The essence of the sustainability framework presented in this report is to enable environmental decision makers to consider the longer-term and intergenerational social, environmental, and economic (the “three pillars”) impacts. Sustainability means more “comprehensive, farsighted, critical and integrated approaches on important policies, plans, programs, and projects” (Gibson 2006). The framework capitalizes on an increasingly sophisticated suite of tools for assessing and forecasting impacts.
This chapter examines the benefits of adopting the Sustainability Assessment and Management framework in EPA’s accomplishment of its mission. It reviews several of the complex challenges the agency faces as it enters its fifth decade of work on behalf of public health and the environment, and as its experience grows in using sustainability principles in decision making. A strong sustainability focus could increase the agency’s effectiveness today and over the long term.
A key notion underlying the Committee on Incorporating Sustainability in the U.S. EPA’s recommendation for the three pillars and the proposed principles is that EPA needs to move beyond only ensuring that society is “doing less bad” (by applying risk management in regulatory decisions). EPA also needs to ensure that society is “doing more good” at the same time as EPA performs its risk management work and decision-making. Lisa Jackson, EPA administrator, noted that “We have a new opportunity now to focus on how environmentally protective and sustainable we can be. It’s the difference between treating disease and pursuing wellness. It’s a difference, I believe, that will be fundamental to the future of EPA” (Jackson 2010).
The Sustainability Assessment and Management approach will equip the agency with new tools to analyze and solve new and existing problems and new
opportunities to make a positive difference for all Americans, and can also set an example for other federal agencies that face similar challenges to take an integrated approach to public policy issues falling within their purview. These points are amplified in the text below, and Boxes 7-1 to 7-7 provide illustrative examples from the public and private sectors.
Despite substantial progress in achieving cleaner air, water, and land in the United States, the nation faces new and even more complex challenges. Environmental quality and natural resources are under great stress from a growing population, ever increasing consumption of energy and natural resources, technologic developments, urbanization, and land development. These pressures are occurring against the background of climate change and its probable disruptive effects on resource productivity, water systems, human health, and ultimately the quality of life and livelihoods on the planet. The scope and complexity of these challenges means that more traditional approaches to environmental protection are not likely to be effective. A selection of complex problems and future risks confronting the agency and the country includes the following:
- Approximately 127 million people lived in counties that exceeded at least one air-quality standard in 2008 (EPA 2010a). Ground-level ozone and particle pollution still exceed health protection levels, and recent scientific studies have established beyond doubt their adverse effects on human heart and respiratory functions (HEI 2010). EPA has a huge number of conventional and toxic pollutant standards to complete as well as its work to begin to control greenhouse gases from stationary sources such as utilities. Multiple pollutant and sectoral strategies and even emissions trading are options under consideration.
- Major nationally important water bodies fail to meet water-quality standards sufficient to protect human uses, such as fisheries and jobs, including the Chesapeake Bay, the Great Lakes, and the Gulf of Mexico. The northern Gulf of Mexico is the site of the second largest dead zone in the world, now measured as the size of New Jersey. The area lacking life-sustaining oxygen (hypoxia) caused by nutrient runoff from the Mississippi River watershed continues to grow. Similar dead zones occur in the Chesapeake Bay and in the coastal waters off the coast of Oregon (Walker 2006, EPA 2010b, NOAA 2010). The U.S. pollution-control system has so far failed to mobilize the resources and actions needed to restore these waters and the marine life and human livelihoods they support.
- Many areas in urban centers, particularly in highly industrialized zones, contain persistent sources of contamination due to past disposal prac-
tices. Although cleanup has occurred, having over 450,000 brownfield sites (see EPA 2010c), many sites remain as potential sources of human and environmental exposure. Cleanup of large complex sites remains difficult and the cleanup process is slow. Only 347 Superfund sites of the roughly 2,000 sites listed in the National Priorities List (NPL) have been taken off the list (as of March 2011), and the 347 sites still contain residual contamination that may pose long term risks to the environment.
- The cumulative burden of pollution sources, even those meeting standards, on communities already lacking adequate housing, health care, and other community services requires attention to environmental equity and a search for innovative ways to provide benefits to community residents in site remediation and redevelopment decision making. EPA and its regions have been pioneers in making environmental justice a priority in their work with communities and other federal agencies to deliver multiple benefits.
