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1. There were many important executive orders issued by @POTUS yesterday, so it's easy to overlook one with the wonky title of "Modernizing Regulatory Review". But it is key to addressing the intersection of the climate crisis and racial justice.
THREAD https://www.whitehouse.gov/briefing-room/presidential-actions/2021/01/20/modernizing-regulatory-review/
THREAD https://www.whitehouse.gov/briefing-room/presidential-actions/2021/01/20/modernizing-regulatory-review/
2. First, some background. Environmental policies undergo regulatory impact analyses to examine the costs and benefits of those policies. Those analyses typically focus on total costs and benefits, without much consideration of distributions.
3. Environmental justice is often mentioned, but vaguely and qualitatively, and it rarely is central to the decision process in regulatory analyses. This is for a number of reasons, but the lack of specific quantitative insight is part of it.
4. The new EO asks OMB to "propose procedures that take into account the distributional consequences of regulations, including as part of any quantitative or qualitative analysis of the costs and benefits of regulations..."
5. "...to ensure that regulatory initiatives appropriately benefit and do not inappropriately burden disadvantaged, vulnerable, or marginalized communities". Some of this echoes language already in place, but in my mind, "procedures" is key in getting more specific.
6. Where does this tie back to the climate crisis? If you look at national policies addressing CO2 like the Clean Power Plan, regulatory impact analyses are at the heart of justifying the policies.
https://19january2017snapshot.epa.gov/sites/production/files/2015-08/documents/cpp-final-rule-ria.pdf
https://19january2017snapshot.epa.gov/sites/production/files/2015-08/documents/cpp-final-rule-ria.pdf
7. Future climate action will continue to be justified in part by near-term health benefits, which are real (related to air pollution, physical activity, green space) and can be readily quantified.
8. The question is, where and how to invest? There are huge opportunities to address environmental injustice while addressing the climate crisis, but only if we have a formal mechanism to do so.
9. One thing that has been shown in multiple analyses is that reducing exposures for disadvantaged communities can often be more efficient, as you have more vulnerable and highly exposed individuals. For example: https://onlinelibrary.wiley.com/doi/10.1111/j.1539-6924.2011.01629.x
10. The key will be making this concrete and specific, with easily applicable methods. Luckily, those methods exist. See, for example: https://www.mdpi.com/1660-4601/10/9/4039
11. I am looking forward to seeing this conversation move forward, giving us the tools to address the climate crisis with an explicit racial/environmental justice lens...
