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The State of Detroit’s Environment: An Initial Assessment Using the Framework of Environmental Justice The impetus of this assessment was an invitation to participate in the creation of an Environment Report for the city of Detroit, generated in collaboration with many organizations throughout the metro area, to be prepared for use by the Detroit Works Project (DWP). We perceive the operating procedures of the DWP to be lacking genuine community direction and protections. That their membership includes individuals and organizations that perpetuate environmental injustices presents the DWP with a conflict of interest that we feel must be resolved before Sierra Club Detroit collaborates in this process. As a result, we felt inclined to produce our own report on the state of Detroit’s environment, using the most up-to-date, unbiased and most relevant information available to our office. May this report be useful to both community members and policy-makers. statistics are consistent with statistics for the entire United States (NOAA, 2012)2. These record temperatures are attributed to human caused climate disruption(IPCC, 2007)3. Atmospheric concentrations of carbon dioxide (CO2) are higher today than at any other point in the last 650,000 years (IPCC, 2007)4. The development of modern civilization, with the resulting decrease in vegetation and the combustion of fossil fuel is the principal cause of climate change, which is accelerating due to an elevated concentration of atmospheric CO2 (IPCC, 2007)5. Although Detroitspecific information has not been released, climate disruptions projected to have significant effects upon the Great Lakes region of the United States, and will play a critical role in shaping the economic and social well-being of the region (Karl et al, 2009)6. The Great Lakes region has been warming at a rate of 0.4°F per decade, since the 1970s. Perhaps more alarming, average winter temperatures are rising at a rate of 0.9°F per decade (Union of Concerned Scientists, 2009a) 7. By the year 2100, average temperatures will be 3.6 to 11.2° F higher in the Great Lakes region (GLISA, 2012)8. Water levels of the Great Lakes and surrounding lakes are projected to decline, and maintain this steady pace of decline throughout the future (NOAA GLERL, 2012)9. This will undoubtedly affect fresh water availability, as well as disrupt commerce and agriculture throughout the region (Kling et al, 2003)10. Climate disruptions are affecting public health and well-being through rising temperatures and changes within the hydrologic cycle (Bajayo, 2012)11. These risks will likely challenge the economic, social, and geophysical environments that promote and sustain human health (WHO, 2008)12. The extent to which climate impacts affect any given population is directly related the resident’s wealth, occupation and assets, institutional links, and social networks (Agrawal, 2009)13. Disparities in wealth, employment opportunities and available resources throughout the Great Lakes region will render certain demographic and socioeconomic groups more vulnerable to health problems. These populations tend to be the elderly, the infirm, the poor, children, minorities, or marginalized populations (Altman, 2012)14. Without access to proper health care and resources, these groups will likely become more marginalized and vulnerable, possessing less resilience to the stressors. Oftentimes, While we applaud the DWP’s efforts at enhanced community engagement laid out in their January 9, 2013 rollout of the “Detroit Future City” Plan, it remains unclear to what degree community feedback genuinely has or will be taken into account in this or future versions of the DWP. Some of the proposals for creating “green” and “blue” spaces to beautify areas of the city while allowing residents to remain in their homes with city services provided sounds promising on paper. However, the basic plan to channel resources toward certain target areas of the city while neglecting others remains intact and fundamentally contradicts the principles of environmental justice. Furthermore, the DWP plan offers nothing toward alleviating existing environmental justice hazards listed below. The continued push of privatization of public lands and resources with respect to land use, air and water quality is also not addressed and remains a concern of the Sierra Club. Complete and transparent independence