Issues Of The Environment: Setting School Siting Guidelines To Reduce Environmental Hazards
Michigan currently does not have a statewide approach to school siting that takes into account environmental quality. More than 40 percent of schools in Michigan are located near major sources of air pollution. What can be done about it now? On this week's "Issues of the Environment," WEMU's David Fair talks with Dr. Paul Mohai from the U of M's School for Environment and Sustainability on ways to address these questions.
- A new report, “Michigan School Siting Guidelines: Taking the Environment into Account,” addresses the need for considering environmental factors when assessing and determining the location of public schools. This is also an issue of environmental justice, as a larger percentage of black, Hispanic, or economically disadvantaged children attend schools nearest to pollution emissions than white students.
- In their report, the authors state: “Michigan currently does not have a statewide approach to school siting that takes into account environmental quality. In 2011, the United States Environmental Protection Agency released national voluntary School Siting Guidelines, calling on states to develop and implement their own school siting and environmental cleanup standards. A number of states have done so...”
- Dr. Paul Mohai (University of Michigan - SEAS) and Dr.Byoung-Suk Kweon (University of Maryland), have studied the impact of environmental quality and school performance in Michigan for many years. Their research has shown that:
- Schools located closer to highways and industrial facilities had higher risks of respiratory and neurological diseases than those located farther away. We also found that schools located closer to major highways had a higher percentage of students failing to meet the state standards.
- A large and growing body of evidence shows that pollution burdens fall disproportionately on low-income and racial or ethnic minority communities. Students of the schools with the worst pollution had lower educational attainment, poorer health, and more absences. Policy suggestions include requiring environmental assessments of all school sites and providing remediation as needed. Half of the states, including Michigan, do not require any evaluation of the environmental quality of areas under consideration as sites for new schools, nor do they prohibit siting new industrial facilities and highways near existing schools.
2020 Report Outlines Recommendations as to Where Schools Should be Located Based on Environmental Quality
A new report, “Michigan School Siting Guidelines: Taking the Environment into Account,” addresses the need for considering environmental factors when assessing and determining the location of public schools. Drs. Paul Mohai (SEAS) and Byoung-Suk Kweon (University of Maryland) were the principle investigators on the report that was released on July 3, 2020.
In their report, the authors state: “Michigan currently does not have a statewide approach to school siting that takes into account environmental quality. In 2011, the United States Environmental Protection Agency released national voluntary School Siting Guidelines, calling on states to develop and implement their own school siting and environmental cleanup standards. A number of states have done so, and, with support from the Kresge Foundation, the Michigan School Siting Task Force — a group of scholars, policy professionals, Michigan legislators, and members of non-governmental organizations and Michigan’s school communities — has worked to identify tools and best practices that could facilitate healthy school siting decisions in Michigan.”
The purpose of Mohai and Kweon's report was to explain the need for a school siting policy in Michigan, document the work of the School Siting Task Force, evaluate the resources available for developing a school siting policy, and provide recommendations for a school siting policy for the State of Michigan. Their report documents that their work is intended to stimulate policy debate and timely concrete action among Michigan legislators, policy advocates, and school communities. Its ultimate goal is to galvanize state lawmakers to develop a statewide school siting policy in Michigan that safeguards students’ health and well-being.
In 2017, a group of state Democratic lawmakers introduced a seven-bill package that called for the creation of a plan to annually test water and air quality in every Michigan school and to create an environmental education task force. Mohai spoke at the ensuing press conference, saying children cannot choose where they live or attend school, and they are especially vulnerable to environment toxins. “This makes it especially important they go to schools in clean, healthy and safe environments. In our research, we have found more than 40 percent of schools in Michigan are located near major sources of air pollution,” Mohai said.
