OCS Study

BOEM 2024-065

US Department of the Interior

Bureau of Ocean Energy Management

Gulf of Mexico Regional Office

New Orleans, LA

Environmental Justice Technical 

Workshops for the Gulf of Mexico 

Region 

 

 
OCS Study

BOEM 2024-065

US Department of the Interior

Bureau of Ocean Energy Management

Gulf of Mexico Regional Office

New Orleans, LA

Environmental Justice Technical 

Workshops for the Gulf of Mexico 

Region

July 2024 

Author:

Brian Snyder

Prepared under Cooperative Agreement M22AC00004

by

Department of Environmental Sciences

Louisiana State University

93 South Quad Drive

Baton Rouge, LA 70803
iii

DISCLAIMER

Study collaboration and funding were provided by the U.S. Department of the Interior, Bureau of Ocean 

Energy Management (BOEM), Environmental Studies Program, Washington, DC, under Agreement 

Number M22AC00004 with Louisiana State University. This report has been technically reviewed by 

BOEM, and it has been approved for publication. The views and conclusions contained in this document 

are those of the authors and should not be interpreted as representing the opinions or policies of BOEM, 

nor does mention of trade names or commercial products constitute endorsement or recommendation for 

use.

REPORT AVAILABILITY

Download a PDF file of this report at https://espis.boem.gov/Final%20Reports/BOEM_2024-065.pdf. 

To search for other Environmental Studies Program ongoing and completed studies, visit

https://www.boem.gov/environment/environmental-studies/environmental-studies-information/. 

CITATION

Snyder BF. 2024. Environmental justice technical workshops for the Gulf of Mexico region. New Orleans 

(LA): U.S. Department of the Interior, Bureau of Ocean Energy Management. 45 p. Obligation No.: 

M22AC00004. Report No.: OCS Study BOEM 2024-065. 

ABOUT THE COVER

The ExxonMobil Refinery in Baton Rouge, Louisiana. Source: Wikimedia Commons. W Clarke.

ACKNOWLEDGMENTS

We greatly appreciate the time and insights of the panelists. 
iv

Contents

List of Figures ............................................................................................................................................. v

List of Tables ............................................................................................................................................... v

List of Abbreviations and Acronyms .......................................................................................................vi

1 Introduction ......................................................................................................................................... 7

1.1 Origins of Environmental Justice................................................................................................... 7

1.2 Contemporary Environmental Justice Industrial Practice ............................................................. 8

1.3 Examples of Environmental Injustice ............................................................................................ 8

1.4 Macro-scale measures of Environmental Justice ......................................................................... 9

1.5 How does Environmental Justice Impact Louisiana?..................................................................10

2 Summary of BOEM Workshop I: Environmental Justice Issues in the Gulf of Mexico Region 12

2.1 Introduction..................................................................................................................................12

2.2 Issues Raised..............................................................................................................................12

2.2.1 Communities are not always spatially defined........................................................................12

2.2.2 BOEM-regulated activities have positive and negative impacts on local communities ..........12

2.2.3 Vietnamese and Native American communities are of special concern................................. 12

2.2.4 Linking negative impacts to offshore leasing and across space is difficult.............................13

2.2.5 Industrial boundaries of BOEM’s thinking should extend at least to refining..........................13

2.2.6 BOEM can improve community engagement .........................................................................14

2.2.7 BOEM has options for improving EJ in the GOM....................................................................14

2.2.8 Renewables present new challenges .....................................................................................15

2.2.9 Carbon Sequestration (CS).....................................................................................................15

2.3 Concerns .....................................................................................................................................16

2.4 Summary .....................................................................................................................................16

3 Summary of BOEM Workshop II: Geographic Scope of Environmental Justice Issues in the 

Gulf of Mexico Region – Defining EJ Communities ..............................................................................17

3.1 How do we define Environmental Justice communities in the Gulf of Mexico?..........................17

3.2 What are BOEM’s Environmental Justice Impacts and how are they related to specific 

communities? How do threats interact?..................................................................................................18

3.3 Building Resilience in Gulf Communities ....................................................................................19

3.4 Renewables................................................................................................................................. 19

4 Summary of BOEM Workshop III: Environmental Justice, Data, and Empirical Issues in the 

Gulf of Mexico ...........................................................................................................................................20

5 Summary of Workshop 4: Generating Study Concepts for BOEM’s Environmental Justice 

Portfolio......................................................................................................................................................22

5.1 Introduction..................................................................................................................................22

5.2 Topic 1: Improving Environmental Justice Analytics and Community Identification...................24

5.3 Topic 2: Inter-agency Intersections.............................................................................................25

5.4 Topic 3: How is the Transition Experienced Locally ...................................................................25

6 Conclusions .......................................................................................................................................27

References.................................................................................................................................................28

Appendix 1: Workshop Agendas.............................................................................................................29

Appendix 2: Presentation Used to Frame Workshop 3.........................................................................35

 
v 

List of Figures

Figure 1. US and Louisiana census tracts included in CJEST. ................................................................. 10

List of Tables

Table 1. EJ-related people, issues, threats, and science in the Gulf..........................................................23

Table 2. Initial questions and study ideas identified by the panel, lightly edited for clarity .......................24

Table 3. Panel’s highest three priorities for environmental justice studies .................................................24

Table 4. Outline of the Improving Environmental Justice Analytics and Community Identification study...24

Table 5. Methods and outcome of the proposed inter-agency intersections study ....................................25

 
vi

List of Abbreviations and Acronyms

Short form Long form

BOEM Bureau of Ocean Energy Management

CAP Community Advisory Panel

CS carbon sequestration

EJ Environmental Justice

EO Executive Order

EPA Environmental Protection Agency

GOMESA Gulf of Mexico Energy Security Act

Gulf Gulf of Mexico 

OCS Outer Continental Shelf

PCB poly chlorinated bisphenol
7 

1 Introduction

In 1994, President Clinton signed Executive Order (EO) 12898, the first Federal Order concerned with 

environmental justice (EJ). EO 12898 directed Federal agencies to incorporate EJ into their decision 

making; in practice, this often involves the consideration of EJ in permitting or NEPA processes. This 

was significant because it was the first EO to direct the Executive Branch to incorporate EJ into its 

decision-making processes. More recently, President Biden signed EOs 14008 and 14096. EO 14008, 

Tackling the Climate Crisis at Home and Abroad, contains a number of sections, but, for our purposes, 

the most notable component of EO 14008 is the Justice40 Initiative, a plan to ensure that 40% of the 

economic benefits from certain Federal investments flow to disadvantaged communities. While Justice40 

is not precisely aimed at EJ communities, it has raised awareness of EJ and further focused the federal 

government’s attention on EJ and related issues. EO 14096, Revitalizing Our Nation's Commitment to 

Environmental Justice for All, takes a “whole of government” approach to EJ and has been seen as an

extension of EO 12898, seeking to add more specific direction to EO 12898‘s more general framework. 

At the same time, there has been a growing public interest in EJ and a burgeoning realization within the 

regulated community that the public’s perception of EJ will impact the social license to operate. We see 

this clearly in Louisiana, where public opposition has stalled the construction of the Formosa Plastics 

Plant in St. James Parish, and public opposition from within Livingston Parish may derail plans for CO2

storage in the Lake Maurepas area. These industrial developments (e.g., plastics production and carbon 

storage) are quite different and impact different communities, but they are both demonstrate the ability or 

potential for citizens who oppose development due to EJ concerns to organize to successfully resist 

development. 

BOEM needs to understand how the activities it regulates might impact EJ. This is especially relevant in 

the Gulf of Mexico (Gulf) region because of its long history of EJ problems. This report describes a series 

of four workshops held at Louisiana State University in late 2022 and 2023. Participants in the workshops 

included BOEM personnel, academics, industry personnel, and environmental lawyers. The purpose of 

these workshops was to discuss BOEM’s information needs for its technical analyses of EJ in 

environmental assessments and how to address them. This report begins with a brief historical overview 

of EJ to provide context, before describing the four workshops. The summary in this report results from a 

combined effort between the facilitator and the meeting participants (including BOEM staff) and is 

intended to reflect the sentiments expressed during the meeting in an accessible manner.