from any entities significantly contributing to environmental hazards in the city is critical if local environmental groups intend to advocate on behalf of the general public. Accordingly, the Sierra Club of Detroit feels it necessary to release this separate report in hopes of engaging our fellow environmental groups and citizens of the various Detroit Metro communities, along with both corporate and non-profit institutional stakeholders in dialogue about the best ways to preserve the highest possible environmental quality throughout the Detroit Metro area. Climate Change and Public Health The period from January to June 2012 was the hottest temperatures ever recorded in the state of Michigan, since recording began in 1895, with record highs in the city of Detroit (Edwards, 2012)1. These 1 the inequitable distribution of resources after the occurrence of extreme weather events further exacerbates the vulnerability of these populations to negative health outcomes (McEntire, 2005)15. Given these realities, we assume that residents of Southeast Michigan and surrounding communities are disproportionately vulnerable to the negative outcomes of climate change, and will face significant challenges in adapting to new environmental and climatic realities. Below, Sierra Club will illustrate several other environmental issues facing Wayne County, MI, with specific focus on Detroit, MI. related mortalities in the forty cities surveyed by the year 2055 and second again by the year 2099, only being surpassed by Louisville, KY (Altman, 2012)23. EHE days can provoke or exacerbate lifethreatening illnesses, such as kidney diseases, cardiovascular disease, heat exhaustion and heat stroke. In addition to these, excessive heat can also invoke cramps, fainting, and swelling. Further complicating human health is the prevalence of high humidity during EHE days, which hinders the evaporation of sweat from human skin. This causes the body temperature to rise, without the regulation of natural cooling mechanisms like sweat (Altman, 2012)24. The populations most vulnerable to heat waves are the elderly, the infirm, young children, the poor, as well those comprising minority ethnic and racial demographics. Residents of city centers are more vulnerable to the effects of heat because paved surfaces and infrastructure magnify the heat’s intensity (the urban heat island effect). As Detroit is an urban center lacking tree cover, it is particularly vulnerable to this type of excessive heat buildup. The State of the People Per the 2010 census, there are 713,777 residents within the city of Detroit (US Census Bureau, 2012)16. Of these, 82.7% are African American (US Census Bureau, 2012)17. The median household income level in Detroit is $25,787 per year, with 32.3% of the population living below the poverty level (US Census Bureau, 2012)18. Educational attainment remains low within the city, with 22.6% of the population lacking a high school diploma. Residents of Detroit suffer an unemployment rate of 45.3% (US Census Bureau, 2012)19. Due to bleak economic opportunities and vast divides between social classes, families within the city are unstable. Out of all the housing units within the city, 22.8% are vacant (US Census Bureau, 2012)20. Detroit remains one of the most racially segregated cities in the United States, upon analysis of individual neighborhoods. And African Americans and Latinos within the city are disproportionately burdened with industrial pollution. We believe this reality contributes to many of the social statistics outlined above. Industrial Epidemiology The Michigan Department of Community Health has found that Detroit adults suffer from asthma 50% more than the state of Michigan as a whole (Wasilevich et al, 2008)25. Detroit children are also hospitalized for asthma 50% more than Detroit adults. Roughly 13.7% of all Detroiters suffer from asthma. In addition, Detroiters suffer from asthmarelated hospitalizations three times more than Michigan as a whole. Asthma-related deaths are two times higher in Detroit than Michigan at-large. Perhaps even more troubling is the racially divided statistics of asthma prevalence; hospitalizations due to asthma among white Detroiters is roughly 27 per 10,000 people, whereas among black Detroiters, the rate jumps to 56.9 per 10,000 people. African Americans residing within the city of Detroit are more than two times more susceptible to asthma hospitalizations than white