Solidarity with Beniteau WHEJAC Public Comment

November 18, 2021

White House Environmental Justice 
Advisory Council Public Meeting
Public Comment

This written comment is submitted in addition to my spoken comment made during the WHEJAC public meeting on November 17-18, 2021. Details around this issue are changing rapidly so this comment reflects what I am aware of as of November 18, 2021.  

I would like to thank the White House Environmental Justice Advisory Council for this opportunity. I would also like to recognize the environmental justice communities across the country and their righteous appeals to this body. I also want to reflect and lift the commenters from Flint; the latest victims of the discrimination and injustice inherent in the state of Michigan’s air quality permitting process and the Michigan Department of Environment, Great Lakes and Energy, or EGLE.

My partner, our 3 young children and I live on the eastside of Detroit. Our house is in what is referred to as the ‘impact area’ of the newly expanded and massive Jeep Stellantis Detroit Assembly Complex. I am also an organizer with Detroit People’s Platform and have been working with my neighbors on Beniteau Street, who live in closest proximity to the plant.

While my family and I live only blocks away from the plant and are impacted by the expansion, I’m presenting here to support the efforts of my neighbors on Beniteau. It is my belief that if the impact of this site is adequately mediated and remedied for those living right up on the complex, my family and everyone living around the plant will benefit.

Since the expansion was announced in early 2019, EGLE has hosted 3 public hearings and approved 2 air quality permits. My neighbors and I, along with advocates and experts have participated in each public hearing EGLE has hosted. 

During these hearings a primary concern, repeated through the public comments is the extreme asthma hospitalization rates in the zip codes around the site. Experts called for environmental, economic, and public health impact assessments to be completed before making a decision. Others called out the environmental racism inherent in moving ahead with the expansion in a nonattainment zone for ozone by decreasing emissions at a suburban plant to offset the increase in our 94% African American, majority Black backyards

A recent letter to EGLE from elected officials noted that EGLE was aware of a high level of preexisting respiratory conditions in the area before granting permits to the company. Solid data, emotional pleas, and righteous outrage were shared but couldn’t be heard. EGLE considers air quality permits in a vacuum and by doing so makes the residents most impacted invisible. EGLE’s website reads “Comments EGLE can consider include technical mistakes, grammar and spelling mistakes, other rules that should be considered, and other items which should be included or removed.” Further, and more to the point, “Some issues EGLE cannot consider include popularity of the action, emission sources that are not part of the action, indoor air pollution, traffic, hours of operation, noises and lighting, and zoning issues.”

This is where EGLEs inherent race-problem perpetuates itself. How is it possible for our state regulators to protect frontline or environmental justice communities they can’t see or hear? The parameters they have established to make their decisions also become the justification of their abuse. They can’t consider the national study linking long-term exposure to air pollution and COVID-19 mortality. They can’t consider that in the U.S., Black children suffer disproportionately from asthma, and are seven to eight times more likely to die of asthma than white children. The fact that communities of color face nearly 40% more exposure to toxic air pollution than white communities is not just lost on EGLE, it can’t be heard. 

The new Jeep Grand Cherokee L went into production this summer and residents have reported an increase in odors and health issues since. EGLE has issued multiple violations that stem from their having to respond to resident complaints. Being overwhelmed by paint fumes, burning eyes, itchy throats and headaches, Beniteau residents have been calling the state’s Pollution Emergency Alert System (PEAS) hotline.

On Monday, September 20, 2021 EGLE filed a violation notice against Stellantis. A second air quality violationwas issued on Monday, October 14th. On Wednesday, November 3rd a third Violation was issued against Stellantis’ Mack Assembly Plant. These violations and the subsequent engineering issues uncovered in the process have not been adequately responded to by EGLE or Stellantis. Jeeps continue to roll off the line and as this statement is being prepared, fumes can still become overwhelming on the street. Residents continue to call in with complaints.

The fact that they are being made to live through violations and over-exposure has led many residents to believe that EGLE exists only to facilitate the operation of polluting industries rather than to protect the most vulnerable and disproportionately impacted in Michigan. 

Earlier this month, on November 8, 2021, my neighbors on Beniteau filed a Title VI Civil Rights complaintagainst EGLE with the EPA. The complaint focuses on the racial disparities in the state’s permitting process and details the impact of EGLE’s decisions on the residents who live closest to the plant. “When my eyes start to burn, I start to become more afraid of all the things I can’t smell than those that I can” one of my neighbors shares in the complaint. 