1.1 Origins of Environmental Justice

In 1983, sociologist Robert Bullard discovered that garbage dumps in the city of Houston, Texas, were 

located disproportionately in African American neighborhoods. Though the city was 27.6% Black, all five 

of its landfills and four of its five trash incinerators were in Black communities; the fifth incinerator was 

in a Hispanic community (Bullard 1983). At approximately the same time, a predominantly Black 

community in North Carolina began to protest against the placement of a toxic waste dump in their 

community. This dump, the Warren County PCB landfill, was to accept toxic wastes that had been 

dumped on roadsides in other parts of the state. Eventually, the Warren County PCB landfill was 

constructed, accepted PCB wastes, and then suffered a series of containment failures. The opposition to 

the construction of the landfill was covered in the national news, spreading the concept of EJ beyond 

academia. Together, these two events mark the beginning of the EJ movement.

Since then, the field of EJ has grown significantly, but it still revolves around the fact that low income

communities and communities of color shoulder a disproportionate share of the environmental health 

burden caused by industrial activity. Further, EJ is concerned with the inability of residents in low income
8 

communities and communities of color to participate in the decision-making processes associated with the 

use of their surrounding environment (e.g., extractive industries, dumps, processing facilities), negatively 

impacting the quality of the environment, quality of life, health, and their access to it. Thus, EJ involves: 

1) ensuring industrial activity does not place an undue burden on communities, and 2) ensuring that

communities have access to the decision-making process associated with potential development actions in 

or near their community. Furthermore, as exemplified by the Justice40 initiative, there is a desire for 

communities that are impacted by industrial development to share in some of the economic benefits of 

that development.

1.2 Contemporary Environmental Justice Industrial Practice

At present, government and industry attempt to ensure the two goals of EJ described above, although such 

attempts are uneven (see below). In general, it is the government’s responsibility, thorough its regulatory 

authority, to ensure that industrial activity does not place an undue burden on communities. In many 

cases, this responsibility is exercised through the Clean Air Act and Clean Water Act, the Resource 

Conservation and Recovery Act, and the National Environmental Policy Act. Often, regulatory authority 

is delegated to the state, especially though the Clean Water Act and Clean Air Act. Notably, none of the 

aforementioned laws are explicitly designed to address EJ concerns, and, indeed, most were passed before 

Bullard’s work or the Warren County PCB Landfill controversy. As a result, former President Clinton and 

President Biden have used EOs to try to encourage Federal agencies to incorporate EJ into their decision 

making, but this can create an uneasy legal balance due to potentially conflicting mandates. For example, 

if a regulatory agency has a legislative mandate to grant permits under a specified regulatory process, an 

EO cannot override that legislative mandate.

The second core component of EJ–that communities have access to the decision-making process–is most 

often ensured through two mechanisms. First, there are public comment periods before most major state 

and federal regulatory decisions. Second, industry has formed Community Advisory Panels (CAPs) 

which are composed of citizens from impacted communities. At CAP meetings, CAP members hear 

reports about current and planned activities from local industries. Both of these methods for ensuring 

public participation have weaknesses. Expecting the public to submit comments on proposed industrial 

activity requires that the public have significant time and resources to learn about the costs and benefits of 

proposed industrial activity, understand often complex environmental, legal, and regulatory jargon of 

proposed regulations, and have access to community meetings or web portals through which they may 

submit comments (e.g., transportation, computer/internet access, time). CAPs are limited because they 

include a very small fraction of community members who may not represent all relevant perspectives 

within a given community. 

1.3 Examples of Environmental Injustice

Considering these limitations, it is not surprising that there are a number of documented cases of 

environmental injustice in the U.S. Studies have found that: 

• toxic waste disposal sites in California specifically targeted minority communities (Pastor et al. 

2001), 

• soil concentrations of heavy metals are higher in low-income neighborhoods in California, 

creating an elevated cancer risk (Masri et al. 2021), 

• environmental violations are more common in lower income mining communities in Appalachia 

(Stretesky and Lynch 2011), 

• Hurricane Harvey disproportionately affected low income and minority communities (Collins et 

al. 2019), 
9 

• vehicular air pollution is more likely to impact Black and Hispanic children than White children 

in the U.S. (Rubio et al. 2021) and in Texas (Chakraborty 2022), 

• regulators take longer to respond to Clean Water Act violations in low income and Hispanic 

communities (Konisky et al. 2021), 

• that school districts with more black or foreign-born children had a higher lifetime cancer risk 

than other districts (Grineski and Collins 2019).

1.4 Macro-scale measures of Environmental Justice

Two commonly used tools for EJ screening are the EPA’s EJ Screen and the Council on Environmental 

Quality’s CEJST (Climate and Economic Justice Screening Tool). Both are intended for a “screeninglevel” look and are not designed as in-depth risk assessment or to constitute the entirety of an EJ analysis. 

It is essential to remember that screening-level results do not, by themselves, determine the existence or 

absence of environmental justice concerns, nor do they provide a risk assessment. These tools also have 

limitations related to granularity and scale (USEPA 2024). As we discuss in later chapters, they both have 

weaknesses that could be remedied with additional data and some adjustments. 

EPA’s EJ Screen1

 uses data on environmental hazards taken largely from EPA’s air pollution databases 

and uses them along with socio-economic data to create an EJ risk profile at a variety of census scales. 

CEJST2

 was developed to help stakeholders identify census tracts that are eligible under Justice40. Note 

that much of the Gulf Coast and Louisiana are identified as eligible for Justice40 funding under CEJST

(Figure 1). Note also that CEJST does not identify EJ communities, but the broader definition of 

“disadvantaged communities” under EO14008. 

1 See the EPA’s EJ Screen here: https://ejscreen.epa.gov/mapper/

2 See Council on Environmental Quality’s Climate and Economic Justice Screening Tool here: 

https://screeningtool.geoplatform.gov/en/#3/33.47/-97.5
10

Figure 1. US and Louisiana census tracts included in CJEST. 

1.5 How does Environmental Justice Impact Louisiana?

Louisiana has a history of racial inequality. African Americans make up 33% of Louisiana’s population, 

and the average African American worker earnings just 66% of the statewide average income. Nationally, 

African Americans earn 80% of the U.S. average (IPUMS USA 2024). Thus, the already significant 

national earnings disparity between White and Black incomes is more pronounced in Louisiana.
11

Louisiana also has several sites of historical EJ significance or particular concern. For example, the 1981 

U.S. Supreme Court case of McCastle v Rollins Environmental Services concerned environmental 

injustice in the town of Alsen, Louisiana in East Baton Rouge Parish. The case and the protest that led to 

it were among the first social movements against environmental injustice, and the case set a precedent 

allowing residents to be viewed as a class. More recently, the U.S. Department of Justice has sued Denka, 

a Japanese chemical company, which owns a neoprene plant in Laplace, Louisiana (a separate 

investigation of the same facility by the EPA was dropped). The plant is located in a heavily minority 

census tract and emits enough of the carcinogen chloroprene to give it some of the most toxic air in the 

nation (US EPA 2019). In Colfax, Louisiana, a firm called Clean Harbors burns munitions in the open, 

the only location in the country permitted to burn hazardous waste outside of an incinerator. The area near

the incinerator in Colfax is a largely minority community with a long and disturbing history of racial 

injustice. To date, the health effects of the open-air burning are unclear.

 
12

2 Summary of BOEM Workshop I: Environmental Justice Issues in 

the Gulf of Mexico Region

See Appendix 1 for agenda and panelists.

2.1 Introduction

BOEM faces a unique challenge in advancing and ensuring EJ for the communities in the Gulf. BOEM 

regulates activities on the Outer Continental Shelf (OCS), including longstanding oil and gas leasing, 

exploration, development, operations and decommissioning, and the newly introduced renewable energy 

and carbon sequestration programs. These activities affect the people of the Gulf, but understanding these 

impacts is difficult because the most harmful impacts are likely to be the least direct. The EJ literature is 

replete with examples of industrial activities impacting fence line communities, but how can BOEM 

understand EJ when much of the activity is offshore? This workshop sought to understand this question 

by identifying potential EJ impacts and communities in the Gulf. Thus, it was intended to scope out EJrelated issues of relevance to BOEM’s Gulf activities. 

