In Jeremy Cox’s December 9th 2025 article in The Bay Journal “Maryland downplays race, ethnicity in its environmental justice scoring system” Cox analyzes the changes and reactions to the changes the Maryland Department of the Environment made to their Enviroscreen 3.0 tool compared to previous versions.
The tool is designed to help analyze the disparities between communities in Maryland by taking into account a number of factors to meet the requirements of The Climate Solutions Now Act (Md. Code, Envir. § 1-702) through the creation of “a methodology for identifying communities disproportionately affected by climate impacts. The law specifies the inclusion of: Areas that are vulnerable to climate impacts, such as flooding, storm surges, and urban heat island effects; Underserved communities; and Overburdened communities.”
What the code does not require, and what has been removed from the calculation of how susceptible a community is to climate vulnerability compared to older models, is race and ethnicity.
Cox’s article quotes Sacoby Wilson, director of the University of Maryland’s Center for Community Engagement, Environmental Justice and Health, who said
“Race is the single most important indicator of environmental hazards. Some parts of the state that had higher scores are [now] lower, which means it’s not really capturing the environmental justice experiences happening on that ground.”
Cox also references Rebecca Rehr, director of climate policy and justice at the Maryland League of Conservation Voters who says,
“Decades of social science research point to race and ethnicity as being associated with poorer health outcomes and greater environmental burdens at a community level. I think there’s ample evidence to show that we’re justified in including race in decisions about environmental pollution.”
While the tool is arguably less accurate without the indicators of race being taken into account, the relative scores are still meeting the goals of the Climate Solutions Now Act. Communities of color whose scores have dropped because of the removal of race from the equation still present a higher percentile of Environmental Justice (EJ) scores relative to the rest of the state. A community that dropped from the 96th percentile to the 80th percentile is still very high on the EJ Index compared to communities in the 25th or even 50th percentile.
Cox acknowledges that the changes to the tool were made to avoid targeting by Federal oversight for supposedly problematic anti-racist policy language. MDE also points out that data for race and ethnicity is still available by using the slider on the Enviroscreen Tool to see which communities are overburdened or underserved, but it is not used to calculate the overall EJ Score. These tools can be used in concert to display a clear view of the reasons why a community is or is not susceptible to environmental justice issues.
Gunpowder RIVERKEEPER® would like to thank Jeremy Cox and The Bay Journal for providing this critical analysis of the state’s toolkit and to remind readers that our mission is unchanged: protecting the water quality, the sensitive species than inhabit them, and the rights of the communities that depend on them, especially traditionally overburdened and underserved communities.
Check out our initial blogpost for a complete overview of the tool and our post on Baltimore County’s Proposed Data Center Moratorium to see how we use the tool to inform our advocacy,