Engaging the Public on Environmental Justice - NYC Mayor's Office of Climate and Environmental Justice
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Executive Summary

Engaging the Public on Environmental Justice

Meaningful involvement, a core principle of environmental justice, means the public has an opportunity to influence environmental decision- making that may affect their health and well-being. Understanding and participating in these complex and variable processes can be at times confusing, resource intensive, time consuming, and inaccessible for New Yorkers, thus limiting the perspectives represented. City agencies, as discussed in this section, have used online engagement tools and participatory planning workshops to overcome some of these barriers; however, there are opportunities to expand these efforts in the future.

Public comments are only one aspect of decision- making and must be weighed against other inputs such as technical analysis and citywide goals such as addressing the housing crisis . Furthermore, in certain instances, public comments processes can become dominated by those with the time and resources to promote their desires which may be at odds with equity and environmental justice priorities. While the concept of public engagement and consensus building means that some community members will inevitably be disappointed by the outcome, equitable public engagement processes seek to center the interests of those most impacted.

This chapter evaluates select City engagement processes to better understand the barriers to participation. While not fully exhaustive of the City’s efforts, these case studies span different EJ issues and City agencies to give a snapshot of current engagement practices. This evaluation is supplemented by findings from a series of focus groups with New Yorkers in EJ communities, as well as stakeholder interviews with community leaders on the frontlines of the EJ movement. The conversations revealed both positive and negative experiences engaging with City agencies on EJ issues, highlighting critical concerns for the City to address in the forthcoming EJNYC Plan. The City seeks to expand successful engagement practices and explore new methods of partnership to ensure City efforts to advance environmental justice reflect community voices.

This section evaluates select examples of formal public engagement, public engagement that is not legally required, and environmental processes without public engagement, per the public scope. These evaluations are followed by high-level summaries of the key takeaways from the EJNYC focus groups and interviews.

‌formal Public Engagement‌

Specific City programs and processes include legally mandated public engagement. This section evaluates some key examples; this list is not exhaustive.

City Administrative Procedure Act (capa)

The City Administrative Procedure Act (CAPA) is the process by which a City agency may propose and adopt rules necessary to carry out its duties as dictated by federal, state, or local law. The rulemaking process generally takes a minimum of 60 days and requires the agency to solicit and consider public comments. The Act states that each agency should conduct outreach to the relevant communities, collect written comments and conduct a public hearing. The agency may adopt a final rule “after consideration of the relevant comments presented,” but there is no requirement for the agency to make public how it considered such comments.454Citywide Administrative Procedure Act. (n.d.). NYC Mayor’s Office of Operations. NYC Government.

The rulemaking process is crucial to environmental justice as it is the vehicle for the creation of environmentally impactful rules such as Department of Parks and Recreation’s requirement for planting of replacement trees destroyed during a construction project and the Department of Health and Mental Hygiene’s eligibility criteria for the Grocery-to-Go program which was created to address food insecurity in New York City.455The City Record Online. (n.d.). NYC DCAS. NYC Government

Although proposed rules must include a statement of basis and purpose, written comments on proposed rules have raised concerns around the difficulty in understanding the legal language in which the rules are typically drafted, stating that citizens are unable to weigh in on issues if they do not know what is being proposed. Similarly, while public hearings may provide the opportunity to ask clarifying questions, members of the public who are unable to attend hearings have no way of better understanding the propositions.

Another concern around these public engagement processes is the question of impact. Stakeholder feedback has called for the exploration and development of a clear and quantifiable requirement for incorporating public comments into decision-making. This concern was evident in the adoption of amendments to the Department of Sanitation’s Siting Requirements Regarding Transfer Stations. The Department sought to alter the definition of “public park” to exclude Bronx River Parkway lands abutting an active railroad line, with the aim of siting a solid waste transfer station in the North Bronx and advancing the City’s efforts to export waste by rail.456DSNY Proposed Amendment of Solid Waste Transfer Station Rules. (2017). DSNY. NYC Government.

Through the public comments process, several interested parties, including the New York Botanical Garden and the New York City Environmental Justice Alliance, submitted written comments arguing against the proposed rule change. One of the comments stated that the presence of an existing railroad line adjacent to the park was a reason to limit further environmental burden on the area, rather than exacerbate it. Another comment suggested that siting a transfer station in the Bronx River Parkway could limit future beneficial uses for the park. Ultimately, the proposed amendment was adopted although the planned North Bronx transfer station was not built.”457DSNY Final Amendment of Solid Waste Transfer Station Rule. (2018). NYC DCAS. NYC Government. Although the Department considered the comments in making its determination, CAPA does not require the agency to make public how it considered such comments.