2.2 Issues Raised

2.2.1 Communities are not always spatially defined

In the Gulf, communities are not always only places in which people live. Communities are often defined 

by shared interests, history, and identity. For example, members of the United Houma Nation (Houma) 

are a community with a link to specific coastal settlements, but members may live in other parts of the 

state. Similarly, fishers, shrimpers, and oyster harvesters may work in different parts of the coast over the 

year, and yet may have residences in other areas. In recent decades, some coastal workers now commute 

to the coast from inshore areas because they have been physically displaced by the changing environment

(e.g., storms, hurricanes, offseason employment opportunities). Offshore oil and gas workers may

constitute a community with a particular exposure to environmental risk, but due to the nature of their 

work shifts may live hundreds of miles from the coast. To further complicate the definition of community, 

individuals may simultaneously identify as part of multiple communities at once. An individual may work 

for the oil and gas industry, fish recreationally, and identify as Native American. These factors make it 

difficult to draw a conceptual box around the term “EJ communities”.

2.2.2 BOEM-regulated activities have positive and negative impacts on local 

communities

The workshop panel agreed that oil and gas development has had positive economic impacts on the 

region, in addition to the potential for EJ harms. These positive impacts include employment and tax 

revenue, as well as a strong influence on the region’s economy that is profound but difficult to explicate. 

2.2.3 Vietnamese and Native American communities are of special concern 

The panel was asked about specific communities that may be of special concern. The panel suggested that 

the Vietnamese fishing and shrimping community in Louisiana and Alabama is of special concern, as are 

the Native American tribes in the region, especially the Houma. BOEM interacts with the Houma, a Staterecognized tribe, but does not consult with them in a government-to-government relationship as it would 

for a Federally recognized Tribe. Fishing, shrimping, and other natural resource occupations are important 

to these groups, both economically and culturally, and so any negative impacts on fisheries from BOEMregulated activities would be a potential source of environmental injustice.
13

2.2.4 Linking negative impacts to offshore leasing and across space is difficult

People often draw a connection between BOEM-regulated activities and impacts from specific onshore 

facilities (e.g., shorebases, refineries, petrochemical plants, transportation systems), but empirically 

linking such impacts to BOEM-regulated activities is difficult. The panel agreed that BOEM has 

developed significant data tools for estimating the environmental impacts of its operations but that these 

do not link the impacts to the places where these impacts might occur. For example, BOEM may estimate 

emissions factors associated with natural gas processing in its programmatic EIS, but the available data

for a programmatic EIS BOEM uses cannot identify the specific sites where the estimates of the gas will 

be produced and emissions will result as a result of a regional lease sale. This limitation in analysis scope 

and available data is a problem in all cases in which BOEM estimates onshore socioeconomic impacting 

factors. Considering the data limitations, this problem holds retrospectively, as well. Making such a link 

is non-trivial due to the complexity of offshore operations, but new analytical approaches and data tools 

may make such a task possible.

Land loss is a critical concern to many communities in South Louisiana and partially linked to pipeline 

corridors, although many other natural and anthropogenic factors also contribute. While few new pipeline 

landfalls are installed for oil and gas production, new pipeline infrastructure would need to be developed 

for carbon sequestration (CS) and this could exacerbate land loss and lead to EJ impacts. Similarly, new 

high voltage cable would need to cross the coastal zone to facilitate offshore renewable energy projects.

2.2.5 Industrial boundaries of BOEM’s thinking should extend at least to refining

Impact areas are supposed to include all significant impacting elements. Because of the offshore 

petroleum industry’s complex, integrated, and distributed industrial organization, BOEM has always 

faced difficulties in geographically bounding its analyses. The boundary is difficult because its constituent 

elements operate within their own (often global) market conditions at scales that are often discordant and 

difficult to bound. Strictly oil-related businesses like drilling and refining operate in the Gulf and 

elsewhere. Heavily oil-engaged Gulf industries like shipbuilding build ships and platforms for the 

industry, but also U.S. Coast Guard and fishing vessels and foreign yards build ships and jackets for Gulf 

oil and gas activities.

BOEM has approached this boundary in three steps:

1. BOEM began with each coastal State’s Coastal Zone Management Area (CZMA). Because

NEPA is an environmental law, BOEM began with the coastal area that states defined as 

environmentally sensitive to coastal and offshore developments. 

2. BOEM identified for inclusion areas with concentrated industries and infrastructures involved in 

offshore petroleum activities. BOEM used these two processes to define the outer boundary and 

this was adjusted at times as information changed. 

3. Within the defined GOM Affected Environment, BOEM determined what it would and would not 

consider (e.g., it historically included some upstream activities but excluded downstream ones).

Virtually all onshore impacts due to OCS activities are indirect and outside of BOEM’s statutory 

authority. In BOEM’s NEPA analyses, the Bureau has, for the most part, historically chosen not to 

address in detail such onshore, indirect effects. When considering EJ, understanding the indirect 

impacts of BOEM activities necessitates drawing a conceptual box around the industry to

demarcate what BOEM will include and exclude in any analysis. Should BOEM include flood 

controls, ports and waterways, ship construction, refining, petrochemical production, and gasoline 

consumption? These are important questions because the most significant EJ impacts will likely be 

indirect. Issues related to upstream infrastructure and activities have not been systematically investigated 

but downstream activities are well known to have significant EJ impacts and the panel concluded that 
14

refining might be one plausible place to draw such a box. This does not imply that placing the boundary at 

refining is possible or desirable. That is, the panel may agree that understanding the EJ impacts of 

BOEM-regulated activities from production to processing and/or refining would be beneficial, but the 

panel acknowledged that it may not be possible. Traditionally, BOEM drew the conceptual line upstream 

of refining because it was assumed that refineries’ activity was driven by demand (e.g. demand for 

gasoline, jet fuel, etc.) rather than supply and that in the absence of offshore oil and gas, Gulf refineries 

would substitute with imports. As a result, even if we could say that a barrel of Gulf oil leads to a VOC 

emission of x in community y, it does not follow that this is also the marginal impact of Gulf production

as this impact may occur even if supply was from overseas (i.e., not from the US OCS).

2.2.6 BOEM can improve community engagement

EJ is not limited to understanding the distribution of harms, but also includes the need to ensure equal 

access to decision-making among communities. BOEM has an opportunity to improve EJ by expanding 

access to its decision-making process. At present, BOEM primarily interacts with the Gulf community 

through public meetings and comment periods, but many people do not have the training or time to 

engage with these processes. 

The panel noted several potential options. First, other agencies (e.g., the Department of Defense) provide 

funding so that local communities can hire attorneys to read and comment on NEPA documents on their 

behalf. Second, the panel noted that BOEM’s Alaska region did an especially good job of interacting with 

local populations, although their socioecological context is different from the Gulf’s. Third, the panel 

suggested that new anthropological or sociological studies might be a good way for the Bureau to 

understand impacted communities and for communities to understand that BOEM is interested in their 

concerns. Fourth, the panel suggested that community advisory panels (CAPs) used by industry might be 

a model for BOEM to follow. CAPs are standing committees that include both industry and community 

representatives and are designed to allow the industry to update the community on a monthly or some 

other routine schedule. Fifth, the panel recommended the use of fact sheets in multiple languages that 

provide basic information about BOEM activities. Sixth, the panel suggested that BOEM conduct 

informational meetings designed to teach the public about the industry rather than meetings tied to 

specific lease sales. The panel was concerned that by the time BOEM gets to lease sales, they have 

already missed the opportunity to educate the public. Seventh, the panel noted that agencies cannot just 

come into communities armed with the questions they want to talk about, they have to elicit and 

understand the specific issues community members identify as identify as important. Agencies cannot set 

a concrete or inflexible agenda for EJ meetings and/or engagements with communities if they wish to 

have an engaged and informative dialogue with community members on their views of the proposed 

action or on other related issues.

