In contemporary discussions of important societal issues in the United States, two concerns often rise to the surface because of the combination of their severity and urgency. The first is the growing threat of climate change, and the second is the housing crisis that is now being felt in every corner of the country. While these might seem like two separate issues that will require distinct policy responses, the reality is precisely the opposite. Affordable housing and the environmental justice are inherently linked, and each domain will be most effectively addressed by policies that take both into account simultaneously. Indeed, successfully grappling with skyrocketing housing costs and increasingly frequent environmental stressors will require a multidisciplinary approach—a set of policies that improve both affordability and sustainability.

This new approach must also pay especially close attention to its impact on those who have continually paid the highest price for previous housing and environmental policy failures. American history has been defined by a blatant lack of both fair housing and environmental justice, especially for communities of color and households with the lowest incomes. However, by building on recent momentum and pursuing a set of ambitious policies at the intersection of housing and climate, it is possible to put the country on a path to ‘green’ and affordable prosperity. The Opportunity Starts at Home—a multi-sector campaign built on the recognition that housing affordability is central to other national priorities, like health care, food security, education and more—has long known that ‘housing policy is environmental policy,’ but there has never been a more urgent time to act on both fronts—the future of our communities depends on it.

A Lack of Environmental Justice

In 1982, following years of illegal dumping by private companies, the State of North Carolina selected the community of Afton—a majority Black community with elevated levels of poverty—as the final disposal site following the cleanup of accumulated toxic waste. This decision itself was not particularly unusual; at the time, waste siting decisions like this often ended with marginalized communities bearing the burden of others’ mistakes (Bullard, 1990). The result, however, was remarkable. The decision—and the resulting civic activism—are credited with launching the global environmental justice movement which continues to this day. After Afton residents began coordinating protests against the new waste site, national civil rights organizations including the National Association for the Advancement of Colored People (NAACP), Southern Christian Leadership Conference (SCLC), and United Church of Christ (UCC) joined the effort, thereby bringing greater attention to the issue. As a result, the protests over a single state-level decision morphed into a national discussion about the intersection of race, poverty, and the environment.

Environmental Racism

Benjamin Chavis of the UCC gave this intersection a name: environmental racism. He noted, “Environmental racism is racial discrimination in environmental policy making, the enforcement of regulations and laws the deliberate targeting of communities of color for toxic waste facilities, the official sanctioning of the life-threatening presence of poisons and pollutants in our communities, and the history of excluding people of color from leadership of the ecology movements.” The last phrase should not be overlooked—in addition to policy measures that negatively impacted low-income communities of color, leaders from these communities were often also marginalized within environmental activism organizations as well.

As the result of efforts by civil rights leaders like Chavis, growing recognition of environmental racism led to a push for greater formal scholarship on the topic. Chavis himself and the UCC published a groundbreaking1987 report, Toxic Wastes and Race in the United States, which demonstrated that the proportion of people of color in a given zip code was the single best predictor of commercial waste sites, even after controlling for numerous other factors. Shortly thereafter, Dr. Robert Bullard, who had been involved in the first lawsuit involving the intersection of race and toxic waste in the United States (which took place in Houston in 1979), published Dumping in Dixie (1990), a book that documented numerous examples of environmental racism throughout the American South.

In the book, Bullard described a shift in the racial and socioeconomic dynamics of waste siting resulting from newfound concerns about pollution in the 1970s and 1980s. As civic leaders and community activists, increasingly aware of the health impacts of toxic waste and industrial pollution, mobilized against pollution in their own backyards, communities with less political power—those with lower education levels, fewer resources, and more people of color—became more likely to end up with pollution in their backyards (Bullard, 1990).

These groundbreaking studies launched an entire field of scholarship documenting the connection between race, wealth, and pollution. As summarized by Paul Mohai, David Pellow, and J. Timmons Roberts in 2009, the result is “…hundreds of studies conclude that, in general, ethnic minorities, indigenous persons, people of color, and low-income communities confront a higher burden of environmental exposure from air, water, and soil pollution from industrialization, militarization, and consumer practices.” Importantly, these disparities also exist independently of one another. For example, even after controlling for income, race still predicts greater exposure to pollution and waste (Ash et al, 2009). While there have been many attempts to debunk this statistical relationship as a byproduct of selective analysis, the connection is now well established, especially with the emergence of new, highly sophisticated data analysis methods that reinforce the findings of Chavis, Bullard, and many others (Mohai et al, 2009).

