The Health Equity and Policy Advocacy Clinic - Environmental Division, directed by Professor Emily Benfer recently celebrated a milestone achievement, thanks to the dedicated work of our Environmental Justice (EJ) student team. This fall, the student-attorneys submitted a powerful comment to HUD’s federal Notice of Comment. Drafted on behalf of 20 organizations, associations, and individuals, this document is a persuasive submission that combines principles of environmental justice, housing equity, and health standards to advocate for stronger protections for children from lead hazards.
The team’s extensive outreach efforts inspired other stakeholders, such as the American Academy of Pediatrics, to echo their points, underscoring the influence of their work on this critical public health issue. When HUD issued a Notice of Comment on September 11, 2024, proposing a reduction in the definition of elevated blood lead levels from 5 µg/dL to 3.5 µg/dL in alignment with CDC guidelines, the EJ team recognized the urgency of a response. They quickly mobilized, diving into administrative law questions, studying statutory language, analyzing scientific data, and collaborating with experts to prepare a well-rounded comment. Working closely with their partners at Earthjustice and the National Housing Law Project, the students developed fact sheets and coordinated outreach efforts, even drafting four templates simultaneously to cover all bases.
The result was a robust commentary that not only welcomed HUD’s proposed change but also challenged other practices impacting children’s health. The students’ persistence paid off. Their efforts galvanized many other organizations to join in, either by signing on to the Clinic’s comment or submitting individual comments based on its language. The students also engaged GW Law student groups and GW Medical School students, broadening support across disciplines.
The final comment was submitted to the Federal Register and received high praise from partners and professionals. In addition to their advocacy work, the Clinic partnered with Professor Brendan Hurley from GW’s Department of Geography and Environment to create a GIS map linking housing voucher use to census data for pre-1960 housing, with interpretation support from Dr. Gourishankar at Children’s National.
The map will inform ongoing projects and future research into health impacts related to housing and environmental justice. This tremendous achievement wouldn’t have been possible without the commitment of each team member and the guidance of Professor Benfer. Their work exemplifies the Environmental Division’s mission to fight for healthier, more equitable communities and is dedicated to protecting children from the devastating effects of lead exposure. Congratulations to EJ team, including Jaylah Richie (Class of 2026), Sidney Lee (Class of 2025), Emma Stinson (Class of 2024), and Post-Graduate Fellow, Nana-Yaw Owusu for their excellent advocacy.