A. Lack of recreational opportunities – large or small – has severe impacts on urban populations struggling with obesity, diabetes, heart disease, and chronic illness. Opportunities to enjoy outdoor activity are vital for public health and the well being of people of all ages and walks of life.” “Parks in the river corridors and Puente Hills are few and far between, and lack the resources to adequately provide opportunities for residents and to walk, jog, bike, picnic, or enjoy other outdoor recreational activities.” “Numerous studies have shown that recreational spaces increase property value and increase revenues for local businesses.”[8]

The proposed legislation addresses these values through a diverse public advisory council including environmental justice representatives, comprehensive management and visitor plans, and a partnership among federal, state, tribal, and local authorities and the private sector. We support an analogous public advisory council relative to the national monument.


Diverse allies ranging from health and environmental justice advocates to mainstream environmental organizations have submitted comments adopting the above framework to support specific outcomes to address environmental quality, health, and environmental justice in the San Gabriels Mountains and Watershed. Click here to download the August 26, 2014, letter to President Barack Obama, and the August 12, 2014, Memo from the San Gabriel Mountains Forever Campaign.

These diverse allies include: Amigos de los Rios; Anahuak Youth Sports Association; Asian and Pacific Islander Obesity Prevention Alliance; Asian Pacific Policy & Planning Council (A3PCON); Robert Bracamontes, Acjachemen Nation; The City Project; Coalition for Responsible Community Development; Concerned Citizens of South Central Los Angeles; Conservation Law Foundation; EndOil/Communities for Clean Ports; Global Community Monitor; State Senator Tom Hayden (ret.); Latino Coalition for a Healthy California (LCHC); Los Angeles Wilderness Training; Los Jardines (The Garden Institute); Multicultural Communities for Mobility; National Parks Conservation Association; New Mexico Environmental Law Center; Natural Resources Defense Council; Social and Public Art Resource Center (SPARC); Social Justice Consultancy

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[1] NPS, Healthy Parks, Healthy People Community Engagement Resource eGuide at p. 15 and The complete eGuide is available at

[2] NPS, San Gabriel Watershed and Mountains Special Resource Study & Environmental Assessment, p. 231 (Newsletter #5, Nov. 2011) (San Gabriel Study). Please click here for a copy of the relevant excerpts from the National Park Service San Gabriel Study.

[3] 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

[4] Office of Civil Rights, U.S. Dep’t of Agric., DR 4300-4, Civil Rights Impact Analysis (2003), available at

[5] See, e.g., Deborah J. Chavez, Mexican-American Outdoor Recreation: Home, Community & Natural Environment, proceedings paper, Hawaii International Conference on Social Sciences 5, 41-43 (2003); Deborah J. Chavez, Adaptive Management in Outdoor Recreation: Serving Hispanics in Southern California, 17 (3) West. J. Applied Forestry 132 (July 2002).

[6] Healthy Parks, Healthy People U.S. Strategic Action Plan (2011) at 8, citing Preamble to the Constitution of the World Health Organization as adopted by the International Health Conference, New York, 19 June – 22 July 1946; signed on 22 July 1946 by the representatives of 61 States (Official Records of the World Health Organization, no. 2, p. 100) and entered into force on 7 April 1948. See WHO FAQ at

[7] Id. at 34-38.

[8] See Congresswoman Judy Chu, San Gabriel NRA Proposal FAQs,