Food Environmental Impact Statements

On Monday, Manhattan Borough President Scott Stringer released a proposal to require government agencies and developers in NYC to assess the impacts of their projects on the food system and to mitigate anticipated negative effects, whenever environmental assessments and environmental impact statements (EISs) are prepared.

The City’s Environmental Quality Review process (CEQR) requires all discretionary actions of government (building new facilities, granting zoning variances) to undergo an assessment to determine whether the action will create adverse environmental impacts. The city’s environment is defined broadly to include the natural and physical environment as well as the socioeconomic environment and related infrastructure (e.g., housing) necessary for humans to live in cities. Despite the importance of food to human health and welfare, the effects of projects on the food infrastructure (such as the displacement of a supermarket by a proposed development, or the removal of an urban farm by a city facility) has never been required to be analyzed in an EIS. Stringer’s proposal is for the city’s CEQR manual to explicitly require such food system assessments.

EISs generally analyze the adequacy of existing infrastructure when a proposed action will increase the population of a neighborhood by, for instance, allowing tall residential buildings to be constructed in an area formerly zoned for low-density uses. Under the current practice, the effects of population growth on the water and sewer system, and other key parts of the city’s infrastructure, must be analyzed, and if the project will over-tax the existing infrastructure, the EIS must examine alternatives with lower impacts and measures to mitigate unavoidable impacts. EISs have not considered whether the existing supply of healthy food is sufficient to meet the demands of population-generating projects.

Under Stringer’s proposal, environmental impact statements would have to identify the following key information:

  • The number, type and location of food retail stores including full-line supermarkets, convenience stores, restaurants, and fast-food establishments;
  • The frequency, size, location and hours of farmers’ markets, green carts and fruit stands, urban agriculture sites, and other sources of fresh food; and
  • The availability of authorized fresh food retailers that participate in Federal, State or City programs related to healthy food access such as the Supplemental Nutrition Assistance Program (“SNAP”) and the Women, Infants, and Children (“WIC”) program.

One of the benefits of the environmental review process is that it enables city agencies, developers, and the affected community to discuss what alternatives and mitigation measures, if any, are needed and feasible. If an EIS were to identify adverse impacts on the food system, potential mitigation measures could include:

  • no action — not building the project
  • creating new on-site or off-site healthy food suppliers;
  • improving existing fresh food supply by, for example, supplementing existing resources such as farmers’ markets; or
  • by reserving retail space in a proposed project for fresh food retailers authorized to participate in programs such as SNAP or WIC.

The environmental review process is no guarantee that government decision-makers will use the information in them to require better projects that have fewer adverse impacts, which often makes developers irritated with the cost of preparation and the possibility that flaws in the impact statement will hold up a project.

Nevertheless, EISs are often the only publicly available sources of detailed data and analysis to enable communities and decision-makers to understand the anticipated consequences of new projects and programs. Adding the food system into that analysis, along with water, energy, transportation, open space and other critical urban systems, would provide the tools for agencies, developers, and citizens to become aware of potential negative impacts on the food system so that they can, hopefully, avoid them before irreversible decisions are made.

For more information about the proposal, see Manhattan Borough President Scott Stringer’s website.

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