Community District (cd) Needs Statement

Community Boards are local representative bodies that act as the official liaisons between community residents and City agencies, and advocate for the residents and needs of their districts. Each Community Board comprises up to 50 non-salaried members and may employ other staff and consultants to fulfill its duties. Funds are allocated by the City to each board to cover staff salaries, rent, utilities and other administrative expenses. As part of each Community Board’s ‌responsibilities, the City Charter mandates the production of an annual Community District (CD) Needs Statement which identifies the funding priorities in each district and informs the City’s neighborhood and infrastructure planning.

The CD Needs Statement has three main components:

  • “Top 3” Pressing Issues section which highlights the most critical issues affecting the community district.
  • Policy Issue Areas section which identifies the most important issue within each of seven distinct policy areas: Healthcare and Human Services; Youth, Education and Child Welfare; Public Safety and Emergency Services; Core Infrastructure and City Services; Housing, Economic Development and Land Use; Transportation; and Parks, Cultural and other Community Facilities. The Policy Issue Areas section also includes agency-specific needs to help make the callouts more actionable.
  • Finally, the Needs Statement includes a prioritized capital budget request for City services and infrastructure investments that address local needs.458CD Needs Overview Handout. (2022). NYC DCP. NYC Government.

The CD Needs Statement development entails an engagement process to collect input from Community Board members and the public through surveys and dialogues, budget consultations with City agencies, and a drafting process to synthesize findings. A 2021 report published by The Future of Community Boards Working Group (a coalition of Community Board district managers and staff across the five boroughs) indicated that Community Board members sometimes may not have the adequate skillset needed to conduct surveys or assess issues across the policy areas and must rely heavily on their staff. However, Community Boards have not had a significant baseline budget expansion since 2014, making it difficult to hire additional staff.459The Future of Community Boards Report. (2021). Future of Community Boards Working Group. NYC Government. The report also expressed concerns about the working relationship between Community Boards and some City agencies, with some agencies limiting their participation in the budget consultation process.

In Some Cases, the Demographics of Community Board Members Do Not Reflect the Diversity of the Districts They are Representing. this Has Resulted in Instances Where the Interests of Community Boards and Environmental Justice Advocates are Not Aligned And, in Some Instances, Incongruous.

However, the Department of City Planning has made significant efforts to streamline the preparation of CD Needs Statements and support Community Boards throughout the process. Online materials including training videos, reference guides for developing budget requests, surveys for gathering input about CD Needs, and tips to strengthen submissions, are available on the DCP website. DCP has also invested in the development of the online CD Priorities platform to enable ‌Community Boards to submit Needs Statements in a timely and consistent manner that can be easily integrated into City agency planning460The Community District Needs Process. (n.d.). NYC DCP. NYC Government. Responding to feedback from Community Board staff, the agency subsequently made changes to make the platform more user-friendly, conducted training sessions, and provides a step-by-step user manual to ensure successful adoption of the platform by Community Boards.

A different challenge to the success of the Community District Needs Assessment as a tool for advancing environmental justice is rooted in representation; in some cases, the demographics of Community Board members do not reflect the diversity of the districts they are representing. This has resulted in instances where the interests of Community Boards and environmental justice advocates are not aligned and, in some instances, incongruous. Efforts to address this issue led to the 2018 City Charter revision which requires Borough Presidents to report on their diversity efforts to ensure that board members represent the demographics of their communities.461The Future of Community Boards Report. (2021). Future of Community Boards Working Group. NYC Government.

