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Lee highlights the importance of consolidating an empirical definition for “disproportionate impacts” by situating his argument within current discussions on systemic racism stemming from police brutality and the COVID-19 pandemic. Additionally, in calling attention to premises of resistance from the EPA to address EJ integration, as well as the agency’s careless disregard for EJ processes generally, Lee articulates the need to further define an analytical framework to EJ application. He additionally calls attention to current developments within the EJ sphere in operationalizing “disproportionate impacts” via new quantitative and geographical analysis tools, stating the necessity of such tools in bringing EJ movements beyond its present stagnation.

“While such microaggressions have been examined in the context of implicit bias, Harrison is the first to look at them in terms of policymaking and program implementation. “We do ecology, not sociology,” a key stan- dard narrative cited by Harrison, is reminiscent of EPA’s response to my seminal Toxic Wastes and Race report.10 In 1987, J. Winston Porter, former assistant administrator for solid waste and emergency response, wrote that “EPA deals with issues of technology, not sociology.” (Lee, 2021, p 10209)

“Without such an analytical framework built on properly identifying, characterizing, and integrating disproportionate impacts, the default response for EJ issues devolves into a perfunctory “box to be checked” exercise. “ (Lee, 2021, 10233)

The author, Charles Lee, is credited as a well-respected leader within the field of environmental justice. His leadership roles in establishing the foundation for environmental justice policy in the U.S., particularly in linking environmental justice issues to systemic racism, gives credibility to his established position as an environmental policy analyst. Institutionally, he is affiliated with the U.S. Environmental Protection Agency, where he currently serves as the Senior Policy Advisor for Environmental Justice.

“This mapping capacity not only enables examination of information based on objective (based on empirical evidence), comparable (quantitative), and visualizable (mapped) terms, it also puts this information in front of the analysts and decisionmakers in a form they cannot ignore.” 7; HOFFMAN, community science model: “In his mind, this model consists of (1) serving as a focal point for bringing together community residents, scientists, and policymakers; (2) serving to generate knowledge that can be a catalyst for change; and (3) developing methodologies and products that can be scalable—particularly for neighborhood use. The visualization of the problem through redlining maps is critical. … EJ at its core is about the spatial distribution of environmental benefits and burdens. Winling described redlining as the Rosetta Stone that unlocks an understanding of the spatial organization of most American cities. It “most definitely created a template” that would be built out over generations.” 15

Lee argues that EJ practice has long stagnated over an inability to properly define the concept of disproportionate (environmental and public health) impacts, but that national conversations on system racism and the development of EJ mapping tools have improved his outlook on the potential for better application of the concept of disproportionate impact. Lee identifies mapping tools (e.g. CalEnviroScreen) as a pathway for empirically based and analytically rigorous articulation and analysis of disproportionate impacts that are linked to systemic racism.

In describing the scope and nature of application of mapping tools, Baker highlights the concept of cumulative impacts (the concentration of multiple environmental, public health, and social stressors), the importance of public participation (e.g. Hoffman’s community science model), the role of redlining in creating disproportionate vulnerabilities, and the importance of integrating research into decision making processes.

Baker ultimately argues that mapping tools offer a promising opportunity for integrating research into policy decision making as part of a second generation of EJ practice. Key areas that Lee identifies as important to the continued development of more effective EJ practice include: identifying good models for quantitative studies and analysis, assembling a spectrum of different integrative approaches (to fit different contexts), connecting EJ research to policy implications, and being attentive to historical contexts and processes that produce/reproduce structural inequities.