Investigating the Impact of Environmental Justice Advisory
Councils within Metropolitan Planning Organizations
A comparative case study between San Diego Association of Governments and
Atlanta Regional Commission to examine the effectiveness of disaggregated versus
aggregated environmental justice advisory councils in metropolitan planning
organizations
A research proposal submitted to the Urban Studies and Planning Program Senior Sequence
Class of 2011-2012
November 8, 2011
Jenny Lee
University of California, San Diego
Urban Studies and Planning Program
JYL058@ucsd.edu
Abstract
In recent years, metropolitan planning organizations (MPOs) have been making stronger efforts
to address environmental justice (EJ) issues and to incorporate EJ advocates and EJ populations
into the regional planning process. This study examines one part of that effort by questioning
whether having a specific and consolidated EJ committee/advisory council within an MPO is
more effective at addressing EJ issues and populations, and implementing EJ strategies, than
having disparate EJ advocacy entities disaggregated in various working groups and committees
in an MPO. Two MPOs will be examined, the San Diego Association of Governments
(SANDAG) and the Atlanta Regional Commission (ARC). Data will be collected through
analysis of documents and scholarly articles, interviews and surveys, and participant
observations. This study will help contribute to current literature on the nexus between
sustainable development and social equity, so that there may be more understanding of how
MPOs can more effectively achieve better inclusion of underrepresented populations, and
improve regional equity efforts in order to improve the quality of life for EJ populations and their
region as a whole.
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INTRODUCTION
Many metropolitan planning organizations (MPOs) have been making stronger efforts in
recent years to address equity issues by including more environmental justice (EJ) populations
(defined as low-income and/or minority populations [Executive Order 12898]) into processes of
public participation and representative input needed for drafting regional plans and policies.
Thus, one way for an MPO to improve social equity in regional planning could be to have an EJ
advisory council or committee that makes policy recommendations to Policy Advisory
Committees and/or the Board of Directors of an MPO. San Diego Association of Governments
(SANDAG) currently has a system where EJ advocacy groups and community-based
organizations (CBOs) have representatives in various working groups that fall under SANDAG’s
five policy advisory committees. This study will examine how effective this particular model is
at addressing EJ concerns and including EJ populations in policy discussions compared to
ARC’s model of having an aggregated EJ advisory council, (which the ARC calls a social equity
committee), to make recommendations for their PLAN 2040, the regional framework for their
transportation plan.
This research seeks to understand how having consolidated versus dispersed EJ advisory
councils in MPOs are effective in achieving regional equity, especially with respect to
environmental justice. This study can be utilized by SANDAG or other MPOs to consider if an
aggregated or disaggregated model of EJ advocates and population representatives better fits
their organization. In order to guide the overall conceptualization of the research, and in order to
provide an academic context upon which current policies are based, this study will examine
theories and studies about sustainable development, environmental justice, social and/or regional
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equity, and urban planning processes. The limitations of this study lie with the scope; only
comparing two MPOs creates very specific criteria which cannot be generalized to all MPOs.
CONTEXT: STRUCTURES OF MPOs AND RELEVANT POLICY
In order to place this study in context, the structure of MPOs must first be discussed.
MPOs vary in size and structure across the United States, as well as in designated authority, but
for larger MPOs, generally, the structure involves a coalition of local, city, and/or county
governments. This type of coalition is also called Council of Governments (COG). Select
officials from those governments represent their jurisdictions on the Board of Directors, which is
the body in charge of policy decisions at an MPO. The Board gets policy recommendations from
policy advisory committees, which are further broken down into sub-committees and working
groups that give input and policy recommendations in specific areas. MPOs determine the
region’s transportation plans and funding decisions, as well as land use decisions.
More recently, MPOs have taken on more responsibilities to include social equity/EJ
requirements (Sanchez and Wolf 2007, 250). Two federal mandates have propelled MPOs to
advance equity: Executive Order (EO) 12898 (“Federal Actions to Address Environmental
Justice in Minority Populations and Low-Income Populations,” also known simply as “EJ”) of
1994 and Title VI of the Civil Rights Act of 1964. Title VI prohibits discrimination based on
“race, color, or national origin” (Title VI, section 601, Civil Rights Act of 1964) for all federally
funded programs. EJ was designed to reinforce Title VI by requiring federal agencies to conduct
EJ analyses in order to effectively implement EJ strategies. EJ also requires MPOs and other
federally funded organizations to make more public participation efforts to include EJ
populations in policy-making and planning processes. Efforts and methods of inclusion are
varied. They include community surveys, meetings with CBOs and advocacy groups, and having
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equity committees and/or temporary working groups in MPOs.