- Climate change presents significant risks to the environment, human health, and society. “Climate change is occurring, is very likely caused largely by human activities, and poses significant risks for—and in many cases is already affecting—a broad range of human and natural systems” (NRC 2010a, p.3). Projected impacts on the United States include greater risk of drought in the West and increased flooding and reduced water quality in most regions; adverse effects on crops and livestock production; increased risk in coastal areas of sea-level rise and storm surge; and greater heat-stress and other human health risks (USGCRP 2009). Because climate change is affecting—or will affect—every sector of society and because climate-change mitigation and adaptation will require all levels of government and society as well as a great variety of legal and policy tools, traditional pollution-control approaches by themselves will be insufficient (NRC 2010a, b, c, d).
- Emerging technologies are hard for agencies like EPA to evaluate and oversee using existing legal mandates and analytic tools. Nanomaterials, materials so small that they require super-powerful microscopes to be seen, are likely to become a major part of the economy in the coming decades. Already there are more than 1,000 consumer products that use such materials and probably an even larger number of industrial products that use them. Standard risk-based approaches to hazard identification and dose-response analyses are challenged by agents that have different properties at such a small size and agents that may be more toxic at lower doses (Goldstein 2010). The whole area of nanotechnology is one which requires the anticipatory approach encouraged by sustainability. Sound decisions about nanomaterials will require consideration of social and economic factors as well as environmental ones (Davies 2006, 2009; Hodge et al. 2011).
Given this brief inventory of some of today’s pressing problems, there is wide agreement that the United States needs to find new solutions to achieve objectives set forth in EPA’s governing statutes and to extend the benefits of a clean environment to everyone. EPA is already active in applying sustainability thinking to environmental problem solving in particular cases. Boxes 7-1, 7-2, and 7-7 in this chapter describe the kinds of activities or problem solving EPA has already undertaken. They provide evidence of the benefits that can be gained from a broader analysis of the social, environmental, and economic impacts of alternatives and from a collaboration with other agencies and stakeholders on finding solutions. The benefits likely to result from greater incorporation of sustainability into EPA’s work include the following:
- Reduced compliance costs. The use of green infrastructure in cities with combined sanitary and storm-sewer overflows in Kansas City, Philadelphia, and elsewhere has already saved cities hundreds of millions of dollars. Similarly, installation of energy-saving light fixtures in more than 700 schools in the New York City public-school system made it possible to replace existing and contaminated fixtures within the system’s existing budget rather than requiring it to spend more than 1 billion dollars. Energy efficiency and conservation can also reduce greenhouse gas emissions and produce cost savings at the same time. By combining otherwise different regulatory regimes, EPA, DOT, and the state of California reduced compliance costs for greenhouse gas and fuel economy rules for automobile manufacturers.
- Greater environmental justice and more livable communities. The EPA-HUD-DOT collaboration in Boston’s Fairmont Rail Corridor will clean up contaminated sites, create jobs, provide new housing, and improve public access to mass transit. The use of green infrastructure tends to make communities more attractive. The reconstruction of a public bus depot in northern Manhattan to a “green” bus depot helped to reduce air pollution.
- Greater environmental and public health benefits. Philadelphia’s use of green infrastructure is also protecting its drinking-water sources. The use of energy-efficient lighting in New York City public schools is making it possible for the city to replace its existing PCB contaminated fluorescent lights, reducing student and teacher exposure to a known carcinogen. The work of the SURF, which EPA supports, will probably lead to more sustainable remedial decisions while meeting the protective cleanup standards at many sites.
- More effective use of federal funds. By pooling resources to address sustainability problems in the Fairmont Rail Corridor, three federal
In many older cities in the northeast and Midwest, the most serious water-quality problems result from the overflow of sewers containing untreated sewage when rainwater enters combined sewers and the resulting flow exceeds the capacity of the wastewater treatment plant. The construction of separate pipes or tunnels and storage capacity to hold water until it can be directed to the treatment plant involves costly engineering and construction projects and substantial disruption to streets and businesses for long periods. These costs and community impacts have led to more serious consideration of green infrastructure approaches that could reduce the inflow of rain and stormwater runoff through nonstructural solutions.
