SUSTAINABLE
C I N C I N N AT I
FALL 2018 PLAN 5131 / 6031
SUSTAINABLE DEVELOPMENT NORTH AMERICAN RESPONSES
SCHOOL OF PLANNING UNIVERSITY OF CINCINNATI
Environmental Justice Framework for an Environmental Justice Policy in Cincinnati
OUR TEAM
Andy Yang
Christian Umbach
CO
NT EN T
Introduction Major Threats to Environmental Justice in Cincinnati Existing Response Efforts in Cincinnati Case Studies of Successful Approaches to Environmental Justice Outline of Environmental Justice Action Plan Works Cited
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Introduction Why is Environmental Justice Important for Cincinnati? Environment Justice seeks to ensure that all citizens, regardless of socioeconomic status or ethnic background, are protected from a variety of environmental hazards through equitable policy. Unfortunately, cases of environmental injustice exist in many United States cities, including Cincinnati. Many of Cincinnati’s vulnerable communities, low income and African American, have disproportionally faced a series of environmental crises. The most prominent examples include methane leakages from the ELDA landfill in Winton Hills and the Queen City Barrel Fire in Lower Price Hill. Today, the most pressing contributing factor is air pollution from industry and highway traffic. Several heavily trafficked interstate highways (I-71, I-75, I-74) run directly through the city, producing ultra-fine particles and causing dramatic health impacts. In fact, Cincinnati is one of the 25 worst cities in the nation regarding air pollution (American Lung Association 2018). The problem is worsened by the city’s hilly topography, which allows stagnant air to linger in the valleys. Cincinnati also has a large stock of old industrial buildings several of which are neglected and abandoned. As these sites deteriorate, they pose unknown
and potentially harmful threats to the surrounding communities. Sadly, disadvantage communities reside closest to these hazardous sites and therefore find themselves at a greater risk of detrimental health factors. The 2018 Cincinnati Green Plan calls for the city of Cincinnati to develop an Environmental Justice program that will identify communities that are disproportionately burdened by pollution and other health and safely threats, and in turn act to reduce or eliminate these burdens (City of Cincinnati 2018). The purpose of this chapter is to first gather background information on both past and current cases of environmental injustice in Cincinnati. This report also highlights several cases studies from around the country that provide best practices for environmental justice response and planning. Finally, the end product of this chapter is an outline of a proposed Environmental Justice Action Plan, which will be used by the city of Cincinnati to direct future environmental justice policy.
Source: (Umbach 2018)
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Major Threats to Environmental Justice in Cincinnati When considering environmental justice issues in Cincinnati, there are a wide variety of threats that exist. Some threats, such as industrial pollution and brownfields, are a result of Cincinnati’s past as a manufacturing and heavy industry hub. Other challenges, like climate change and environmental gentrification, represent future threats to environmental justice. Currently, it appears that pollution from highway traffic is Cincinnati’s most urgent problems. The graphic below displays a list of all 9 threats along with their classifications. Highway Traffic Air Pollution Air pollution from highway traffic is likely the largest contributing factor to Cincinnati’s poor air quality. Not surprisingly, residents living adjacent to these major highways are disproportionally low income and African American. Three major interstates (I-71, I-74, and I-75) cut directly through the heart of several city neighborhoods. In particular, interstate 75 carries a large amount of diesel fueled semi-trucks, which emit high levels of fine particulate matter (PM) (Zhu et al. 2002). Numerous scientific studies reveal that
exposure to high levels of PM can lead to childhood asthma and reduced overall lung function (Brugge et al. 2007). While highway pollutants diminished over distance, PM levels remain dangerously high as far as 1,300 feet away from these roadways (Brugge et al. 2015). In addition to PM, harmful air pollutants include carbon monoxide, volatile organics and greenhouse gases, which contribute to climate change (Barboza 2017). This air pollution problem is worsened by daily congestion due to traffic back-ups. Vulnerable neighborhoods most affected include: West End, Camp Washington, South Cumminsville, Walnut Hills, Avondale, and Evanston. When considering justice in respect to historic highway planning, it is important to note that sections of these aforementioned neighborhoods were dismantled during interstate construction in the mid-twentieth century. In most cases, interstate development worsened the economic and social condition of these disrupted neighborhoods, while serving the economic interests of surrounding suburbs. With this history in mine, inner city highways represent a compounding form of environmental and economic injustice.