residents. Excessive Heat Events A recent study from the American Meteorology Society (Green, 2011)21, published in Weather, Climate and Society, surveyed forty US cities, over one million in population, for the relationship between, heat, weather conditions and mortality projected into the future. Ten cities within Great Lakes region are projected to show a considerable increase in Excessive Heat Event days (EHE) due to climate change (Altman, 2012)22. These EHE days are projected to dramatically increase heat-related mortalities within Great Lakes cities. Perhaps the two urban centers most vulnerable are Detroit, MI and Cleveland, OH. Most relevant to this assessment is that Detroit is projected to experience 4,109 additional EHE mortalities by mid-century and 17,877 by the end of the century. Detroit ranks as second highest heat- Air Pollution Around Schools Dr. Paul Mohai of the University of MichiganAnn Arbor’s School of Natural Resources conducted a research study examining the extent of air pollution from industrial sources near 3,660 public schools in Michigan (Mohai, 2011)26. This study examined whether pollution burdens varied by demographic characteristics of the student body, whether air pollution is linked to student performance, and how pollution burdens flux throughout the state of 2 Michigan, metropolitan centers as well as the various school districts within Michigan. Public schools in Michigan are disproportionately located in places with high air pollution from industrial sources; the majority of Detroit public schools fall within the 10th decile of most polluted areas (please refer to Figure A) (Mohai, 2011)27. The research found that 67.3% of all Michigan students attended schools within the two most polluted deciles. Forty-four percent of white students attended schools within the most polluted decile, versus 81.5% of African American students and 62.1% of Hispanic students (Mohai, 2011)28. The majority of air pollutants found at the schools were diisocyanates, manganese, sulfuric acid, nickel, chromium, trimethylbenzene, hydrochloric acid, molybdenum trioxide, lead, cobalt and glycol ethers (Mohai, 2011)29. These chemicals have been associated with increased risks of cancer, neurological disorders, respiratory disorders, cardiovascular disorders, and developmental disorders (Good Guide, 2012)30. from mobile sources, such as cars and trucks in Wayne County, Michigan. Roughly 14.4% (55 schools) of schools within the Detroit School District are within 150 meters of major roads, compared with 5.5% (25 schools) of the remaining schools in Wayne County. In the urban core of Wayne County, 7.6% of students are traffic-exposed while at school (Wu and Batterman, 2006)31. The majority of the exposed students are African American or Hispanic, recipients of a meal program, and reside in low-income neighborhoods (Wu and Batterman, 2006)32. Traffic-related exposures of pollution are associated with a myriad of negative health outcomes, such as respiratory diseases, asthma, cardiopulmonary mortality, and adverse birth outcomes (Wu and Batterman, 2006)33. Motor City Automakers Ford Motor Company owns a number of facilities in the community of Dearborn, MI. Of all Detroit automakers, Ford produces the largest burden of industrial pollution. The cumulative emissions of toxic substances released by the Ford Motor Company in 2010 is 604,041 pounds, 90.8% of which was released into the air (RTK, 2012)34, contributing to an elevated risk of asthma-related illnesses in neighboring communities. The sprawling facility of the GM DetroitHamtramck Assembly Center not only manufactures cars and car parts, it also exacerbates negative public health outcomes in the neighboring community of Hamtramck, MI. This particular facility is not far from the Detroit Renewable Power incinerator, and contributes to the cumulative impact of environmental toxicity in the region. In 2010, GM produced 184,388 pounds of toxic releases and 240,711 pounds of waste generated (RTK, 2012)35. Much of what is released by the operation of this plant is methanol, hydrochloric acid, and 1,2,4-Trimethylbenzene, which is almost all released into the air. It isn’t just the automobiles being manufactured that assails the health of neighboring communities, it is also I-94 that skirts the GM plant, contributing to mobile-source pollution. The Chrysler Jefferson North Assembly plant produces slightly less toxic releases than GM, though generates much