EPA defines green infrastructure projects as wastewater treatment technologies or processes that use natural or engineered systems, such as green roofs, rain gardens, and permeable placement, that mimic natural processes and direct stormwater to areas where it can be stored, infiltrated, evapotranspirated, or reused. There are encouraging examples of more willingness to test green and mixed gray and green solutions to achieve more cost-effective and environmentally beneficial results. For example, the city of Portland, Oregon built tunnel and storage facilities as required by the state permitting authority but also installed over 400,000 square feet of green roofs and is adding over 80,000 trees, all to manage stormwater as close to the source as possible and to test the approach for future growth. Last year, in Kansas City, Missouri, EPA settled a major case of water-pollution violations, which provides a mix of control approaches, including an adaptive management approach, to use green infrastructure effectively in lieu of or in addition to structural controls (source: EPA consent decree with Kansas City ).
These examples help demonstrate how green systems will actually work and how the adoption of experimental approaches can satisfy the requirements of EPA’s combined sewer overflow standards. They offer the promise of less costly and more sustainable urban water solutions achieved through more flexible and collaborative approach (Scarlett 2010).
agencies are likely to achieve greater benefits than if they had addressed these problems separately or in separate places.
Companies that successfully adopted sustainability strategies can offer some useful approaches and tools to EPA (Boxes 7-5 and 7-6). Corporations are in the business of making goods and services for customers for a profit; providing additional social and environmental benefits is not normally considered to be their primary mission. Beginning with the Rio Earth Summit in 1992, however, forward-looking businesses, led by the World Business Council for Sustainable Development, have worked to define and implement principles of sustainability in the belief that they will make their companies more competitive, resilient,
In cooperation with EPA, the city of Philadelphia has implemented select green infrastructure features to manage stormwater runoff more efficiently. The Philadelphia Water Department has implemented green infrastructure through demonstration and restoration projects, a new stormwater fee system, and new stormwater regulations for all new construction and redevelopment projects. Philadelphia’s stormwater fee structure is now based on amount of square feet of a property’s impervious surface, allowing the financial burden of the fees to fall more equitably on parties that own the greatest amount of contributing surface. Philadelphia’s permitting system was restructured to streamline stormwater permits, easement of flood and channel requirements if 20% reduction in impervious surface can be met. As a result, most developers now build on infill sites instead of undeveloped natural areas. Many of these urban redevelopment projects reach the 20% reduction through a variety of green infrastructure practices, including roof downspout disconnections, porous pavement, tree plantings, and green roofs. These areas manage most 1-inch rain events, reduce CSO inputs by a quarter billion gallons, and have saved Philadelphia an estimated $170,000,000 in infrastructure costs. The city also saves money on the costs of maintaining pipe networks and the upkeep of treatment plants by removing flow from these systems. Through interagency and stakeholder collaboration, fiscal responsibility, and a commitment to sustainable development best practices, Philadelphia has benefited from green infrastructure by improved compliance with the National Pollutant Discharge Elimination System and the Total Maximum Daily Load requirements of the Clean Water Act, increased protection of drinking-water sources, and aesthetic improvements in the urban built environment (EPA 2009).
nimble, able to attract and retain customers and employees, and better able to work with government regulators and financial institutions. The World Business Council for Sustainable Development, where much of this work began, recently produced “Vision 2050,” which outlined strategies to take the economy and the market to a far more sustainable future (WBCSD 2010).
In addition to considering the experience and lessons learned by companies in their sustainability programs, EPA has the opportunity as a science agency to support company efforts by working collaboratively with industry on issues of mutual interest, such as defining best practices in life cycle analysis, where there are many different tools and applications available for users. EPA’s focus and expertise in green chemistry is another sustainability interest that is shared by industry and presents opportunities for further exploration of ways to make green chemistry principles more widely understood and adopted. Hecht (2009) noted that “EPA has been active domestically and internationally in promoting sustainable development through green chemistry.” The committee is confident that a
In response to concerns about PCB contamination in light fixtures in public schools, New York City has agreed to a broad cost-saving effort to replacing these faulty fixtures with energy-efficient alternatives (NYCDOE 2011). EPA investigation of older fluorescent light fixtures has shown leaking capacitors and frequent exceedences of PCB guidelines in virtually every New York City school thus far evaluated (EPA 2011). PCBs are considered to be human carcinogens, and leaking capacitors have resulted in electrical fires. The New York City public-school system initially resisted the call to replace the light fixtures present in over 700 schools because it would cost over a billion dollars and lead to the layoff of teachers. However, when the energy saving of the new light fixtures was included in the estimates, New York City found that the replacement costs were low enough to be accommodated within its usual capital budget without any impact on school operations (Navarro 2011). In addition to improving efficiency and cost-savings in the long run, school buildings will undergo regular energy audits to determine how to improve overall energy efficiency in each building. Improvements will translate into even greater cost savings in the long run (NYCDOE 2011).