Read the story in the 2017 Detroit News article. A link to the full report, "Michigan School Siting Guidelines: Taking the Environment into Account" can be found on the Deep Blue website. (Source: *directly quoted* https://seas.umich.edu/news/michigan-school-siting-guidelines)
Children with consistent exposure to air pollution have increased asthma, chronic respiratory problems, and neurobehavioral dysfunction. However, many schools are located in close proximity to highways and industrial facilities which are key sources of air pollution to children. The goal of this study is to explore the association between the proximity from schools to highways and industrial facilities, and children’s school performance and health hazards. We measured the distances from 3,660 Michigan public schools to highways and industrial facilities, and linked these to the Michigan Educational Assessment Program test performance rate and the National Air Toxics Assessment’s respiratory and neurological hazards. We found that schools located closer to highways and industrial facilities had higher risks of respiratory and neurological diseases than those located farther away. We also found that schools located closer to major highways had a higher percentage of students failing to meet the state standards than the latter after controlling for the location of schools, student expenditure, school size, student–teacher ratio, and free lunch enrollment. In addition, a larger percentage of black, Hispanic, or economically disadvantaged children attended schools nearest to pollution emissions than white students. (Source: *directly quoted* https://journals.sagepub.com/doi/pdf/10.1177/0265813516673060)
ABSTRACT - Exposing children to environmental pollutants during important times of physiological development can lead to long-lasting health problems, dysfunction, and disease. The location of children’s schools can increase their exposure. We examined the extent of air pollution from industrial sources around public schools in Michigan to find out whether air pollution jeopardizes children’s health and academic success. We found that schools located in areas with the highest air pollution levels had the lowest attendance rates—a potential indicator of poor health—and the highest proportions of students who failed to meet state educational testing standards. Michigan and many other states currently do not require officials considering a site for a new school to analyze its environmental quality. Our results show that such requirements are needed. For schools already in existence, we recommend that their environmental quality should be investigated and improved if necessary.
There are more than fifty-three million schoolchildren and more than 135,000 public and private schools in the United States. 1 Are these schools safe and healthy places for children to grow, play, and learn? Or are we exposing children to unhealthy pollution?
Children are known to be more vulnerable than adults to the effects of pollution. Exposure to environmental pollutants during important times of physiological development can lead to long-lasting health problems, dysfunction, and disease. 2 Children’s lung functioning is not yet fully developed. 3–5 Compared to adults, they breathe in greater levels of polluted air relative to their weight and spend more time outside when air pollution levels are the highest. 5 And because of differences in metabolism, mouthing behavior—such as the tendency to put their hands and objects in their mouths—and respiratory rates, children are often exposed to higher levels of lead, arsenic, pesticides, and other pollutants. 4 Moreover, children have little or no choice about where they live or go to school.
Childhood is a critical period for brain formation. Researchers have shown that children exposed to air pollution perform worse on cognitive functioning tests 6 and have impaired neurological function 7–9 and lower IQ scores 10 compared with other children. Also, children exposed to high levels of nitrogen dioxide—a common air pollutant generated by the burning of fossil fuels—have been found to have “decreases of 6.71, 7.37 and 8.61 points in quantitative, working memory and gross motor areas, respectively.” 11
Similarly, children with high levels of exposure to nitrogen dioxide and particles 10 micrometers or less in the air—a standard used by the Environmental Protection Agency (EPA) to measure air quality—perform significantly worse on neurobehavioral tests, even after confounding variables are controlled for. 6 In one example of this kind of test, to measure line discrimination, the subject is instructed to hit the space bar on a computer keyboard within a second after seeing a long line, when being presented with long and short lines. And children with high levels of estimated exposure to black carbon—tiny particles released into the air by diesel exhaust, for example—have a decreased ability to perform well on both verbal and nonverbal intelligence and memory assessments, such as the Kaufman Brief Intelligence Test and the Wide Range Assessment of Memory and Learning. 10
A large and growing body of evidence shows that pollution burdens fall disproportionately on low-income and racial or ethnic minority communities. 12–15 There is little evidence of disproportionate pollution burdens on children in these groups. However, a recent study by Manuel Pastor and his colleagues 16 found that California students in these categories were disproportionately exposed to high levels of respiratory risks from outdoor air pollution. Furthermore, the authors found that such exposure was associated with lower performance on standardized tests, even after controlling for important confounding variables such as school size, suburban—as opposed to urban or rural—location, and demographics of the student body.
