Public Health Economic Analysis

This essay is responding to a post on the Spirit of 1848 listserv on the publication of the racial equity law database.

August 15, 2024

By Christopher Williams, PhD

Thanks for sharing. I wish to share applied public health economic analysis as part of understanding health inequity reproduction. Racial equity laws can be highly beneficial but depends on the overall health of the public health economy. An example from Washington, DC is instructive to elucidate the concept of the public health economy. This economy contrasts with the traditional growth and employment economy. Public health economic theory levels with the political, economic, and social realities to enrich public health understanding of health inequity reproduction. While it takes public health well beyond its traditional disciplinary boundaries, the notion of the public health economy seeks fuller explanations for persistent disparities. 

What Happened to City Planning?

The District of Columbia government said in 2006 that comprehensive planning should entail understanding the benefits and risks of spurring neighborhood change. Council passed a law that required an environmental assessment whenever there were changes to the Comprehensive Plan - the central planning document for the city. The legislative intent was to capture social and economic costs (what economists call "externalities"). When the District passed major revisions to its Comp Plan in 2021, the Council and mayor did not submit this assessment. Instead, the District sought to pass off a six-page document as the legally required environmental assessment. It lacked analysis consistent with laws on conducting environmental assessments. Here "environmental" is contextual or neighborhood, as opposed to just ecological, though that is a part of it too. The last assessment in 2006 was about 300 pages and conveyed a comprehensive understanding of what may arise from acute urbanization. In 2021, the city gave matter-of-right redevelopment for 200 million square feet of real estate, despite that the city was the top US city for African American displacement in the 21st century due to eroding affordability, higher housing costs, and deep income disparities.

Law
Nearly a dozen plaintiffs sued because the government was not following its own planning laws. Some plaintiffs alleged District-directed environmental racism, demographic trends in displacement, and higher housing costs. The trial judge denied legal standing. The standards for standing are a high bar. In this instance, plaintiffs need to prove 1) concretized, cognizable injury that is 2) traceable to or caused by the District, and 3) redressable by the court. Even if the plaintiffs did meet the standards of standing, the lower court judge said that he could only make the District complete the required progress reports and environmental assessment. He could not make the entire Comp Plan unlawful. This case is being appealed. Despite the immense social costs, the Plan, according to the judge, could not be legally prevented from being set in motion. The takeaway is that the government can violate its own laws and Plaintiffs must meet a high bar for the court to have jurisdiction. Taking a case to the court based on violations of the law is not sufficient in the eyes of the court. This is our legal system - a reality important to all of public health. Public health economic analysis seeks to draw attention to this and other aspects of health inequity reproduction.

The District had also violated another planning law that requires progress reports every four years related to implementation of the Comp Plan. In other words, the law had intended for the Executive to provide updates on how things were going - good or bad. The District only performed two of the four legally required progress reports since 2006. These full progress reports would have likely captured the social costs caused by the District to include strengthening of racial inequity and may have caused early legislative intervention.

Economics
The economic explanation for the Comp Plan's passage in 2021 was that District policy on the economy relied on the economic elite to drive policy, much as it had since the early 2000s when it was coming from under a federally-mandated budget control board. Still in the aftermath of the Covid pandemic, the political and economic regime felt uneasy about out-bound migration trends (e.g., consequence of telework) and the vulnerability of their real estate investments in the city. After all, Washington, DC became a major city for international capital. For example, the investment arm of the Canadian public employee pension became a major investor in the public-private partnership along the city's waterfront. That redevelopment - one of the largest on the East coast - was public land that was heavily subsidized by taxpayers, in addition to being sold for $1. After securing the contract, developers successfully petitioned DC Council to lower the affordable housing considerably - which was initially one-third.