more waste on average (RTK, 2012) 36.. This facility located in an area of Detroit that is much less beleaguered by industrial pollutants in comparison to other communities discussed above. Chrysler’s impact is further magnified by the Detroit Axle Plant that generates 16,934 pounds of waste per year (RTK, 2012). Figure A: Map of Michigan, generated by Dr. Paul Mohai, indicating locations of polluting facilities in proximity to public schools. Exposure of Schools to Traffic-Related Pollutants A recent study from Dr. Yi-Chen Wu and Dr. Stuart Batterman from the University of Michigan-Ann Arbor’s Department of Environmental Health Sciences studied the prevalence of air pollution in K-12 schools 3 Detroit Renewable Power Detroit Renewable Power (DRP) is the nation’s largest solid waste incinerator and operates within the city of Detroit. This facility is purported to burn 432,000 tons of waste per year. Residents complain of noxious odors emitting from the plant, due to the rotting garbage on the premises. However, residents have much more to worry about than stinky trash. Recent reports from the Michigan Air Emissions Reporting System shows that the DRP is Wayne County, Michigan’s fourth largest producer of nitrous oxides (MDEQ, 2012)37. Residents living in the census tracts near this facility are 94% African American, earning a median household income of $18,479 per year, versus $25,787 for the city of Detroit at-large (US Census Bureau, 2012)38. Figure B: Locations of brownfields throughout Wayne County, Michigan (EPA, 2012)46. Brownfields The term brownfield refers to “real property for which the expansion, redevelopment or reuse may be complicated by the presence or potential presence of a hazardous substance, pollutant or contaminant (US Congress, 1980)39.” There are numerous locations, throughout the city of Detroit and neighboring communities that fit this criteria, and pose a very serious public health risk to community members (please refer to Figure B). The Michigan Economic Development Corporation has estimated that more than 44,000 acres of brownfields exist in the state of Michigan (MEDC, 2008)40. The estimated number of brownfields within the city of Detroit ranges from 45,000 sites (EPA, 2000)41 to 90,000 sites. As many of these sites are abandoned industrial lots, there remains considerable amounts of heavy metals, hydrocarbons, pesticides, and other toxic substances that were once utilized or produced on-site (Adelaja, 2010)42. Not only are these locations hazardous to residents, they are barriers to economic development (Dorsey, 2003)43 and contribute to a decaying aesthetic that emotionally affects community members (Adelaja, 2010)44. Brownfields also promote urban sprawl, by discouraging the reuse of contaminated inner city land (Adelaja, 2010)45. Detroit brownfields remain a very serious environmental threat to residents, though there is much promise in the possibilities of brownfield redevelopment for purposes of clean energy generation. Michigan Zip Code 48217 Southwest Detroit zip code, 48217, is Michigan’s most polluted zip code, based upon the emissions of industrial facilities weighted for toxicity of the chemicals released (please refer to Figure C) (Lam, 2010)47. In addition to the enormous burden of industrial pollution, this zip must grapple with the immense mobile sources of pollution, most notably from Insterstate-75 that skirts the community. In fact, Southwestern High School is located just half a city block from I-75. Neighbors assert that nearly every household in the community has at least one case of asthma, leukemia, sarcoidosis or other rare forms of cancer (Lam, 2010)48. The industrial facilities that most impact 48217 are the Severstal Steel plant, the DTE River Rouge coal-fired power plant, Marathon Oil Corporation oil sands refinery, EES Coke and Battery (owned by DTE), and Edward C Levy Company which produces slag for Severstal Steel (RTK, 2010) 49. Many of these industries are quite literally across the street from people’s homes, and many are adjacent to public schools in the community (Lam, 2010)50. 