The risks of air pollution around public schools were highlighted in a series of articles in USA Today. 17 The series provided estimates of air pollution from industrial sources for more than 125,000 schools in the United States, using data from the EPA. Schools were ranked based on the estimated pollution burdens around them. The USA Today analysis prompted the EPA to conduct a study of its own, and it selected sixty-four schools nationwide (two were in Michigan, where we conducted our study) for air quality monitoring, the results of which have been posted online by the agency. 18 However, neither USA Today nor the EPA examined the links between air pollution, health, and academic performance. Nor did they examine demographic disparities related to pollution burdens around schools.
School siting policies should protect children from their vulnerability to environmental pollution. However, many states do not have any school siting policies. 19 According to a 2006 survey, only fourteen states prohibit or severely restrict school districts from siting schools on or near sources of pollution or hazards that might pose a risk to children’s health. 20 Twenty-one states have policies suggesting that officials “avoid” siting schools on or near specified manmade or natural environmental hazards, or “consider” those hazards when selecting school sites.
In November 2010, the EPA released a draft of voluntary school siting guidelines. 1 The draft guidelines recommend an initial assessment of air quality around a potential school site using existing data, such as the agency’s air quality monitoring data or data from its National Air Toxics Assessment. 21 Although the guidelines do not propose maintaining minimum distances between schools and highways, factories, airports, rail lines, or other potential environmental hazards, they do recommend mitigating the effects of such hazards by using noise barriers, vegetation, or buildings. The agency says that “the guidelines are intended to assist communities and community members in making the best possible school siting decisions.” 1 However, one critic has expressed concern that the voluntary guidelines might not be strong enough and could be ignored by many school districts. 22
Children’s health and well-being are viewed by many as top priorities in American society, but links between air pollution and children’s school performance and health have received little attention and are not well understood. Our study started with three questions: Do public schools tend to be located in areas of less or more air pollution, compared to average or median levels for the state, the metropolitan area, and the school district? Are disparities in pollution burdens related to the demographic characteristics of the student body? And are levels of air pollution linked to student performance and health?
AIR POLLUTION AND SCHOOL DEMOGRAPHICS - The demographics of the schools’ student bodies followed a similar pattern. We found that 44.4 percent of all white schoolchildren in the state attended schools located in grid cells in the 10th (most polluted) decile, but 81.5 percent of all African American schoolchildren and 62.1 percent of all Hispanic schoolchildren did so. In those schools, 62.2 percent of all students were enrolled in the free lunch program, our chief socioeconomic indicator ( Exhibit 3 ).
AIR POLLUTION, HEALTH, AND ACADEMIC PERFORMANCE - Are air pollution burdens around schools linked to student health and performance? Although we cannot conclusively establish cause and effect linkages from our macrolevel analysis, we can nevertheless examine associations and rule out obvious confounding variables, such as school demographics, school expenditures, and locations (suburban versus urban or rural) of schools. 16 And we can determine how robust the associations are, and whether they warrant concern.
CHEMICALS IN THE AIR - We found that 95 percent of the estimated total air pollution concentrations around the schools came from twelve chemicals: diisocyanates, manganese, sulfuric acid, nickel, chlorine, chromium, trimethylbenzene, hydrochloric acid, molybdenum trioxide, lead, cobalt, and glycol ethers. The chemicals are listed in order, with diisocyanates contributing the most to pollution, and glycol ethers the least. These chemicals come from a variety of sources, including the motor vehicle, steel, and chemical industries; power plants; the manufacturers of rubber and plastic products; and the manufacturers of wood products. The chemicals are suspected of producing a wide variety of health effects, including increased risk of respiratory, cardiovascular, developmental, and neurological disorders, as well as cancer. 27
Some of the chemicals, such as lead and manganese, may have direct effects on brain functioning and hence children’s ability to perform well in school. 28 However, chemicals that have other health effects, including carcinogens and those that increase the risk of respiratory disorders, may also result in absences from school and otherwise impair students’ ability to perform well.