CURRENT LITERATURE/LITERATURE REVIEW
This study is grounded in several frameworks of social movements and urban studies and
environmental concepts. This study will examine environmental justice; urban movements like
Smart Growth and sustainable development; and regional equity. These movements and concepts
overlap in content and in goals to improve quality of life, but often have different emphases and
methods of accomplishing their vision for a more just and sustainable way of living and
governing.
The first critical framework that this study is based in is the EJ movement, which began
in the 1980s and has “two distinct but inter-related dimensions” (Agyeman 2005) of grassroots
political mobilization and policy making, working to connect issues such as poverty, public and
occupational health, racial justice and environmental concerns, all of which were previously seen
as disparate issues (Pezzulo and Sandler 2007). The EJ movement’s struggles to make significant
victories at the federal level, despite the passage of EO 12898, have caused a trend of
collaboration between EJ activists and local or state governments (Faber 2007, 136), where
policies are more tangibly created and enforced, and public participation is more inclusive than
at the federal level. However, Pearsall and Pierce’s (2010) study on how well local governments’
sustainability indicator projects were including EJ elements found that while the number of local
governments making efforts to include regional and environmental justice concerns into their
various plans/policies had increased, the actual implementation of EJ related policy and even the
broader contextual understanding of EJ developed in their plans were insufficient and that EJ
was lower in priority than other sustainability issues.
Much EJ research has already been done documenting the disproportionate number of
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environmental hazards, health problems, and racially discriminatory and exclusionary land use
practices that low-income people and/or communities of color have had to face (Pellow and Park
2002; Bullard 2000; Agyeman 2005). These numerous studies also point to a deeper problem:
lack of representation in planning meetings and decision-making tables. Reasons for the gap
vary, stemming from racial injustices, like racial residential segregation and isolation that
negatively affect life chances of minority groups (Massey and Denton 2003; Wilson 1987;
Bullard 2007), to language barriers for new immigrants. This would point towards a need to have
a more intentional way of bringing in EJ populations into the tables of conversation and
decision-making. One way to do so would be to create an EJ committee where residents,
community organizers, and other advocates can come together to make policy recommendations
within MPOs where many regional planning decisions get made.
The current policies and projects developed by MPOs are usually based on the
frameworks of smart growth and sustainable development. Sustainable development has become
a guiding principle for many local and regional governments (Saha and Paterson 2008).
Essentially, sustainable development seeks to harmonize equity, economic development, and
environmental concerns (the “Three E’s”) in a way that “meets the needs of the present without
compromising the ability of future generations to meet their own needs” (Brundtland
Commission 1987). Smart growth principles tie in with sustainable development goals by
advocating for things like livable communities with mixed-use land uses, complete streets, and a
reduction of urban sprawl. Critics of smart growth accuse it of disadvantaging low- and
moderate-income families by causing the gentrification of the neighborhoods and communities
in which they live (Bullard 2007), while others claim that smart growth has potential to increase
EJ and regional equity by breaking down barriers such as transportation and zoning that have
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typically hindered the advancement of racial minorities and low-income people (Bullard,
Johnson, and Torres 2000). Furthermore, despite equity being a key principle in sustainable
development theory, in practice, MPOs and other local governing bodies of power have usually
prioritized economic development or macro-level sustainability issues like climate change and
greenhouse gas reductions at the expense of social equity concerns in general (Pearsall and
Pierce 2010).
EJ issues, smart growth, and sustainable development fit into the broader framework of
regional equity, or new regionalism. The regional equity framework advocates activities and
policies that benefit the region as a whole, versus having localities competing against one
another for resources. If one locality is plagued with poverty and crime for instance, then this
disadvantages the whole region economically and socially. Thus, regional equity views all
localities as interrelated, from the rural to suburban to central city locations, and therefore,
regional policies should be enacted to combat that which hurts the region as a whole— “poverty,
segregation, and place-based inequalities that impose significant economic costs” (Bollens
2003). While regionalism theoretically advocates stances that would help EJ communities, in
practice, most inner-city communities (and therefore, large populations of people of color, many
of whom are concentrated in central cities) are precluded from participating in those discussions
because new regionalism and smart growth emphasize middle-class priorities, and thus have a
middle class bias (Rast 2006). Thus this shows the need for further inclusion of EJ populations in
smart growth discussions. Furthermore, Bollens (2003) found in his study that many regional
governments were addressing equity issues indirectly through various orders scattered
throughout different policies rather than because of the direct efforts of or pressure from
community-based organizations (CBOs) or other advocacy groups. However, the effectiveness of
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the efforts made by regional governments is shown to be only a preliminary point in which to
address equity issues. Therefore, there must be more active participation by CBOs and
representatives that speak on behalf of EJ populations in the policy-making process to make
more direct changes, which this study will explore.