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Major Threats to Environmental Justice in Cincinnati Industrial Pollution and Brownfields The Cincinnati region continues to house a significant amount of heavy industry. In the city of Cincinnati, the most well defined industrial corridor runs along Interstate 75 and the Mill Creek river valley. These industrial facilities produce a variety of air and water pollutants, which have known effects on both the health of local residents and natural ecosystems. By nature, it is difficult track and examine the effects of industrial air pollution. The EPA helps by documenting all industrial emitters within a Toxic Release Inventory (TRI). Hamilton County contains 90 TRI sites and the State of Ohio is ranked the 5th worst state for TRI sites per square mile (US EPA 2016). Within Cincinnati, the zip code 45232 (Winton Hills) contains a dense cluster of 10 TRI sites (US EPA 2016). Another 10 sites are located within Northside and western hills neighborhoods. Based on table 1, all of these neighborhoods are both low income and largely African American. Furthermore, an entire host of scientific research has documented this relationship between disadvantaged communities and proximity to industrial pollution (Chakraborty et al. 2011). While industry is currently regulated by the Ohio EPA to comply with federal and state emission standards, this does not ensure full compliance. For instance, it is not mandatory for companies to report excess emissions (Trapp 2002). Therefore, there is still an element of risk and uncertainty regarding pollution regulation.
is fair to speculate that addition unknown threats exist in other former industrial sites throughout the city. Landfills While there are currently no active landfills within the city limits of Cincinnati, two former landfill sites, Center Hill and ELDA, still may present unknown threats. Opening in 1973, the ELDA landfill accepted especially hazardous waste, including asbestos, zinc cyanide, heavy metals, and wastewater sludge (Trapp 2002). After a series of non-compliance issues with the Ohio EPA, the city shut down the plant in 1997. During that time, methane leakages from the landfill were discovered in the basement of the Ridgewood apartment complex located across the street (Trapp 2002). As a result, residents were relocated and a portion of the apartments were demolished. Both plants are located in Winton Hills, a low income neighborhood with a majority African American population and home to Cincinnati Metropolitan Housing Authority subsidized housing. It is still unclear how these exposures have affected the health of residents. To make matters Table 1. High Risk Neighborhoods
Former industrial sites, known as brownfields, are also a challenge for Cincinnati. In fact, there has been a recent history of pollution leading to environmental degradation, which have required numerous site clean-ups. The EPA has documented these clean-up efforts at three brownfield sites in Cincinnati in just the past five years (US EPA 2018). These cases dealt with aging and/or abandoned industrial facilities that contained a variety of hazardous materials. Most notably was the Queen City Barrel fire, a large fire that released tons of toxic gases into the air, spreading across a large section of the city (US EPA 2018). The former site of the Queen City Barrel plant, now a brownfield, is located in Lower Price Hill. Brownfield sites can be dangerous because they present unknown hazards to both the environment and residents living near-by. This trend is also the case today in Hamilton County, which is home to three EPA Superfund sites, which are highly polluted sites that present severe environmental health threats (US EPA 2018). This history clearly reveals a lack of responsibility among a portion of local industry. It 6
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Major Threats to Environmental Justice in Cincinnati worse, the owners of the ELDA property, Ohio Waste Management, tried to reopen and operate a waste transfer station on the site. Fortunately, local advocates lead by Cincinnati’s Communities United of Action (CUFA) were able to stop the station from begin constructed. This problematic narrative reveals some of the most appalling examples of environmental injustice in Cincinnati. Wastewater Treatment In regards to wastewater, one must consider both proximity to wastewater treatment facilities and the effects of combined sewer overflows. First, research suggests that the air closely surrounding treatment plants may contain high levels of pathogenic airborne microorganisms (Vantarakis et al. 2016). The health impacts on residents living adjacent to these facilities must be considered. For Cincinnati, the Mill Creek Wastewater Treatment Plant is located in the neighborhood of Lower Price Hill, the home of many low income residents. Second, Cincinnati has a combined sewer and stormwater system. During heavy rain events, stormwater carries untreated sewage directly into local waterways. Homes and businesses located in low lying areas are at higher risk to flood damage and the