RE: Comments on Proposed Draft Construction Permit to GIII, LLC
Dear Mr. Guy,
Thank you for the opportunity to provide comments on GIII, LLC’s (“GIII”) request to construct a recycling facility at 11600 S. Burley Avenue in Chicago. The Metropolitan Planning Council has a longstanding interest in healthy, thriving rivers and racially equitable development policies. As we consider the environmental racism and poor planning embedded in this proposal, we urge the Illinois EPA to deny GIII’s construction permit.
The most important reason to deny this permit is because it epitomizes institutional environmental racism. Racist outcomes do not require racist intent. We do not know the intent behind the permit request, nor of the reviewers, and we are not claiming to. But based on the following three components, we are confident of the outcome.
- Racially unjust siting. Put frankly: GIII is proposing to relocate a harmful industrial use from a wealthier, whiter part of the city to one that has more black and brown residents. Again, racist outcomes do not require racist intent. The outcome of this relocation is to remove a health hazard from an affluent white neighborhood and place it in a lower-income Latinx neighborhood. Institutional racism, intentionally or not, produces outcomes that chronically favor or disfavor racial groups. That is exactly what a permit for this would do. This is most assuredly a racist outcome.
- Compounding health hazards already exist for low-income communities of color in the Calumet Industrial Corridor, and would be worsened by this. This relocation would layer yet another health hazard on top of the overlapping health threats that already exist near the proposed site. The site is located within the Calumet Industrial Corridor and the greater Calumet region, where multiple industries contribute to poor air quality. Compared to citywide averages and most other industrial corridors in Chicago, there are higher rates of chronic obstructive pulmonary disease and heart disease within this corridor, signaling existing negative health impacts. Some of these compounding health effects are spelled out in additional detail in a letter submitted to your office by NRDC and signed by groups throughout the state (including MPC). Residents of the Southeast Side should not be asked to bear yet another health burden.
- Insufficient participatory process. The public outreach process undertaken was insufficient, meaning that a Latinx community was effectively left out of the decision-making process. The insufficiencies of that process - for instance, outreach meetings held in only in English, a language which many residents of the community do not speak - have been documented in the aforementioned letter submitted to your office.
In addition to - and in many ways because of - the environmental racism embedded in this relocation proposal, it also represents poor land-use planning.
Find a PDF of the full statement