4 Figure C: Industrial facilities with the largest toxic releases into the community of 48217. Ecorse, MI The community of Ecorse, MI experiences an immense amount of environmental pollution as a result of the operations of the US Steel facility, also known as Great Lakes Works (please refer to Figure E) (RTK, 2012)54. Among all industrial facilities in Wayne County, Michigan, Great Lakes Works is the most polluting. This particular facility released 10,198,270 pounds of toxic releases and 10,598,638 pounds of waste in 2010 (RTK, 2012)55. Among the substances most emitted by this facility are zinc, manganese, asbestos, creosote and lead. The Great Lakes Works facility has been found to have concentrations of manganese at levels far higher than MDEQ’s Residential Particulate Soil Inhalation Criteria (Beck, 2009)56. Long-term exposure to manganese can result in neurological damage, with symptoms ranging from tremors to memory loss (NIEHS, 2012) 57. River Rouge, MI The community of River Rouge is another area disproportionately burdened by the pollution from industrial facilities relative to most other communities within the Detroit metro area (MOJO, 2012)51. The facilities that pose the greatest health risk for the residents of River Rouge are the DTE River Rouge power plant, the EES Coke battery plant (owned by DTE), and the Detroit Wastewater Treatment Plant, among many neighboring facilities not physically located within the geographic boundaries of River Rouge (please refer to Figure D) (RTK, 2012) 52. Much of what is released into the community of River Rouge by the facilities listed above are barium compounds, hydrochloric acid, fine particulate matter, sulfuric acid, mercury and volatile organic compounds (RTK, 2012)53. Figure E: Toxic substances released into the community of Ecorse in 2010. Toxic Substances Released (lbs/year) Pounds Per Year, Manganes e compoun ds , 1,228,566 , 13% Figure D: Industrial facilities located in River Rouge, MI, with toxic releases represented in pounds released per year. Releases per pound per year, EES Coke Battery LLC… Releases per pound per year, BP Products NA Inc,… Releases per pound per year, Fritz Enterpris es Inc,… Releases per pound per year, Carmeus e NA, 41,065… Pounds Per Year, Asbestos , 3,380,000 , 35% Pounds Per Year, Lead compoun ds , 133,731, 1% Zinc compounds Asbestos Manganese compounds Creosote River Rouge Power Plant In 2010, the Clean Air Task Force estimated that the Detroit Edison River Rouge coal-fired power plant releases mercury, nitrous oxides, sulfur oxides, and particulate matter in quantities that provoke 44 deaths, 72 heart attacks, and 700 asthma attacks on a yearly basis (CATF, 2010)58. Despite receiving a community service award from the Michigan Department of Environmental Quality for the restoration of native species and habitat around the plant, DTE remains one Hazardous Industries (lbs released/year) 1,621,382 Pounds Per Year, Zinc compoun ds , 4,730,964 , 49% Pounds Per Year, Creosote , 179,725, 2% DTE River Rouge Power Plant EES Coke Battery LLC (DTE) Carmeuse NA 5 of the biggest polluters of the community of River Rouge, emitting more than 3.7 metric tons of carbon dioxide annually (CARMA, 2012)59. In sum, this facility generates 1,621,382 pounds of toxic releases annually, with 1,839,563 pounds of waste generated (RTK, 2010)60. The NAACP has ranked the River Rouge power plant to be the ninth worst coal-fired power plant for health outcomes in communities of color (NAACP, 2011)61. This facility places an additional burden on school children, as it is 0.8 miles from River Rouge High School. remains a vital source of energy for this plant (Kueppers, 2012)65. Marathon Petroleum Since 2001, MDEQ has issued 13 airpollution violations notices to Marathon’s Detroit Refinery. These violations from 5,400 tons of pollutants expelled into the atmosphere each year have resulted in $460,000 in fines to settle clean air act violations. Since the $2.2 Billion expansion of its tar sands oil refinery in 2008, Marathon has been forced to commit to investing in over $2 million dollars of equipment to bring them into compliance with EPA guidelines after four years of expelling in excess of 15 tons of toxic compounds and at least another ton of the primary hazardous bi-product of tar sands refining – benzene over that four year period. Meanwhile, Marathon has agreed to relocate up to 90% of residents from the nearby Oakwood Heights community, but has failed to reach similar buyout agreements with residents of 48217 who live even closer to the refinery. Residents of 48217 had to conduct their own air sampling to prove benzene, sulfur dioxide and other hazardous toxins were being pumped into their basements via the public water main as Marathon pumps over three million gallons of waste water