Another neighbor on Beniteau shares “The migraine headaches, and the burning in the eyes, and tightness in my chest… I just know when I’m out too long, I get that way, but I can’t say today is going to be worse than tomorrow. I know yesterday it was just too much. I was crying.” I am also submitting the full Title VI complaint with this comment. I encourage council members to read these stories from residents who have been greatly impacted by the failure of state regulators.  

The complaint states that: “[t]he decisions by Michigan’s Department of Environment, Great Lakes, and Energy (EGLE) allowing Stellantis to significantly expand its facilities continues the discriminatory legacy of requiring communities of color to bear the disproportionate burden of the industrial pollution generated by all of society. Unfortunately, the Stellantis Complex (“Facility”) does not exist in isolation.”

Last Minute Update: Based on public pressure building around the violations and the Title VI Civil Rights complaint on November 18, 2021 EGLE issued a press release stating that they were going to fine Stellantis. While a step in the right direction, the statement is extremely non-committal. 

Residents’ current post-violation needs include:

  • Immediate emergency relief including but not limited to emergency housing, windows, roof repair, weatherization, HVAC improvements, air purifiers, filters, public education, medical and health services. 
  • Remedies that include an “out of the box thinking” Supplemental Environmental Plan (SEP) that adequately responds to resident need for home repair, voluntary relocation and others based upon individual assessment.
  • Rapid response through a fast-tracked enforcement process with EGLE and the EPA on the Title IV Complaint.
  • Environmental, health and economic impact assessments must be conducted to determine the most impacted and most vulnerable. Residents have requested individual assessment to determine what will be needed to make their homes safe to live in or for successful voluntary relocation. Assessment, which was not included as part of the permitting process, is essential to correcting course and determining adequate remedies.  It is also vital that assessment be considered as part of EGLEs ‘job’ and not as a remedy. Assessment is a tool to be used to determine remedies.

To conclude, we live in a majority Black city that has been subject to the suspension of democracy through emergency management and economic restructuring through municipal bankruptcy. In Detroit we see violence against Black bodies, families and communities show up every day in public policy and decisions made by those in power. 

Detroiters have witnessed this through mass water shutoffs, mass foreclosures and evictions, and through a massive redistribution of public wealth and resources into the hands of developers that are predominantly wealthy and white and to global corporations like Ford and Stellantis. 

The fact that decision makers and regulators approved this project based upon economic promises and flawed engineering models rather than the environmental, health and economic impacts of those most directly impacted has led to this situation; Detroiters are being made to live in and through violation after violation. 

I ask your support in addressing the injustice inherent in the states’ permitting process and in pushing for relief and remedy for Beniteau residents and anyone whose air quality and quality of life has and is being impacted by these failures. Again, I would like to thank the White House Environmental Justice Advisory Council for this opportunity. 

Michigan Environmental Justice Confrence Day One

I’m attending the 3 day Michigan Environmental Justice Conference hosted by the Michigan Department of Environment, Great Lakes and Energy. I’ve been posting some of my responses and observations here.

There has been a great deal of emphasis on a new data tool from EGLE called the MI EJ Screen. This is a state-based version of the EPAs EJ Screen that provides data on polution, populations and public health. This afternoon I attended a presentation on this technology.

Data tools like the new MI EJ Screen are very impressive for the amount of information that can be accessed and shared. Our community on the East Side of Detroit has used tools like these, the EPA’s EJ screen for example, in our work attempting to address inequities inherent in the new Fiat Chrysler, now Stellantis plant expansion.

We’ve used data collected to make arguments for reduction of emissions, increased monitoring, better buffering, and to make the case for environmental justice at large for our residents who live in the shadow of the first new auto assembly line to be built in Detroit in over 40 years.

Before COVID-19 we were able to share this data and other public health information with our neighbors by attending and hosting regular community meetings, through canvasing and informative flyers that have been well received and increased the awareness of how air quality impacts our quality of life.

Our neighbors have responded by becoming more active, with large numbers attending and speaking out at EGLE public hearings, with the circulation of petitions submitted to local, state and federal representatives, EGLE and Fiat Chrysler themselves. While we do not know the level of engagement with EGLE in the rest of the state we believe that our efforts have dramatically increased participation and advocacy around this project.

While access to data as available through the EJ screen has supported our efforts to increase public education of the impact of pollution on our quality of life and has increased engagement and participation in EGLE’s permitting process it is challenging not to think that it is all in vain based on the outcomes for our neighborhoods.