Uniform Land Use Review Procedure (ulurp)

New York City’s Zoning Resolution establishes an orderly pattern of development across the city by identifying what may be built on any piece of property.462What is Zoning? (2023). NYC DCP. NYC Government. Most proposed developments are designed to comply with the Zoning Resolution. However, land use actions requiring changes to zoning designations, area-wide rezonings, site selection for capital projects led by city agencies, and the sale, lease or exchange of City-owned land, are subject to an approval process.463Uniform Land Use Review Procedure. (n.d.). NYC DCP. NYC Government. ULURP is the standardized procedure whereby such actions are publicly reviewed and decided on. It is a crucial decision-making process as it plays a role in the distribution of environmental burdens and benefits The establishment of ULURP in 1976 reflected two trends underway in the 1950‘s and 1960‘s: the increasing involvement of the city‘s Community Boards in the development of the city and a substantial increase in community participation in many aspects of government.464Evolution of ULURP.(n.d.). NYC DCP. NYC Government

The Department of City Planning (DCP) ensures that all land use applications for changes to zoning regulations, the City Map, siting of public facilities, and grants of site-specific actions are complete before they are reviewed by the public. Once complete, relevant Community Board(s) and Borough President(s), City Planning Commission, City Council and the Mayor weigh in on these land use applications. As part of the Community Board(s) and City Planning Commission reviews, public hearings must be held to receive community input that informs their recommendations and decisions.465Uniform Land Use Review Procedure (ULURP). (n.d.). NYC DCP. NYC Government.

Community Boards (CBs) are required by the City Charter and the City Administrative Code to conduct monthly public hearings except in July and August, provide adequate public notice ahead of such sessions, and maintain websites accessible for non-English speakers and persons with disabilities. The City Planning Commission’s (CPC) public meetings are generally held at the same location twice monthly on Wednesdays. In response to the COVID-19 pandemic, CBs and CPC have adopted virtual meetings which have improved accessibility to public hearings. CPC shares information about upcoming public meetings with links to virtual meetings on NYC Engage, the City’s central public engagement website. CBs maintain individual websites and sometimes post information about upcoming hearings. Public comments can be provided orally during hearings or as written submissions.

A 2021 report by The Future of Community Boards Working Group comprised of staff from CBs across the city stated that zoning rules and ULURP applications are often very complex and CB members may not have the necessary knowledge to navigate the process or support their residents in understanding matters under deliberation.466The Future of Community Boards Report. (2021). Future of Community Boards Working Group. NYC Government. Stakeholder feedback from focus groups, interviews and informal conversations conducted ‌as part of this evaluation shared similar sentiments that proposal documents and evaluations of environmental impacts prepared pursuant to the State Environmental Quality Review Act are often hundreds of pages long and written in technical language that makes public participation difficult.‌

The City has made efforts to support CBs in better engaging their residents and participating in ULURP through the Civic Engagement Commission (CEC) which provides support and training to CBs related to community engagement and parliamentary procedures.467CEC Annual Report. (2022). NYC Civic Engagement Commission. NYC Government. Past CEC workshops for CB members have covered Land Use and Equity Planning, Public Engagement, and Fair Housing, among other topics.468Community Boards Training. (n.d.). Civic Engagement Commission. NYC Government. DCP also makes filed land use application materials available online to increase transparency and public access.469ENDNOTECOPY

In addition, the ‘Get Stuff Built’ plan, released in 2022 to streamline and improve the City’s land use and permitting approval processes, identified opportunities to improve public participation for ULURP. These include amending the application process to file materials earlier, providing advance notice, and providing additional time for CBs and the public to review the extensive proposal documents. Other recommendations include allowing members of the public to subscribe to automatic notices for applications in a specific area and exploring the inclusion of SMS notifications in addition to email notifications. Subscribers would be notified when an application is filed in their subscribed Community District.470Get Stuff Built: A Report of the Building and Land Use Approval Streamlining Taskforce. (2022). NYC Mayor’s Office. NYC Government.

Public Engagement That is Not Legally Required

In addition to the formal public processes conducted under legal mandate, the City engages the public in many decision-making processes without being legally required to do so. Some illustrative examples are presented below; this list is not exhaustive.

Permanent Affordability Commitment Together (pact)

Initiated in 2018, the Permanent Affordability Commitment Together (PACT) program allows public housing developments to be converted to Project-Based Section 8, by including developments in the federal Rental Assistance Demonstration (RAD). This allows NYCHA, and partners selected by resident leaders, to unlock funding to complete comprehensive repairs, while also ensuring homes remain permanently affordable and residents have the same basic rights as they possess in the public housing program.471PACT Projects. (n.d.). NYCHA. NYC Government.