well-defined sustainability framework to support priority setting and decision making at the agency can, over time, multiply the cases of optimizing solutions to problems and take EPA’s performance to a new level. As illustrated with the text boxes in this report, such a framework has the potential not only to mitigate harmful unintended consequences of decisions but also to foster more imagination and creativity in forging solutions to pressing problems.
A sustainability approach can strengthen EPA as an organization and a leader in the nation’s progress toward a sustainable future. Adopting a vision for sustainability as a goal will provide a unifying and forward-looking stimulus to the agency. EPA has never had a formal mission in law. Its individual legal mandates, which have driven the agency’s actions and analysis, have not been revised in many years. The individual programs have lacked a vision as a basis for a unified approach. Sustainability gives the agency a more positive vision and lays the basis for an approach capable of inspiring commitment and enlisting cooperation from different parts of the agency as well as from diverse stakeholders.
As the vision of sustainability is implemented, the processes that follow from the vision bring a variety of benefits. EPA and its programs can be organized on the basis of approaches that cut across the traditional boundaries enshrined in law.
WE ACT, an environmental justice organization, has demonstrated the success of community-based organizations in encouraging sustainable efforts to address environmental health issues in disadvantaged communities. Air pollution associated with idling buses at transit depots in Manhattan has been an important concern for neighboring communities, particularly as studies have indicated that traffic exposure exacerbates asthma among children (HEI 2010). Five of six public transit bus depots in Manhattan are located in low-income communities. In 2000, following a complaint by WE ACT, the Federal Transit Administration ruled that the Metropolitan Transit Authority (MTA) was discriminatory in their siting of the depots and had failed to comply with rules to promote public health and community development. Ultimately, the MTA decided to remove and rebuild one of the facilities, the Mother Clara Hale Bus depot. WE ACT partnered with MTA to support sustainability efforts at this redevelopment, including work toward a Leadership in Energy and Environmental Design (LEED) green building certification. In addition, WE ACT worked to increase community involvement in the project by soliciting advice about the redevelopment of the depot and organizing the Mother Clara Hale Community Taskforce to formalize the community’s role in development activities. In 2008, the Mother Clara Hale Community Taskforce recruited 170 residents to assist MTA in designing the depot with green design features, such as a green roof, gray-water reclamation, and air-pollution controls The net result is an involved community now cooperating with local government in decreasing air pollution while increasing sustainability (WE ACT 2010).
Place-based efforts can increasingly become the ways in which agency programs are implemented.
Central to the integrated and positive sustainability approach is a focus on preventing harm rather than dealing with it after it occurs. Pollution prevention under the Sustainability Framework would not be categorized as belonging to any single medium, and would aim to be socially beneficial, environmentally effective, and economically more efficient than current pollution control. Sustainability encourages EPA to anticipate problems and invest in solutions before the problems become critical. Encouraging a more long-range and holistic view, sustainability is likely to enable EPA to avoid mistakes and thus maximize the value received for the agency’s investments.
EPA’s efforts can become more internally coordinated and its sustainability approach can become more inclusive of other regulatory and nonregulatory agencies, state and local agencies, businesses, and nongovernmental organizations. It will not be possible for EPA to incorporate social and economic factors without
Large remediation projects are energy and resource intensive and may ultimately result in discharges of various air pollutants, including greenhouse gases. The Sustainable Remediation Forum (SURF), initiated in 2006 by DuPont, provides an example of a private sector effort to incorporate sustainability into decisions on remedial actions at contaminated sites. The mission of this forum, which has received some support from EPA (Region 2), is to “establish a framework that incorporates sustainable concepts throughout the remedial action process while continuing to provide long-term protection of human health and the environment and achieving public and regulatory acceptance” (Ellis and Hadley 2009). SURF, which has grown in size to over 300 members including the international community, recently published a white paper providing recommendations on how to integrate sustainability principles into remediation projects. SURF noted that sustainability can be applied both to new projects and those already under way, adding that the remediation profession needs to consider sustainability principles and practices in all remediation-related activities. The group also noted that that sustainability assessments matter during remediation, recommending that these assessments be flexible, site-specific, and reflect stakeholder values. Uniform guidelines and metrics are necessary to produce consistent sustainability assessments (Ellis and Hadley 2009). In addition to SURF, the Interstate Technology and Regulatory Commission (ITRC) has recently published a document titled “Green and Sustainable Remediation: State of the Science and Practice (ITRC 2011). In addition to a comprehensive evaluation of technologies for more sustainable soil and groundwater cleanups, the document provides an appendix summarizing over 30 software tools that can be used to conduct sustainability assessment of remedial options.