But while the research base on environmental racism is now decades old, requisite policy solutions have lagged behind and the effects of environmental racism continue today. Two recent studies, published in the last five years, contain findings that might as well have been written by Benjamin Chavis or Robert Bullard. Fore example, a 2017 joint report from the NAACP and the Clean Air Task Force found that “Black Americans are 75 percent more likely to live near and be directly impacted by a company, industrial, or service facility,” while a 2020 report from the Princeton Student Climate Initiative found that “people of color are more likely to die from environmental causes and are more likely to live near hazardous waste.”

Intersections with Housing Policy

The connection between race, income, and exposure to environmental hazards is complex and multi-faceted, but housing policy is always part of the equation. In some instances, the relationship between environmental racism and housing policy is explicit and direct. For example, the disproportionate exposure to pollution suffered by low-income communities of color is often the direct result of racist zoning practices such as redlining that legally cloistered marginalized communities in certain neighborhoods for decades. The legacy of these policies continues today—a fact well-documented by recent research (Lynch et al, 2021)—alongside countless examples of contemporary racial and socioeconomic discrimination by both landlords and banks.

In other cases, sometimes termed ‘side-effect’ discrimination, many low-income communities of color are still forced to bear the disparate impact of having to find housing in less desirable areas—including industrial areas or those close to other sources of waste and pollution—due to structural barriers including exclusionary zoning policies, such as those preventing multi-family developments. As another example, because of intransigence from affluent communities, public housing complexes were often placed in less desirable areas, including those in close proximity to industrial activity and designated superfund sites. As a result, thousands of public housing residents live near the most polluted places in the nation (APM, 2021) Furthermore, lack of investment in maintenance of public and affordable housing also exposes residents to unhealthy living conditions, including exposure to lead-based paint and pipes.

More indirectly, but just as problematic, housing policies that prevent the construction of affordable housing in well-resourced, high opportunity communities contribute to the problem by decoupling housing and economic opportunity, resulting in longer commutes and higher pollution. Cities and inner ring suburbs that serve as economic hubs and job centers have made it hard or impossible to build housing. As a result, households with low incomes are priced out of convenient commuting neighborhoods and move further away, resulting in sprawl that destroys ecosystems, clogs freeways, and increases greenhouse gas emissions. Despite not being explicitly discriminatory in nature, the result of these policies has been the same: devastating and ongoing effects on communities that have been historically marginalized.

The Rising Threat of Climate Change

Disproportionate exposure to toxic waste sites and air pollution may be some of the most blatant and visible aspects of environmental racism, but it represents only one facet of a larger problem. Another major component of the issue—also intertwined with housing policy—is related to the effects of carbon and methane emissions. More specifically, low-income and non-white households are both disproportionately exposed to environmental hazards caused by the growing threat of climate change. For example, research suggests that low-income communities and communities of color are at greater risk from natural disasters and extreme temperature events, both of which are occurring more frequently as the result of man-made emissions (Berberian et al, 2021). Importantly, even attempts to combat these issues and increase resilience contain potential equity challenges, such as the unintended phenomenon of ‘resilience gentrification,’ in which recovery efforts reduce housing affordability and hasten displacement of long-time residents.

There are now decades of research demonstrating a causal connection between rising emissions and both extreme temperatures and natural disasters—and this research also suggests that the consequences of these trends are not distributed equally. For example, research suggests that Black, Latino, and Native American communities had higher mortality rates as the result of higher temperatures and extreme heat events, while Native Americans and Alaska Natives were disproportionately impacted by extreme cold (Berberian et al, 2021). Furthermore, low-wealth and non-white communities have also been found to face greater risks of flooding during natural disasters and greater risk of negative health effects as the result of wildfires. Again, this disproportionate exposure is not coincidental—the same housing policies that have resulted in exposure to toxins and pollution also increase vulnerability to hurricanes, floods, and ‘urban heat islands.’