The federal RAD program has minimum requirements for resident engagement set by HUD. NYCHA’s engagement and planning process follows these requirements at a minimum but the agency has also created formal processes for resident input and partnership.472NYCHA Establishes PACT Resource Team to Facilitate Resident Involvement in PACT. (2022). NYCHA. NYC Government. Residents share their priorities for areas of investment in their community and form official Resident Review Committees to review project proposals, interview potential partners and select the partner team.

As a baseline, the agency provides relevant information on resident rights and responsibilities, employment opportunities under PACT, and sample residential leases for the program in multiple languages including Spanish, Chinese, French, and Russian. In February 2022, the agency established a community-based Resource Team to facilitate resident involvement in the PACT conversion process. Partner organizations include Local Initiatives Support Corporation (LISC NYC), Public Works Partners, Public Policy Lab, and Pratt Institute. The PACT Resource Team’s stated objective is to “provide NYCHA residents and resident leaders with invaluable support that helps inform, organize, and empower their involvement in the PACT planning process.473ENDNOTECOPY

‌new York City is Home to an Expansive Network of Knowledgeable, Energetic, and Dedicated Community Leaders Who are Improving Their Neighborhoods and Organizing to Address Interconnected Quality of Life Issues Across the City.

Nyc Streets Plan

In 2021, the Department of Transportation (DOT) published its latest planning document which outlines the agency’s framework for selecting and implementing solutions to improve New York City’s streets, public realm, and transportation. Notably, the plan established an equity-focused model for prioritizing transportation investments. The model uses three indicators in its assessment of investment priority: proportion of non-white and low-income residents, job and population density, and level of prior investment, with the race and income indicators given a combined 50 percent weighting. It serves as a blueprint for other agencies seeking to prioritize EJ communities in investment decisions.

The Streets Plan was developed in part through a robust public engagement and input process that included online activities and surveys, public workshops and small group discussions, telephone polling, and accessibility focus groups. Over a six-month period, 12,500 people provided input through the online platform, 1,260 people participated in telephone polling, and over 600 New Yorkers attended the workshops.474NYC Streets Plan (2021). Department of Transportation. NYC Government. This process was facilitated by the DOT Streets Ambassadors who meet New Yorkers where they are: on busy streets, in movie theaters, churches, and parks.475Beyond the Workshop: NYC DOT Street Ambassadors. (2017). NYC DOT. NYC Government. Neighborhoods with low participation in the online surveys were also engaged through telephone polling. By going beyond the traditional form of engagement and adopting a multichannel strategy, DOT reached a wide range of people and obtained input that is more representative of the needs of New Yorkers.

Neighborhood Planning

In 2014, the City established the Housing New York Plan to outline strategies for preserving and creating affordable housing units and engage communities in a comprehensive planning process to strengthen neighborhoods and foster socio-economic development.476NYC Neighborhood Planning Playbook. (n.d.). NYC HPD. NYC Multiple City agencies are involved in these efforts including the Department of City Planning (DCP), Department of Housing Preservation and Development (HPD), and Economic Development Corporation (EDC), among others. Since the adoption of Housing New York, these agencies have led interactive Community Visioning Workshops to bring residents, elected officials, community-based organizations, and other government agencies together to develop strategies for delivering affordable, quality housing, and has produced numerous site-specific predevelopment plans and almost a dozen neighborhood plans in mostly EJ Areas.477Neighborhood Planning. (n.d.). NYC HPD. NYC Government. Two notable examples are the East New York Neighborhood Plan (Brooklyn) and the Resilient Edgemere Community Plan (Queens).

East New York is a low-income community with a predominantly Black and Hispanic or Latino population with 66 percent of renter households spending over 30 percent of their income on housing as of 2015.478East New York Community Plan. (2015). NYC DCP. NYC Government Consequently, through an extensive community planning process involving visioning sessions, report- back events, and town halls, DCP developed the East New York Neighborhood Plan and rezoning proposal.479East New York Community Plan. (n.d.). NYC DCP. NYC Government. The plan’s goals include preserving and creating affordable housing, promoting growth and economic development, and investing in community resources and infrastructure. A key outcome of the planning process was the identification of a city-owned parcel within the rezoning area that would be a suitable site for new affordable housing.

‌Participants discuss future visions for Edgemere during the “Create” workshop.

