Environmental and Climate Justice Assessment and Reporting: A Step to Correct Infrastructure Inequities

Environmental justice seeks to redress historic and continuing policies that have harmed low-income communities such as redlining, infrastructure disinvestment, lead poisoning, industrial pollution and concentrated poverty.

That history includes routing freeways through or near low-income neighborhoods — a toxic legacy that I witnessed firsthand more than 20 years ago as a graduate student at Tulane University School of Public Health while conducting heavy metal (lead) research with Pharm D students from Xavier University of Louisiana School of Pharmacy.

Transportation planning in the 1940s and 1950s routed huge highways throughout the U.S. through neighborhoods that were disregarded by those planners and considered unimportant.

As a result, culture and heritage was disrupted, homes and businesses of property owners (residential and commercial) in these communities’ lost value and some went out of business. Tree canopies were lost, resulting in urban heat islands. Many residents have suffered high rates of lead poisoning, asthma and other illnesses — the same underlying conditions that have made residents of these and other poor neighborhoods more vulnerable to COVID.

Connections between equity, policy and infrastructure may not be apparent to everyone, including many lawmakers. But throughout my professional career, I have seen gradual improvement in concern for these problems and a sharpened focus on environmental and climate justice in policy and infrastructure design and implementation.

As Roth observed, the Bipartisan Infrastructure Law “integrates equity by seeking to reckon with past injustices and using investment to create more positive futures for impacted communities.”

The commitment to equity is deepening across federal infrastructure agencies and among private investors, lenders and developers engaged in infrastructure. An essential aspect of this trend is the growing rigor with which project sponsors and contractors are required to analyze and publicly report on their environmental, climate and social justice impacts.

This type of environmental impact reporting ranges from reports required by federal funders to voluntary analyses and disclosures of environmental, social and governance (ESG) performance for a project or an entire corporation.

ESG reports are typically submitted on a voluntary basis to nonprofit certification entities such as the Carbon Disclosure Project or Global Real Estate Sustainability Benchmark. However, regulatory drivers are increasing for ESG reporting, as evidenced by the U.S. Security and Exchange Commission’s recently proposed climate change transparency rule.

Shortly before the pandemic, environmental and climate justice reporting was gaining momentum as a more serious endeavor for companies. It was evolving beyond greenwashing and the use of cookie-cutter, check-the-box language tailored to the criteria of the relevant agency to incorporate more thoughtful insight. Gradually, organizations have become more committed to their environmental responsibilities — often in response to legal challenges or due to growing stakeholder pressure. Regardless of motivations, simply using stock phrases in reporting was no longer acceptable.

Reporting tools have evolved to assist project sponsors and contractors in analyzing and reporting on environmental justice impacts. By Sept. 30, 2023, EPA will develop and implement a cumulative impacts framework, issue guidance on external civil rights compliance, establish a set of indicators to track EPA’s performance in eliminating disparities in environmental and public health conditions, and train staff and partners on how to use these resources.

In the meantime, tools frequently used include EPA’s recently revised environmental justice mapping and screening tool, EJScreen 2.0, as well as the new Climate and Economic Justice Screening Tool (CEJST).

According to the White House, CEJST is designed to support the Biden Administration’s Justice40 goal of ensuring that “federal agencies deliver 40 percent of the overall benefits of climate, clean energy, affordable and sustainable housing, clean water and other investments to disadvantaged communities.”

For example, using metrics and tools, such as the Centers for Disease Control and Prevention’s Social Vulnerability Index tool, FEMA evaluated equity impacts to the Building Resilient Infrastructure and Communities (BRIC) national competition and Flood Mitigation Assistance (FMA) to ensure they align with the Justice40 initiative. As a result, more than $510 million will be distributed through BRIC and FMA to communities that meet Justice40 criteria for being underserved or disadvantaged.

In many cases, proprietary environmental justice reporting tools can provide more value than these public tools. WSP’s reporting tools, for example, augment the environmental and demographic data of the federal tools with additional data sources, then adapt the analysis criteria and performance metrics for specific clients or projects.

However, even the most sophisticated tools can’t replace on-the-ground consultation with community members. You can start with desktop data analyses and phone calls, but then you need authentic community engagement in which you really listen to people.

For every designer, engineer and contractor engaged in building or upgrading infrastructure, the consequences of inadequate environmental or climate justice reporting are not limited to legal and reputational complications. Weak reporting makes it more likely you’ll hurt a vulnerable community. But with rigorous geomapping and geocoding, you can identify and mitigate potential negative impacts — such as the months or years of construction-related traffic required for major infrastructure projects.

Using infrastructure to improve equity — especially health outcomes — must start long before construction plans are finalized. Recently, the U.S. Department of Transportation halted the expansion of Interstate 45 through Houston after environmental review “found it would have a massive impact on the communities it would roll through, displacing more than 1,000 homes and housing units, 344 businesses, five places of worship and two schools,” according to Politico.

If we upgrade U.S. infrastructure without using the lens of equity to examine our priorities and practices, then we risk continuing to disenfranchise our most vulnerable communities. Thankfully, we have a rare opportunity to make things right and build infrastructure that considers the benefits for all who are impacted.

UN Climate Change Conference (Nov. 6-18)

WSP is all in for the United Nations (UN) Climate Change Conference (COP27) this year in Sharm El-Sheikh, Egypt. The firm’s delegation is working in close collaboration with the UN Climate Champions team and numerous partners, including the International Coalition for Sustainable Infrastructure, Resilience Rising, Resilience First, the Coalition for Climate Resilient Investment and the Coalition for Disaster Resilient Infrastructure.

WSP is helping shape the discourse and presenting on a wide range of topics — the future of funding the net-zero transition, realizing infrastructure’s resilience dividend, mainstreaming nature-based solutions and integrating green infrastructure into grey — and supporting the Resilience Breakthroughs implementation labs across the spectrum of impact systems: food & agriculture, water & nature, human settlements, oceans and infrastructure.

Learn more about how WSP is activating its engagement at COP27, hybrid events you can register to attend, and the distinct suite of capabilities that make WSP a leader in climate, resilience & sustainability: https://www.wsp.com/en-us/campaigns/cop27

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