All of these efforts have been met with a permitting process and with state policy that discards the reality of the data shared and the research done. The decision making conducted by EGLE puts the project seeking a permit in a vacuum that does not and apparently cannot access the data that the MI EJ screen makes available to the public.

Just last week, after two years of hard work by residents struggling to be heard, EGLE approved yet another air quality permit for Fiat Chrysler/Stellantis. They did so without considering resident voice, heart-rending stories shared in public comment, or hearing what it is like to live next to a massive industrial facility already under construction. They did so without recognizing our so-called “frontline” “environmental justice” community that is 90% majority Black and poverty ravaged. Without considering that we were in the midst of multiple public health crises beforeCOVID-19.

The 17 principles of Environmental Justice created by delegates to the First National People of Color Environmental Leadership Summit held in 1991 demands the right to participate as equal partners at every level of decision-making, including needs assessment, planning, implementation, enforcement and evaluation.

While tools like the EJ screen and other data sharing technologies increase awareness, until the permitting and regulatory hands of EGLE are connected with the data collection hands of EGLE, I cannot see how it will be possible for environmental justice to be found here on the East Side of Detroit or anywhere else in the state of Michigan.

Until there is a paradigm shift and EGLE changes their permitting process to consider public health, cumulative impacts and considers their decisions impact on quality of life for residents these tools don’t equal justice for frontline communities. Until they actually can hear residents and use the very tools they are creating these efforts are mere motions.

For now, tools like the MI EJ screen only to serve as means to increase awareness of how much damage is being done rather than their being used to support solutions or address the inequities inherent and rampant in industrial development.

Sidebar: This is the most frustrating thing I’ve experienced in a minute. Last week, EGLE approved the FCA/Stellantis paint plant in our back yard. Now I get to hear about ALL they are doing for frontline communities. As far as I’m concerned, as long as they continue to put their permit approval and regulatory processes in vacuums that neglect the reality of the people impacted my their decisions we will get nowhere.

EGLE Air Quality Public Hearing March 16th

Please note that the public hearing period for this permit has been extended to Friday March 26, 2021

FCA/Stellantis – Chrysler is making changes to the proposed installation of a new paint line and changes to existing equipment at their Jefferson North Assembly Plant.and we want FCA to reduce facility emissions more with improved air pollution control technology and by using new rather than refurbished equipment

Residents who will be most impacted by this poor air quality call for EGLE and FCA to increase protections for residents by more funding for home repairs for frontline residents on Beniteau and to install filters on public spaces like schools, public housing and libraries.

Due to these changes the Michigan State Department of Environment, Great Lakes and Energy (EGLE) will be holding another public comment period until March 22nd and a virtual public hearing on March 16th for the community to weigh in.

In order to hold FCA accountable we want the following commitment from the State:

  • That FCA will be required by the State to continue to improve source monitoring and require additional record keeping from FCA.
  • That FCA will be required by the State to make sure this data is open and available and easily accessible to residents and others in the public such as through a web portal or app.

Register for the EGLE Info Session and Public Hearing on Tuesday March 16th at 6pm http://bit.ly/EGLEFCApaint

Please submit comments on this permit before March 26, 2021

  • Email a public comment: EGLE-AQD-PTIPublicComments@michigan.gov
  • Mail a public comment: EGLE, Air Quality Division, Permit Section, P.O. Box 30260, Lansing, Michigan 48909- 7760.
  • Call and leave a public comment: Voicemail: 517-284-0900

CBA Resource Guide

What is the community benefits approach?

Major energy development and infrastructure projects provide significant opportunities, as well as challenges, for local communities. Although they often create new jobs and economic growth, they do not automatically result in sustained, local economic benefits. Increasingly, state and local governments and communities are looking for tools that help build sustained benefits to host communities.

The DOE Office of Minority Business and Economic Development (MBED) supports the nation’s energy goals by fostering entrepreneurship, innovation, and job creation for diverse communities in the high-growth energy sector and in DOE programs and research opportunities. MBED develops tools and resources to increase diverse participation in the energy economy, drive American innovation, and increase America’s competitiveness.

These materials are intended to provide information to communities and state and local governments on Community Benefit Agreements (CBAs) and how to bring them to fruition.

Crains: Duggan: ‘We gotta clear’ more land for new factories

Read the full article: https://www.crainsdetroit.com/detroit-homecoming/duggan-we-gotta-clear-more-land-new-factories

Speaking at the opening night of Detroit Homecoming, Duggan touted the city’s success in assembling more than 200 acres for Fiat Chrysler Automobiles to get the automaker to invest $2.5 billion in two auto plants that will bring nearly 5,000 new jobs to the east side.