Following the approval of the Neighborhood Plan and rezoning in 2016, Community Visioning Workshops were held to identify community priorities and gather ideas for future development at the city-owned Dinsmore-Chestnut parcel in East New York. Findings from the community workshops included the need for different affordable housing types, cultural and active recreation facilities, and affordable commercial spaces. A report containing the workshop findings was included in the RFP released by the agency for developers.480Dinsmore-Chestnut Community Visioning Workshops Report. (2016). Housing New York. NYC Government. As a result, the now completed Chestnut Commons is a 275-unit affordable housing project with units reserved for individuals and households between 20 and 80 percent of the area median income (AMI) and 55 units designated for formerly homeless New Yorkers. The building also features a community center, solar roof, rooftop garden and an on-site composting system that generates fertilizer.481Chestnut Commons Debuts At 110 Dinsmore Place in Cypress Hills, Brooklyn. (2022). Morris, N. New York YIMBY. News Article.

Edgemere, a neighborhood on the Rockaway Peninsula that is largely comprised of Black and Hispanic or Latino residents, was devastated by Superstorm Sandy and continues to face extensive flooding due to frequent and intense storms and sea level rise. To address these issues and drive investment to the neighborhood, the HPD launched the Resilient Edgemere Community Planning Initiative in 2015 to define neighborhood climate resilience, urban development goals, and identify concrete strategies to meet these goals in collaboration with Edgemere residents. The result of the initiative was a Community Plan that outlined projects to help “protect the neighborhood ‌from flooding” and “create resilient housing and maintain the low density feel.”482Resilient Edgemere Community Plan. (2017). NYC HPD. NYC Government.

While many of the planned outcomes of the Resilient Edgemere planning process have been welcomed, some residents expressed concern over the portion of the rezoning effort that sought to facilitate the development of mid-rise buildings with affordable housing. Community Board (Queens CB-14) voted to reject the rezoning plan stating that “the plan would add too many apartments to a low-rise residential area and strain local roads and infrastructure.” Conversely, the Borough President recommended approval of the land use actions. In July 2022, the City Council approved the Resilient Edgemere Community Plan and rezoning application which included a $14 million investment to raise the shoreline, $2.3 million towards sewer and drainage infrastructure upgrades, and the development of over 500 new affordable homes.483Mayor Adams Celebrates City Council Passage of Resilient Edgemere Community Plan (2022). Mayor’s Office. NYC Government This is in addition to several investments that have been made since 2017 including $25 million installation of new sewer infrastructure, over $50 million street and sidewalk infrastructure upgrades, as well as building rehabilitation and raised elevation for over 100 homes.

The mixed response to the rezoning efforts in the Resilient Edgemere Community Plan demonstrates the complexity of building consensus for all aspects of a neighborhood plan while supporting broader citywide needs such as the need to increase the supply of resilient and affordable housing. Still, it is important to note that neighborhood planning does not stop when land use actions are adopted. In the case of Edgemere, community planning will be part of the development of new HPD housing projects, including the pioneering of a Community Land Trust. Since the creation of the East New York and Edgemere neighborhood plans, the City has sought to build on lessons learned to improve neighborhood planning efforts. In 2023, the Department of City Planning announced the creation of a new Community Planning and Engagement division that is intended to center community voices in all planning work.484NYC Planning Agency Adds New Division for Community Engagement. (2023). NYC Planning. NYC Government.

Qualitative Research Findings

New York City is home to an expansive network of knowledgeable, energetic, and dedicated community leaders who are improving their neighborhoods and organizing to address interconnected quality of life issues across the city. This leadership in the EJ movement is found from the hyper-local, neighborhood scale to citywide and regional scales, and is present in both formalized leadership roles (such as those at community-based and not-for-profit organizations, civic associations, and community boards), as well as informal roles (such as block leaders, classroom leaders, and local volunteers). They range in age from high school students to retired adults and are as diverse as the city itself. Through their persistence, these leaders and their communities have achieved considerable success in improving EJ and quality of life issues.

Interviews and focus groups included 42 New Yorkers living or working in EJ communities from across the five boroughs about the challenges they face regarding environmental injustices, how they are managing these issues, and what their experiences have been in engaging with the City’s related programs and decision-making processes. Furthermore, 992 New Yorkers responded to a survey developed by MOCEJ and the EJ Advisory Board, and distributed by six CBO partners, about their participation in local civic and environmental matters through a survey. Additional details on the scope and methodology of this research can be found in the Qualitative Research Methodology (p. 206) in the Appendix.

