The state of environmental justice analyses in NEPA: The case of Arizona

As the unequal impacts of environmental harms and climate change have become apparent, environmental justice (EJ) is an increasingly salient matter in US environmental policy and impact assessments. The EJ impacts of important infrastructural decisions and investments are most often analyzed in environmental impact statements required by the National Environmental Policy Act (NEPA)—a globally influential piece of legislation—with significant discretion given to organizations on how to conduct these analyses. There is little systematic understanding of how these analyses are conducted and what the findings of these analyses tend to be. In this paper, we analyze a decade's worth of EJ analyses that appear in environmental impact statements conducted in the state of Arizona in the US as a first attempt to fill this gap in understanding. We find that throughout EJ analyses 11 different demographic indicators, ten different community boundaries, and eight different population thresholds are used with considerable variation to identify EJ communities. The variation in how these criteria are applied points to an inconsistent definition of an EJ community throughout the federal government. Still, analyses consistently do not find negative EJ impacts to be likely. While NEPA has promoted positive environmental outcomes in the past, it may currently be failing to do this for EJ. We highlight possible flaws in EJ analysis methods and shortcomings of the NEPA process itself that may cumulatively obstruct meaningful EJ consideration. With the widespread influence of NEPA on environmental impact assesment approaches globally, our findings raise questions that EJ analyses in environmental impact assesments outside the US could suffer from the same methodological shortcomings we identify.