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Office of Administrator Michael Regan
Environmental Protection Agency

November 28, 2022

Dear Administrator Regan,

Congratulations on the launch of the Office of Environmental Justice and External Civil Rights (OEJECR). We share your excitement about all the important work this new part of the Environmental Protection Agency (EPA) will do to protect unjustly marginalized populations from the harms of environmental degradation.

We are a group of varied organizations working to end environmental injustice and/or the maternal health crisis in the US. As you know, important indicators of maternal and newborn health like maternal mortality, as well as serious illnesses during pregnancy, and preterm birth, are higher in the US than most industrialized nations, are in many cases rising, and are unjustly higher for women of color than white women.

We have been increasingly concerned about the impact of climate change and other mounting harms from environmental degradation on the health of pregnant people and newborn babies. These negative impacts, which reflect specific biological as well as socioeconomic vulnerabilities of pregnancy, are inequitably distributed. Such impacts compound and interact with poverty, racism, and other forms of marginalization, and can have life-long ramifications that in turn reinforces inequality and corrodes future community resilience, including to disasters arising from the climate crisis.

Known impacts arising from air pollution, extreme weather driven by the climate crisis, fossil fuels (including extraction, refinement, and use), low quality housing, toxins from soil and water and other environmental factors include preterm birth, low birth weight, still birth, and higher rates of some maternal diseases. Please see below for some examples of relevant studies. Without action, environmental injustices will continue to worsen the US maternal health crisis, deepening unjust inequities in rates of maternal morbidity and mortality and adverse birth outcomes, with worse rates for Black, Indigenous, and other women and birthing people of color.

We ask that you take the following steps to address these concerns:

  • Create at least one high-level reproductive justice position within the OEJECR, including a position senior enough to allow coordination with other parts of government managing environmental justice funds and other resources. We envisage this person contributing scientific and policy understanding of sexual and reproductive health vulnerabilities to climate change, toxics, and other environmental health problems. The position holder should also have a deep understanding of the maternal and newborn crisis in the US and how pregnant people and newborns in some communities are especially vulnerable to environmental health harms because of systemic racism or other forms of marginalization.
  • Announce an explicit commitment to reproductive justice for the OEJECR at the next possible opportunity, and that you create agency webpages dedicated to the intersection of environmental justice and reproductive justice in the US.
  • We ask that the EPA directs resources, including those aimed at addressing environmental injustice, to reproductive justice and environmental health and sexual and reproductive health and rights and support local health practitioners including community health clinics, public health departments and public health workers and community health workers such as doulas.
  • We also hope that you will include reproductive justice language, evidence from studies showing environmental health harms to maternal, newborn, adolescent, fertility and other sexual and reproductive health and rights, and studies showing disparate impacts on historically marginalized communities as you develop work plans for the OEJECR.

Our sincere thanks for your consideration. We would be delighted to speak further on this with you or your colleagues.

Yours sincerely,

A Better Balance

Air Alliance Houston

Alliance of Nurses for Health Environments

Birthmark Doulas

Black Millennials for Flint

Center for Biological Diversity

Center for Reproductive Rights

EverThrive Illinois

Every Woman Connecticut

Florida Clinicians for Climate Action

Human Rights Watch

Medical Students for a Sustainable Future

Metro Mommy Agency

Moms Clean Air Force

National Association of Nurse Practitioners in Women's Health

National Birth Equity Collaborative

National Lawyers Guild of Lewis & Clark Law School

National Resources Defense Council

New Voices for Reproductive Justice

Nurses for Sexual and Reproductive Health

Nurturely

Raising Illinois

Start Early

The Connecticut Maternal and Child Health Coalition

The Connecticut Reproductive Justice Alliance

University of California, San Francisco’s Program on Reproductive Health and the Environment

Women’s Fund Miami Dade

Women’s Voices for the Earth

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