This letter was submitted by the the Administrator of Oregon’s Office of Environmental Public Health by invitation from the Oregon Department of Planning and Development and is their response to a review of the “Big Look: Choices for Oregon’s Future” draft report. -SO (EB co-editor)
Thank you for the opportunity to comment on your department’s “Big Look: Choices for Oregon’s Future” draft report (Report). Oregon’s Public Health Division is charged with “protecting and promoting the health of the people of Oregon” within the Department of Human Services’ (DHS) mission to help people become independent, healthy and safe. The Big Look report holds promise for furthering that mission and we greatly appreciate your commitment to solicit feedback to build a shared vision of Oregon’s future.
Toward that end, we offer the following comments on the May 30, 2008 draft report for your consideration. In addition to some broader statements, this letter provides more specific comment on individual sections of the draft report.
Overall, we encourage the Department of Land Conservation and Development (DLCD) and the Big Look Task Force (Task Force) to identify and address the very real connections between land use and human health. Such recognition can begin by re-stating the overarching principles to specifically include protecting and promoting human and community health. Ensuring people are aware of the adverse human health impacts from unplanned or poorly planned land development can protect both the land and the people of our state.
Assuring Oregon landscapes support healthy people and communities can be a powerful motivating factor for intelligent land use decision-making. To assist in this regard, Health Impact Assessments, either singly or as part of an Environmental Impact Statement, Environmental Assessment or other environmental review, are increasingly recognized as a critical diagnostic and policy tool to identify and evaluate development options. DHS is moving into this arena, and is committed to collaborating with its local public health partners to support sustainable land use decisions and statewide programs that protect and promote health.
Specific comments regarding proposed recommendations follow:
Introduction
Chronic diseases are killing and crippling Oregonians at high and increasing rates. These diseases are recognized by medical and public health experts as linked to environmental conditions that can be improved by thoughtful planning
Resource Lands and Rural Areas
Reliably safe and clean drinking water is an essential resource for Oregonians, and thus should be mentioned in this section. Some current land development and land use practices threaten the quality and reliability of drinking water supplies. Key surface waters and groundwater recharge areas should be a top priority for protection, in order to land development principles to be effective at meeting the needs of Oregonians in all parts of the state in the future.
Protecting Oregon’s drinking water sources is essential. DHS, in partnership with the Department of Environmental Quality (DEQ), has assessed risks to drinking water from nearby land uses, and we urge local governments to use these published risk assessments as a key factor in considering approval of land use and zoning applications.
Growth Management
Current Problems
Growth management policies can have powerful and long-lasting impacts on human health. Transportation decisions, for example, can determine whether there are practical alternatives to a single-occupancy vehicle commute, and walking, biking, and public transit all have both direct and indirect positive health impacts. In contrast, obesity, diabetes, heart disease, asthma and other health conditions are linked to sedentary lifestyles and traffic-exacerbated air pollution.
Preliminary Recommendations
Incorporate public health considerations into all aspects of growth management, including planning, zoning, design review, safety and other code review, etc.
Climate Change
Climatic disruptions will cause or contribute to significant challenges to protecting the public’s health. Just two examples: 1) drinking water; and 2) increasing toxicity of environmental hazards.
Drinking Water
Sixty percent of Oregonians rely on surface water as the sole or primary drinking water source, and floods, slides and wildfires can/do impair those water bodies (suspended solids, broken infrastructure, turbidity, etc) and require emergency response. Public Health anticipates the frequency, duration, and severity of such impairments will grow and will affect other parts of the state as well.
The other 40% of Oregonians dependent on reliably safe groundwater supplies for drinking water are also at risk. One scenario example: as topsoil becomes dryer and less productive, farmers understandably apply more fertilizer, pesticides and herbicides to maximize yield. Such chemicals, however, migrate to aquifers and combine with other contaminants to unknown/unstudied effect. At the same time, the aquifers are already and increasingly stressed from over-use, resulting in previously unheard of concentrations of contamination.
Increasing toxicity of and exposures to environmental hazards
Climatic changes may exacerbate already-present environmental hazards, from toxic algae to everyday chemicals. Regarding the former, data point to increasing frequency, duration and toxicity of algal blooms, affecting drinking water sources, recreational uses and food fish habitat.
Regarding the latter, studies indicate that some plant & animal species may be more vulnerable to heat-related harm if the subjects have been previously exposed to certain chemicals. Similarly, in some lab experiments certain chemicals exhibit toxicity at lower doses of exposure in lower temperature settings.
Governance
Because Oregon’s public health system is founded on statutory partnership with local Public Health Departments, we are familiar with the locally-led governance model of Oregon’s land use laws. At both the local and the state levels, however, there is a dangerous disconnect between land use planning and development on one hand and population-based health on the other that can be remedied by recognizing and utilizing the specialized expertise Public Health provides.
At the local level, planning, zoning, building and development oversight is often the purview of cities, while public health authority and responsibility reside at the county level. Even when counties are the local authority for land use, there is only occasional (and generally after the fact) involvement with Public Health. We thus urge that city/county (or county/county) connections be made a necessary part of land development and use decisions, in order to ensure public health issues get the benefit of public health professionals.
At the state level, we recognize that none of the 19 statewide land use Goals specifies or even includes human health protection. While we do not recommend amending or adding to the Goals, we do urge DLCD and LCDC to recognize this omission and commit to providing guidance, support and other technical assistance to local governments to rectify the situation.
Biology dictates that human health simply cannot be sustained in an unhealthy environment, and the use of our land – in urban, suburban, exurban, rural and frontier settings alike – is one of the most powerful determinants of our environmental health. Government’s dedication to provide for the common welfare, and proper stewardship of tax dollars, thus require us to consistently and meaningfully incorporate public health protection into land use oversight.
Economic Prosperity
For both obvious and covert reasons, poverty may be the single most powerful risk factor for healthy communities, and DHS applauds the task force for highlighting this key issue. At the same time, we know that, from a population-based perspective, it is impossible to sustain healthy people in an unhealthy environment. Recognizing the inextricable connection between healthy people and healthy communities is thus essential to provide for and nurture sustainable economic prosperity.
Conclusion
Thank you requesting and considering these comments as you continue to refine and improve Oregon’s land use oversight. We encourage continued partnership with Public Health at both the state and local levels, and look forward to working together as DLCD finalizes its “Big Look.”
Sincerely,
/s
Mel Kohn, MD, MPH
Public Health Director
/s
Katherine Bradley, PhD, RN
Administrator
Office of Family Health
/s
Gail Shibley
Administrator
Office Environmental Public Health