The fast-tracked project has spurred interest from FCA suppliers to locate in Detroit. Dakkota Integrated Systems plans to build a 600,000-square-foot parts plant that will employ another 625 workers on the former Kettering High School property along Van Dyke Avenue in a deal that was orchestrated by the Duggan administration and the Detroit Economic Growth Corp.

“We know that if we can deliver quickly, cut through the bureaucracy, get the permits done quickly that we’ve got the workforce here that wants to work hard and be trained — and we think that’s the formula,” Duggan said. “And now I just have to assemble some more land.”

“We gotta clear it,” the mayor added in an on-stage conversation with KC Crain, publisher of Crain’s Detroit Business, which produces the annual Detroit Homecoming gathering of former metro Detroiters.

The mayor’s office emphasized the land assemblage for new manufacturing developments will come from land already zoned commercial and industrial, not residential neighborhoods.

At Detroit Homecoming VI’s opening dinner at the historic State Savings Bank on Fort Street, Duggan was joined on stage with FCA North America’s chief operating officer Mark Stewart to discuss the city and Auburn Hills automaker’s deal this spring to plant the first new vehicle assembly plant in Detroit since Chrysler’s Jefferson North Assembly Plant opened in 1992.

Back in February, the automaker gave Detroit 60 days to assemble the land it needed to convert its Mack Avenue engine plants into an assembly plant for Jeep Grand Cherokees and a new three-row Jeep SUV expected to roll off the new assembly line in the fourth quarter of 2020.

“It was about the best 60 days we ever invested in,” Stewart said.

FCA’s is adding on a 800,000-square-foot addition to its two Mack Avenue engine plants as part of the $1.6 billion investment in converting the facility into a new Jeep SUV assembly plant, Stewart said.

Construction companies working for FCA have moved quickly this summer to build the steel structure of the addition and siding began going up on the plant Wednesday, Stewart said.

Duggan and Stewart talked about FCA’s pledge to give Detroiters a one-month head start to apply and interview for jobs at the expanded Mack Avenue plant and modernized Jefferson North Assembly Plant.

“I basically said, ‘You can pretty much write all of the sections the way you want, but I’m going to write one section — and that’s the preference for hiring Detroiters,'” Duggan said.

Read the full article: https://www.crainsdetroit.com/detroit-homecoming/duggan-we-gotta-clear-more-land-new-factories

PublicHealthFund

Environmental ‘Public Health Fund’

September 16, 2019

The Fiat Chrysler expansion presents a new opportunity to consider community benefits that respond to Environmental Health issues around development projects that use public funds.  This is due to the environmental impacts of the project, the existing respiratory health crisis in the neighborhoods surrounding the plant and the “additional monitoring and community benefits” included in EGLE’s approval of FCAs “permits to install”.

“The permittee shall work with the City of Detroit, through the Community Benefits Ordinance to identify additional projects for the community surrounding the facility. No less than 180 days after beginning construction pursuant to Permit to Install No. 14-19, the permittee shall submit to the AQD District Supervisor and AQD Permit Section Manager a plan for the additional projects. Some examples of additional projects may include the installation of filters at area residences and local schools or fence-line monitoring.(R 336.1201(3))” https://www.michigan.gov/egle/

Existing Public Health Fund

The City of Detroit has an existing Public Health Fund that has not yet been funded. The Public Health Fund was created as part of the Bulk Solid Materials Storage Ordinance. The fund can receive donations from any source. Money in the fund remains in the fund at the end of the fiscal year and does not go into the general fund. Donations to the fund must be accepted by City Council and can include conditions. The expenditure of the money from the Public Health Fund must be approved by City Council.

https://detroitmi.gov/departments/buildings-safety-engineering-and-environmental-department/environmental-affairs/bulk-solid-materials-storage

The Public Health Fund can receive Environmental Community Benefits funds from FCA that will:

  1. Support health and environmental education activities centered on community learning and engagement which will prioritize resident training, public information; and community survey assessments.  
  2. Support environmental mitigations including purchase of air quality monitors; and the installation and maintenance of air filters in local schools, libraries, head starts location, senior residencies and other locations where vulnerable populations gather.  

