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PSR PA Comments on EPA Draft Strategic Plan

Updated: Apr 8, 2022

Physicians for Social Responsibility Pennsylvania (PSR PA) promotes social responsibility by protecting health, the environment and communities through education, training, direct service, and advocacy. PSR Pennsylvania is a public health, 501c3 non-profit organization which fulfills its mission through programs focused on health and the environment and working with youth. Composed of a variety of health professionals, PSR Pennsylvania is uniquely equipped to speak to threats posed to public health in our region.

We applaud the EPA for including children’s environmental health in its goals and strategies, especially the focus on lead poisoning and asthma exacerbations. When it comes to the climate crisis, we must remember how climate change’s effects have a substantial impact on children’s health. Children are not “little adults” and their biology is unique from adults, with greater risk of exposure and susceptibility to harmful effects of pollutants. We encourage the EPA to continue keeping children in mind when considering regulations curbing climate change and to continue following the evidence on the myriad of ways the climate crisis is making children’s health suffer.

The overarching aims of the EPA’s strategic plan are well-chosen and vitally important. We applaud the inclusion of justice and equity as guiding principles of this plan and note their integration into the goals and objectives. Nonetheless, we have concerns about both depth and breadth. Regarding depth, there is considerable variability in the degree of specificity offered in the design and implementation of needed programs for many of the identified public health and environmental targets. While in some instances the report offers a high level of detail (e.g., Objectives 4.1 and 7.1), in other places, critical details are notably lacking. This is apparent in some foundational sections, including one of the four Cross-Agency Strategies: “Consider the Health of Children at All Life Stages and Other Vulnerable Populations.” The report could usefully identify specific targets, metrics, approaches, and outcomes of interest as well as relevant stakeholders, affected communities, and methods and plans for communication of progress and outcomes. Secondly—regarding breadth—there are missed opportunities to bring attention and resources to essential elements of health that were overlooked in this plan’s goals and objectives. As the scope of the plan is limited to physical health, it neglects to include mental health and illness in its assessment of the dangers climate change and environmental degradation pose to human health. This is in spite of the fact that a considerable body of scientific literature has been growing to document such effects. Without this inclusion, key variables are absent in the EPA’s effort to understand and protect our citizens, particularly many of the most vulnerable.

In closing, while PSR PA appreciates and commends the EPA’s efforts we want to highlight that this strategic plan must first and foremost focus on the health and future of children. Secondly, we ask that you seek input from health professionals who specialize in climate change and environmental justice when delineating the tasks that you hope will achieve your goals and objectives. PSR PA is always available to participate in such discussions.

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