Environmental Protection Agency Public Comment Re: RACER Buick City Project

Sep 13, 2023 | Uncategorized | 0 comments

September 13, 2023 

To: U.S. Environmental Protection Agency 

Re: the RACER Buick City Development 

Flint community members, particularly our youth leaders, are appalled by the lack of acknowledgement of the 17 Principles of Environmental Justice and complete disregard of the Jemez Principles which calls for inclusivity and community-centered decision making as it relates to projects that could potentially cause environmental risks and public harm.  On June 21, 2023, we attended the RACER Trust Public Information Meeting located at the Dome Auditorium at Flint City Hall.  This “meeting” did not demonstrate authentic community engagement, but served as sheer pandering as questions posed to RACER staff (and representatives present from the Michigan Department of Environment, Great Lakes & Energy–EGLE) were not answered regarding their “research” regarding not just new public health risks the potential project could pose, but how co-pollutants could exacerbate existing body burden as Flint still has legacy pollution from the Flint Water Crisis and decades of inconsequential pollution from the automobile industry.  After an outpour of community dissent, the Environmental Protection Agency (EPA) co-hosted a community meeting on August 29, 2023 where we also attended.  The meeting was completely unorganized and lacked clear guidance on how both EPA and RACER would truly take seriously the overwhelming pushback from Flint community members who do not want this development to move forward–despite the taxpayer dollars (with the consent of taxpayers) already being invested in the project.  Neither RACER nor EPA staff present could adequately address the pertinent questions posed by community members–nearly identical to the experience with the meeting hosted by RACER back on June 21, 2023. We would be remiss not to acknowledge how this process resurfaces the trauma of the lack of transparency and generational harm caused by former Governor Rick Snyder, his emergency managers, and all complicit with the Flint Water Crisis. 

The following questions were posed by our youth leaders since June 2023  that were not answered: 

1) With the remaining funding that is needed to complete the remediation as RACER has shared, where and how will this gap be closed to be sure that innocent taxpayers are not footing the bill for a polluter (GM for example) who was not fully held responsible after their bankruptcy in 2009? 

2) What restorative resources and support has been or will be provided to Flint residents that have suffered public health issues due to the proximity to the toxic, and formerly abandoned area? 

3) How is it that ARPA dollars were allocated for this project; whereas Flint community members have been asking for transparency with the ARPA funding to support local work and their asks have not been prioritized. For example, it appears that the ARPA investment for this project supersedes the investment in youth programming in Flint (why aren’t social services deemed as a high priority)?

4) This project is allegedly supposed to bring “good paying jobs” to Flint; however, what’s the proposed ratio of Flint residents/natives having senior/executive level positions as opposed to solely labor intensive roles. Additionally, since ARPA funds were received for this project, what are the specific Justice40 benefits for Black, Latinx, Indigenous and economically disadvantaged Flint community members? 

5) Knowing the history of legacy pollution caused by the automobile industry in Flint, what ongoing oversight and accountability measures will be implemented to ensure pollutants aren’t being emitted in the air, water, and soil and if pollution is being emitted, what are the specific consequences for the polluter?

The following are testimonial statements from Flint Youth Environmental Justice Leaders who disapprove of the RACER Buick City Project: 

“During my attendance [at the August 29, 2023 Public Meeting], it felt like each company was present in order to simply have a public comment listed as completed on paper. Things went from saying there is no plan, to insisting that the ‘Brownfield Plan’ remains [are] being utilized. Yet finances were a top priority before even having a fully thought out strategy. Moreover, what concerns me most would be that this project was once seen as in the final stages and a proper environmental assessment was not conducted until years after their initial proposal. This public [meeting] genuinely increased worry regarding true intent.” 

–Jada Robinson, Flint Environmental Justice Griot 

“My reaction about the RACER Trust/Ashley Capital is that they will be furthering the damage that has already been done by General Motors in Flint by building industrial facilities. I do not believe RACER is listening to Flint residents and only care about lining their pockets. We should not have to [use taxpayer dollars] to help fund this project nor should the project be done in our vulnerable community.” 

–Dionna Brown, National Director, Youth Environmental Justice Programs & Flint Native

On behalf of youth community leaders in the City of Flint, we are in absolute opposition to the development of the RACER Buick City Project. 



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