2.2.7 BOEM has options for improving EJ in the GOM

The panel identified several ways BOEM might improve the analysis of EJ impacts of its activities. First, 

the panel suggested that BOEM could replicate the design of the Coastal Marine Institute–a joint BOEMLSU partnership–to create a “Community Studies Program” in which BOEM came together with 

communities to develop studies that were of joint interest. This connects with the developing communityengaged research paradigm that has been supported by the National Institutes of Health and that emerges 

from the assumption that the community, rather than academics or bureaucrats, best understands its 
15

problems3

. Once these problems are identified by the community, the community then works with 

academics and bureaucrats to study and address them.

Second, the panel felt that BOEM has a role in building resilient communities. Considering the 

complexity of environmental problems in the Gulf and their multiple and overlapping causes, it may not 

be possible to rectify them all. However, BOEM might encourage the development of the community’s 

capacity to be resilient to these issues. For example, the panel identified hurricanes, a long-term 

population exodus, land loss, and the 2010 Macondo oil spill as major problems affecting the region over 

the last two decades. Future BOEM actions are unlikely to have a significant impact on the long-term 

socio-environmental problems in the Gulf, but BOEM could build capacity so that communities can be 

more resilient to the next stressors.

Third, the panel proposed adding EJ language (such as clauses or credits) to leases that was similar to 

mimicking the language added to renewable leases in the Atlantic to ensure local content. Such language 

might require lessees to ensure that the benefits and costs of their activities are fairly distributed and/or 

that the benefits go to the communities most negatively impacted by the activities.

2.2.8 Renewables present new challenges

Renewables were not seen as a panacea for EJ issues, but as a new source of both positive and negative 

impacts. A primary concern for renewables is the laying of cables, especially where they come onshore, 

and the potential for saltwater intrusion and wetland loss. There were also concerns about fisheries, 

viewsheds, port use, and how components would be decommissioned. In addition, there was concern 

about whether the negative impacts of offshore renewables would “pile on” to the same communities 

experiencing the negative impacts of oil and gas. The panel noted that the scale and distribution of 

impacts from renewables will be different from oil and gas. Offshore renewables will likely use smaller 

vessels operated from smaller ports closer to site. As a result, smaller shorebases that have declined over 

the past several decades may experience a resurgence. This will create new positive and negative effects 

for local communities.

2.2.9 Carbon Sequestration (CS)

The panel discussed carbon sequestration and its EJ concerns. In addition to concerns about the need for 

new pipelines and new pipeline landfalls, there was a concern about the perception of CS safety. 

Interestingly, while the panel did not think CS was unsafe, it did note that people think it is unsafe. This 

might make people perceive CS as environmentally unjust and/or risky regardless of whether or not it 

does in fact present environmental risks and thus the potential for injustice. 

Throughout the workshop, the panel emphasized that perceptions are valuable. That is, if someone 

perceives that they are discriminated against, it is important to listen to them. Similarly, if someone feels 

that CS is environmentally unjust, that belief should not simply be dismissed. The panel also noted that 

BOEM has a role to play in building trust with the local community in order to build genuine, two-way 

communication so that all sides can understand each other’s perspectives. 

3 This is along standing principle within applied anthropology and kindred social sciences, that community issues or 

challenges, whether agricultural, energy development, etc. can’t be adequately addressed without an understanding 

of the relevant perspectives, customs, practices of community members.
16

2.3 Concerns

To conclude, we asked the panel about their primary concerns with EJ. They noted:

• We can’t assume that we really know what we think we know unless we talk to the communities. 

Our models and high-level data can only take us so far in understanding what actually goes on.

There is a need for ground truthing.

• BOEM’s EIS analysis focuses more on the environmental harms than the benefits of offshore 

activity and the distribution of those benefits.

• The inability to perfectly quantify impacts does not imply that they shouldn’t be discussed. It is 

difficult or impossible to link many BOEM activities to EJ impacts, but an honest attempt may be 

appreciated by communities. Furthermore, transparency about the Bureau’s capabilities in 

assessing EJ impacts in light of its jurisdiction, as well any technological and/or data limitations. 

• BOEM needs a two-way, holistic understanding of communities. 

• Communities need help (e.g., technical, financial) bolstering their resilience and scientific literacy 

to fully engage in the decision-making process. However, regulatory and operational constraints 

make this challenging.

• Fishing and shrimping are a critical concern for the Houma for cultural and economic reasons. 

Losing those activities–as from oil spills–would ultimately impact their cultural identity as the 

practices, lifeways, and relationships manifested, in part, by these harvest activities are in essence 

who the Houma are.

• The lack of Federal recognition of the Houma as a tribe has limited BOEM interaction with the 

Houma. This could be rectified by BOEM policy requiring coordination with state-recognized 

tribal groups. Given the tribal leadership’s understanding of the community, this would provide 

an obvious means to understand the challenges of the community.

2.4 Summary 

The purpose of the workshop was to understand the scope of the EJ issue–how BOEM regulated activity 

impacted EJ, where these impacts occurred, and who they most profoundly affected. The panel concluded 

that negative effects are generally indirect and difficult to link to specific BOEM actions, but that positive 

impacts also occur. The panel did not provide a specific list of potential EJ impacts but did note that the 

Houma are a key constituency that need to be consulted. Broad, high-level analysis are useful as a 

scoping tool, but to truly understand the EJ impacts of BOEM activities, more local data and information 

is needed, and thus interaction with the community is critical.

 
17

3 Summary of BOEM Workshop II: Geographic Scope of 

Environmental Justice Issues in the Gulf of Mexico Region – 

Defining EJ Communities

See Appendix 1 for agenda and panelists.

3.1 How do we define Environmental Justice communities in the Gulf of 

Mexico? 

The focus of this second workshop was on the geographic scope of EJ issues in the Gulf of Mexico 

region, with a particular focus on the definitions of EJ communities. Therefore, the workshop began with 

a brief discussion of the three types of methods which some government agencies use to distinguish EJ 

from non-EJ communities. Informed especially by the USDOI Bureau of Land Management, these are:

1. “50%” analysis in which if 50% of the community is identified as minority or low-income the 

community may be considered an EJ community.

2. “Meaningfully greater” in which if the community has a minority or low-income population that 

is meaningfully greater than a reference community, often contiguous or nearby. 

3. “Threshold analysis” in which local information is used to identify communities that might 

exceed an arbitrary threshold of minority or otherwise vulnerable populations. 

We solicited the panel’s thoughts on these approaches and asked about other potential approaches or data 

sources. The members recognized the data limitations used to identify EJ communities, particularly for 

sparsely populated areas such as coastal Louisiana and the members sought to identify alternative sources 

of data. They suggested that other sociological data sets may be useful, specifically data on healthcare 

availability, educational attainment, and poverty data. The panel noted that data on free and

subsidized lunches are readily available at granular levels and may be useful for capturing both people 

in poverty and those just slightly above federal poverty guidelines. The panel also noted the availability 

of the CDC social vulnerability index which contains many of these datasets, but the panel discussed 

the idea that the individual data layers in the index may be more useful for identifying vulnerable 

communities than the (composite) CDC vulnerability index itself. One panel member also noted that the 

United Houma Nation collects information about its members for use in assisting them with hurricane 

recoveries. This information might be available.

The panel also discussed whether these three high-level approaches may miss some EJ communities in 

the GOM. There was a particular concern about the fishing community because its members have 

multiple overlapping racial/ethnic identities (e.g., White, Vietnamese, Native American, African 

American), are multi-lingual (English, French, Vietnamese), may not live in the communities in which 

they fish, and may have complex ways of making a living by working in multiple industries at different 

locations or times of the year. The on-the-ground experience of these individuals might be very different 

from that captured in census data or any strictly place-based approach to data. This issue is heightened 

because coastal people face particular threats from land loss, climate change, and the changing offshore 

oil and gas industry.