Example: The Housing Trust Fund Coalition 

The Housing Trust Fund Coalition has been successful influencing policy intended to respond to Detroit’s housing crisis. In 2018, the coalition supported the creation of the Housing Trust Fund and organized to get it on the books. This summer the Affordable Housing Task Force was seated as an oversight committee. Thus far the Affordable Housing Task Force has been successful in driving $2 Million into the fund.

Free Press:“To that end, the HTFC spent two years organizing residents to pass an ordinance that created the Detroit Affordable Housing Development and Preservation Fund, which will collect 20% of commercial land sales revenue to build accessible, affordable housing. Through that effort, we were able to get $2 million allocated from the city’s budget to the housing fund.” https://www.freep.com/story/opinion/contributors/2019/07/30/detroit-needs-reliable-fund-affordable-housing-heres-what-council-can-do-it/1836610001/

FCA Land Swaps Map

“Morouns, speculators look like winners in Detroit land swap to ensure FCA factory jobs” FROM: https://www.freep.com/story/news/local/michigan/detroit/2019/05/20/speculators-moroun-detroit-land-swap-fca-jobs/3664661002/

TOTAL Properties 881
Hantz Woodlands 367
Soave Enterprises 210
Michael Kelly 15
DTE Energy 28
Crown Enterprises 261
TOTAL Properties 881

https://www.google.com/maps/d/u/0/viewer?mid=1zh6Hi8tlpD7PuIUgdNPwjx9ilHWU4JW8&hl=en_US&ll=42.356444913493675%2C-83.03124552817383&z=13

FCAMap

Environmental Health Survey Summary of Findings

Eastside Resident Environmental Health Working Group
http://eastsideenvironmental.org

Eastside Environmental Health Survey Summary of Findings
July 26, 2019 

Based on community concerns about environmental health in our community, and in particular concerns about air pollution and health impacts of increased emissions from the expansion of the Fiat Chrysler Automotive (FCA), a community survey was conducted to gather information about community concerns and conditions regarding environmental health. 

Surveys were completed using a combination of methods, including door to door canvassing, phone calling, distributing paper surveys to local community organizations, and surveying residents at a local grocery store. In total 161 surveys were completed. Respondents included residents of the following zip codes: 48213, 48214, 48215, 48224, which includes the FCA impact zone. 

This survey is ongoing. This summary of findings based on data collected before July 26, 2019.

KEY FINDINGS: 

Health Concerns 

●  28% of respondents indicated that 1 or more person in their household has asthma. 

●  57% of respondents have 1 or more person in the household with allergies 

●  53% have 1 or more person in the household with respiratory illnesses such as sinus or frequent colds. 

Indoor Air Quality 

●  37% of households surveyed have no central air conditioning or window air conditioner. 

●  Of those households with some form of air conditioning, two-thirds have a window air conditioning unit. 

●  73% have no air filter or air purifier in their home. 

Outdoor Air Quality 

●  Only 37% of residents described their air quality as “good”. 42% described their air quality as “not good” or “poor”. 20 % responded “I don’t notice.” 

●  When respondents who described their air quality as “not good” or “poor” were asked what they thought would improve air quality, responses included “less dust and trucks from FCA,” “pollution from factories,” “fumes from factories,” “same smell in the neighborhood from past 30 years,” “close the plant or factory,” “remove factories,” “reduce truck traffic,” “provide clean air through monitoring factories” and “plant more flowers.” 

Previous research which has shown high asthma rates in the City of Detroit. A 2016 Michigan Department of Community Health report found that during 2012-2014, 15.5% of Detroit adults had asthma, compared with 11.0% of Michigan adults.1 The report also showed that 3 of the 4 eastside Detroit zip codes included in our survey (48213, 48214, 48215) were among the zipcodes with the highest asthma hospitalization rates in the City of Detroit. 

Asthma, allergies and other respiratory illnesses may be caused by, or exacerbated by exposure to air pollutants. The finding of 28% of households having one or more persons with asthma indicates a vulnerable population for impacts of air pollution from emissions from Fiat Chrysler Automotive Mack Avenue Plant. The plant has been permitted for a significant increase in emissions of volatile organic compounds (VOCs). 

VOCs can cause irritation of the eyes, nose and throat, as well as difficulty breathing and nausea. They can also damage the nervous system and other organs. 2 In the air, VOCs can react with nitrogen oxides, to produce ozone pollution, also known as smog. Ozone is associated with premature death, cardiovascular disease, respiratory illness, including increased hospitalization for asthma. Increasing evidence indicates that exposure to ozone may harm newborns; research has linked ozone levels to lower birth weight and decreased lung function. People with existing respiratory illnesses such as asthma and COPD, are particularly vulnerable to the health effects of ozone 3 

The large number of homes with no air conditioning indicates that many homes will have open windows in the summer, increasing resident’s exposure to outdoor air pollution. 

