Thanks, Nicole. Do you have any examples of this: "this input occurs early enough to
result in changes in the actual plan." A very common problem with public
participation/public involvement is that community input is taken and then ignored.
Best,
Marc
----- Original Message -----
From: "Nicole Iroz Elardo" <irozelardo(a)yahoo.com>
To: "marcomcast" <mbrenman001(a)comcast.net>
Cc: h+t--friends(a)chrispy.net, "j mindell" <j.mindell(a)ucl.ac.uk>
Sent: Wednesday, June 11, 2014 9:56:51 PM
Subject: Re: [H+T--Friends] HIA Webinar
Marc,
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.
~Nicole
On Jun 11, 2014, at 4:05 PM, mbrenman001(a)comcast.net wrote:
----- Original Message -----
From: "marcomcast" < mbrenman001(a)comcast.net >
To: "Nicole Iroz Elardo" < irozelardo(a)yahoo.com >
Cc: h+t--friends(a)chrispy.net , "j mindell" < j.mindell(a)ucl.ac.uk >
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.
Marc
----- Original Message -----
From: "Nicole Iroz Elardo" < irozelardo(a)yahoo.com >
To: "marcomcast" < mbrenman001(a)comcast.net >, h+t--friends(a)chrispy.net
Sent: Wednesday, June 11, 2014 3:25:42 PM
Subject: Re: [H+T--Friends] HIA Webinar
Marc,
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
Nicole Iroz-Elardo, PhD
Portland State University
irozelardo(a)yahoo.com