Last week, the LSPA sent this letter to the Massachusetts Executive Office of Energy and Environmental Affairs ("EEA") as part of its public comment period on the secretariat-wide draft Environmental Justice (EJ) Strategy. The comment period ends on Friday, February 17, 2023. The effort to develop the report was led by EEA’s Environmental Justice Task Force and convened by EEA’s Director of Environmental Justice in September 2020.
In its materials, EEA noted that it seeks the public review to “elaborate on approaches that are likely to be successful, identify strategies that were missed, and highlight practices that may fall short of our mutual goals to establish a more just and equitable commonwealth.” The strategy is intended to improve the internal management of EEA agencies and the intended audience is EEA staff in their efforts to engage the public. In addition to an overview of the EJ Policy, the report is organized into 13 sections, one for each EEA agency, that outline how each specific agency intends to implement actions for promoting and integrating EJ considerations across its programs, policies, activities, and other strategies.
One key point the LSPA’s letter makes is that LSPs are in a unique situation in the environmental community; they are neither MassDEP staff nor wholly independent. In their work adhering to the MCP they are an integral component of the implementation of the MCP and the success of the waste site cleanup program. As such, the LSPA believes that there are key aspects of the EJ Strategy in which LSPs need to be included. We identify and comment on these aspects throughout the letter. It is important that LSPs are not only aware of EEA’s strategy but that they also understand specific details of how MassDEP wishes to integrate EJ into its outward looking work with the public as well as implementation of its programs and policies.
The report notes that “This collection of environmental justice strategies is intended to improve the internal management of EEA agencies and collect, in a single document, the various strategies being employed throughout the Secretariat. …. The intended audience of this document is EEA staff to use to assist EEA staff in engaging the public on matters relevant to EEA functions and implementation of programs and policies under its purview.
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