The Association of Metropolitan Water Agencies (AMWA) supports the U.S. Environmental Protection Agency’s (EPA) continuing emphasis on establishing environmental justice (EJ) priorities based on science and data. AMWA believes EJ policies should be integrated into the central practices of EPA and not waver depending on the administration. EPA’s continued commitment to making sound policies to combat environmental injustices is critical to establishing water equity.
EPA defines environmental justice as “the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.”1
AMWA believes that federal, state, and local levels of government must work together to address long-standing injustices in environmental and water policies. AMWA stands firmly against all injustice and racism and believes the federal government should:
Ensure access to safe, clean drinking water services:
Federal policy should address disproportionate and systemic inequities in drinking water contamination and lack of access to drinking water and wastewater services.
Ensure access to affordable drinking water service:
- AMWA believes that the federal government should use a consistent definition of “disadvantaged communities” that is, disadvantaged communities can exist in water systems of any size. This should incorporate subsections of a utility service area’s most vulnerable populations. This practice will help ensure systems get funding to assist all disadvantaged ratepayers.
- Federal policy should address inequities in water financing and funding to disadvantaged communities in both urban and rural settings and remove barriers that may prohibit the efficient application and use of federal funds. This should include providing funding to support required capital investments, which directly and indirectly benefit disadvantaged areas of a water system.
Promote community resilience to climate risks:
Federal and local government policy should recognize that climate change will disproportionately affect our society’s most vulnerable citizens, including low-income communities and communities of color.
Ensure communities have access to procedural justice:
AMWA encourages EPA to emphasize transparency in its outreach to under-and un-represented populations to ensure early and effective public participation in rulemaking development and other regulatory processes.
AMWA supports the efforts of local drinking water utilities to develop their own Environmental Justice policies to guide their funding, community engagement, planning, design, and construction process. As part of these efforts, local governments should offer a forum or platform that allows community engagement and input on capital projects. This effort should include targeted outreach when the project is being considered in an area defined as a disadvantaged community.
Rationale:
- AMWA recognizes the historical, social, and economic factors that amplify detrimental environmental conditions, such as aging or deteriorating pipes. AMWA supports EPA’s goal for environmental justice efforts, that is to provide an environment for everyone to have equal protection from environmental and health hazards and equal access to the plans, processes, and policies that ensure a healthy environment.2
- Environmental injustices occur in communities across the U.S. These may be the result of issues related to water quality or lead service lines,3 neighborhoods that are unconnected to public water service due to redlining practices or other reasons,4 or water shortages due to drought or contamination related to extreme weather events resulting from climate change or failing infrastructure.5
- Disadvantaged communities across the United States face disproportionate burdens from environmental hazards, including proximity to hazardous waste storage sites,6 or landfills,7 flooding,8 heat islands,9 and more.
- Environmental inequities will worsen as climate change exacerbates. Research has shown that climate change most severely and disproportionately affects underserved and marginalized communities that are already poorly prepared to respond to and recover from these impacts.10
- Many water utility officials are painfully aware of systemic racism and discrimination within their own communities and, in some cases, in their own experiences.
1 “Environmental Justice.” (2022). Environmental Protection Agency. Retrieved from: https://www.epa.gov/environmentaljustice
2 “EPA and Environmental Justice.” (2022) Environmental Protection Agency. Retrieved from https://www.epa.gov/environmentaljustice/learn-about-environmental-justice.
3 Pieper, K. J., Martin, R., Tang, M., Walters, L., Parks, J., Roy, S., ... & Edwards, M. A. (2018). Evaluating water lead levels during the Flint water crisis. Environmental science & technology, 52(15), 8124-8132.
4 Leker, H. G., & MacDonald Gibson, J. (2018). Relationship between race and community water and sewer service in North Carolina, USA. PLoS One, 13(3), e0193225.
5 Aging water infrastructure in the United States. Juuti, P., Mattila, H., Rajala, R., Schwartz, K., & Staddon, C. (Eds.). (2019). Resilient Water Services and Systems: The Foundation of Well-Being. IWA Publishing.
6 Pastor, M., Sadd, J., & Hipp, J. (2001). Which came first? Toxic facilities, minority move‐in, and environmental justice. Journal of urban affairs, 23(1), 1-21.
7 Evan J. Ringquist. 2005. “Assessing Evidence of Environmental Inequities: A MetaAnalysis.” Journal of Policy Analysis and Management 24(2): 223-247.
8 Chakraborty, J., Collins, T. W., & Grineski, S. E. (2019). Exploring the environmental justice implications of Hurricane Harvey flooding in Greater Houston, Texas. American journal of public health, 109(2), 244-250.
9 Hsu, A., Sheriff, G., Chakraborty, T., & Manya, D. (2021). Disproportionate exposure to urban heat island intensity across major US cities. Nature communications, 12(1), 1-11.
10 “EPA Report Shows Disproportionate Impacts of Climate Change on Socially Vulnerable Populations in the United States.” (September 2, 2022). USEPA.