Developing Policy on Environmental Quality, Schools, and Health

Abstract

In this report, we discuss current research on school siting and environmental health, specific school siting policies in states other than Michigan, federal school siting guidelines, and, lastly, we present a range of policy options for addressing environmental health issues as they relate to school siting in Michigan. As children can spend upwards of seven hours per day in school, the location and condition of their school can have a significant impact on their overall exposure to toxicants in their environment. Furthermore, school location can have an effect on what proportion of children are able to walk or bike to school, and, as such, can have profound impacts on healthy lifestyle choices (Miles, Adelaja, and Wyckoff, 2011). In particular, this report focuses on the environmental pollution burdens faced by children from sources external to the school, such as air pollution from motor-vehicle traffic or industrial sources, and soil and groundwater pollution from hazardous waste sites. Currently, there is no state regulation in Michigan that addresses school siting with respect to environmental quality considerations. At the state level, school siting policies and guidelines currently exist in twenty-six states (Fischbach, 2006). At the federal level, the Environmental Protection Agency (EPA) recently issued guidelines on school siting in October 2011 that they recommend local education agencies follow (U.S. EPA, 2011a). The EPA guidelines serve an important role as a tool for improved child health, but because the EPA did not mandate or go into specifics about school siting rules due to the vast differences occurring from state to state, the guidelines can be broad and vague. The EPA’s national guidelines provide a basis for understanding key concerns and shortcomings of existing school siting policy, and how it may be used in state and local policies. So, in spite of the fact that these EPA guidelines are available, the presence of policies on school siting at the state level is still necessary to add more state-specific considerations to them. Literature Review We present a broad review of literature related to school siting to help frame the importance of the issue and lend context to the subjects in our Interview Synthesis and Policy Recommendations sections. This includes sections on health and environmental pollution as it relates to schools, school siting and environmental justice, the EPA school siting guidelines, school siting policies that exist in other states, and the current and historic atmosphere of school siting in Michigan. P a g e | 4 Methodology In addition to our review of relevant literature, we conducted a series of telephone interviews with state and federal government agency officials, public health researchers, school administrators, land-use experts, and non-governmental organization representatives. These stakeholders included informants from Michigan, other states, and at the national level. The aim of these interviews was to assess key issues with the status-quo siting process in Michigan, important benefits and drawbacks of policies and guidelines used by other states, and notable considerations to account for in crafting a set of policy recommendations for Michigan. Our interview process was approved by the University of Michigan Institutional Review Board. We used an informal, qualitative process to analyze the information we gathered in these interviews and used this information, along with information from a variety of literature sources, to craft a set of policy recommendations. Interview Synthesis We encountered a number of common themes throughout the course of our interviews. One such theme was the need to foster an environment of collaboration between local education agencies and local government organizations. We found that in the current siting environment, there is often disconnect and a lack of communication between local education agencies and local governments with regards to siting matters. Additionally, informants from many states acknowledged that costs not borne directly by local education agencies at the time of land acquisition and construction were frequently neglected in siting decisions. Schools built far from community centers serve as an example of how schools neglect the true costs of siting decisions. In Michigan, the county road commission frequently bears the cost of building infrastructure to the distant school site. Another example of this type of ‘hidden cost’ is the increasing incidence of symptomatic respiratory illness among students and faculty members in areas with more air pollution. A point of contention between informants was the relative benefits of a system of mandates as opposed to a system of guidelines to inform siting decisions. While some interviewees preferred the rigidity of mandates, expressing that school districts would likely not do much to comply with voluntary guidelines on siting, many interviewees preferred the flexibility of guidelines. Some claimed that mandates would face stiff political opposition, and might also generate resistance from local education agencies. In contrast, one superintendent exclaimed that school administrators would welcome such mandates if they made the job of siting easier, and expressed that the only difficulty in passing a mandate would be in getting it accepted by some portions of the state legislature. P a g e | 5 Policy Recommendations Our literature research and interviews uncovered numerous issues, hurdles, unique situations, and policy recommendations that encompassed a range of topics, as there are many interconnected factors which must be addressed in changing Michigan’s status-quo of school siting. To better understand all these factors and to better organize our research, we grouped the topics into broad themes and developed and crafted our policy recommendations around these themes. We anticipate that a school siting policy in Michigan may occur as a piecemeal process. Instead of having one overarching policy output, we separated the policy recommendation into themes to accommodate many political climates and stringency levels of the policies. These themes are: health, government, environment, community needs, and other (themes that could not be grouped into any of the other four groupings). Admittedly, these groups are broad and many topics overlap. Here is a brief explanation of our groupings and the thought process behind the grouping categories.  Health themes include: site acreage; pollution mitigation; prohibited sites; air quality; soil contamination; groundwater and regional pollutants. We grouped site acreage in with health because often schools that are located further away from city centers have larger site acreage. States with site minimum acreage requirements for schools (ex: one acre for every 100 students) discourage communities from building in town centers where walkability to school increases, thus increasing the health of the students from the increased physical activity.  Environment themes include: topography; seasonal variations; and rural, suburban, and urban siting. Rural, suburban, and urban siting factors were grouped into environment because these areas have different physical environments and environmental stressors.  Community themes include: historic preservation; conflict resolution between stakeholders; accounting for true-cost estimates; promoting public participation; and providing comment periods on siting plans. We grouped true-cost estimates into community, as opposed to government because often community members are not aware of what the true cost to build a school will be (i.e. how much will the construction plus addition infrastructure cost).  Government themes include: decision points; conflict resolution; and inter-agency coordination and communication. ‘Decision points’ refers to which organization has the final say in a school siting decision. Should it be the local school board, the school district, the local government, or a state agency that has the final decision for if and where a school should be built? Other themes include: inclusion of charter and parochial schools in a siting policy; transition strategies between the status quo and widespread use of a set of guidelines or a regulatory system related to siting; and site-specific considerations. These grouping could not fit P a g e | 6 in one specific category. Within all of these groupings, there were overarching themes that were addressed in each grouping. These themes include: the overall issues of transportation; site assessments and review processes; feedback on policy efficacy; outcomes of monitoring efforts; third party consultations; and safe routes to school program involvement Within these broad groupings of school siting considerations, we then developed separate “stringent,” “moderate,” and “lenient” policy recommendations for the ways that school districts could address each factor. Stringent policy recommendations often involve mandatory regulations and aim to minimize health risks associated with school sites to the greatest extent possible. However, these considerations may face funding questions and political barriers in the legislative process. Alternatively, lenient recommendations seek to create beneficial health outcomes, but through a system that makes few reforms to the status quo and requires very little financially. Our moderate recommendations offer a middle-ground between these two points. The policy recommendations found in our report are a synthesis of the Rhode Island Legal Institute’s foundational work, the EPA guidelines, interview feedback, lessons from siting policies implemented in other states, specific considerations for the state of Michigan, and, finally, contributions of new criteria for the school siting process. Ultimately, interested readers of this report can use the information and options that we provide to craft a well-reasoned policy based on the current climate of the state. A listing of complete policy recommendations can be found in Appendix I. Conclusion Michigan needs to enact a school siting policy that aims to promote the health and wellbeing of this state’s children. Since children are mandated to attend schools for a significant portion of their day, it is imperative that we foster a healthy environment in which they can thrive. Our policy recommendations provide a variety of avenues through which legislators can achieve this goal.