SCHOOL ATTENDANCE RATES - Because direct measures of health at the level of the individual school are not available in Michigan, we used school attendance rates as a proxy for health outcomes. We found that attendance rates were lower in schools with greater concentrations of pollution around them. This relationship was not linear, so we sorted the schools into quintiles based on the total estimated air pollution concentration within two kilometers. Although attendance rates did not vary appreciably for schools in the first three quintiles, we found statistically significant decreases in these rates for schools in the fourth and fifth quintiles. This was true even after we controlled for confounding variables, such as the rural, suburban, or urban location of the school; average expenditure per student; size of the student body; student-teacher ratio; and percentage of students enrolled in the free lunch program (see Appendix Exhibit 1). 24
STUDENT PERFORMANCE IN ENGLISH AND MATH - Our next step was to determine whether a relationship existed between pollution levels around the schools and the percentage of students who failed to meet the Michigan Educational Assessment Program standards for English and math. We first examined the overall pattern between pollution levels around the schools and the percentages of students failing to meet the state standards. As with attendance rates, we found that this relationship was not linear, so again we looked at quintiles of schools based on the total estimated air pollution concentration within two kilometers.
We first examined performance on the English tests. For each grade level for the schools in each quintile of pollution, we determined the average percentage of students who failed to meet the standards. As Exhibit 4 shows, there was no appreciable difference in the average percentages of students failing to meet the standards for English among the schools in the first, second, and third quintiles. However, there were distinct increases in these percentages for schools in the fourth and fifth quintiles. This was true for every grade level. We next examined performance on the math tests and obtained nearly identical results .
CONCLUSIONS AND POLICY IMPLICATIONS - Our findings show that schools in Michigan were disproportionately located in places with high levels of air pollution from industrial sources, whether the basis of comparison was the median level for the state or the school’s metropolitan area or school district. Fewer than half of the white students in the state (44 percent)—but substantial majorities of African American students (82 percent), Hispanic students (62 percent), and students enrolled in the free lunch program (62 percent)—attended schools in the most polluted (by industrial sources) 10 percent of the state.
Furthermore, schools located in areas with the highest pollution levels also had the lowest attendance rates (a potential indicator of poor health) and the highest proportions of students failing to meet the state’s educational testing standards. These associations remained statistically significant even when we controlled for important confounding variables such as schools’ locations (urban, suburban, or rural), spending per student, and school socioeconomic characteristics. Because of the lack of available data, we could not control for all possible confounding variables. Future studies should include variables such as parental education levels; language and cultural differences; and crowding, natural versus artificial light, and ventilation in the classroom, which might influence children’s school performance as well.
What explains these patterns, and what should be done about them? Because little attention to date has been given to the environmental quality of where schools are located, it is difficult to pinpoint all of the possible causes of the patterns we found. The large amount of land that a school requires and the costs of land acquisition probably mean that officials searching for new school locations focus on areas where property values are low, which may be near polluting industrial facilities, major highways, and other potentially hazardous sites. 29
A recent survey of Michigan school superintendents verified the fact that land availability and cost are a major consideration in school siting decisions. When the superintendents were asked to rank various considerations in school boards’ decisions about where to locate new schools, the two most important considerations were the availability of land and whether the school district already owned the land. 30
Half of the states, including Michigan, do not require any evaluation of the environmental quality of areas under consideration as sites for new schools, nor do they prohibit siting new industrial facilities and highways near existing schools. This makes it likely that new schools will be built in undesirable locations to keep the cost of land acquisition down.
Our findings underscore the need to expand the concept of environmental justice to include children as a vulnerable population. They are required to attend school and have little or no say in where they live or go to school, which makes them particularly dependent on governmental policies to protect them from harm. Moreover, as our findings show, children of color are disproportionately at risk.
There is a need for proactive school policies that will protect children from exposure to unhealthy levels of air pollution and other environmental hazards. To achieve that goal, we make four policy recommendations, which we discuss in turn: site analysis, minimum distance requirements, environmental mitigation, and multilevel cooperation.
