January 12, 2024
Submitted via regulations.gov
Stacy Murphy
Deputy Chief Operations Officer/Security Officer
Office of Science and Technology Policy
Executive Office of the President
1650 Pennsylvania Ave., NW
Washington, DC 20504
Re: Document Number: 2023-27632. Request for Information To Support the Development of a Federal Environmental Justice Science, Data, and Research Plan; Reopening of Comment Period
Dear Ms. Murphy,
Thank you for considering The Partnership for Inclusive Disaster Strategies comments. The Partnership for Inclusive Disaster Strategies (The Partnership) is the only U.S. disability-led nonprofit organization with a focused mission on equity for people with disabilities and people with access and functional needs throughout all planning, programs, services, and procedures before, during, and after disasters and emergencies.
We achieve our mission through disability-led disaster response and community resilience; community engagement, organizing, and leadership development; advocacy and systems change; training, technical assistance, and research; and unwavering support for local disability organizations.
We extend our gratitude for the opportunity to contribute to the Request for Information to Support the Development of a Federal Environmental Justice Science, Data, and Research Plan. As the only U.S. disability-led organization focused on equity for people with disabilities in all aspects of emergency management, we bring a unique perspective to this discussion.
A critical issue that often goes unrecognized in environmental justice efforts is the disproportionate impact of climate change, disasters, and air pollution on people with disabilities. Despite making up nearly 27% of the population and experiencing inordinate impact, disabled people are frequently excluded from environmental research efforts as researchers, subject matter experts, and subjects. This exclusion not only undermines the effectiveness of such research but also fails to address the disproportionate barriers the disability community encounters.
People with disabilities are integral to all environmental justice efforts and must be included in all aspects of research for and implementation of these policies. Our inclusion ensures that research and policies are more comprehensive and truly reflective of the diverse needs of all impacted communities.
The data collection process must include information collected from disabled people directly. To help ensure data collection is complete, the Office of Science and Technology Policy (OSTP) and other environmental researchers must comply with legal obligations to disabled people under disability civil rights law, including the Americans with Disabilities Act (ADA) 42 U.S. C. § 12102 et seq. and sections 504 and 508 of the Rehabilitation Act 29 U.S.C. § 701 et seq. This includes providing sign language interpreters, and written and electronic material in accessible formats; conducting physical meetings in accessible spaces; and making reasonable modifications to policies, practices, and procedures where necessary to avoid discrimination. Efforts should be made to recruit, hire, and retain researchers with disabilities in order to begin to mitigate disability bias.
OSTP must assess how environmental factors due to climate change exacerbate the social inequities encountered by people with disabilities and determine how to mitigate them. It is essential that future environmental justice science, data, and research plans not only recognize the needs of people with disabilities but also actively involve us at every phase of the research and decision-making processes. This can be facilitated by collaborating with disability-led organizations and disabled leaders in the disability community, as well as integrating compliance with disability rights mandates and adherence to principles of disability justice into all aspects of research and policy development.
We hope that our insights contribute to a more inclusive and effective Federal Environmental Justice Science, Data, and Research Plan. We thank you for considering our perspective and look forward to seeing these crucial elements reflected in the final plan.
Germán Parodi & Shaylin Sluzalis
Co-Executive Directors
The Partnership’s Comments in Response to Request for Information To Support the Development of a Federal Environmental Justice Science, Data, and Research Plan
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Updated: June 8, 2024 by admin
January 12, 2024
Submitted via regulations.gov
Stacy Murphy
Deputy Chief Operations Officer/Security Officer
Office of Science and Technology Policy
Executive Office of the President
1650 Pennsylvania Ave., NW
Washington, DC 20504
Re: Document Number: 2023-27632. Request for Information To Support the Development of a Federal Environmental Justice Science, Data, and Research Plan; Reopening of Comment Period
Dear Ms. Murphy,
Thank you for considering The Partnership for Inclusive Disaster Strategies comments. The Partnership for Inclusive Disaster Strategies (The Partnership) is the only U.S. disability-led nonprofit organization with a focused mission on equity for people with disabilities and people with access and functional needs throughout all planning, programs, services, and procedures before, during, and after disasters and emergencies.
We achieve our mission through disability-led disaster response and community resilience; community engagement, organizing, and leadership development; advocacy and systems change; training, technical assistance, and research; and unwavering support for local disability organizations.
We extend our gratitude for the opportunity to contribute to the Request for Information to Support the Development of a Federal Environmental Justice Science, Data, and Research Plan. As the only U.S. disability-led organization focused on equity for people with disabilities in all aspects of emergency management, we bring a unique perspective to this discussion.
A critical issue that often goes unrecognized in environmental justice efforts is the disproportionate impact of climate change, disasters, and air pollution on people with disabilities. Despite making up nearly 27% of the population and experiencing inordinate impact, disabled people are frequently excluded from environmental research efforts as researchers, subject matter experts, and subjects. This exclusion not only undermines the effectiveness of such research but also fails to address the disproportionate barriers the disability community encounters.
People with disabilities are integral to all environmental justice efforts and must be included in all aspects of research for and implementation of these policies. Our inclusion ensures that research and policies are more comprehensive and truly reflective of the diverse needs of all impacted communities.
The data collection process must include information collected from disabled people directly. To help ensure data collection is complete, the Office of Science and Technology Policy (OSTP) and other environmental researchers must comply with legal obligations to disabled people under disability civil rights law, including the Americans with Disabilities Act (ADA) 42 U.S. C. § 12102 et seq. and sections 504 and 508 of the Rehabilitation Act 29 U.S.C. § 701 et seq. This includes providing sign language interpreters, and written and electronic material in accessible formats; conducting physical meetings in accessible spaces; and making reasonable modifications to policies, practices, and procedures where necessary to avoid discrimination. Efforts should be made to recruit, hire, and retain researchers with disabilities in order to begin to mitigate disability bias.
OSTP must assess how environmental factors due to climate change exacerbate the social inequities encountered by people with disabilities and determine how to mitigate them. It is essential that future environmental justice science, data, and research plans not only recognize the needs of people with disabilities but also actively involve us at every phase of the research and decision-making processes. This can be facilitated by collaborating with disability-led organizations and disabled leaders in the disability community, as well as integrating compliance with disability rights mandates and adherence to principles of disability justice into all aspects of research and policy development.
We hope that our insights contribute to a more inclusive and effective Federal Environmental Justice Science, Data, and Research Plan. We thank you for considering our perspective and look forward to seeing these crucial elements reflected in the final plan.
Germán Parodi & Shaylin Sluzalis
Co-Executive Directors
Category: Disability Advocacy, Public Policy and Legislation Tags: Americans with Disabilities Act Compliance, Climate Change Impact on Disabilities, Disability Inclusion in Environmental Policy, Environmental Justice Science Plan, Inclusive Environmental Policy Making