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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.