With the pandemic, too, there were more vocal calls for addressing deep racial disparities, which could severely limit the political choices that had favored their economic power over city policies. In addition, communities were much more actively engaged in political and legal spaces challenging the city's economic schema, developments, and the related environmental harm to public health. The economic elite prepared a general strategy. Get around all of these concerns by seeking approval of massive increased density - matter-of-right redevelopment. They saw the new housing that they had built as investments, threatened by the pandemic, social activism, and increased legal action (e.g., challenges to PUDs). While it was true that ten years ago the District was not building enough housing to keep up with population growth, the housing crisis was always most acute among those needing affordable housing. Later studies showed that the District actually produced too much market housing while also concentrating new affordable housing stock in low-income, super-majority Black neighborhoods. To but, the District perpetuated redlining by opening minority neighborhoods east of Rock Creek Park and west of the Anacostia River to intense redevelopment while maintaining single family zoning west of Rock Creek Park - historically redlined areas.

The effects of these policies were not fully captured in the 2006 assessment or progress reports. On the ground, District policy caused massive real estate speculation with high social costs. Public health and safety crises were growing due to landlords, who preparing to sell, divested from landlord obligations for pest control, housing conditions, and violence (e.g., ghettoization). As a tenant association president, I experienced this firsthand with my neighbors. Populations were being displaced from properties in public housing and private housing when new owners came on board or in the run up to a sale. As its primary objective, the economic policies sought to attract high-income populations to the city. However, those populations caused the area median income (AMI) to rise, which caused increased housing costs for renters and homeowners. Rental increases, even for rent-controlled properties, are pegged to AMI. Housing vouchers were also becoming inflated due to rising AMI, eroding affordability due to overpayments to landlords. This latter issue is subject of a federal investigation nation-wide. 

The DC Housing Authority also took part in the real estate frenzy - displacing wholesale public housing communities to make way for mixed-income redevelopments that did not restore the original number of affordable housing units. With its attention on securing real estate deals, the quality of its existing stock rapidly declined, causing acute public health and safety crises. In addition to mold- and pest-infested units across communities, drug houses and community violence were permitted to take root - clear signs of agency-directed ghettoization. The public health implications have been profound. I saw firsthand how these harmful policies led to drug use, mental health decline, and poor health among public housing residents. The agency is yet to restore affordable housing units from properties that were razed over 20 years ago. In several instances, public housing residents were forced to sue (e.g., Barry Farm, Park Morton). Other communities are on the chopping block for displacement. Meanwhile, the agency is under intense federal oversight following a scathing 2022 HUD audit. Public housing residents are one of many subpopulations that experiences "apartheid-adjacency" that warrant sustained public health attention.

Environmental Regulation
To supply the newly constructed buildings with concrete, the District required new industries. The District approved many of these sources of pollution next to low-income, Black communities in many cases. In the case of the Southwest neighborhood, two at a time. The removal of these polluters remains a point of contention with neighborhoods. Neither federal nor District policy has any mechanism for assessing or weakening the cumulative impact of multiple polluters on a single neighborhood - only setting standards for each source of pollution. The EPA is in its early stages of establishing cumulative impact standards - efforts that may abruptly end depending on the outcome of the US presidential election. A report by Southwest Voice raised major issues with the city's environmental regulator, in which its air permit reviews did not comport with environmental law - lack of findings of fact, loosening requirements, and not taking into account non-attainment areas.


Political Theory

The District sees itself primarily as a corporation - spur growth and expand the tax base. This crude position was consistent with much-debunked urban planning theory that marginalized economic mobility and equity-driven policies. Like an irresponsible corporation, the city was largely inattentive to externalities insofar as they impeded economic goals to transform the city demographically and environmentally. In terms of political theory, corporate values and accountability to Wall Street and investors displaced democratic accountability and governance. Large swaths of the population were bearing the brunt of poor planning and high-income-driven policies. Urban regime theory helps to understand the economic and political alliance. In theory, expanding the tax base is a key economic measure for any city because it can increase services and programs. However, the District's huge budget - the highest per capita for any major US city - was not realizing equity consistent with its growth. The District's budget increased by $1 billion from FY24 to FY25. Yet, studies have "found the nation's capital to rank dead last in terms of racial integration" [1]. "Washington DC ranks dead last in economic racial equality" [2]. The federal government noted that DC's fourth- and eighth-grade average reading levels were unchanged in a comparison between 1992 and 2022. 

These points raise the importance of public health economic analysis. The public health economy is a transdiscipline warranting a disciplinary shift.

Sincerely, 

Christopher Williams, PhD
https://www.drchristopherwilliams.com/

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