health effects of sewage exposure. It is unclear whether there exists a relationship between socioeconomic status and risk of flooding in Cincinnati. Regardless, low income residents recovering from flooding will face greater cost burdens. Finally, sewer bills have increased dramatically in recent years, and low income residents are struggling with this added expense (CUFA 2014). Climate Change The Cincinnati Green Plan address the future impacts of climate change in Cincinnati. A rise in both heat and severe storms will cause a variety of environmental and health implications for Cincinnatians, especially the most vulnerable. First, higher summer temperatures will further exacerbate the city’s already detrimental air pollution problem. Additional reliance on air cooling systems may create cost burdens for low income residents and small businesses. Second, heavy storms will indeed lead to more flooding. The city is already pushing the boundaries of their flood control systems. In February of 2018, a large flood event triggered the Mill Creek Barrier Dam to run at maximum capacity. The dam was able to protect over 3 billion dollars’ worth of potential property
damage, but it will require maintenance to keep it running in the long term (Dykes 2018). The dam is directly adjacent to Lower Price Hill, a hotspot for environmental justice threats. Another result of heavy rainfall is landslides, which are rather common in the region. While there is no known correlation between landslides and socioeconomic status, there is evidence of poor historic development practices. For example, early quarreling operations led to a series of landslides in East Price Hill (Sheets 2011). It remains unclear whether the area is still in danger. In order to ensure environmental justice in to the future, the city must consider the effects of climate change. Environmental Gentrification Environmental gentrification generally refers to inequitable access to green space. Quality parks that offer a variety of desirable recreation and social amenities tend to be located in more affluent neighborhoods. Poor access to green space leaves low income residents at a disadvantage, as proximity to parks provides many health benefits. Contrary to these trends, Cincinnati currently has excellent park access across all socioeconomic levels. However, the quality of these green spaces may not be equal throughout the city. The Ten Minutes to Green Space chapter discusses these issues in further detail. Another component of environmental gentrification occurs when a new or renovated green space causes property values around the park to increase dramatically, in turn reducing affordability and triggering displacement (Wolch et al. 2014). In Cincinnati, the renovation of both Washington and Ziegler Parks in Over-the-Rhine and Pendleton are one of many contributing factors to rising property values in these neighborhoods. In the future, the city must consider the real estate market effects of park renovations on surrounding neighborhoods. Other issues already being addressed The presence of toxic lead paint in older buildings was a major problem in Cincinnati. Extensive research, known as the Cincinnati Lead Study, has been conducted on 300 participants exposed to lead. This research has linked lead exposure to serous developmental and behavioral disorders (Dietrich 2007). Lead exposure was also tied to race and income, as vulnerable households were more likely to reside in older and cheaper homes. Since the city has already taken several steps (Lead Poisoning Prevention Pro7
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Existing Response Efforts in Cincinnati -gram) to address this issue, this report will not discuss lead exposure further. Food deserts are another source of environmental injustice. They refer to the geographical spaces with inequitable access to fresh and healthy foods. We have also chosen not to discuss food deserts in this report, because stakeholders within the Cincinnati region are already taking steps to address food deserts. The Civic Garden Center is operating several community gardens in many disadvantaged neighborhoods in the city. Also, the Healthy Harvest Mobile Market supports at rick residents by delivering fresh foods to vulnerable neighborhoods. Background of Pollution Control in Cincinnati Historically, the City of Cincinnati has taking the lead in addressing air pollution. In 1881, the City of Cincinnati passed its first Smoke Ordinance which was the result of a collaborative effort from a progressive political community. Cincinnati was one of the first cities in the nation to regulate the production of smoke. Influenced by the third Smoke Ordinance in 1907, City Council created the Office of the Smoke Inspector. Due to financial issues the city transferred the Division of Air Pollution Control program over to Hamilton County. Seventy three years of continuous air pollution regulations were wiped out and all previous city ordinances were repealed. Beginning in 1980, the newly formed Southwest Ohio Air Pollution Control Agency (SOAPCA) was given the responsibility of regulating