Presented to NACEPT by 

Heather Anne Case, MPH, MBA

Office of Environmental Justice

January 20, 2011

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Vulnerability

 A concept that provides a holistic approach to 

addressing environmental justice issues

Plan EJ 2014

 Plan EJ 2014 is road map for advancing 

environmental justice 

Actions to Advance EJ

 Work in rulemaking and science focus on 

multiple factors that can lead to 

disproportionate impacts

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“Expanding the conversation on environmentalism and 

working for environmental justice”

 Build strong working relationships with tribes, 

communities of color, economically distressed cities 

and towns, young people.

 We must include EJ principles in all of our decisions.

 The protection of vulnerable subpopulations is a top 

priority

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 “A matrix of physical, chemical, biological, 

social, and cultural factors that result in certain 

communities and subpopulations being more 

susceptible to environmental factors because 

of greater exposure to such factors or a 

compromised ability to cope with and/or 

recover from such exposure.”

World Health Organization: Principles for

Evaluating Health Risks (2006).

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PAST

PRESENT

“True North”

• Prevent and/or reduce adverse 

environmental and health 

impacts from pollution 

• Ensure equal access to 

decision-making process

• Increase economic, social, 

health and environmental 

benefits 
Plan EJ 2014: Road Map for 

Advancing Environmental 

Justice

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Plan EJ 2014

 The Guiding Document and framework for 

organizing EPA’s on-going and future work to 

advance environmental justice

 4-year horizon to correspond with 20th

anniversary of E.O. 12898

 Implements principles in EPA’s Strategic Plan, 

Cross-cutting Strategy for EJ and Children’s 

Health

 Implementation of elements lead by Agency 

Programs Regions

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 5 cross-agency focus areas:

 Rule making

▪ Incorporate EJ into rule making

 Permitting 

▪ Consider EJ concerns in EPA’s permitting process

 Compliance enforcement initiatives

▪ Accelerate compliance and enforcement initiatives

 Community-Based Action

▪ Support community-based action programs

 Administration-wide action on EJ

▪ Foster Administration-wide action on EJ

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 4 tool development areas:

 Science 

 Law

 Information

 Resources

 Program Initiatives

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 EPA developed interim 

guidance related to its 

rule making process. 

Purpose is to:  Explicitly integrate EJ 

considerations into the 

fabric of EPA’s ADP—from 

rule inception through all 

the stages leading to 

promulgation and 

implementation

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For all rules with potential EJ concerns three questions

frame the development of the rule:

 How will your public participation process provide 

transparency and meaningful participation for 

minority, low-income, and indigenous populations, 

and tribes? 

 How do you plan to identify and address existing and 

new disproportionate environmental and public 

health impacts on minority, low-income, and 

indigenous populations during the rulemaking 

process? 

 How did the actions taken under #1 and #2 impact 

the outcome or final decision? 

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Proximity Cumulative Impacts Physical Infrastructure

Susceptible Populations Unique Exposure 

Pathways

Ability to Participate in DecisionMaking (social capital)
 Articulate how and why minority and/or low income 

groups experience disproportionately higher 

environmental health risks.

 EPA commissioned the development of papers on the 

following topics:

 Proximity to pollution sources

 Unique exposure pathways

 Multiple and cumulative exposures and impacts

 Physical infrastructure 

 Lack of community capacity/Diminished ability to participate in 

decision making

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 Papers include: 

 state of the science reviews, 

 conceptual frameworks for integrating specific concepts, and 

 papers on conceptual and methodological issues of differential 

vulnerability across population groups.

 EPA is collaborating to publish these papers in the 

American Journal of Public Health with:

 National Institute for Minority Health and Health Disparities

 Office of Minority Health/HHS 

 Anticipated publication date - Summer 2011.

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EJ in Rulemaking Technical Guide

 Apply science to the ongoing development of technical guidance to 

support rulemaking process guidance.

 Provide regulatory analysts with:

 A framework for integrating EJ into their analyses

 Methods for assessing disproportionate environmental health risks –

existing and anticipated:

▪ Among minority and low income populations relative to a defined comparison group(s).

▪ Within the various rule making contexts/statutory authorities

 Overarching goal is to design analysis so as to facilitate its application in 

decision making.

 Anticipated EPA Science Advisory Board Peer Review - Spring 2012

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 Administrator Lisa P Jackson 

“.....An area that calls for innovation and bold thinking, and I 

am challenging all of our employees to bring vision and 

creativity to our programs”

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