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RMG/SOUTHSIDE RECYCLING HIA:Process and LessonsMay 18, 2022

AGENDA Background on the RMG/Southside Recycling Permit HIA Process– Values– Screening & Scoping– Assessment– Decision-Making Lessons LearnedPLANNING DOCUMENT - NOT FOR DISTRIBUTION**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**2

BACKGROUND3**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

RMG/SOUTHSIDE RECYCLING Reserve Management Group (RMG) is anOhio based metal recycling company Purchased General Iron, then operating inLincoln Park, in 2019 Seeking permit for Southside Recycling at11600 S. Burleyo Planned Manufacturing District (PMD) 6oCalumet Industrial Corridor Has operated recycling facilities in the wardfor 30 years Would accept scrap metal, including end oflife vehicles, for processing and recycling4**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

PERMITTING TIMELINESouthside Recycling LRFpermit applicationsubmittedBUILDINGpermits approvedZONINGapproved2019CDPH permitreviewsuspendedLarge RecyclingFacility (LRF) rulesadopted20202021CommunityTown Hall #1ILLINOIS EPApermit approvedCDPH permitdenied, HIAreleased2022HIA engagementsessionsCommunity Town Hall #2,public comment period,deficiency letter5**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

HIA PROCESS:VALUES6**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

HEALTHY CHICAGO 2025 CDPH’s citywide community healthimprovement plan Goal is to close the racial lifeexpectancy gap: 10 years betweenBlack and white Chicagoans, lifeexpectancy declining for Latinx Focus on the root causes of health –including institutional racism – andsupporting community power indecision-making7**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

EQUITY & ENVIRONMENTAL JUSTICEEquity is both an outcome and aprocess that results in fair and justaccess to opportunity andresources that provide everyonethe ability to thrive.Source: Illustration by Ricardo Levins Morales Define the problem/opportunity Acknowledge history Compare conditions on Southeast Side to non-EJcommunity areas Look at numbers and narratives Shift power through authentic engagement Measure the benefits and burdens Embrace transparency and accountability Commit to actionSources: Chicago's Equity Statement of Principles; Health and Race Equity ImpactAssessment Guiding Questions, developed by HREIA Community Accountability Committee**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**8

HIA PROCESS:SCREENING & SCOPING9**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

SCREENING FACTORS10**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

SCOPING PROCESSPre-HIAInput CDPH reviewedand themedinput fromhearings,comments,mediaInitial HIAScoping CDPH aydiagramCommunityEngagement Communityprioritizedimpacts forassessmentduring HIAengagementsessionFinal HIAScoping CDPH updatedpathwaydiagram andresearchquestions,definedgeographicscope“As a business owner myself in the10th Ward, I would question whya city that is losing revenue andpopulation daily would not besupporting a local business thathas been in this community forover 29 years, they provide aliving wage that feeds andsupports local families andchildren.”11**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

HIA RESEARCH QUESTIONS What are the current community conditions on theSoutheast Side? What are the potential impacts of the proposedSouthside Recycling operations on the environment,health, and quality of life for Southeast Side residents? Who would benefit and who would be burdened by adecision to grant the permit? How could we minimizeburdens and maximize benefits? What could we learn through this process about waysto improve City and other policies and practices topromote health and racial equity?12**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

PATHWAY DIAGRAM13**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

GEOGRAPHIC SCOPE14**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

HIA PROCESS:ASSESSMENT15**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

MIXED ion Plans-Traffic Study-Zoning MaterialsCOMMUNITYINPUT ANALYSIS-2 town halls-4,000 publiccomments-Media monitoring-Facilitated smallgroup discussionsand surveysEXISTINGCONDITIONSANALYSISENVIRONMENTALAND HEALTH RISKASSESMENTLITERATUREREVIEW-Public health datasets-U.S. EPA AmbientAir Quality Report-ATSDR HealthConsultation-Emissions inventoryand calculations-EJ and cumulativeimpact frameworks-On-site soilsampling-Mental health andwell-being-Risk modelingPLANNING DOCUMENT - NOT FOR DISTRIBUTION16

VALUING LIVED EXPERIENCE17**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

HIA PROCESS:DECISION-MAKING18**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

IMPACT RATING19**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

FACTORS FOR PERMIT DECISION-MAKING Extent of current community burden and vulnerability Extent of potential benefits to Southeast Side residents Extent of potential negative impacts on environment, health, and qualityof life that cannot be adequately addressed through mitigations Actions of the company, including compliance history20**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

HIA PROCESS:LESSONS LEARNED21**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

PROCESS, TOOLS & METHODS Need for new frameworks that unite racial equity impact assessment, EJ analysis,and traditional environmental impact and human health risk assessment– Lends to interdisciplinary, mixed methods approach– Consider organizing around conceptual model and research questionsrather than pathways given complex, interrelated impacts– Requires deriving from theory, literature review Develop screening tools for when/how HIA will be applied– Challenging to ‘retrofit’ the HIA onto an ongoing permitting process Conduct process evaluation to show accountability and honest reflection– Ensure process meets the HIA minimum elements, strive for best practices22**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

EQUITY & STAKEHOLDER ENGAGEMENT Consider how to advance equity and engagement given the decision context– E.g., legal constraints, timeline, status of community partnerships Successful, authentic engagement takes specialized expertise– Support needed for facilitation, conflict resolution, trust building Use tools like the Spectrum of Public Participation to determine how thecommunity will be involved in each step of the HIA– Be clear about when you are informing versus co-designing Consider how to proactively engage media to shift public narratives– Media has a strong influence on public perception and trust23**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

CORE ELEMENTS OF HIAGoing back toour equity andengagementvalues . Define the problem/opportunity Acknowledge history Compare conditions to non-EJ community areas Look at numbers and narratives Shift power through authentic engagement Measure the benefits and burdens Embrace transparency and accountability Commit to action24**CONFIDENTIAL AND PROPRIETARY INFORMATION SUBJECT TO PROTECTION UNDER THE TRADE SECRETS ACT AND FOIA EXEMPT**

RMG/SOUTHSIDE RECYCLING Reserve Management Group (RMG) is an Ohio based metal recycling company Purchased General Iron, then operating in Lincoln Park, in 2019 Seeking permit for Southside Recycling at 11600 S. Burley o Planned Manufacturing District (PMD) 6 o Calumet Industrial Corridor Has operatedrecycling facilities in the ward