air quality under Ohio Law. Currently, the agency provides live online air quality reporting. These daily readings are reported from 18 testing stations across the 5 county region, with 4 stations within the city limits. For the public, they also offer citizen sampling kits upon request (SOAPCA). If a resident believes that they are exposed to harmful air from a nearby pollution source, they can capture the air and send it to the SOAPCA for further analysis. In a few cases, the SOAPCA has used these citizen responses to discover a non-compliant industrial facility. At the state level, the Ohio EPA has a track record of being industry-friendly when dealing with pollution regulation. First, it is not mandatory for industry to report excess emissions. Secondly, in the case of the ELDA landfill, the Ohio EPA conducted a series of spotty site evaluations which allowed the landfill to continue operating for years until the city of Cincinnati and local activists stepped in to close the plant (Ohio EPA 1994). Nearly all environmental justice victories in Cincinnati have come through grassroots
activism led by Communities United for Action (CUFA). CUFA is a multi-issue, grassroots organization that brings diverse people together to affect change. CUFA has been leading the fight for Environment Justice for over 35 years by encouraging low and moderate-income citizens to participate fully in civic life. They also influence public policy and business practices that create positive change in communities. Their current campaigns are Metropolitan Sewer District (MSD) Accountability and A Clean Power Plan for Cleaner Air. The MSD campaign is addressing the increasingly high sewer rates. CUFA is petitioning for transparency on funds spent and progress. The latter campaign is addressing Ohio’s decision to not support or submit a Clean Power Plan. The EPA in 2015 introduced the plan and ruled that each state must create a plan to cut carbon emissions into the air by 30% from 2005 levels by 2030 (CUFA, 2014). Cincinnati’s Environmental Justice Ordinance Cincinnati city council passed the Environmental Justice Ordinance on June 24, 2009, taking effect on December 21, 2009. The ordinance was a first-in-the-nation policy that requires new or expanding industrial facilities to acquire an environmental justice permit prior to operating. Facilities must demonstrate that they will not cause heath issues for the surrounding communities using methodologies stated in the ordinance (Guire, 2012). Since the ordinance was passed, it has not been utilized due to various challenges. One of the biggest difficulties is funding, as the city has not been able to afford regulation and enforcement expenses. The other issue is that the city would receive backlash from industry and the business community if the ordinance was utilized. There are a few valuable lessons that the city can learn from the ordinance. The ordinance was plagued by poor timing, as manufacturing and heavy industry are not currently expanding enterprises. It appears that transportation pollution is a bigger environmental justice issue for Cincinnati today.
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Case Studies of Successful Approaches to Environmental Justice The following case studies are designed to provide Cincinnati with best practices to environmental justice response. It is important to note that not all of these cities are comparable peer matches to Cincinnati. However, in order to discover cutting-edge progressive approaches to environmental justice, all cities must be considered. Mitigating Highway Pollution – Boston, MA Like most cities across the United States, the city of Boston, Massachusetts also houses many major interstate highways. Boston pioneered the practice of capping and burying highways in their downtown. The Central Artery/Tunnel Project, more commonly known as the “Big Dig,” was a multi-decade project that buried sections of highways and created an underwater tunnel to their airport (Gelinas 2007). What was once a noisy interstate dividing the downtown, is now a peaceful network of connected parks. While this project does not directly serve vulnerable communities, there are many design and engineering lessons to be learned from the process. Developed as a collaborative research project between academic institutions and
community participants, the Community Assessment of Freeway Exposure and Health Study (CAFEH) has produced extensive research on the impacts of highway pollution in the Boston area. They are working in some of the area’s most vulnerable communities: Somerville, Dorchester, South Boston, and Chinatown. CAFEH’s latest paper, Improving Health in Communities Near Highways, offers a variety of design solutions (listed below) to mitigate the effects of highway pollution (CAFEH 2015). 1) Filtration 2-3) Air Inlet Locations & Sound Proofing 4) Land Use Buffers 5-6) Vegetative or Built Wall Barriers & Trees and Plantings 7) Decking Over Highways 8) Urban Design 9) Garden Locations & Healthy Vegetables 10-11) Park Locations & Active Travel Locations
Source: Rose Kennedy Greenway Conservancy (2018).