These different forms of environmental racism also build upon and exacerbate one another. One example of this phenomenon is natural technological (‘natech’) disasters, “cascading events in which natural disasters like floods or extreme winds trigger technological accidents that release hazardous materials.” Given the racial and socioeconomic discrimination present in many industrial siting decisions—as discussed above—’natech’ events disproportionately impact marginalized communities, such as in the case of Hurricanes Harvey and Katrina (Berberian et al, 2021).

In recent years, there have been increased efforts to increase the resilience of communities to the greater frequency of climate-related weather events and natech disasters. However, many of these recovery and risk mitigation efforts have had unintended consequences that negatively impact the very people they are intended to help. Without intentional recovery processes that prioritize the needs of current, low-income residents, many structural mitigation efforts result in the upward transfer of housing to the wealthy, who disproportionately benefit from the enhanced resilience of communities while long-time residents are displaced, a phenomenon known as ‘resilience gentrification,’ (Park and Pellow, 2011).

Federal Efforts re: Environmental Justice

To understand the current policy context of environmental justice, it is important to get a sense for the historical scope of governmental efforts to address the issue. The civic activism and growing body of literature around environmental racism that originated in Afton, North Carolina in 1982 eventually attracted the attention of the federal government. In 1990, President George H.W. Bush established the Environmental Equity Working Group, housed within the EPA, which initiated meetings with community leaders on the topic of environmental justice and led to the EPA’s own report on the racial and socioeconomic dynamics of pollution and waste exposure Environmental Equity: Reducing Risks for All Communities. The resulting attention and press coverage also led Congress to hold hearings on environmental racism and justice for the first time.

In 1994, President Clinton issued Executive Order 12898: ‘Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations.’ It directed the federal government to make environmental justice a part of the federal decision-making process across various agencies. In addition, it focused attention on the health and environmental conditions in minority, tribal, and low-income communities with the goal of achieving environmental justice and fostering nondiscrimination in programs that substantially affect human health or the environment.

Unfortunately, as noted in this explainer from the Environmental & Energy Law Program at Harvard, there is no federal law backing up this executive order, which means that the EPA and other federal agencies cannot mandate any policies or accountability mechanisms independent of their authorities under other statutes. As a result of its lack of authority to monitor and enforce Executive Order 12898, the federal government’s environmental justice initiatives and programming have been insufficient to address the scale and severity of environmental racism and discrimination within the United States.

Similarly, more recent attempts to address environmental racism and promote environmental justice have often been well-intentioned half measures that have failed to move the needle. For example, the 1997 Guidance Under the National Environmental Policy Act, which aimed to assist federal agencies with navigating the White House’s Council on Environmental Quality’s procedures, and the 2010 Guidance on Considering Environmental Justice During the Development of an Action, which focused on supporting internal EPA analysis processes of potential environmental justice concerns and encouraging greater public participation in the rulemaking process, both had limited impact without the weight of potential judicial enforcement.

Under President Obama, some efforts were made to directly address the intersection of housing and environmental racism, including a HUD Environmental Justice Plan that outlined strategic priorities from 2016 – 2020. Goals outlined in the document included “identifying and addressing disproportionate environmental and human health impacts, expanding access to resources, information, and best practices for health and environmental benefits from HUD programs, and expanding opportunities for meaningful involvement of minority and low-income populations in HUD’s policies and input on proposed uses of HUD funding.” Unfortunately, as part of a larger gutting of federal initiatives focused on improving equity and addressing discrimination under the Trump Administration, this strategic plan never came to fruition. Furthermore, under Secretary Scott Pruitt, the EPA rolled back regulatory oversight and reduced enforcement mechanisms, rather than strengthening them.

Recent Developments: IRA, Justice40, IIJA

The first two years of the Biden administration have seen important progress take place—with important caveats—especially in the context of the setbacks that occurred during the Trump Administration. Through both executive actions and congressional legislation, environmental justice efforts have become more prominent within the administration than at any other time in recent history—admittedly, a low bar to clear. As one example, the EPA’s newly established Environmental Justice and External Civil Rights office now has 200 people working to advance environmental justice efforts—more than tripling existing staff capacity in these areas. The new office, which reflects a merger of several separate offices within the EPA, has already provided important leadership in the areas of community grant funding, policy and program development, civil rights compliance, and conflict resolution related to disputes over environmental issues.