Throughout these conversations, the following themes emerged:

  • EJ issues are interconnected, have cumulative and compounding effects, and are rooted in and exacerbated by social and economic disparities;
  • Participating in decision-making processes in New York City today, a critical element in addressing EJ issues, requires excessive amounts of unpaid labor; and
  • New York City government’s past and current public engagement processes can feel disingenuous and perpetuate distrust in government.

Key Findings

Ej Issues are Interconnected.

EJ communities experience multiple interrelated issues at once, which are often rooted in and exacerbated by social and economic disparities. The most cited issues affecting participants of the focus groups and interviews include the following:

  • Poor housing quality, including indoor air quality, pests, and general maintenance conditions
  • Poor outdoor air quality, including pollution from nearby motor vehicles, power plants, and factories
  • Climate change impacts, such as flooding and extreme heat
  • Exposure to hazardous materials, including lead, oil spills, construction, and contaminated sites
  • Trash, including litter and illegal dumping, collection, and recycling access
  • Lack of access to fresh food and nutrition
  • Lack of access to parks, waterfront spaces, and other public spaces

For households in EJ communities, these issues are experienced simultaneously and can have compounding impacts. These impacts are connected to both physical and mental health, education outcomes, housing stability, financial security and economic opportunities, resilience to extreme weather events and other shocks, and overall quality of life. For example, for one focus group participant living in Washington Heights, several members of their household developed asthma while facing regular exposure to air pollution from traffic on the adjacent George Washington Bridge. Members of this household also experienced severe cases of COVID-19, made worse by their underlying respiratory health conditions. This young participant also cited obstacles to safely reaching nearby green areas due to traffic and pedestrian safety issues, as well as drug use in public spaces preventing their safe enjoyment.

Addressing the issues raised by participants require both immediate action (such as removal of lead paint indoors) and long term, systemic investments (such as reducing polluting vehicular traffic citywide). Stakeholders noted that City government responses can be reactive to the immediate manifestation of the issue, uncoordinated across agencies, isolated, and/or not designed for long-term sustainable change. In other cases, stakeholders felt that City government responses are restricted to large-scale capital improvements which require years of planning, design, and construction processes before their benefits are felt. One focus group participant in Coney Island, a NYCHA resident, shared “They do try to put programs in the community, but the construction going on all at one time with everything else out here is too much,” in reference to Hurricane Sandy recovery and improvements. This resident also described multiple struggles in their home from maintaining consistent access to utility gas to keeping the home free of soot deposits from the area’s worsened air quality.

Furthermore, both focus groups and interviews identified stark and visible disparities in City services and investments across New York City neighborhoods which also represent pressing EJ issues.

Active Public Engagement Involves Uncompensated Labor.

As stated in the previous section, people in EJ communities face an array of environmental, economic, and social issues at once, often related to basic quality of life needs. Each of these issues demands time and energy. Whether it is a household tackling disease due to the presence of lead paint, mold or pollution; trying to regain access to a safe and stable home after a storm; or voicing concerns over a neighborhood issue; resolving these matters requires extensive organizing acrobatics, all while coping with the issue itself.

This uncompensated labor can involve:

  • Participating in government programs and public engagement processes;
  • Interpreting and navigating information that is written in inaccessible language;
  • Coordinating across agency silos;
  • Navigating local and hyperlocal politics (including elected officials, community boards, and influential Community Based Organizations or CBOs);
  • Engaging with the media to amplify their issue and get the attention of City leadership;
  • Organizing among community and neighbors; and
  • Identifying and chasing down the right contacts and information that can help with an issue.

Stakeholders felt that even in formal public engagement processes, participation is time- and labor-intensive. First, it may be difficult to find information on these events. Where agencies are advertising them is often separate from existing local networks where residents get their information, such as CBOs, Parent-Teacher Associations (PTA), local colleges, faith-based institutions, and local elected officials. This finding was reinforced in our survey responses, in which a majority of respondents reported they learned about opportunities to participate in decision making through both traditional announcements and through neighbors and organizations they belong to. Specifically, respondents shared that they learn about these opportunities primarily from: flyers posted in public places (14 percent); social media (14 percent); neighbors (13 percent), newsletters (13 percent); TV, newspaper, and advertisements (12 percent); and community groups (12 percent). Ten percent of respondents reported that they do not learn about opportunities to engage with the City about decisions being made in their neighborhood at all. More than one third of respondents identified as belonging to one or more community groups, with 15 percent belonging to a religious organization, 11 percent belonging to volunteer organization, and 10 percent belonging to a tenant organization.