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Case Studies of Successful Approaches to Environmental Justice One or a combination of these tools may be most effective depending on the particular highway and neighboring community. Filtration systems in adjacent buildings is an excellent solution which will be discussed in detail in the following case study. Vegetation barriers do a good job of blocking and absorbing pollutants at a short distance. The remaining tools highlight creative development and design patterns specific land adjacent to highways. One unique recommendation is the idea of Buffer Zoning, a potential tool for city planners. Buffer Zoning is a specific set of land use zoning codes that exclude certain vulnerable uses (parks, residential units, etc.) within a buffer around highways. It presents a low cost policy solutions which has the power to protect buffer areas from poor land use decisions. While is can be an effected tool when planning for new developments, most urban core neighborhoods are already densely developed and established. To our knowledge, Buffer Zoning is yet to be implemented on a large scale. Air Filter Ordinance – Los Angeles, CA Los Angeles is home to a vast network of high traffic interstate highways. Due to rapid growth, housing units are often developed within a few hundred feet of highways. To make matters worse, over 4,300 new building permits have been issued by the city of Los Angeles since 2015 (Barboza 2017). As we learned in the previous Boston case study, this lack of development restraint would obviously go against the methods of Buffer Zoning. Nevertheless, the city of Los Angeles has responded with a necessary policy to require air filtration systems in these housing units. In 2016, the city passed an ordinance requiring all buildings within 1,000 feet of freeways to install HEPA (high-efficiency particulate air) filter with a MERV (Minimum efficiency reporting value) of at least 13(Council of the City of Los Angeles 2016). These high performing filters are able to block the dangerous ultrafine particles from highway traffic. However, air-quality experts agree that HEPA filter alone are not an adequate solution, as they do not clock other harmful gasses, like carbon monoxide and volatile organics (Barboza 2017). In addition, the ordinance is poorly enforce, meaning that not all filters are up to code. Transforming Liabilities to Assets – Gary, IN & Philadelphia, PA Due to processes of deindustrialization, economic decline and population lose, many cities are struggling with managing large cohorts of vacant properties. Gary, IN and
Philadelphia, PA have taken creative approaches to address vacant land in disinvested neighborhoods and in turn have created valuable assets for the community. As manufacturing and heavy industry plants closed, Gary was left with numerous brownfield sites, with some including dangerous chemical pollutants. As mentioned before, brownfields are threats to public safety and discourage future investment because of high restoration costs. A large six-acre brownfield, which was classified as a Superfund site by the EPA, had been a liability to the city and neighbors for decades. Through city council leadership and community input a sensible low-cost solution was selected. It’s called phytoremediation: a process that uses selected hearty vegetation to naturally absorb toxic chemicals and cleanse the soil (Carlson 2017). The fifteen year project is being completed by the Delta Institute, a Midwestern environmental non-profit focusing on sustainable land management, and Fresh Coast Capital LLC. The city of Gary has discussed plans to transform the land into an urban forest or greenspace, which would give the community a valuable asset.