drawing on many non-EPA actors. At the same time, sustainability will impose a leadership role on EPA because the agency may need to take the lead in convincing other agencies and organizations to incorporate environmental considerations in nonenvironmental decisions. The agency may have to devote resources to providing technical assistance to make such incorporation effective. It also may have to set an example in adopting sustainability by providing leadership at the national level.
The sustainability mandate to consider social and equity factors can make EPA even more sensitive than it has been to populations that are disproportionately exposed to environmental risks. The agency has a long history and has developed procedures for incorporating environmental justice in its decisions (EPA 2010d,e). Sustainability can reinforce these procedures and will provide a logic and framework for considering environmental justice as part of every major decision.
IBM, a company with revenues approaching $100 billion, believes that focusing on the idea of a smarter planet is beneficial to its business growth and profitability as well as advancing its values. IBM’s environmental policy, first established in 1971, is part of the company’s long-standing, broad-based objective to be at the forefront of companies working to make the world a better place. Company Chairman and CEO Samuel J. Palmisano summed up the IBM position in its 2009 report: “Addressing the issues facing the world now—from clean water, better health care, green energy, and better schools to sustainable and vibrant cities and an empowered workforce and citizenry—does not pose a choice between business strategy and citizenship strategy. Rather, it represents a fusion of the two” (IBM 2010, p. 1). The company’s environmental sustainability priorities, developed by analyzing external stakeholder interests are as follows:
• Energy conservation and climate protection
• Process stewardship
• Product stewardship
• Supply chain management
These objectives often involve actions not required by U.S. law. IBM’s annual energy conservation goal to conserve energy in an amount equivalent to 3.5% of IBM’s energy use was exceeded, reaching 5.4%. Cuts in carbon dioxide (CO2) emissions have been a priority since the early nineties. From 1990 through 2009, IBM saved over 5.1 billion kilowatt hours of energy consumption, avoided over 3 million tons of CO2 emissions, and saved over $370 million. IBM has since embarked on a second generation energy objective under which its CO2 emissions from a 2005 baseline have decreased by a further 5.7%. In the area of process stewardship, by January 31, 2010, IBM had eliminated all uses of perflourooctane sulfonate and perflourooctanoic acid, two persistent chemicals from its microprocessing manufacturing processes.
The company has also increased the use of recycled plastics in its products and reduced packaging material. Its researchers are working with Stanford University scientists to develop green chemistries that could result in biodegradable products made from renewable resources. Success will mean that plastic bottles recycled once but then disposed of in landfills might degrade.
Supply-chain management strategies are focused on guiding the capacity and accountability of IBM’s suppliers to succeed. In 2010, IBM announced a first-of-a-kind requirement for its global suppliers to develop environmental management systems, establish their own goals, and publicly disclose their progress. Identifying use of “conflict materials” (e.g., timber or diamonds used to fund civil wars) and their sources is another new initiative responsive to both social and environmental concerns (IBM 2010).
For more than a decade, state laws to develop renewable energy and energy efficiency have been known to create jobs, result in the development of new technologies, reduce the effect of high and fluctuating fossil-fuel prices on the poor as well as business, lead to economic savings, and reduce pollutants, such as sulfur dioxide and particulates. The laws have also, and often incidentally, reduced greenhouse gas emissions (Dernbach et al. 2000). As states have begun to address climate change more directly, it is apparent that appropriate legal and policy instruments, if scaled nationally, could create millions of net new jobs, produce considerable economic savings, create a net increase in gross domestic product, and significantly reduce U.S. greenhouse gas emissions (Peterson and Wennberg, 2010). Perhaps the most important of these instruments are those that foster energy conservation and efficiency (NRC 2010e).