In sum, a specific threshold based on a single variable (e.g., race, place) may not be as useful as a multidimensional analysis. In addition, specific EJ communities experience effects and impacts in communityspecific ways, and, as such, the process of identifying and documenting the identity of EJ communities is 

complex and contextually contingent and thus impacts and effects are not “one-size fits all”. For example, 

reduced fish catch may impact Vietnamese and African American communities differently. 
18

The panel also discussed the utility of “Purposeful Sampling” or “Chain Referral” as a complement and 

alternative to the random sampling usually employed in data-driven social science research. That is, the 

panel wondered if the complexity and out-migration of the Gulf coastal zone would be better captured 

from a more resource-intensive and anthropological analysis rather than the census data-based approach 

that is more typical of the three threshold methods above. This purposeful sampling approach was 

determined to be somewhat similar to an industry approach to environmental justice that one of our 

panelists described. In this approach, industry reaches out to elected officials (e.g., city councils), local 

non-profits (e.g., United Way), local churches, and local hospitals to get insight into the community and 

to understand the community’s issues. Purposeful sampling identifies knowledgeable and respected

individuals within the target communities by speaking to community members and requesting referrals – 

i.e., ‘Who would you say knows a lot about topic X?’. 

In addition, some of the communities in the coastal zone are not communities in the sense that the term is 

typically understood, i.e., a contiguous locale where all know each other, and work, live and play 

together. Because of recent population declines, the region lacks the physical infrastructure that anchors a 

community to a place (e.g., hospitals, community centers, schools, grocery stores). Following each 

impactful hurricane season, a new group of people are displaced, many of whom do not return. As a 

result, the coastal community–and the Native American tribes in particular–is in some sense a diaspora 

with individuals spread across the region and physically, if not emotionally, separated from a specific 

locale. This raises a problem because the concept of a geographically bound community underlies most 

EJ analyses and, in many cases, this concept may not be appropriate for the Gulf coastal zone.

3.2 What are BOEM’s Environmental Justice Impacts and how are they 

related to specific communities? How do threats interact?

Industrial activities result in a diversity of environmental impacts, and these impacts may have differential 

impacts on the larger population, thus sub-populations (in some sense distinct communities) may be 

impacted differently (i.e., extent, nature, etc.). For example, some industrial activities release air 

pollutants and elderly populations are particularly susceptible to air pollution. Therefore, we asked the 

panel about how BOEM-regulated activities were related to specific populations and communities in the 

Gulf? The panel identified fabrication activities (air quality), pipeline and other spills (water quality), 

waste disposal, truck traffic (road impacts and/or traffic), dredging (fishing and/or shrimping impacts), 

sandblasting (air quality and/or dust), ship traffic (air quality), helicopter traffic (noise) and pipeline and 

cable laying (land loss) as having potential impacts. There has also been increasing interest in methane 

leakage in the literature, and this could be a new area of concern as both a greenhouse gas and a source of 

ozone. In addition, the panel mentioned “scope 3” emissions, or the CO2 emissions associated with the 

combustion of the oil and gas produced on the OCS. The panel also mentioned that there could be 

potential EJ impacts under a no new lease scenario. 

These various impacts affect some communities more than others. For example, land loss is most likely to 

affect shrimpers and tribal communities while road and helicopter traffic might impact communities along 

Highway 1, the main linkage between the onshore logistics system and the offshore supply port at 

Fourchon. 

Finally, the panel identified some unique EJ issues that may be outside those typically considered in 

academia or the regulatory community. The panel identified the issue of a “brain drain”, in which people 

drop out of school for well-paying jobs in the offshore industry, but as the offshore industry follows its 

historical boom-bust cycles, these people often lose their industry jobs and lack the school training that 

may have provided access to other employment opportunities. Another unique EJ issue that arose was the 

concern that Native American community traiteurs would not pick medicinal herbs from areas presumed 

to be contaminated. Thus, the perception of environmental degradation, regardless of the actual state of 
19

the environment, could create environmental injustice. The panel also noted that current changes to flood 

insurance policy will also likely be a significant factor in changing demographics and infrastructure.

The panel also discussed potential avenues for mitigation of these concerns. Many concerns have 

relatively simple means of mitigation, for example, better consultation of local communities in road siting 

or no wake zones for vessel traffic. However, the panel argued that consultation was not, by itself, 

sufficient mitigation. On the other hand, the panel mentioned that many EJ issues are already mitigated to 

some degree through regulation. For example, vehicles are required to have catalytic converters and this 

has greatly improved air quality and reduced the EJ impacts of traffic. The panel also brought up that the 

Gulf of Mexico Energy Security Act (GOMESA), which includes revenue sharing from oil and gas 

development with Gulf states for the purpose of coastal restoration, was intended to mitigate offshore oil 

and gas development.

Perhaps the most notable EJ impact in the Gulf related to BOEM’s analytic purview is the increase in the 

severity of tropical storms and hurricanes associated with climate change. The panel noted that this is 

connected to all other issues because it is associated with outmigration and because wealthier 

communities are more resilient than lower income communities. In addition, it was noted that people who 

relocate after storms are likely to settle in flood prone areas (because these are more affordable and thus 

more available) in other regions, continuing the cycle of disproportionate harms. There was some concern 

that due to outmigration, the coast was to become a “sportsmen’s paradise” in which people come to hunt 

and fish, but communities of year-round residents can no longer exist. Note that the panel’s use of the 

term “sportsmen’s paradise” was intended to imply a type of gentrification in which wealthy individuals 

hunt and fish on the coast rather than a broader criticism of hunting and fishing. Yet while tropical storms 

and their connection to climate change are of great interest, BOEM is constrained in its ability to respond.

3.3 Building Resilience in Gulf Communities

Resilience is critical to the Gulf because it is dynamic and faces multiple anthropogenic and natural 

threats. We asked the panel about how to build resilience in the Gulf and they noted that improving 

transportation networks, ensuring access to insurance, and the diversification of the economy as the main 

drivers of resilience. Of course, outmigration makes resilience more difficult and is driven by economic 

factors. As a result, the panel mentioned that the people left in coastal communities are often the people 

with the fewest resources and capabilities to leave. 

Connecting to Topic 1, the outmigration in the coast also creates a challenge in the use of 10-year or 5-

year frequency data from the U.S. Census. Specifically, the pace of change is too fast to be accurately 

reflected in these data.

3.4 Renewables

There is a growing consensus that offshore wind projects will be developed in the Gulf. The panel agreed 

that this would create jobs for the coast, but that the spatial distribution of these jobs would be different 

from those in the offshore oil and gas sector. Further, the panel noted that while the outlook for offshore 

wind in the Gulf may be unclear, offshore wind development on the Atlantic is progressing and many of 

the services required for oil and gas are also required by the offshore wind industry (e.g., lift boats, 

jackets, crew boats). Thus, the panel expects the Gulf to benefit from activity elsewhere on the OCS.

 
20

4 Summary of BOEM Workshop III: Environmental Justice, Data, and 

Empirical Issues in the Gulf of Mexico 

See Appendix 1 for agenda and panelists.

The goal of this third meeting in BOEM’s EJ Technical Workshop series was to identify existing and 

potential data sets and empirical issues in the Gulf of Mexico Region that could be leveraged to provide 

for BOEM’s future EJ data needs. That is, are there socio-economic, biophysical, or novel datasets (e.g., 

remote sensing, social media, and so on) that could inform BOEM decision making regarding EJ? 

Similarly, are there new datasets that could be developed which would provide information to future 

decision makers? To achieve this, we asked the panel to imagine that some event impacted the Gulf, for 

example, a hurricane, oil spill, land loss, etc. We then asked them to consider the sorts of data that were 

currently available for understanding this event and its differential impacts on communities across the 

region and asked them to imagine the sorts of data that they might wish were available to understand 

differential impacts. 

Before discussing data explicitly, the workshop began with a brief discussion of the previous workshops 

and the lessons learned from those workshops. Participants indicated a desire for the discussion from 

these previous workshops to be translated into action, potentially through better community engagement. 

The panel also discussed the difficulties in identifying “EJ communities”, noting that some communities 

that do not identify as “EJ communities” by outside entities (Federal, state academic) might be identified 

as such using Federal geospatial data tools like the Climate and Economic Justice Screening Tool 

(CJEST), while other communities that are identified as “EJ Communities” object to being so labelled. In 

other words, there is a disjuncture between top-down and bottom-up ways of identifying as EJ. This is an 

important issue for data analysis because defining populations to sample and compare to other 

populations is critical. 