from the refinery to the city’s Wastewater Treatment Plant. Similarly, several fire, noise and other environmental hazards from flaring and other activities at the refinery continue to plague residents in the area. Detroit Wastewater Treatment Plant The Detroit Wastewater Treatment Plant processes waste from over 250 of the region’s most polluting facilities and has a history of violating its permit, most recently from late 2009 to 2011. It is the largest source of discharge into the Detroit River. In 2011, the Detroit Waste Water Treatment Plant polluted over 47 billion gallons of diluted raw sewage and storm water into the Detroit and Rouge Rivers from combined sewer overflows (Great Lakes Protection, 2012)62. Impacts from the sewage overflows contribute to contaminated drinking water, decreased property values, waterborne illnesses and basement backups (Sierra Club, 2012)63. Downriver residents, especially in the community of River Rouge, use these waterways for fishing, and water for domestic use. As a result of the water contamination from the treatment plant, these residents are experiencing a myriad of negative health outcomes. Addressing Environmental Injustice On November 21st, 2007, the Governor of Michigan signed an Executive Directive, charging the MI Department of Environmental Quality with developing and implementing a state environmental justice plan to promote environmental justice in Michigan. The DEQ was then combined with the Department of Natural Resources (DNR) to form the Department of Natural Resources and Environment (DNRE) which developed an Environmental Justice Plan in December of 2010. The two pillars of environmental justice are stated in this plan as: Severstal Steel The second largest emitter of toxic releases in Wayne County, Michigan is the Severstal Steel plant in Dearborn, Michigan. In the year 2010, Severstal emitted 8,573,618 pounds of toxic releases and generated 11,486,806 pounds of waste (RTK, 2012)64. This facility is literally located just behind Salina Elementary school, the sight of which evokes quite an ironic juxtaposition. Community members of 48217 engaged Severstal Steel in a lawsuit because of immense amounts of particulate fallout and the resulting negative health outcomes. They suspect that much of this fallout is zinc, manganese and lead compounds. Since the Keystone XL pipeline was proposed, Severstal has expanded their operations to generate steel for the spiral and seam pipes used to transport the oil sands to refineries. Severstal also generates much of the steel used to manufacture the pipes for purposes of hydraulic fracturing an industry that has grown in the Midwest in recent years. The plant’s operations benefit doubly from expanded natural gas extraction, as gas “Fair, non-descriminatory treatment means that no group of people, including racial, ethnic or low-income populations should bear a disproportionately greater burden resulting from environmental laws, regulations, policies and decision-making. The activities and actions of the DNRE and the other state agencies have the potential to significantly impact the health and environmental well-being of all Michigan residents and 6 businesses; particularly individuals living in minority and low-income communities.” Works Cited 1 Edwards, Chris. "It's Official! First Half of 2012 Was Hottest Ever Recorded in Michigan and U.S." Detroit 7 Action News. N.p., 9 July 2012. Web. 10 July 2012. <http://www.wxyz.com/dpp/news/itsofficial-first-half-of-2012-was-hottest-ever-recorded-in-michiganand-us>. 2 "Global Analysis May 2012." State of the Climate. National Oceanic and Atmospheric Administration, n.d. Web. 10 July 2012. <http://www.ncdc.noaa.gov/sotc/global/>. 3 IPCC. "2. Causes of Change." Climate Change 2007: Synthesis Report Summary for Policymakers. Intergovernmental Panel on Climate Change, 2007. Web. 10 July 2012. <http://www.ipcc.ch/publications_and_data/ar4/syr/en/spms2.ht ml>. 4 Ibid. 5 Ibid. 6 Global Climate Change Impacts in the United States, Thomas R. Karl, Jerry M. Melillo, and Thomas C. Peterson, (eds.). (2009) Cambridge University Press. 7 Union of Concerned Scientists. (2009a). Climate change in the Midwest projections of future temperature and precipitation. Hayhoe, K., VanDorn, J., Naik, V., and Wuebbles, D. Retrieved from http://www.ucsusa.org/assets/documents/global_warming/midw est-climate-impacts.pdf 8 Great Lakes Regional Integrated Sciences and Assessments Center (GLISA). (2012). Climate Change in the Great Lakes Region. GLISA. 