At the federal level, EPA and the U.S. Department of Transportation (DOT) in 2010 adopted combined corporate average fuel efficiency (CAFE) standards and greenhouse gas emission limits for light-duty motor vehicles (including passenger cars and light-duty trucks). Beginning in 2016, these vehicles will be required to have a combined average emissions level not exceeding 250 grams of CO2 per mile, which is equivalent to 35.5 miles per gallon. The government estimates that “these standards will cut greenhouse gas emissions by an estimated 960 million metric tons and 1.8 billion barrels of oil over the lifetime of the vehicles sold under the program.” This rule making brought together a great variety of stakeholders, including automobile manufacturers and the state of California. In prior regulatory efforts, EPA, California, and DOT adopted separate standards for automobile pollution and fuel efficiency. By contrast, this rule represents a harmonized national program for a new generation of cleaner vehicles that is explicitly intended to foster economic development, job creation, environmental protection, and national security (EPA/DOT 2010).
The emphasis on the future contained in sustainability’s concern for future generations is likely to have an impact on EPA’s perspective as well as on its decision-making process. The agency can become more anticipatory, making greater use of new science and of forecasting. At the same time, it may become more self-evaluating, making greater use of health and environmental monitoring tools, and program evaluation tools, such as benefit-cost analysis and life-cycle analysis (Chapter 4).
There is no certainty that these changes will take place in the agency or to what degree they will take hold or what form they will take. But the stimulus provided by adopting a sustainability framework could provoke reflection and change within EPA, and the changes will better equip the agency to deal with the challenges it will face. Assuming that EPA adopts the goal of sustainability, there will be benefits for the United States as a whole. There is likely to be a closer
meshing of economic and environmental policies to the benefit of both. The result is likely to be a cleaner environment and stronger economy. These benefits are likely to be shared more equitably as social considerations are weighed alongside environmental and economic ones. The economic benefits may not be limited to improved coordination. As sustainability focuses attention on greener products, the United States can hope to capture a larger part of the world market in a variety of goods. It can play an important role in building the tools and workforce for a more sustainable world.
In summary, the committee sees EPA moving into a leadership role in using a sustainability framework to deliver better results for the nation and its future. EPA’s national pollution-control responsibilities give the agency important influence on management of natural resources and the opportunity and obligation to help build better national policy and strategy. As an agency with strong science capability and wide expertise, EPA is equipped to be a catalyst for sustainability in activities beyond its traditional regulatory and grant-making roles. EPA is a thought leader, convener of governmental partners and private stakeholders, and funder of innovative environmental strategies; and the agency provides reliable information on environmental conditions and materials that can inform government, businesses, citizens, and consumers in their choices and decisions. These capabilities provide a solid platform for EPA leadership in advancing a sustainability agenda.
7.1. Finding: EPA can adopt sustainability principles while fulfilling its core mission of protecting public health and the environment. The embrace of sustainability at EPA can promote new thinking and provide powerful new tools to forge better solutions to current and future problems (p.112-113).
7.1. Recommendation: EPA should foster a culture of sustainability to increase EPA’s capacity to imagine and implement better solutions and increase recognition of the economic and social value of the benefits of environmental protection. Agency staff should be encouraged to seek opportunities to further EPA’s sustainability goals in all decisions and actions.
7.2. Finding: The agency can be a promoter of economic development as well as a regulator. In that role, for example, EPA can help to encourage manufacturing of greener products and to create new markets in sustainable goods and services (p.114-117).
7.2. Recommendation: EPA expertise in sustainability should be leveraged into nonregulatory environmental improvement programs for businesses of all sizes, creating synergy for the sustainability, public health, and competitiveness of American businesses.
7.3. Finding: Disadvantaged communities often bear a disproportionate burden of environmental stressors, such as higher pollutant burdens that are often coupled with poor housing, inadequate health care, and other place-based problems (p.114).
7.3. Recommendation: To maximize social benefits as well as reduce health risks, EPA should target activities to decrease and eliminate environmental inequities. Research aimed at elucidating the cause-and-effect relationship between an environmental problem and an adverse consequence, especially cumulative impacts, should be focused on disadvantaged communities and should seek their engagement and cooperation.
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