The facilitator gave a brief presentation to frame the discussion in terms of threats to coastal residents. 

Two of the most important threats facing coastal Louisiana are land loss and the related changes to 

insurance costs. Using data from the 2023 Coastal Master Plan, the panel was shown projections of land 

loss and discussed changes to FEMA’s flood insurance program (FEMA Risk 2.0). The panel then 

connected these issues back to their discussion of community. The panel was concerned that the change in 

flood insurance would lead to a situation where only part-time, wealthy residents can afford to own 

homes in the coastal zone. Lower income residents and older residents may be trapped in place, while 

younger and middle-class residents may relocate. Those left in the communities might be the least capable 

of having the funds to elevate their homes. 

The panel proffered that communities are comprised of people who are “fully invested in the present and 

future of their community”. They articulated that the change in flood insurance may cause residents to 

move out of the area and thus change the composition of these communities as residents realized that

continued investment in the area could no longer be protected. 

It is also important to note that the people who leave coastal Louisiana may relocate to areas with 

increased flood risk. Thus, just because people avoid coastal flooding, they may be more susceptible to 

inland flooding. Receiving communities may be strained from coastal outmigrants. For example, new 

housing developments may exacerbate flooding for existing residents (e.g., Prairieville, Louisiana). 

Receiving communities must also be able to handle increased infrastructure use (e.g., school systems) and 

provide economic opportunities. To complicate these issues further, after severe storms, people may leave 

and move back after periods of months or years. We need data tools that extend beyond the coastal zone 

and follow displaced residents to their final destination. 
21

In sum, the panel suggested that we need better inland flood data, we need to understand the relationship 

between migration and employment, and how this relationship may vary with age, and agreed that these 

types of issues could likely be answered with existing data sets. However, new data might be required for 

answering questions about employment in more fluid sectors (e.g., oil and gas), resilience of industry to 

natural hazards, natural disasters impacting industrial hazards (NaTech events), and the relationship 

between movement and class. Because children are of special concern in EJ (i.e., vulnerable subpopulation), one potential dataset may be data on children’s services (e.g. daycare, schools) as an 

indicator of community health.

The panel expressed some concern about how such data may be used. In the 2017 Coastal Master Plan, 

there is a discussion of social vulnerability and the use of indexes to compare vulnerability across the 

coastal zone. As a result of this process, stakeholders might look at their community in bright red on a 

map and conclude that there is no hope if they remain or are hit by a storm, or due to long term trends of 

inundation. The implication being that care (i.e., sensitivity, awareness of messaging/interpretation, 

desired outcomes of info and potential outcomes) is needed when we discuss and/or communicate (e.g., 

through graphs and figures) the EJ of coastal communities and that the goal should be to give 

policymakers, businesses and individuals more information for decision-making, especially about 

mitigation of vulnerability. 

Fishing was also seen as an important domain of data, in terms of importance and need (i.e., data gaps). 

The panel noted that the wives of shrimpers often act in the capacity of advocacy, as the shrimpers 

themselves are constrained by the demands of their occupation and don’t have the time to attend public 

hearings, etc. The panel also noted that employment by industry, not occupation, might better capture 

impacts to fishers. Further, the panel wondered if public assistance data might capture data on fishermen. 

The panel noted that California has a system in place to assist communities with capturing impacts of 

concern. A fee is paid to communities to have a scientist and/or attorney to collect data for impacts. This 

could be a path that BOEM might look into for future developments, especially with renewable energy 

and carbon capture projects. 

One of the core issues in any socio-ecological analysis is scale. The panel argued that data at finer scales 

are nearly always preferred (i.e., the old adage “you can always aggregate data”), but not always 

available. Therefore, a mixed-scalar model was proposed in which different scales of the best available 

data are combined to address assessments as best as possible. 

 
22

5 Summary of Workshop 4: Generating Study Concepts for BOEM’s 

Environmental Justice Portfolio

See Appendix 1 for agenda and panelists.

5.1 Introduction

The fourth workshop was intended to generate potential study ideas for BOEM. To begin, we explained to

the panelists that their generation of research ideas would not guarantee such study ideas would be

funded, nor would their participation in the workshop provide the panelists with any competitive

advantage if a solicitation based on workshop ideas was offered.

Workshop 4 was structured differently from the first three workshops. The first three workshops were 

primarily intended to brainstorm and discuss EJ-related issues in the Gulf and how they related to BOEM 

authority. While built around themes, they were intentionally discursive and exploratory. In Workshop 4, 

we narrowed the participants and sought to identify potential studies that BOEM could support that might 

fill the knowledge gaps that had been previously identified. We selected the participants based on their 

previous engagement with earlier workshops. In this way, most of the participants had been thinking 

about BOEM-EJ issues for at least six months and the panelists had experience with one another.

Before the workshop, the panelists were given a sample BOEM Request for Proposals (RFP) so that they 

had some familiarity with the sorts of data and ideas that are needed to justify an RFP. The panel began 

with a discussion of the sample RFP, then moved to a brainstorming session to identify potential topics. 

Table 1 depicts the results of the brainstorming. Topics were broken into four categories, with several 

topics crosscutting multiple categories. In each category, the panel identified potential research interests 

or topics. For example, one category of research interest might be the Houma and other tribes, and issue 

might be the “gentrification” of the coast, etc.
23

Table 1. EJ-related people, issues, threats, and science in the Gulf 

Alt text: A table that shows the issues identified by the panel. Health and the upstream/downstream industries are 

cross-cutting. 

People/Groups Issues/trends Threats Science

Fishers: Commercial, 

Recreational,

“Subsistence” 

Shallow water decline Climate change and 

storms 

Data needs

Houma and other tribes CCUS Land loss Screening tools

EJ communities Population declines Oil spills Sampling

Employers and/or 

taxpayers

Coastal “gentrification” Insurance Community engagement

Cajun and/or Creole 

groups

Decarbonization Diversions Scope of analysis

Laotian Permitting and the social 

license to operate

Air quality/fires Indirect effects & 

regulation

- Non-economic values Compounding factors State/Federal regulation

- Poverty Uncertainty Benefits

- Justice40 - - 

- Sand & non-oil and gas 

minerals

- - 

Note: Health and the upstream and downstream industries are cross-cutting.

Next, the panel developed research questions based on these topics (Table 2). These research questions 

were brief conceptual ideas and all potential ideas were recorded. We then used a voting system to 

identify the ideas that were most important to the panel and grouped conceptually similar ideas together to 

create a list of three research priorities (Table 3). Finally, the panel developed these ideas in more detail.
24

Table 2. Initial questions and study ideas identified by the panel 

Big picture dynamics and EJ: how does the energy transition, declines in oil and gas, land loss and climate change 

impact EJ in the GOM?

Are there adjustments to CEJST and other screening tools that could improve community identification? What are 

the comparative analytics?

What are the descriptive/qualitative characteristics of EJ communities?

What processes can BOEM use to facilitate interactions between people/groups? What is the value of these 

interactions?

How can we link ethnographic and big picture data as in EJ Screen and CEJST?

What is a realistic scale for wind energy? How will this impact GOM economies?

How can we add local (tax/school) data to impact analysis?

How does workforce development relate to EJ? In state and local governments? In wind and carbon capture 

utilization and storage (CCUS)? 

How do we define EJ communities?

What are cumulative impacts of multiple stressors to people/groups? What are the impacts of decline?

Can we identify/map handoff points in regulatory control? Can we identify an interagency working group for EJ; 

who would participate in such a group?

How do changing dynamics of oil and gas influence decision making and migration of people/groups?

What are the impacts of the energy transition on people/groups?

What is BOEM’s role in terms of new technology, workforce development and research translation?

How can lease clauses be used as levers to promote sustainability?

How do impacts regulated by other (non-BOEM) agencies impact EJ, and what is the role of federalism in creating 

and mitigating EJ impacts?

Lightly edited for clarity.