9 National Oceanic and Atmospheric Administration (NOAA) Great Lakes Environmental Research Laboratory (GLERL). (2012). “Water levels of the Great Lakes.” National Oceanic and Atmospheric Administration. Retrieved from http://www.glerl.noaa.gov/pubs/brochures/lakelevels/lakelevels. pdf. 10 Kling, G.W. et al. (2003). Confronting climate change in the Great Lakes Region: Impacts on our communities and ecosystems. Union of Concerned Scientists, Cambridge, Massachusetts, and Ecological Society of America, Washington, D.C. 11 Bajayo, Rachael. "Building Community Resilience to Climate Change through Public Health Planning." Health Promotion Journal of Australia 23 (2012): 30-36. Print. 12 World Health Organization Secretariat. Climate Change and Health. Report No.: EB 122/4. Geneva (CHE): WHO; 2008 January 16. 13 Agrawal, Arun. (2009). “The Role of Local Institutions in Adaptation to Climate Change.” Paper Presented at the Social Dimensions of Climate Change Workshop. World Bank. March 2008. 14 Altman, Peter. (2012). “Killer Summer Heat: Projected Death Toll from Rising Temperatures in America Due to Climate Change.” Issue Brief, Natural Resources Defense Council. 15 McEntire DA. “Why Vulnerability Matters: Exploring the Merit of an Inclusive Disaster Reduction Concept.” Disaster Prevention and Management. 2005;14(2):206-22. 16 "Profile of General Population and Housing Characteristics: 2010." American FactFinder. US Census Bureau, n.d. Web. 10 July 2012. <http://factfinder2.census.gov/faces/tableservices/jsf/pages/prod uctview.xhtml?pid=ACS_10_1YR_DP03>. 17 Ibid. “Meaningful involvement means that residents have an appropriate opportunity to participate in decisions about a proposed activity that will affect their environment and/or health. To be effective, an environmental justice plan must incorporate comprehensive measures for including the public in legal and policy decisions related to environmental issues. Indeed, full public involvement in governmental decision-making is a basic tenet of democracy.” Many communities within the state of Michigan are beleaguered by the immense quantities of environmental pollutants emitted by industrial facilities. Most of these industrial facilities are located in communities principally comprised of people of color. These communities tend to be at overwhelmingly low socioeconomic thresholds, and without legal recourse or resources with which to defend themselves or improve their domestic situations. Given the contamination of their immediate environments, these communities have inordinately high levels of asthma, cancer, neurological disorders, and birth defects. These communities embody the Executive Directive’s definition of Environmental Justice communities and are bearing a “disproportionately greater burden” of pollution today. It is therefore essential and required by the DNRE’s Environmental Justice Plan, that state decisions work to reduce and not increase the burden of pollution in these communities. Before issuing permits for any new or modified facilities that emit toxic air pollutants in the city of Detroit, the Michigan Department of Environmental Quality must ensure that these facilities do not create disproportionate impacts on already burdened communities. The MDEQ should set stringent limits for these facilities based on a careful analysis of the cumulative impacts of polluting facilities faced by many Detroit communities. In the absence of action initiated by State agencies, the City of Detroit has responsibility to call the State’s attention to issues of pollution and environmental justice. Any solutions lacking this analysis and consideration will perpetuate existing environmental injustices and human rights abuses of Detroit residents by some of the most profitable corporations of the region. 7 18 40 "Selected Economic Characteristics." American FactFinder. US Census Bureau, n.d. Web. 10 July 2012. <http://factfinder2.census.gov/faces/tableservices/jsf/pages/prod uctview.xhtml?pid=ACS_10_1YR_DP03>. 19 Ibid. 20 Ibid. 21 Greene, S; Kalkstein L; Mills D; Samenow, J. 2011. “An Examination of Climate Change on Extreme Heat Events and Climate–Mortality Relationships in Large U.S. Cities.” Weather, Climate and Society, October 2011, 3, 281-292. 22 Altman, Peter. (2012). “Killer Summer Heat: Projected Death Toll from Rising Temperatures in America Due to Climate Change.” Issue Brief, Natural Resources Defense Council. 