HHS Seeking Public Comment on 2022 Environmental Justice Strategy and Implementation Plan Draft Outline

Akin Gump Strauss Hauer & Feld LLPKey Points:

  • The OASH under HHS is soliciting input from the public on its 2022 Environmental Justice Strategy and Implementation Plan Draft Outline. Comments are due to HHS by May 19, 2022.
  • The 2022 HHS Environmental Justice Strategy and Implementation Plan will support the Biden Administration’s policy priorities related to environmental justice.
  • By seeking public input for this updated plan, along with developing the OCCHE last year, HHS has demonstrated a clear commitment to implementing long-term actions to address health-related harms caused by adverse environmental conditions.

On Friday, April 8, 2022, the U.S. Department of Health and Human Services (HHS) requested public comments on the agency’s 2022 Environmental Justice Strategy and Implementation Plan Draft Outline. The plan will identify priority actions and strategies to best address environmental injustices and health inequities for people of color and disadvantaged, vulnerable, low-income, marginalized and indigenous populations. These policy priorities mirror those of the Office of Climate Change and Health Equity (OCCHE), which HHS established in August 2021. 

All potentially interested stakeholders, including individuals, associations, governmental, non-governmental organizations, academic institutions and private sector entities are encouraged to respond. Comments must be submitted via email to the Office of the Assistant Secretary for Health (OASH), OASHcomments@hhs.gov, as a Word document or in the body of an email by midnight Eastern Time (ET) on May 19, 2022.

The 2022 Draft Strategy Outline features the following six proposed strategic elements with related “priority actions” that commenters can address:

  1. Services
  2. Partnerships and Community Engagement
  3. Policy Development and Dissemination
  4. Research and Data Collection, Analysis and Utilization
  5. Education and Training
  6. Performance Measures.

The Request for Information (RFI) also seeks input from the public on the following questions:

  • What Environmental Justice Core Principles should be included in the HHS Environmental Justice (EJ) Strategy to advance environmental justice for disadvantaged communities?
  • How should HHS incorporate Environmental Justice Core Principles in the HHS EJ Strategy?
  • Do the Strategic Elements reflect relevant areas of environmental justice that address the needs of disadvantaged communities?
  • Are there additional Strategic Elements that should be included in the HHS EJ Strategy?
  • Do the Priority Actions capture the urgent, environmental justice issues of today?
  • If not, what additional Priority Actions should be included within the HHS EJ Strategy?
  • What research methods, research questions, and data tools should HHS use to address environmental justice and social determinants of health?
  • What other strategies can be included within the 2022 HHS Environmental Justice Strategy and Implementation Plan to address environmental justice and health equity issues for disadvantaged populations?

Stakeholders may address these specific questions and proposed strategic elements and priority actions, as well as any additional areas of interest that are not included in the RFI.

For a detailed discussion on the relationship between climate change, environmental justice and health equity, please read Akin Gump’s “HHS Turns Up the Heat on Climate Change with New Office.”

 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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