Table 3. Panel’s highest three priorities for environmental justice studies

Topic 1: Improving EJ Analytics and Community Identification

Topic 2: EJ-related Inter-agency Intersections

Topic 3: How is the Energy Transition Experienced Locally

5.2 Topic 1: Improving Environmental Justice Analytics and Community 

Identification 

Throughout the workshops, one common theme was the inadequacy of existing macro-scale 

quantifications of EJ and EJ communities. Specifically, the panel felt that tools like EJ Screen and CJEST 

are useful as screening tools but are often used in situations for which they were not designed. The panel 

showed an interest in the development of new tools that were able to incorporate more granular social 

data rather than rely on large-scale data from the U.S. Census or other sources. This potential research 

topic sought to address this need.

Table 4 shows the panel’s recommendations for a potential study or group of studies. The panel suggested 

that, in addition to linking with existing datasets in novel ways, there were new data needs that must be 

met. That is, we need to collect new data via “boots on the ground” surveys and focus groups rather than 

only rely on readily available datasets.

Table 4. Outline of the Improving Environmental Justice Analytics and Community Identification 

study

Data needs

• Points of oil and gas interest/infrastructure

• Local fiscal/school data, free and reduced lunch data

• Health data, insurance data, data from USDA

• Unstructured/semi-structured interviews

• Focus groups, surveys

Conceptualization
25

• Defining the community

• Creating relationships with the community

Analytical outcomes

• Definition of the community

• Disproportionately impacted zones

• Comprehensive description of the community

• Case studies

• Outward-facing tool

• Protocol

• Identification of impacts and mitigation

Next, the panel discussed the conceptualization of the RFP. It discussed that the EJ community was 

defined as a critical component of the study design and interrelated to the data needs. In addition, the 

panel discussed whether a community-based participatory method would be appropriate and noted that 

such designs present a tradeoff with more standardized approaches. Nonetheless, the panel was generally 

supportive of the community-based participatory design. The panel also noted that relationships–between 

the research team and the community and among community members–are critical to the 

conceptualization of the study. Researchers do not always have strong relationships with local 

communities, particularly in the somewhat insular communities of the coastal Gulf. At the same time, 

communities within the coastal Gulf are not monolithic and often conflict and cooperate in ways that may 

be unknown to researchers. For example, members of the same community can work in shrimping and the 

oil and gas industry, and these industries may have different and antagonistic motives. Understanding 

these complex relationships is critical.

5.3 Topic 2: Inter-agency Intersections

The panel noted that the regulation of offshore activity is complex involving multiple state and federal 

agencies with different regulatory mandates. As a result, EJ needs to be considered in an inter-agency 

framework, but these interagency connections have not been elucidated. Therefore, the panel proposed a 

conceptually simple study to document the regulation of EJ in the Gulf (Table 5). Yet while simple in 

concept, the panel noted that in practice the work may be difficult because there is no simple way to 

identify these regulators. The panel suggested that the study would start with a conference in which 

researchers assembled all potential regulators to map out regulatory authority.

Table 5. Methods and outcome of the proposed inter-agency intersections study

Methods

• Conference

• Identify impacts and who regulates each impact

• Develop a case study of one project

Outcomes

• Regulator roadmap and whitepaper

5.4 Topic 3: How is the Transition Experienced Locally

In the coming decades, the Gulf will be impacted by the energy transition, or, as one panelist called it, the 

energy addition, as, in his view, previous energy transitions have added new fuels to the mix, rather than 

replaced one fuel with another. In either case, oil and gas production will shift in response to growing 

concerns about climate change and new energy sources like offshore wind may be added to the Gulf

energy mix. At the same time, the effects of climate change and land loss will grow more significant for 

Gulf communities, though the ways in which this will affect the different populations in the Gulf is not 

clear. Some sub-populations may benefit from increased employment opportunities (e.g., in the offshore 
26

wind shipbuilding industry) while others may lose their jobs (e.g., decarbonization impacting offshore oil 

and gas) while still others may lose their homes (e.g., from land loss and hurricanes). Current data and 

methods do not allow us to understand how these various changes will impacts the varied Gulf

communities.

To conduct this study, the panel proposed a case study, narrative history, or historical meta-analysis 

approach. In any case, the panel believed that a mixed-methods approach would be required. The panel 

suggested that potential avenues for fruitful study might include the people of Lake Charles and their 

experiences both with recent storms as well as recent investment in CCUS and offshore wind; the people 

of Morgan City and their experience with storms, the declines in the offshore oil and gas industry and out 

migration; and the tribal perspective and their experiences with storms, land loss, and out migration. 

 
27

6 Conclusions

The coastal Gulf is composed of exceptionally vulnerable communities, many of which have a history of 

environmental injustice. The communities are threatened by both biophysical factors, most notably land 

loss and climate change, and sociological changes including outmigration driven in large part by tropical 

storms and a lack of economic opportunities and diversity. At the same time, many of these coastal 

communities are home to industrial facilities developed to support the offshore oil and gas industry. These 

facilities process natural gas, refine oil, produce petrochemicals, build and maintain ships, dispose of 

waste, and conduct many other activities required to support the offshore industry. Some of these 

activities have the potential to create significant environmental harms. 

BOEM is charged with regulating the offshore industry, yet, especially given the recent EOs, they are also 

tasked with understanding how their offshore regulation impacts people and communities onshore. This is 

an exceptionally challenging task and one that is almost certainly impossible to understand solely through 

quantitative approaches. That is, BOEM cannot reasonably expect to estimate how a given lease sale will 

impact any readily measurable outcome variable for EJ communities (e.g., health metrics, outmigration

numbers, etc.). However, BOEM can support approaches that will build a qualitative understanding of

how its regulated activities impact EJ in the Gulf and this approach can be consistent with BOEM’s 

responsibilities under NEPA and OCSLA. Indeed, this qualitative approach can be more informative than 

quantitative approaches that lack robust data at appropriate scales and in some cases suffer from the 

ecological fallacy. 

Specifically, the panel proposed that BOEM undertake applied social science research to understand: 1) 

how to best use local data and/or ethnography to augment existing tools and documentations of EJ 

characteristics and confront current data gaps; 2) how the various federal, state, and local governments 

with regulatory authority over some aspect of offshore oil and gas can work together to identify their 

exclusive and overlapping responsibilities, and 3) how local communities experience regional, national, 

and/or global trends (such as the “energy transition”). 

 
28

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[CPRA] Coastal Protection and Restoration Authority of Louisiana. 2023. Louisiana’s comprehensive 

master plan for a sustainable coast. Coastal Protection and Restoration Authority of Louisiana. Baton 

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Collins TW, Grineski SE, Chakraborty J, Flores AB. 2019. Environmental injustice and Hurricane 

Harvey: a household-level study of socially disparate flood exposures in Greater Houston, Texas, 

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Grineski SE, Collins T. 2019. Lifetime cancer risks from hazardous air pollutants in US public school 

districts. J Epidem Comm Health. 73(9): 854–860. 

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heavy metal contamination at the census tract level in the city of Santa Ana, California: implications 

for health and environmental justice. Environ. Sci. Processes Impacts, 23(6), 812–830. 

Rubio R, Grineski S, Collins T. 2021. Children’s exposure to vehicular air pollution in the United States: 

Environmental injustices at the intersection of Race/ethnicity and language. Environ Soci., 7(3): 187–

199. 

Stretesky PB, Lynch MJ. 2011. Coal strip mining, mountaintop removal, and the distribution of 

environmental violations across the United States, 2002–2008. Landscape Res. 36(2): 209–230.

[USEPA] United States Environmental Protection Agency. 2024. Purposes and uses of EJScreen. 

[accessed 2024 May 22]; https://www.epa.gov/ejscreen/purposes-and-uses-ejscreen . 