23 Ibid. 24 Ibid. 25 Wasilevich EA, Lyon-Callo S, Rafferty A, Dombkowski K. “Detroit - The Epicenter of Asthma Burden”. Epidemiology of Asthma in Michigan. Bureau of Epidemiology, Michigan Department of Community Health, 2008. 26 Mohai, Paul, Byoung-Suk Kweon, Sangyun Lee and Kerry Ard. “Air Pollution Around Schools is Linked to Poorer Student Health and Academic Performance.” Health Affairs, 30, no. 5 (2011): 852862. 27 Ibid. 28 Ibid. 29 Ibid. 30 Scorecard. Chemical profiles [Internet]. Washington. (DC): Scorecard; [cited 2012 Jul 9]. Available from: http://scorecard.goodguide.com/chemical-profiles/ 31 Wu, Yi-Chen, and Stuart A. Batterman. "Proximity of Schools in Detroit, Michigan to Automobile and Truck Traffic." Journal of Exposure Science and Environmental Epidemiology 16.5 (2006): 457-70. Print. 32 Ibid. 33 Ibid. 34 "Ford Motor Co Dearborn Truck Plant (2010)." The Right-toKnow Network. N.p., n.d. Web. 12 July 2012. <http://www.rtknet.org/db/tri/tri.php?reptype=f&facility_id=481 21FRDM23001M&reporting_year=2010&dbtype=C&detail=1&datype=T> 35 "General Motors GM VA Detroit-Hamtramck Assembly Center (2010)." The Right-to-Know Network. N.p., n.d. Web. 12 July 2012. <http://www.rtknet.org/db/tri/tri.php?reptype=f>. 36 "Chrysler Jefferson North Assembly Plant (2010)." The Right-toKnow Network. N.p., n.d. Web. 12 July 2012. <http://www.rtknet.org/db/tri/tri.php?reptype=f&facility_id=482 15CHRYL2101C&reporting_year=2010&dbtype=C&detail=1&datype=T>. 37 "Detroit Renewable Power LLC." Michigan Air Emissions Reporting System. Michigan Department of Environmental Quality (MDEQ), n.d. Web. 11 July 2012. <http://www.deq.state.mi.us/maers/facility_info.asp?SRN=M414 8&EI_Year=2010>. 38 "Selected Economic Characteristics." American FactFinder. US Census Bureau, n.d. Web. 10 July 2012. <http://factfinder2.census.gov/faces/tableservices/jsf/pages/prod uctview.xhtml?pid=ACS_10_1YR_DP03>. 39 U.S. Congress, 1980. Comprehensive environmental response, compensation, and liability act of 1980—Section 101 (42 U.S.C. 9601), Washington, D.C., U.S. Library of Congress. Michigan Economic Development Corporation (MEDC), 2008. Michigan Economic Development Corporation (MEDC), 2008. Brownfield Redevelopment. The Michigan Economic Development Corporation <http://ref.themedc.org/cm/attach/b0bc12b6-18b0-4e74-823f50b40d116e36/BrownfieldSBT.pdf>, accessed October 13, 2008. 41 "Brownfields Supplemental Assistance." Solid Waste and Emergency Response. Environmental Protection Agency (EPA), Apr. 2000. Web. 12 July 2012. <http://nepis.epa.gov/Exe/ZyNET.exe/P100AIP4.TXT?ZyActionD=Z yDocument&Client=EPA&Index=2000+Thru+2005&Docs=&Query= &Time=&EndTime=&SearchMethod=1&TocRestrict=n&Toc=&Toc Entry=&QField=&QFieldYear=&QFieldMonth=&QFieldDay=&IntQF ieldOp=0&ExtQFieldOp=0&XmlQuery=&File=D%3A%5Czyfiles%5CI ndex%20Data%5C00thru05%5CTxt%5C00000027%5CP100AIP4.txt &User=ANONYMOUS&Password=anonymous&SortMethod=h%7C &MaximumDocuments=1&FuzzyDegree=0&ImageQuality=r75g8/r 75g8/x150y150g16/i425&Display=p%7Cf&DefSeekPage=x&Search Back=ZyActionL&Back=ZyActionS&BackDesc=Results%20page&M aximumPages=1&ZyEntry=1&SeekPage=x&ZyPURL>. 42 Adelaja, Soji. "Potential Application of Renewable Energy on Brownfield Sites: A Case Study of Michigan." Energy Policy 38.11 (2010): 7021-030. Print. 43 Dorsey, J. “Brownfields and Greenfields: the Intersection of Sustainable Development and Environmental Stewardship.” Environmental Practice, 5 (1) (2003), pp. 69-76. 44 Adelaja, Soji. 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Web. <http://www.freep.com/article/20100620/NEWS05/6200555/482 17-Life-Michigan-s-most-polluted-ZIP-code>. 51 Hertsgaard, Mark. "How a Grassroots Rebellion Won the Nation's Biggest Climate Victory." Mother Jones, 2 Apr. 2012. Web. <http://www.motherjones.com/environment/2012/04/beyondcoal-plant-activism?page=2>. 52 "TRI Facilities for River Rouge, MI (2010)." The Right-To-Know Network. N.p., n.d. Web. 9 July 2012. <http://www.rtknet.org/db/tri/tri.php?citystate=river+rouge%2C +mi>. 53 Ibid. 8 54 "TRI Facilities for Ecorse, MI (2010)." The Right-To-Know Network. N.p., n.d. Web. 9 July 2012. <http://www.rtknet.org/db/tri/tri.php?citystate=ecorse%2C+mi>. 55 Ibid. 56 Beck, Barbara D., and Gradient Corporation. "Health Consultation: Public Health Implications of Inhalation of Manganese in Downriver Soils." Agency for Toxic Substances and Disease Registry, 26 Mar. 2009. 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