ANALYZE POTENTIAL SCHOOL SITES - Our first policy recommendation is that potential school sites be thoroughly analyzed. The analysis should include testing the quality of the soil, water, and air; inventorying nearby sources of pollution, such as highways, industrial facilities, power plants, and airports; investigating previous and current uses of the land; and studying the local climate—that is, characteristics such as usual wind direction and wind tunnels—topography, and other physical aspects of the site.
The quality of the environment around existing schools should also be evaluated, and steps taken to address unsafe conditions.
REQUIRE MINIMUM DISTANCES BETWEEN SCHOOLS AND POLLUTION SOURCES - Second, policies need to be enacted that insist on a minimum distance between sources of pollution and school locations. The locations of existing schools need to be taken into account when considering new highways, industrial facilities, and other potential sources of contamination. Currently, only seven states (California, Florida, Indiana, Kentucky, Mississippi, Utah, and West Virginia) prohibit locating schools near sources of pollution such as factories, plants, stables, mills, and stockyards. Six of the seven states do not mandate any specific distance. Only Indiana specifies a minimum distance: 500 feet from a school to a source of pollution, a distance too small to completely protect children from environmental hazards. Even though no previous research indicates what is a safe distance, pollution levels generally decrease with greater distance from the sources of the pollution. 31,32
ADOPT POLICIES TO REDUCE EXPOSURE - Third, environmental mitigation policies should be adopted, to reduce children’s potential exposure to pollution. It may be particularly important to implement mitigation approaches in urban settings where land is scarce, and where sites for schools away from sources of pollution are difficult to find. California and Florida allow schools to be built on previously polluted sites if the pollution has been cleaned up and removed, and children attending the school will not be exposed to contaminants.
Improving indoor air quality and minimizing the infiltration of air pollution into school buildings are other mitigations that may reduce exposure to contaminants. The EPA created its voluntary Indoor Air Quality Tools for Schools Program 33 to improve indoor air quality for children. The program provides an action kit that describes best practices (such as painting with organic compounds that are not very volatile), industrial guidelines (cleaning carpets according to manufacturers’ guidelines), sample policies (banning bus idling), and a sample management plan. Jerome Paulson and Claire Barnett recommend regulating indoor air quality for schools with standards that are “appropriate to children’s higher respiration rate[, which] enhances vulnerability to toxins.” 34
These efforts should improve the current environmental conditions of schools, but they should not be used as a way to make up for poor school siting decisions.
ENSURE COOPERATION AMONG AGENCIES - Finally, oversight and enforcement at the national, state, and local levels are needed to ensure better school environments. Until the EPA’s recent draft voluntary school guidelines, 1 the federal government had little involvement in school siting policy. And although the guidelines address a wide range of issues, because the guidelines are voluntary, they may be ignored. Nevertheless, state and local agencies interested in creating healthier schools can benefit from the EPA’s scientific knowledge, technical expertise, and environmental data.
State environmental agencies already cooperate with the EPA in regulating the redevelopment of brownfields—properties that contain or may contain some hazardous substance whose presence affects any future use of the properties. And brownfield redevelopment and school siting have been linked. Alison Cohen reports that because of the problem of land availability, brownfields are often considered as viable sites for schools. 35 However, building schools in previous brownfields requires great caution. The standards for cleaning brownfields up are not necessarily high enough; Michigan lowered its standards in 2000, for example. 36 Thus, state environmental agencies should develop stringent standards for cleaning up brownfields intended as school sites.
All relevant national, state, and local stakeholders—including school administrators and health officials, parents, teachers, industry and community leaders, public health professionals, environmental scientists, and educational policy makers—need to work together to develop policies that will ensure safe learning environments for schoolchildren. In states such as Michigan, school districts are mainly responsible for deciding where to build new schools. 30 However, previous cooperation between the EPA and state agencies demonstrates that different levels of government can work together on these issues. Indeed, they must, if we are to protect the health and enhance the learning environment of the nation’s children. (Source: *directly quoted* https://www.healthaffairs.org/doi/full/10.1377/hlthaff.2011.0077)
School Siting Bills - Michigan 2017
A group of state Democratic lawmakers introduced a seven-bill package on Monday that calls for the creation of a plan to annually test water and air quality in every Michigan school and create an environmental education task force.