“i Get Overwhelmed by Them, You Know, and It’s Kind of My Job to Participate in Them. I Do Think for an Average Community Person, It’s Just Particularly Overwhelming to Keep Track of What Each Meeting is About, Especially Since There’s Such Huge Gaps Between Meetings and It’s Not Clear What’s Happening with Them.”

A Bright Spot

Focus group and interview participants affirmed that resources to support capacity building and leadership development are the most effective means of advancing environmental justice. Resources like grants and political trainings empower communities to self-organize and participate in decision-making, enabling them to advocate for neighborhood improvements more effectively. People appear able to self-organize and fill gaps in services when they can access financial resources (e.g., grants and other direct funding programs) and access political power (i.e., elected officials) most effectively.

Relatedly, WE ACT for Environmental Justice (WE ACT) will receive at least $10M over the next five years to support capacity-building and training in EJ communities across EPA Region 2 (including New York and Jersey). The funding comes from the US EPA’s Environmental Justice Thriving Communities Technical Assistance Centers (EJ TCTAC) Program, granting funds to establish nationwide centers supporting communities with EJ concerns. The centers will focus on guiding communities in grant proposal writing, navigating federal systems, managing grant funding, and conducting effective, inclusive community engagement.

It is worth noting that local leaders tend to be interested in holistic improvements to quality of life, therefore community EJ leadership and civic engagement can also be supported through non- environmental programs.

“…I received the grant and then that’s what I did with the grant money. I bought cleaning things and got the Girl Scouts, Boy Scouts, and a lot of local people. And we just cleaned the buildings, wiped them down as much as we possibly could ‘cause it’s overwhelming, to get rid of the soot that we’re inhaling every single day.” —FOCUS GROUP INTERVIEWEE LIVING IN A NYCHA DEVELOPMENT WHO EARNED A GRANT THROUGH THE CITY’S LOVE YOUR BLOCK PROGRAM,

“A program that I participated in was a teen art collective within the Bronx Museum… And I feel like that experience was pivotal in shaping who I am today. It allowed me to be expressive and be open about my cultural background without fear of judgment, because we were able to run our own collective and display our art based on our cultures and identity.” — FOCUS GROUP INTERVIEWEE WORKING AT GREEN CITY FORCE, A CITYWIDE ORGANIZATION FOCUSED ON TRAINING YOUNG LEADERS TO POWER A GREEN AND INCLUSIVE ECONOMY

Relatedly, stakeholders noted that City agencies may hold stand-alone public engagement events, instead of integrating engagement into meetings that residents are already attending. This requires making arrangements to attend separate meetings, adding to the time burden.

A few interviewees and focus group participants mentioned feeling planning fatigue, as there are so many processes and meetings to attend. “I get overwhelmed by them, you know, and it’s kind of my job to participate in them. I do think for an average community person, it’s just particularly overwhelming to keep track of what each meeting is about, especially since there’s such huge gaps between meetings and it’s not clear what’s happening with them.” Stakeholders noted that it often felt as though agency staff had not reviewed previous inputs (or previous plans, website content, or reports) from CBO participants, requiring community attendees to start from scratch, sharing their issues and ideas multiple times to different agency staff.

Community-based organizations in EJ Areas also provide extensive unpaid services to help fill the gaps in providing information when City staff and contractors are not fully meeting community needs. This work is often unfunded, even as other organizations are paid to provide these services in certain areas through City contracts. This includes services related to outreach and education around City initiatives such as composting, and social services, to name just a few.

Funding from the City to provide these services would allow these organizations to hire people in their communities, build upon existing relationships and trust, and make use of and develop the local expertise that could best meet their communities’ needs. However, the administrative bar to compete for these contracts is often too high for local organizations to meet. City procurement can be complicated and expensive, with processes and requirements geared for larger, higher-resourced citywide organizations or private- sector firms, resulting in missed opportunities for community investment, local capacity building, and efficient, on-the-ground impact. Instead, according to the interviewees, these contracts tend to go to “white-led, highly funded organizations that often have government connections.”

