HIA does not generally enjoy a legal mandate in the U.S. except for in rare project-by-project instances.  So HIA is in this gray area, half in and half out of the official planning process. - this might explain the confusion.  The half-out gives HIA flexibility to advocate in ways that institutionalization associated with NEPA does not.  But it also can limit the ability for the HIA to be truly considered and deliberated by the decision-maker.  If the planners are not willing to cooperate with the public health side, the HIA is easily discounted and buried - so collaboration is key.  By extension, there is not yet legal case precedent for HIA consideration in the U.S.  You should take a look at the I-710 Corridor case in my dissertation as the EJ community used the HIA in its legal argument to reject the draft EIS and join with a lot of other entities in demanding a recirculated environmental process. 

A key step in HIA is making recommendations - essentially pointing the way to which alternative is healthier.  In some HIAs, this includes identifying specific mitigation strategies to make the plan/project more healthy.  There are examples out there of this occurring, much of it being documented in an an influx in the past 6 months in evaluative studies (including my dissertation) to show "effectiveness."  In collaborative/cooperative HIAs, this input occurs early enough to result in changes in the actual plan.  Because of this, the mitigation strategies may not be as obvious as some EJ demands, but it is occurring. 

Finally, HIA practitioners are well aware of and eager to include cumulative impacts.  Does it always occur? No.  Is it nearly always discussed in advisory committees?  In my experience, yes.  The breakdown between wanting to articulate cumulative impacts for vulnerable communities and doing it is a whole other topic that I'll save for some other time.


On Jun 11, 2014, at 4:05 PM, wrote:

From: "marcomcast" <>
To: "Nicole Iroz Elardo" <>
Cc:, "j mindell" <>
Sent: Wednesday, June 11, 2014 3:56:23 PM
Subject: Re: [H+T--Friends] HIA Webinar

Thanks, Nicole. I'm confused by this:  "HIA augments the current planning process" and this: "HIA - particularly when it is outside the regulatory planning/environmental process."  There seems to be a contradiction.  Is HIA within or outside the planning process?  I also haven't observed this, "HIA may point out mitigation measures for factors, design features," but I'm hoping you have some examples of where HIAs have pointed out mitigation factors.  Mitigation, of course, is a concept that grows out of NEPA.  A civil rights violation cannot be mitigated, but the actions that caused the violation must be stopped, remedies crafted, and the adversely affected parties made whole. 

Here you make a good point: "EJ sometimes struggles when addressing spatially diffuse issues."  We call these environmental insults over time and place "cumulative impacts."  They are routinely ignored in NEPA analyses.  Are you saying that they are included in HIAs, and that such inclusion prevents the creation or perpetuation of "sacrifice zones," neighborhoods that repeatedly are adversely affected by big, stinky, and toxic projects?  If so, I'd be curious to hear some HIA success stories of this type.  The HIAs that I've read have been of the advisory or study type, with no compliance or enforcement power whatsoever.  In other words, no power to force change in a positive direction.  This is a major difference between HIAs and legal compliance work under Title VI and the Clean Air Act, for example.  Again, I hope you've got some counter-examples. 

From: "Nicole Iroz Elardo" <>
To: "marcomcast" <>,
Sent: Wednesday, June 11, 2014 3:25:42 PM
Subject: Re: [H+T--Friends] HIA Webinar


Sure.  (And yes, exploited was an ironic choice given the civil rights angle, but not particularly intentional word.) Although I will say it is unclear to me if you are asking how *I* personally know or how the field knows.  I'll assume it is the latter - that you are asking "what does HIA add to a planning process that is not already there and how do we know it helps vulnerable communities." 

HIA is far from perfect and not appropriate for every situation, but it has a valid claim that and HIA augments the current planning process to allow for more informed decisions.  Public health professionals generally view planning as inadequately addressing human health or health equity even though disparities in human health are well-documented as are both social and built-environment factors leading to those disparities.  HIA uses this population-based health evidence to identify intended and unintended health consequences of proposed plans/projects/policies.  It aims to maximize health overall and decrease health disparities for vulnerable communities - a decision-making frame that planners do not necessarily use as they are balancing all sorts of interests in addition to health.  But it is a useful frame, particularly in a social justice situation.  

Transportation planners believe that they protect human health through NEPA, but the reality is that NEPA has been institutionalized to identify exposure concentrations in the physical environment and rarely makes it all the way to human health or to addressing some of the more indirect health pathways.  I believe that the humanizing factor is a pretty big deal.  Additionally, HIA - particularly when it is outside the regulatory planning/environmental process - starts from a place of identifying ALL possible paths to human health.  All paths means even things outside of the defined alternatives - very similar to some traditional EJ work.  So an HIA may point out mitigation measures for factors, design features, or the lack thereof that planners have dismissed as impractical or too expensive, etc.  In some cases, it might suggest that planners need to go back to the alternatives definitions and rework.
One place where HIA may augment traditional EJ for advocating for justice is in its ability to provide a stakeholder/decision-making framework to deliberate about competing health concerns.  An example from my dissertation is the Lake Merritt BART Station Area plan.  When planning for zoning for transit-oriented development, what health consideration is the very-low-income Asian community most concerned about?  affordable housing? losing the park used for Tai Chi?  air pollution?  culturally specific food? culturally specific public space? all of it?  If the community has to choose, then what?  Where to put advocacy efforts?  HIA, by tracing those pathways organizes and provides communities an evidence-base by which to deliberate the various pathways and which has the most impact on health.  It can then guide/augment EJ efforts.

Finally, HIA has health equity as one of a handful of explicit values.  This is completely congruent with EJ values and efforts.  What is different, however, is the ability of public health professionals to articulate that value using professional/academic knowledge and increasingly modeled information.  I'd also argue that HIA, with its flexibility, may be more useful than a traditional EJ approach to health equity in the policy arena because EJ sometimes struggles when addressing spatially diffuse issues.

That said, HIA is a process and product that is centered around information.  HIA documents advocate for human health but will not advocate for a specific outcome/alternative.  That is left up to the actual community to use the HIA information to advocate in an inherently political planning process.   

In sum, a good HIA will augment EJ efforts by outlining where intentional and unintentional health effects and health disparities are likely to occur with a public decision.  This is a good thing and doesn't have to be an either/or.  HIA should tell you where the health problems are and identifies specific human health indicators that might be useful arguing for and monitoring the legal aspects of civil rights and EJ.  Again, a win for vulnerable communities. 


Nicole Iroz-Elardo, PhD
Portland State University