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AG Nessel Joins Comment Letter in Support of Biden Administration’s Ocean Justice Strategy

LANSING Michigan Attorney General Dana Nessel joined a California-led coalition of six attorneys general in submitting a comment letter in support of the Biden Administration’s development of a national Ocean Justice Strategy. Certain communities (ocean justice communities) have been historically excluded from ocean policy decisions — including Black, Indigenous, people of color (BIPOC) communities, as well as people with disabilities, low-income communities, the youth, and the elderly — and ocean justice aims to address those disparities. 

"The Ocean Justice Strategy seeks to reverse policies related to our coastal areas and shoreline communities that, historically, have adversely affected disadvantaged communities and communities of color,” said Nessel. “This strategy will take steps to right those wrongs to give all residents a chance to enjoy the resources of Michigan's Great Lakes. I proudly stand with my colleagues in supporting the Administration's plan to achieve justice for coastal communities, including those along the Great Lakes."   

The Council on Environmental Quality, which was created by the National Environmental Policy Act in 1969 and is within the Executive Office of the President, published a Request for Information on June 8, 2023, seeking public input on what the vision and goals of the Ocean Justice Strategy should be. The California-led comment letter responds to that request.  

In the comment letter, the California-led coalition suggests the following objectives for inclusion in the Ocean Justice Strategy:  

  • Equitable public access to the oceans, coasts, and the Great Lakes. The states encourage the federal government to partner with them to secure equitable public access to the coasts by, among other things, leveraging federal funding to improve coastal access amenities for ocean justice communities and exploring pathways to allow public access to coastal areas on or through federal property. 
  • Alleviate the impacts of air pollution sources on nearby ocean justice communities. Ocean justice communities are disproportionately affected by air pollution from coastal and maritime sources like refineries, oil and gas terminals, power plants, diesel-powered ships, and cargo equipment and diesel trucks at ports. 
  • Comprehensively identify all of the disparate harms ocean justice communities face from various sources of pollution. In addition to air pollution, ocean justice communities suffer disproportionate harm from other sources that affect their health and livelihoods, including water pollution that affects local fisheries, toxic and hazardous waste sites, and agricultural run-off. 
  • Equitable management and protection of the oceans, coasts, and the Great Lakes. The states encourage the federal government to implement co-management of the oceans, coasts, and the Great Lakes with Tribes and Indigenous Peoples. The states also recommend increasing funding to the National Oceanic and Atmospheric Administration (NOAA), which is charged with enforcing environmental laws on over 4 million square miles of ocean.
  • Addressing and mending past harms and injustices. To address past inequitable takings of coastal property from ocean justice communities — whether under the guise of eminent domain or by physical force — the Ocean Justice Strategy should mend these grave injustices and follow the lead of states and localities that are already working to do so.
  • Equitable adaptation to climate change. As sea levels rise and threaten coastal infrastructure, the federal government should ensure that its coastal adaptation strategies do not inadvertently exacerbate burdens on ocean justice communities.
  • Meaningful engagement of ocean justice communities early in the process of any federal action. The federal government should create a community advisory board made up of local residents and tribal communities to review and provide feedback on project proposals, as well as conduct community meetings at times and locations convenient to members of the affected community, such as during after-work hours from 6:00 p.m. to 9:00 p.m., and at locations within the community, such as recreation centers and libraries.  

In submitting the comment letter, Attorney General Nessel joins the attorneys general of California, the District of Columbia, Maryland, Massachusetts, and New York.  

A copy of the comment letter is available here (PDF).


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