 

 
29

A Appendix 1: Workshop Agendas

A.1 Workshop 1 Agenda

BOEM Workshop on Environmental Justice –Dec 13, 2022

Participants:

Invited Panel BOEM/LSU Team

Margaret Reams - LSU

Kenyatta Miles – Shell

Scott Hemmerling -Water Institute

Jessica Laughlin Dugan – United Houma Nation 

Brian Snyder - LSU

David Disumkes - LSU

Sindey Chaky - BOEM

Harry Luton - BOEM

Dustin Reuther - BOEM

Dole Bhandari - BOEM

John Primo - BOEM

Chris Page - BOEM

Sergio Arnoldo Garcia Mejia - BOEM

Idrissa Boube - BOEM

Agenda: 

10:00. Welcome and Introductions

10:30. Overview of the Issues – Sindey Chaky and Harry Luton

 BOEM’s unique position and responsibility

11:00. Defining the spatial, social and economic boundaries of environmental justice at BOEM

 Who, what, where, and how of BOEM’s EJ impacts 

12:30. Lunch

1:30. BOEM’s legal and regulatory options for addressing environmental justice

Balancing the EJ impacts of the offshore industry with BOEM’s legal authority to act

2:30. Environmental justice beyond oil and gas

 CCUS, renewables

3:00 Conclude

 
30

A.2 Workshop 2 Agenda and Guiding Questions

BOEM Workshop on Environmental Justice –March 29, 2023

Participants:

Invited Panel LSU/BOEM Team

Margaret Reams - LSU

Kenyatta Miles – Shell

Scott Hemmerling -Water Institute

Jessica Laughlin Dugan – United Houma Nation

Keith Hall – LSU

Tyler Priest – U of Iowa

Nina Lam – LSU 

Shana Walton – Nicholls State

Harry Luton – Regional expert/ BOEM (Ret.)

Brian Snyder - LSU

David Dismukes - LSU (Ret.)

Sindey Chaky - BOEM

Dustin Reuther - BOEM

Dole Bhandari - BOEM

John Primo - BOEM

Chris Page - BOEM

Thomas Mooreman - BOEM

Kristen Strellec - BOEM

Agenda:

10:00. Welcome and Introductions

10:15. Overview of the Issues & Recap of December Panel – Sindey Chaky 

10:30. Criteria of EJ Communities

 How do we identify/define EJ communities? 

12:30. Lunch

1:30. BOEM and Communities in the GOM

What communities in the GOM are of special concern? What impacts can be qualified if 

not quantified?

2:30. Multiple Interacting Threats

 Economic change, social change, and environmental change

3:00 Conclude

 
31

Guiding Questions for Workshop 2

1) Government agencies use three criteria for determining EJ communities:

a. 50%

b. Meaningfully greater

c. Threshold analysis

Are these criteria likely to include all “real” EJ communities? Are they likely to miss some? Are 

they likely to count some as EJ that aren’t? Are there other or better screening criteria agencies 

could use? What data needs would these other criteria require?

2) In the previous workshop, we discussed the difficulties attributing OCS activities to onshore 

impacts. Given that most of the EJ impacts of OCS activity are likely associated with upstream 

activities and that these can’t be readily quantified, can they be qualified? What OCS processes 

are likely to lead to the greatest EJ harms? What OCS processes are of relatively little concern? 

Does this differ for “traditional” OCS activities (oil and gas) versus newer activities (wind and 

carbon sequestration).

3) What specific communities in the GOM are of special concern? Which are especially likely to be 

directly/indirectly impacted by OCS activities? What challenges do these communities face both 

now and in the future?

4) EJ communities in the GOM face multiple interacting threats. Do OCS activities interact with other 

threats (e.g. land loss) to create a particular burden on EJ communities. Are there specific places 

in which this is especially acute?

5) Some Louisiana communities have struggled as shallow water activity has declined. Such 

changes may continue. Is this an EJ issue? Does it act to exacerbate other EJ issues? 

6) EJ analysis of BOEM’s OCS activities is complex. Are there ways to identify communities and 

potential harms to these communities that do not rely on data that are difficult or impossible to 

meaningfully/reliably generate?

 
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A.3 Workshop 3 Agenda and Guiding Questions

Environmental Justice, Data & Empirical Issues – A Problem-based Approach 

BOEM and LSU 

Invited Panel LSU/BOEM Team

Margaret Reams - LSU

Lourdes Vera – SUNY Buffalo

Kenyatta Miles – Shell

Scott Hemmerling -Water Institute

Jessica Laughlin Dugan – United Houma Nation

Tyler Priest – U of Iowa

Nina Lam – LSU 

Harry Luton – Regional expert/ BOEM (Ret.)

Brian Snyder - LSU

Sindey Chaky - BOEM

Dustin Reuther - BOEM

John Primo - BOEM

June 20, 2023 

The purpose of this workshop is to consider current or future environmental issues in the Gulf Coast, their 

potential to create environmental injustice, and the data needs that would be required for federal 

policymakers and BOEM personnel to understand and mitigate these effects. 

Session 1. Environmental Change 

Land Loss 

The most recent master plan projects significant land loss for coastal Louisiana, and this may be coupled 

with increased storm risk and population displacement. What are the datasets that exist to understand 

how these changes will impact people? What new datasets are needed? 

Insurance 

A hurricane strikes the Gulf and insurance rates rise and companies will no longer insure residential and 

commercial properties in the coastal zone. Who is most affected? Are burdens shared equally? What are 

the impacts on non-coastal economies? What data are needed to understand this process? How does 

this relate to demographic change 

Fisheries 

Fisheries face multiple threats from climate change, overfishing, and changes in salinity associated with 

river diversions. What data are needed to understand the human impacts of these changes and the 

potential for differential effects across space and populations? 

Scenario 2. Social and Anthropogenic Change 

Decarbonization and Renewables 

The working coast will decarbonize over the next three decades. Oil and gas production will decline, and 

renewables and CCS will increase. Shipbuilding for the Atlantic renewable industry will also increase with 
33

potential impacts of the Gulf Coast. How will these changes impact the Gulf economy? What datasets 

might measure this change? What new datasets are needed? 

Oil Spills and Disasters 

An oil spill occurs offshore. How does this effect the people along the coast? Are the effects distributed 

equally across race, gender and socioeconomic status? What datasets would be used to quantify these 

impacts, and what datasets are needed? How does what we learned from Macondo impact our plans for 

collecting new data? 

 
34

A.4 Workshop 4 Agenda

BOEM Data and Analytical Needs Around Environmental Justice 

BOEM and LSU

November 17, 2023

Invited Panel LSU/BOEM Team

Margaret Reams - LSU

Kenyatta Miles – Shell

Scott Hemmerling -Water Institute

Jessica Laughlin Dugan – United Houma Nation

Tyler Priest – U of Iowa

Diane Austin – U of Arizona

Harry Luton – Regional expert/ BOEM (Ret.)

Brian Snyder - LSU

Sindey Chaky - BOEM

Dustin Reuther - BOEM

John Primo - BOEM

The purpose of this final BOEM-LSU workshop is to bring together panelists who have participated in all 

three previous BOEM workshops to generate and refine ideas about EJ in the GOM that may be useful for 

BOEM future funding proposals. 

10:00 – 12:00. Session 1. Brainstorming and Prioritizing

What does a potential BOEM RFA look like? What are the questions BOEM should be addressing? How 

do those questions rank in terms of importance and tractability?

12:00 – 1:00. Lunch

1:00 – 3:00. Session 2. Revision and Refining

Generating rough sketches/outlines of potential BOEM funding requests.

Note: BOEM may or may not use these ideas in funding requests, and any such requests will be subject to 

standard competitive procedures. Participation in this workshop does not impact probability of funding to 

future BOEM solicitations. 
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Appendix 2: Presentation Used to Frame Workshop 3

 
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U.S. Department of the Interior (DOI)

DOI protects and manages the Nation's natural resources and cultural heritage; 

provides scientific and other information about those resources; and honors the 

Nation’s trust responsibilities or special commitments to American Indians, 

Alaska Natives, and affiliated island communities.

Bureau of Ocean Energy Management (BOEM)

BOEM’s mission is to manage development of U.S. Outer Continental Shelf 

energy and mineral resources in an environmentally and economically 

responsible way.

BOEM Environmental Studies Program

The mission of the Environmental Studies Program is to provide the 

information needed to predict, assess, and manage impacts from offshore 

energy and marine mineral exploration, development, and production activities 

on human, marine, and coastal environments. The proposal, selection, research, 

review, collaboration, production, and dissemination of each of BOEM’s 

Environmental Studies follows the DOI Code of Scientific and Scholarly 

Conduct, in support of a culture of scientific and professional integrity, as set 

out in the DOI Departmental Manual (305 DM 3).