Another example of executive action focused on environmental justice is the Justice40 initiative, announced during President Biden’s first days in office via Executive Order 14008. The goal of the Justice40 is to deliver 40% of the benefits of key federal investments in climate, clean energy, affordable housing, clean water, and other domains to disadvantaged communities that are marginalized, underserved, and overburdened by pollution. More specifically, Justice40 is a mandate to transform hundreds of federal programs across every aspect of the government to ensure that disadvantaged communities receive the benefits they deserve after shouldering the devastating burden of environmental racism.

Given the intersection of environmental justice and housing, many HUD programs are impacted by the Justice40 initiative, including the Community Development Block Grant program, the Housing Trust Fund, Public Housing, and Tenant-Based Rental Assistance, among others. As part of Justice40, housing leaders have incorporated environmental justice into the fabric of both existing and new programs. Changes include helping Tribal communities achieve safe, resilient housing and infrastructure; piloting new models for green workforce development; reducing and preventing radon and lead exposure and poisoning;; and updating HUD’s environmental review policies for site selection and placement of new assistance activities.

Many of the federal investments influenced by Justice40 are the result of new congressional legislation passed during the first two years of the Biden Administration. Because major components of these new laws are directly related to environmental (and housing) policy, the new investments created by the law must align with Justice40 efforts. One such example is the Inflation Reduction Act, which a variety of new programs related to both climate and housing: $1 billion for a HUD-led program to improve climate resilience, energy and water efficiency in HUD-assisted multifamily housing; $9 billion in Department of Energy consumer home energy rebate programs for energy efficiency and electrification retrofits focused on low-income consumers; $41.5 billion from the Environmental Protection Agency for tools to address climate change and advance environmental and climate justice including $15 billion will serve low-income and disadvantaged communities; as well as the creation of new and expanded tax credits to increase energy efficiency and renewable energy projects that intertwine with the LIHTC.

While less directly focused on the intersection of climate and housing policy, the Infrastructure Investment and Jobs Act also contained key provisions that can be used to address both areas. For example, the IIJA allocated $3.5 billion to help low-income households families retrofit their homes with upgrades that will increase energy efficiency, health, and safety while also reducing their energy costs. This program has a goal of serving 700,000 low-income U.S. households over the next five years.

Further Solutions: OSAH Policy Agenda

Despite the recent progress made through the Justice40 initiative, Inflation Reduction Act, and Infrastructure Investment and Jobs Act, the present level of investment into environmental justice pales in comparison to the scope of the problem. In communities across the country, households with the lowest incomes—disproportionately households of color—continue to face the consequences of blatant discrimination, exclusionary policies, and poorly designed efforts at recovery and remediation. Given the inherent connection with housing policy, the situation calls for significant federal investments in affordable housing with an eye towards sustainable and environmentally friendly development. While many of the solutions need to come at the state and local level—such as zoning changes that would allow for more affordable housing in high-opportunity regions—the federal government also has an important role to play.

The Opportunity Starts at Home Campaign has identified several important policy levers that could make a huge contribution to both affordable housing and environmental justice:

  • Expand rental assistance for every income eligible household, including the use of mobility vouchers. Expanding vouchers for all eligible households would provide a dramatic reduction in rent burdens and provide a historic reduction in homelessness. As it relates to environmental policy, mobility vouchers allow for households with low incomes to have autonomy in moving to neighborhoods with the most opportunities (economic, educational, and many others), thereby reducing commutes and carbon emissions.
  • Expand the stock of housing affordable to households with the lowest incomes through the construction and rehabilitation of affordable and public housing with a focus on energy efficiency, reduced emissions and climate resilience. Existing public housing is in need of repair following decades of underinvestment; these repairs should include weatherization and other green technology improvements. Furthermore, through the Housing Trust Fund and other investments in affordable and public housing, new construction–particularly in affluent, high opportunity neighborhoods that have previously hindered efforts at integration–should be carried out with an emphasis on sustainable and climate resilient building practices.