Therefore, the academic literature on social and regional equity, as well as sustainable
development and smart growth, helps to better understand how EJ advisory groups (either a
separate committee or integrated into different committees) with CBOs and other representatives
that directly represent the EJ populations in the MPO’s given jurisdictions can provide a more
equitably representative voice for EJ groups in policy decision making processes in MPOs. This
study will investigate whether one model of advisory group is more effective than another, that
is, whether an aggregated and specifically designated EJ advisory council is more effective at
representing EJ needs than having EJ advocacy groups be spread out in different committees and
working groups.
METHODOLOGY
This study will be conducted by comparing two MPOs that have different practices for
including EJ populations with respect to committees. The San Diego Association of
Governments (SANDAG) does not have a separate standing EJ advisory committee or council.
The Atlanta Regional Commission (ARC) has a separate EJ committee specifically created to
make recommendations for the development of ARC’s new regional comprehensive plan, PLAN
2040.
In order to study SANDAG’s EJ advisory groups and effectiveness, the study will make
use of participant observations (through my SANDAG internship) by sitting in on various
relevant working group and/or committee meetings that will show the interaction of EJ advocacy
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groups and communities in the regional planning process. Furthermore, e-mail requests for
interviews will be sent out to relevant SANDAG staff members who can give input about EJ
advisory councils and why they agree or disagree with SANDAG’s current system. The study
will conduct ten to twenty interviews with staff. Interviews with SANDAG staff will be
conducted in person, through my internship placement with SANDAG. Through these
interviews, the study can gain perspective on why SANDAG has its particular structure instead
of having a separate EJ committee. Additionally, e-mail requests and/or phone calls will be made
to CBOs and EJ advocates/representatives that are currently participating or have previously
participated in SANDAG’s various working groups. Interviews with CBOs will gain input from
the community perspective and will establish whether both groups (SANDAG and the EJ
groups/CBOs) feel the same way about the current level of inclusionary participation. Relevant
SANDAG documents pertaining to EJ will also be studied to determine the quality of EJ policies
and how much of a priority EJ is in SANDAG’s land-use and transportation policies. Census
data and other population statistical data may also be examined in order to see how many EJ
populations currently reside in San Diego, given the special case that San Diego is now a
majority-minority population. This may give further implications for reasons to see if the current
set-up of dispersed EJ groups is the best way for SANDAG to include representatives of EJ
populations.
For ARC, interview requests via phone and/or email will be sent out. Since ARC is
located in Atlanta, Georgia, and the study is physically limited to San Diego, interviews via
phone or live video streaming will be conducted with ARC planners who are involved with the
social equity committee in order to gain their views on how effective their EJ/social equity
committee is and how it was before there was a consolidated committee. Interview requests will
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also be sent out to their equity council’s board members and any sub-members who represent EJ
communities to gain their input on how they view the current system. About 10-20 interviews are
expected for this study.
The limitations of this study come with the scope of interview sample sizes as well as not
examining other EJ advisory committees in other MPOs throughout the United States to get a
more reliable sample source. This study will be specific to the two MPOs, and it will most likely
be unable to extrapolate findings to other MPOs. Expenses are not expected to be substantial.
Potential costs include the purchase of a digital voice recorder to record interviews, and fuel/gas
costs from commuting to SANDAG.
CONCLUDING REMARKS
The findings from this study will contribute to knowledge and understanding about the
role and importance of EJ advisory councils/committees in MPOs. It will determine whether a
disaggregated, dispersed set-up or a specific stand-alone committee is better for representing the
needs and voices of EJ communities. This study may contribute to SANDAG policy on EJ
advisory councils if the organization sees fit to include this study as a recommendation. It may
be that one is not better than the other, and that the set-up is best determined by a case-by-case
basis. More expansive studies will need to be conducted about EJ councils in MPOs. It would
also be valuable to have future studies about the roles that CBOs have in EJ advisory councils as
well as their interactions with the other EJ policy groups and government officials.
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