Portable air cleaners, also known as air purifiers or air sanitizers, are designed to filter the air in a single room or area. Central furnace or HVAC filters are designed to filter air throughout a home, and can reduce indoor air pollution; however, they cannot remove all pollutants from the air. 4Only 40% of households surveyed have central air conditioning; the majority of respondents do not have any air filter or air purifier in their home that could filter for indoor or outdoor air pollutants. 

1 Michigan Department of Health and Human Services, Detroit: The Current Status of the Asthma Burden, March 2016, https://www.michigan.gov/documents/mdhhs/Detroit-AsthmaBurden_516668_7.pdf.
2 American Lung Association, VOCs can Harm Health, https://www.lung.org/our-initiatives/healthy-air/indoor/indoor-air-pollutants/volatile-organic-compounds.htm
3 American Lung Association, Who is at Risk from Breathing Ozone? https://www.lung.org/our-initiatives/healthy-air/outdoor/air-pollution/ozone.html
4 USEPA, Air Cleaners and Air Filters in the Home: https://www.epa.gov/indoor-air-quality-iaq/air-cleaners-and-air-filters-home

Taken with the findings of previous research, the survey findings indicate that the community can be considered vulnerable to negative health impacts of increased pollution, as evidenced by high rates of asthma and asthma hospitalization, and significant numbers of homes with no air conditioning. In addition, the majority of residents surveyed think their air quality is not good, citing trucks, factories, and FCA specifically, as concerns. 

Recommended action/request of FCA: 

  1. Air quality monitoring at settings with vulnerable populations– Head Starts, K-12 schools (especially elementary schools), and senior resident buildings, in addition to monitors on the facility’s property. Prior to submitting the plan to EGLE, the locations for air quality monitoring stations should be determined with community support and buy-in through community engagement process.
  2. Air filtration systems within settings with vulnerable populations– Head Starts, K-12 schools (especially elementary schools), and senior resident buildings and ensuring that these are maintained over time. The locations for air filtration systems should be determined with community support and buy-in through community engagement process.
  3. Developing and supporting a community health fund. FCA should utilize the City of Detroit’s environmental health fund to house those funds. $5 million from FCA to support this fund is requested. 
  4. Vegetative buffers – These can make an impact on pollution concentrations from emissions from the facility as well as trucks on the roads. We are not certain that the direct and immediate benefit to indoor air quality, where children spend most of their time, will be as advantageous as the two listed above.
  5. Regular community meetings in partnership with local and environmental organizations, to give updates on the emissions data from the air monitors, take feedback, and engage with the community on environmental and public health issues on a quarterly or bimonthly basis.

Eastside Resident Environmental Health Working Group
http://eastsideenvironmental.org

Recommended Environmental Actions presented to FCA

These recommendations were presented to FCA at a meeting at their Auburn Hills Headquarters on August 2, 2019. This meeting was initiated by Senator Stephanie Chang. Representatives from Detroit People’s Platform and the Eastside Resident Environmental Health Working Group were uninvited to the meeting by FCA. Even though FCA uninvited our representatives, these recommendations and others were presented in the meeting by representatives from other groups that support them.

  1. Air quality monitoring at settings with vulnerable populations– Head Starts, K-12 schools (especially elementary schools), and senior resident buildings, in addition to monitors on the facility’s property. Prior to submitting the plan to EGLE, the locations for air quality monitoring stations should be determined with community support and buy-in through community engagement process.

  2. Air filtration systems within settings with vulnerable populations– Head Starts, K-12 schools (especially elementary schools), and senior resident buildings and ensuring that these are maintained over time. The locations for air filtration systems should be determined with community support and buy-in through community engagement process.

  3. Developing and supporting a community health fund. FCA should utilize the City of Detroit’s environmental health fund to house those funds. $5 million from FCA to support this fund is the ask. Learn more about the existing Public Health Fund.

  4. Vegetative buffers – These can make an impact on pollution concentrations from emissions from the facility as well as trucks on the roads. We are not certain that the direct and immediate benefit to indoor air quality, where children spend most of their time, will be as advantageous as the two listed above.

  5. Regular community meetings in partnership with local and environmental organizations, to give updates on the emissions data from the air monitors, take feedback, and engage with the community on environmental and public health issues on a quarterly or bimonthly basis.