Source: Philadelphia Water Department 2011
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Case Studies of Successful Approaches to Environmental Justice Philadelphia currently has a combined stormwater and sewer system, similar to Cincinnati. However, they are currently implementing the first city-wide green stormwater infrastructure (GSI) plan in the nation. Green stormwater infrastructure uses natural systems to allow water to infiltrate the soil on site, reducing the burden on the combine system. The Green City Clean Waters plan outlines the Philadelphia’s vision to reduce stormwater by 85 percent by creating 3,200 acres of green space and pervious surfaces (Philadelphia Water Department 2011). The genius of the plan is that it retrofits existing city elements, such as parks, streets, roofs, and vacant land, to accommodate stormwater on site. There have been several examples of park and playground remodels that have occurred in low income neighborhoods. The image below shows a vacant lot that has become a community gathering space. This project is directing public water investment to positively impact vulnerable communities. Addressing Environmental Gentrification - Atlanta, GA For nearly twenty years, Atlanta has been planning and implementing a massive economic development project within its urban core, called the Beltline. The Beltline is a network of trails, parks and transit corridor that is connecting 45 neighborhoods along a 22-mile loop. The idea was developed in the late 1990s as a grassroots led vision to revitalize Atlanta’s disinvested inner city neighborhoods, while simultaneity making the city more connected, active and sustainable (Atlanta Beltline 2013). The project has its roots in environmental justice, because it was aiming to bring environmental amenities to disadvantaged neighborhoods. Acknowledging that the Beltline would bring economic growth and increased property values, planners made affordable housing requirements a key part of the plan. Within the Beltline district, an ordinance was passed requiring all new multifamily housing development to include 10 to 15 percent affordable units at 60 to 80 percent AMI (area medium income). This provision is helping to provide a way for low income residents to live near green space amenities, even as property values increase in the area. This type of inclusionary zoning is an effective method that can be used to confront environmental gentrification. To our knowledge, this is the first time that an inclusionary zoning practice has been used in direct conjunction with the development of green space amenities. However, the Beltline is not without setbacks. With a rapidly growing market, property values are increasing quicker than expected. As a
result the city if falling behind on their target of 5,600 units, which on 785 built by 2015 (Quirk 2016). In fact, the founded of the project, Ryan Gravel believes that the project has failed to preserve affability and that other methods are needed to properly address environmental gentrification (Quirk 2016). Planning & Community Advocacy Practices - California From grassroots community activism to city and state policy, California is a pioneer when it comes to addressing environmental justice issues. This is likely due to the state’s rapidly growing cities and high population density. California cities have been forced to address significant pollution challenges, and now they are beginning to support and restore some the most effected and vulnerable communities. In 2016, the state legislator passed a law mandating that all municipal comprehensive plans include an environmental justice section. In addition, the California Environmental Justice Alliance (CEJA) is a powerful statewide network of environmental justice advocacy organizations. They work with disadvantaged communities under the framework of Green Zones: “place-based
Source: Atlanta Beltline Inc 2013
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Case Studies of Successful Approaches to Environmental Justice strategy that uses community-led solutions to transform areas overburdened by pollution into healthy thriving neighborhoods” (CEJA). The Green Zones approach has taken a variety of different manifestations throughout the state. Below are three initiatives that offer valuable best practices for Cincinnati. Mapping Tool “CalEnviroScreen” The Communities Environmental Health Screening Tool (CalEnviroScreen) “identifies highly impacted areas that face a combination of environmental burdens, public health stressors, and socioeconomic issues” The tool ranks every census tract in California based on the condition of a variety of pollution metrics, health outcomes, and demographic profile. In this way, the tool paints a comprehensive picture of the vulnerability of areas to environmental burdens. CalEnviroScreen can be found at https://oehha.ca.gov/ calenviroscreen as a user friendly interactive map application. All California residents are now able to understand what issues are effecting their area and how they compare with other places. This is a valuable first step in informing the public about environmental justice issues. This mapping tool was created by the Office of Environmental Health Hazard Assessment (OEHHA) on behalf of the California EPA.