One interviewee noted that smaller firms with community connections face similar challenges to those of CBOs, especially Minority and Women- owned Business Enterprises (M/WBEs). M/WBEs tend to lack capacity to lead or sometimes even bid on large City Requests for Proposal (RFPs), with onerous application processes, inconsistent payment schedules, and time-consuming administrative requirements such as regular reporting to the City.

Interviewees mentioned the need to create new procurement models through which community organizations can partner with agencies to facilitate higher services levels, such as helping to clean up “blighted” land or educate residents on City initiatives. This would help to build capacity at the community level, while compensating and valuing CBOs for their critical work.

Public Engagement Processes Can Feel Disingenuous and Cause Distrust in Government.

Stakeholders feel that City public engagement processes are not consistently designed or implemented to meaningfully capture and act upon community input. The effect, stakeholders believe, can perpetuate an existing lack of trust of government. Many of the interviewees and focus group participants noted that engagement processes often seem designed to “check the box”, leaving the impression that the City already knows what it plans to do and does not intend to incorporate community input in a meaningful way, especially if it differs from the predetermined outcome. Many respondents to the survey shared these sentiments, with a majority (52 percent) of respondents disagreeing with “The City asks me about what matters most to me and my community,” and nearly half (49 percent) disagreeing with “Input is welcomed and encouraged by the City.” To many participants, the City’s engagement efforts feel performative and disrespectful of participants’ limited time and energy. Relatedly, interviewees noted that the right people are often not at the table, partly due to ineffective outreach and inconvenient meeting logistics. When community members do show up, they experience project presentations that use too much jargon and leave too little time for meaningful input. Finally, those who invested their time in attending and participating in these planning processes are not seeing their input show up in final plans and decisions. As a result, they do not feel the City is valuing their input. This can reduce the motivation to participate in future planning processes.

Both the EJ leaders and community members who participated in the interviews and focus group sessions provided suggestions to improve these processes. They suggest designing engagement processes with community leaders who can help identify existing meetings and opportunities to engage with individuals where they are (as opposed to scheduling separate meetings that require additional investments in time) and to help translate the content to be accessible, emphasizing what is relevant to residents. They also would like to see greater transparency and accountability; for example, information on how their feedback is going to be used, how decisions are being made, and how local expertise is being valued during the process. Many also mentioned the need to “put the thumb on the scale” to give greater weight to the voices from overburdened and often ignored communities during decision- making processes. Participants note that this would help to address the history of, and continued belief that, “the loudest and most well-resourced voices get accommodated as they have the ability to participate so heavily in the process.”

A Bright Spot

Through these challenges, residents of EJ communities are encouraged to remain engaged in City decision-making processes when they see action taken on their issues, including neighborhood improvements (such as parks and green spaces), and greater diversity amongst City staff who are more representative of their communities.

Further examples of City action which have given participants encouragement to remain involved include:

  • Agencies such as the Department of Health and Mental Hygiene (DOHMH), Department of Transportation (DOT), and Department of Cultural Affairs have directly connected with CBO staff for partnership in engagement and have contracted with them for community organizing. This showed effort of collaboration, recognizing the value of CBOs, and incorporation of input from the community.
  • The Mayor’s Office of Environmental Remediation (OER) has a long history of working with CBOs such as UPROSE, who have provided trainings to educate OER staff on how to effectively work with communities. OER staff have responded by making it easy for CBOs to access resources and tools, and they have been effective partners.
  • Many participants noted the accelerated electrification of the municipal fleet as a win for environmental justice.
  • New CBO partnerships have been forged with the New York City Economic Development Corporation (NYCEDC) around community based solar and task forces for the reactivation of South Brooklyn Marine Terminal and neighboring Sunset Park properties. For example, the Executive Director of UPROSE, Elizabeth Yeampierre, serves as co-chair of the NYCEDC’s inaugural Offshore Wind Advisory Council.

“…what’s propelling me to get back involved… I will say, I have noticed a difference in outreach, how the City is sending different people out that is more representative of the community. And I think that helps a great deal. And I think even with our current elected official, our Councilwoman, she’s from the community.” —FOCUS GROUP PARTICIPANT AFTER SHARING A BRUISING EXPERIENCE PARTICIPATING IN A LONG-TERM COMMUNITY PLANNING AND LAND USE PROCESS STEMMING FROM HURRICANE SANDY RECOVERY

The City hopes to build upon these successes in the future through the development of the EJNYC Plan.

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