The bills — announced by state Reps. Stephanie Chang, D-Detroit; Darrin Camilleri, D-Brownstown Township; Kristy Pagan, D-Canton Township; and Robert Wittenberg, D-Oak Park — would help local schools improve the health and wellness of students and staff, reduce environmental impact and energy costs and address environmental understanding.
The bills, which will be formally introduced on the House floor on Tuesday, would:
- Require environmental assessments be conducted for any proposed school construction site or addition to an already acquired site.
- Require the state Board of Education to revise its local wellness policy to include a plan for testing water and air quality in every school.
- Create a one-time, $9 million supplemental appropriation for water- and air-quality testing and remediation in schools.
- Encourage each school building in a district to conduct an energy audit every three years to identify potential efficiencies and conservation improvements.
- Create a task force to develop a curriculum to help students understand and address environmental challenges, contribute to students’ healthy lifestyles and provide activities and programs that advance environmental education.
“Given recent events in our state regarding water and air quality, it’s vital that our schools regularly conduct tests to ensure that our students are drinking clean water and breathing clean air. This package protects students’ longterm health, while also giving parents and families the certainty they deserve about the environmental standards of their child’s school,” Camilleri said.
Chang said studies show school location and air pollution are linked to student attendance and academic performance.
“So if we want our kids to be healthy enough to attend school and to do well in school, then we need to make sure they have a healthy school environment,” Chang said. “These bills outline steps our schools and the state can take, such as my bill that addresses school siting, to create a healthier physical environment for our students.”
Paul Mohai of the School for Environment and Sustainability at the University of Michigan spoke at the press conference, saying children cannot choose where they live or attend school, and they are especially vulnerable to environment toxins. “This makes it especially important they go to schools in clean, healthy and safe environments. Our research we have found more than 40 percent of schools in Michigan are located near major sources of air pollution,” Mohai said.
Emile Lauzzana, director of Community-Michigan for the U.S. Green Building Council, joined lawmakers Monday morning for the announcement. According to Lauzzana, 18 Michigan schools have achieved LEED standards and efficiencies in their buildings. Twelve other states have laws similar to what is being proposed in Michigan, he said. “States with green school policies teach students to lead in a changing world and demonstrate a commitment to fiscal responsibility, good job growth, and healthy, high-performance facilities,” Lauzzana said.
The legislators also announced the formation of the Better Classroom Caucus, which Wittenberg will chair, to address the environmental and health factors in schools. (Source: *directly quoted* https://www.detroitnews.com/story/news/local/detroit-city/2017/09/18/bills-improve-classroom-environment-michigan-detroit/105757578/)
Dr. Paul Mohai
Professor Mohai’s teaching and research interests are focused on environmental justice, public opinion and the environment, and influences on environmental policy making. He is a founder of the Environmental Justice Program at the University of Michigan and a major contributor to the growing body of quantitative research examining disproportionate environmental burdens and their impacts on low income and people of color communities. In 1990, he co-organized with Dr. Bunyan Bryant the “Michigan Conference on Race and the Incidence of Environmental Hazards”, which was credited by the U.S. Environmental Protection Agency as one of two events bringing the issue of Environmental Justice to the attention of the Agency. He is author or co-author of numerous articles, books, and reports focused on race and the environment, including “Environmental Racism: Reviewing the Evidence”, “Race and the Incidence of Environmental Hazards”, “Toxic Waste and Race at Twenty”, and “Which Came First, People or Pollution?” His current research involves national level studies examining the causes of environmental disparities and the role environmental factors play in accounting for racial and socioeconomic disparities in health. Through a grant from the Kresge Foundation, he is also examining pollution burdens around public schools and the links between such burdens and student performance and health.
Professor Mohai is a past member of the National Environmental Justice Advisory Council (NEJAC) to the U.S. Environmental Protection Agency (2007-2013). He is currently a member of the Governor’s Environmental Justice Work Group charged with developing an Environmental Justice Plan for Michigan. (Source: *directly quoted* https://seas.umich.edu/research/faculty/paul-mohai)
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