Source: Office of Environmental Health Hazard Assessment 2018
Community Participatory Testing There are many advantages to research that actively engages the communities in which testing is occurring. In East Oakland, a local environmental justice activism non-profit, Communities for a Better Environment, led an air quality testing study in a vulnerable neighborhood adjacent to several pollution sources. After receiving background education on air testing, local residents were given PM testing kits, which they used to collect scheduled readings from strategic points (near school, highways, and industrial plants, etc.). The results revealed several readings that greatly exceeded state and federal air quality thresholds (Communities for a Better Environment 2010). Through this process, community members gained valuable knowledge and insight into the pollution threats facing their neighborhoods. Community participatory testing is an excellent tool for raising awareness and igniting grassroots activism for environmental justice. Source: Communities for a Better Environment. (2010)
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Outline of Environmental Justice Action Plan Planning Policy “Green Up Clean Up” Green Up Clean Up (GUCP) is a city of Los Angeles ordinance passed in 2016 meant specifically to address environmental justice issues. At its core, it is a policy made up of tailored zoning and development controls designed to limit new industrial uses in three hotspot neighborhoods (Theard & Tishima 2016). Each neighborhood was selected due to high amount of industrial facilities paired with vulnerable population demographics. In addition to zoning codes, Green Up Clean Up policy also creates a full time ombudsperson with the role of ensuring industrial firms comply with regulations and encourage them to adopt green practices through city incentive programs. The hope is that this presence will hold companies accountable and keep the city informed about any threats to environmental justice in these vulnerable neighborhoods. There are certainly parallel between this policy and Cincinnati’s Environmental Justice Ordinance, the main difference being how GUCP focusing on target hotspot neighborhoods. It will be interested to see if this policy is successful in the near future.
This section will provide an outline of the proposed Environmental Justice Action Plan for Cincinnati. Many of the elements have been drawn from the previously discussed case studies. Best practices from these case studies have been adapted and tailored to fit the current needs of Cincinnati. Our plan outline is divided into four sections: Inform, Assess, Restore and Plan. Inform and assess focuses on educating the public about environmental justice issues, along with testing to evaluate the health effects of pollution exposure. Restore looks at what the city can do today to mitigate the effects of environmental injustice. Finally, Plan provides a framework for future policy to ensure environmental justice in the long term. Inform As we have discussed, environmental justice issues are often complex, ambiguous and unseen by the public eye. The purpose of Inform is to provide the citizens of Cincinnati with in-depth information regarding environmental justice challenges. »» Gather Inventory of all known and potential threats The city must first create an inventory of all environmental justice threats. A list of sites that should be included in this inventory can be found below. All of these threats have been discussed in detail in the previous section Major Threats to Environmental Justice in Cincinnati. • • • • • • • • •
Abandoned industrial buildings Brownfields Landfills Wastewater treatment plants Flood Plains Hillsides TRI sites Superfund sites Buffer Zones for Highways and High Traffic Roads 13
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Outline of Environmental Justice Action Plan »» Using GIS, create an interactive online map illustrating these threats
»» Community participatory testing
After the inventory is complete, it is vital for the public to gain access to this information in a user friendly manner. GIS (Geography Information System) technology allows powerful map tools to be shared online. Based on our estimates, this project can be done with limited expenses and in a short time period. Therefore, we recommend that this project be completed by the Cincinnati Area Geographic Information System (CAGIS) division, since they already have easy access local mapping resources. We also recommend that the city analyses the aforementioned CalEnvironScreen application to see if they would also like to include a ranking system for each neighborhood.
Community participatory testing will allow local residents to actively engage in the response process. We recommend that air quality testing be completed in neighborhoods near highway traffic and industry. It is also important to consider both outdoor and indoor testing. We recommend that the city partner to with Communities United for Action in order to help organize a resident bass passionate about these issues. The University of Cincinnati may also be a valuable resources, as they can supply technical expertise, testing equipment and grant funding for research project. Health impact studies should also be completed with residents at high risk of pollution exposure. For this, we recommend partnering with UC Health, which has in the past completed research with local test subject. Finally, the city should educate the public on the air testing and reporting protocols that already exist: namely Citizen Air Sampling kits provided by Southwest Ohio Air Quality Agency.
»» Case Study review of successful environmental justice response Assess At the heart of environmental injustice is the fact that vulnerable communities are overlooked and disregarded. The assess portion of the plan will focus primarily on listening to these communities and gathering their input. The second component is to assess both the damage of environmental threats as well as gauging the dangers that still persists today. This will accomplished through extensive air quality and health impact research. »» Identify “hotspot” neighborhoods with history of environmental injustice and high risk to threats »» Community engagement in “hotspot” neighborhoods Based on analysis of the threats inventory and additional research, the city should identify “hotspot” neighborhoods. We recommend that a series of intentional meetings be held within these communities. The focus will be for city planners to listen to the problems, needs and hopes that the residents identify. Other forms of outreach may include, online, mail or door to door surveying. The hope is that community feedback will help to direct the planning process. Unforeseen challenges and solutions may be uncovered during this process.
