The EPA and Parks, Environmental Justice and the Disposable of Society

August 1, 2015, Department, by Robert García and Ariel Collins

How can the EPA help to improve access to parks and recreation and the health, environment and resiliency of communities of color and low income communities?In Pope Francis’ recently released Laudato Si’ — his encyclical on the interrelated relationship between humans and the environment—he asks the people of the world to care about climate, creation and the poor. “In some places, rural and urban alike,” he writes, “the privatization of certain spaces has restricted people’s access to places of particular beauty. In others, ‘ecological’ neighborhoods have been created which are closed to outsiders in order to ensure an artificial tranquility. Frequently, we find beautiful and carefully manicured green spaces in so-called ‘safer’ areas of cities, but not in the more hidden areas where the disposable of society live.” 

United States Environmental Protection Agency (EPA) Administrator, Gina McCarthy, agrees with the Pope: “I think the most important thing that we can do, working with the Pope, is to try to remind ourselves that this is really about protecting natural resources that human beings rely on, and that those folks that are most vulnerable — that the church has always been focused on, those in poverty and low income — are the first that are going to be hit and impacted by a changing climate.”

Environmental injustice occurs in the context of extreme inequalities in income, wealth and power. During the past four decades, we’ve seen extreme income inequality in the United States explode. In 2010, it was estimated that the top 1 percent of the U.S. population owned 42 percent of non-home wealth, and the top 5 percent owned 72 percent of non-home wealth; according to a report from the University of California, Santa Cruz, the bottom 80 percent owned less than 5 percent. Average white non-home wealth was almost 20 times more than African-American and 70 times more than Latino wealth. These inequities threaten prospects for democracy and environmental justice, according to the North Carolina Environmental Justice Network (NCEJN).

California Rep., Judy Chu (CA-27), emphasizes parks as an environmental justice issue through her leadership on the proposed national recreation area in the San Gabriel Mountains. In a speech before the U.S. House Committee on Natural Resources forum on climate, environmental justice and green access, she said:

“Los Angeles is one of the most park-poor places in the country. Just 15 percent of the region’s population has pedestrian access to green spaces, leaving more than 85 percent of residents without easy access to public parks or green spaces, particularly affecting minorities and those from low-income communities. And there’s a color divide. Did you know that in L.A., white neighborhoods enjoy 32 acres of parks per 1,000 people, but for African-American neighborhoods it’s 1.7, and for Latino neighborhoods it’s .6?”

Even President Obama, when he dedicated the San Gabriel Mountains National Monument in Southern California in 2014, emphasized that there are not enough parks, especially for children of color. 

While these facts are about Los Angeles, communities of color and low income communities across the nation suffer from disparities in access to resources for parks and healthy living. This is part of the continuing legacy and pattern of residential segregation resulting, to some degree, from racially restrictive housing covenants, discriminatory mortgage policies, and structural inequalities in wealth and income.

California-based The City Project, a group working for equal justice, democracy and livability for all, and its allied partners, have asked the EPA to improve access to parks and recreation as an environmental justice and civil rights issue. Communities across the nation led by Earthjustice, the nation’s original and largest nonprofit environmental law organization, have also filed a lawsuit to require the EPA to take civil rights laws seriously by investigating and resolving environmental justice pollution complaints on which the EPA has failed to act for more than 10 years. 

There is hope that the EPA will improve access to parks and recreation and the health, environment and resiliency of communities of color and low income communities. Its proposed EJ 2020 action plan, a strategy to advance environmental justice through its programs, policies and activities, to make a visible difference in environmentally overburdened, underserved and economically distressed communities, could help. But, the EPA has a “record of poor performance” on civil rights, according to a 2011 study by Deloitte Consulting LLP.

What Can the EPA Do? 

To overcome its legacy of poor civil rights performance, and to improve access to parks and recreation as an environmental justice issue, the EPA should take the following steps:


  • Adopt an objective to expand access to healthy parks, green space and natural areas.
  • Develop standards for park access to measure progress and equity and hold public officials accountable. 
  • Add parks, green space and natural areas to the EPA’s online mapping tool called EJScreen, which includes only toxins and pollution.
  • Prioritize protecting and expanding free access to healthy parks, green space and natural areas for communities of color and low-income communities that have long been deprived of these environmental benefits.
  • Provide leadership, best practices and best results in speed, access to clean and healthy natural areas, public information and participation, and community satisfaction in the results, as has occurred in communities without environmental justice concerns. Examples discussed above are best practices. 
  • Enforce civil rights and environmental justice laws and principles to improve park access, and improve the health, environment and resiliency of communities of color and low-income communities.


Title VI of the Civil Rights Act of 1964 and its regulations, for example, prohibit intentional discrimination, as well unjustified discriminatory impacts without proof of intent, based on race, color or national origin by recipients of federal funding. This applies to recipients of EPA funding, including state and local agencies and private recipients. Executive Order 12898, signed by President Clinton in 1994, requires each federal agency, including the EPA, to achieve environmental justice as part of its mission by identifying and addressing disproportionately high and adverse human health or environmental effects of its activities on minority populations and low-income populations.

As NRPA begins its next 50 years, the EPA might do well to help promote NRPA’s Three Pillars of Conservation, Health and Wellness, and Social Equity. We do not seek Blue parks or Red parks, based on ideology or party affiliation. We seek green parks for all.

Robert García is the Founding Director and Counsel of The City Project. Ariel Collins is a Policy Analyst and Juanita Tate Social Justice Fellow for The City Project.