Earlier this year, the New York State Department of Environmental Conservation held a public comment and meeting period regarding the Draft Disadvantaged Communities Criteria (DAC). This criteria, which is being overseen by the Climate Justice Working Group, will help the state “identify disadvantaged communities to ensure that frontline and otherwise underserved communities benefit from the state’s historic transition to cleaner, greener sources of energy, reduced pollution and cleaner air, and economic opportunities.”
While the Adirondack Council supports the overall effort of the DAC criteria, the focus is on urban and suburban areas of New York. The Council feels the criteria should be updated to include the challenges faced by the rural communities of New York, in particular those in the Adirondack Park. Our comments on the DAC criteria are below, as written by Adirondack Council Director of Conservation Jackie Bowen and Clarence Petty Climate and Conservation Intern Andrea Shipton.
Office of Environmental Justice,
On behalf of the Adirondack Council, I would like to provide the following comments on the New York State Draft Disadvantaged Communities Criteria (DAC). The Council is grateful for the opportunity to provide comments on New York’s ambitious Climate Act, which will help shape climate action policy throughout the state for the next several decades. We applaud the NYS Department of Environmental Conservation’s (NYDEC) Office of Environmental Justice for prioritizing this critical issue within the Climate Act. While we support the overall elements captured within the criteria, we believe additional criteria are necessary to account for Adirondack specific impacts.
While the climate crisis affects all New Yorkers, it does not affect all New Yorkers equally. Given the stakes it is imperative that the state sufficiently accounts for both urban and rural environmental justice issues while determining how to direct resources in an equitable manner. Below are the Council’s comments for consideration.
The DAC criteria must account for issues of rural environmental justice that affect daily life for New Yorkers living in the Adirondack Park. While the DAC criteria covers a variety of urban environmental justice issues— such as proximity to toxic waste sites and vehicle pollution— it must also meaningfully consider rural environmental justice issues that threaten the lives and livelihoods of year-round Adirondack residents. Only 15% of rural communities are represented in the draft list of DACs, compared to 26% of suburban tracts and 47% of urban tracts. The Council applauds the inclusion of the “driving time to hospitals or urgent/critical care” criterion, which represents a key health-related risk in sparsely-populated rural communities, though similar criteria should be considered to ensure the climate risks of rural life are fully considered.
In particular, the Climate Justice Working Group (CJWG) should reconsider their decision to eliminate “distance to food stores (or low access/food deserts)” as a DAC criterion. Access to fresh food is vital to the maintenance of public health, and climate change-related disasters that disrupt food supply chains could prove disastrous and even deadly to food-insecure regions. The CJWG removed this criterion from the criteria after collection and analysis of the data due to the limitations of a static distance threshold for rural and urban areas. However, rather than eliminating the criteria completely, the CJWG should improve this metric to account for the fact that households in urban food deserts will have a shorter distance to food stores than those in rural food deserts.
The CJWG also chose to remove “school closings” and “in-migration/gentrification” to the final criteria, the Council believes these key risks need to be included and are essential thresholds to the survival of rural communities. The school consolidations and closings that have swept through the North Country in recent years represent population decline and disinvestment in these rural areas. Future in-migration and gentrification, demonstrated by the Covid fueled demographic shifts to rural communities, could threaten economic stability by forcing low-income and working-class Adirondack residents out of their communities.
The ongoing housing crisis in the Adirondacks is a major threat to the region’s economic vitality and is only growing more challenging. These challenges will be exacerbated as climate change forces climate refugees into the region. The North Country will remain more livable in the coming decades since it is not directly threatened by sea level rise, wildfires, or similar climatic risks relevant to New York City and other parts of the country. Given the region’s inherent climate resiliency, the Adirondacks will likely become a more desirable place to live in the near future. The CJWG should explore other ways to gather data on school closings and in-migration to account for these rural climate risks in the final DAC criteria.
When reviewing these rural environmental injustices, the CJWG should specifically reexamine the four Hamilton County communities for possible DAC status. An analysis of New York State’s ALICE criteria, another method for assessing population vulnerability in the state, reveals an inconsistency between counties identified as low-income and climate-vulnerable. ALICE stands for Asset Limited, Income Constrained, Employed and identifies households that fall under the bare minimum cost of living. Hamilton County has the second largest percentage of residents below the ALICE threshold; only New York City counties are equal or higher. Despite this designation, Hamilton County communities do not score high enough on the population characteristics vulnerabilities scale to render them DACs. Due to the severe risks climate change imposes on low-income communities, the CJWG should further explore the disconnect between the ALICE and DAC criteria.
Other population vulnerabilities threatening Hamilton County include its aging population and vulnerable seasonal tourism economy. Twenty-five percent of Hamilton County residents are age 65 or older, which is in the 98.7th percentile compared to the rest of the state, according to the 2020 census. Not only does this render the population extremely vulnerable to severe climate or weather-related events (such as power outage during a heat wave), but it also raises questions about the social, political, and economic survival of the county considering that such a large percentage of residents are likely retired. The CJWG should retain “population over age 65” as a key demographic vulnerability in the finalized list of DAC criteria.
Along with the risks brought on by an aging population, the seasonal tourism economy of Hamilton County and the rest of the Adirondacks is also increasingly threatened by warming winter temperatures. As climate change diminishes the amount of ice and snow cover on the ground, winter outdoor recreation activities, such as skiing, snowshoeing, snowmobiling, ice skating, and more will become increasingly difficult, more unpredictable, more dangerous, and more temporally limited. Local tourism economies like Hamilton County’s require a steady stream of winter tourists to survive the winter months while tourism revenue is at its lowest. Without these contributors to the local economy, living year-round in Hamilton County will become even more difficult, especially for small business owners. Thus, Hamilton County requires resources to adapt to climate change and diversify the economy for long-term survival.
The Council fully supports the need to account for urban environmental justice issues but believes these criteria would be greatly improved by reflecting and representing New York’s rural communities in the list of DACs. Residents of the Adirondacks are not subject to the same levels of pollution, urban heat islands, lack of green space, and historical redlining found in many intercity communities. Nevertheless, rural communities are subject to their own unique challenges and climate risks that the Climate Action Council must not forget when determining where to direct resources for climate adaptation and mitigation. The CJWG must ensure they keep these rural environmental justice issues and future climate impacts in mind when determining DAC status and should capture those communities that are at significant risk in these criteria. Thank you for considering our comments and we look forward to reviewing the next draft of the Disadvantaged Communities Criteria.
Jackie Bowen, Adirondack Council Director of Conservation
Andrea Shipton, Clarence Petty Climate and Conservation Intern