»» Publicize results of air and health testing to pressure air pollution regulation reform Many past victories of environmental justice are due to public activism and outcry. If test results reveal alarming trends, then the larger public may rally behind these issues. A large public movement may create enough pressure to lead to air pollution regulation reform for both industry and highway traffic. Restore The Restore section of the plan focuses on what can be done now to mend the harmful effects of industrial and highway pollution. »» Vegetation & built wall barriers for highways and high traffic roads They city of Cincinnati should encourage greening along high traffic highways and roads. For interstate highways this will require coordination with the Federal Highway Administration (FHA). Unfortunately, FHA design practices generally discourage vegetation near highways in order to preserve visibility and reduce accidents risks (FHA 14
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Outline of Environmental Justice Action Plan 2017). Besides interstates, the city should also identify high traffic city streets and then prioritize trees plantings along these roadways. Focus neighborhoods should include: West End, Camp Washington, and South Cumminsville.
»» Planning to mitigate environmental gentrification
The city of Cincinnati can pass an ordinance which requires properties near highways to install HEPA air filters. The city should learn from both the successes and challenges of the air filter ordinance in Los Angeles.
Lack of affordable housing may be challenge for Cincinnati in the future. How will the city plan to ensure affordability and minimize the effects of gentrification? A good first step is to identify the effects of public green space investment in low income neighborhoods in Cincinnati, namely Washington and Zeigler Parks. Secondly, when planning future green space projects or expansions, the city should consider an inclusionary zoning policy for that particular area. These types of projects may include: new parks, recreation trails, habitat restoration, green stormwater infrastructure, etc.
»» Adopt Buffer Zoning near highways
»» Planning for climate change resiliency
The city of Cincinnati should consider adopting specific zoning practices for areas near highways. First, a buffer area around highways should be established as an overlay zone. This zoning policy may restrict new development of certain vulnerable uses, such as apartments, schools and parks. If new developments are allowed, then there should be development controls that encourage proper design. The urban design principles in the Community Assessment of Freeway Exposure and Health study in Boston are excellent guidelines for near highways development that help direct pollution away from residents and active spaces.
Heat: As Cincinnati begins to experience hotter summers, it will be important that the city protects vulnerable populations which may not have access to proper air cooling systems. Currently in Cincinnati, landlords are not required to provide air cooling systems to tenants. A few southern cities, including Phoenix have passed ordinances requiring landlords to provide A/C to tenants (Hendricks 2018). In fact, even a northern Chicago suburb, Vernon Hills, passed a similar ordinance (Santana 1995). Cincinnati should also consider such a requirement. They city could start by making this requirement apply first to low income residents receiving government housing subsidies. For homeowners, the Greater Cincinnati Energy Alliance, regional non-profit, is a great resource to help finance energy efficiency projects.
»» Adopt an Air Filter Ordinance for buildings near highways
»» Utilize phytoremediation practices to clean and restore brownfield sites The city should further investigate brownfield land management. The aforementioned Delta Institute may provide assistance with brownfield remediation practices. Focus Neighborhoods such include both Lower Price Hill (site of Queen City Barrel Fire) and Winton Hills (former site of ELDA and Center Road landfills). Plan In order to preserve environmental justice, planning must consider future threats, namely climate change and environmental gentrification. Proper planning will ensure that Cincinnati remains ahead of the curve and a pioneer for smart visionary practices.
Flooding: As Cincinnati prepares for heavy rain events and frequent flooding, it will be vital for the city to adopt and prioritize green storwater infrastructure techniques. Fortunately, it appears that the MSD’s Lick Run Watershed Master Plan has adopted some of these practices. It will be important for the city to learn from the results of this project and adopt green stormwater project city-wide. As for landslides, the city should continue to support the The Hillside Trust in protecting hillsides from development. The city should also be proactive in addressing potential landslide events.
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