A city (or county) is not an accident but the result of coherent visions and aims

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• Project siting decisions. 
Approval of certain industrial facilities or uses can be made conditional if they are within a certain distance of residential or 
school uses and/or contain or produce hazardous materials. This allows the city or county to consider the potential hazards 
associated with individual facilities or uses, together with potential mitigation, on a case-by-case basis. General plan policies 
can outline consistent standards to be used in approving, conditionally approving, or denying proposed locations for industrial 
facilities and other uses that may pose a significant hazard to human health and safety. Such standards should be reflected in 
the zoning ordinance that implements the general plan (see
 implementation chapter
).
• Capping the number of certain facilities and uses. 
Another policy response to over-concentration is to cap the number of potentially hazardous facilities within a certain distance 
of each other. For example, the State of Georgia does not allow siting of a new solid waste facility if two such facilities already 
exist within a two mile radius of the proposed facility. While capping policies are easy to implement and easily understood 
by the public, they also have potential drawbacks. Without analyzing the type, quantity, and concentration of materials to be 
contained or produced at a proposed facility, for example, it may be difficult to determine the number of facilities that would 
create a situation of over-concentration while still meeting the needs of growing communities.
• Changing land use designations in over-concentrated areas. 
One way to address existing or potential future problems of over-concentration is to change the land use designation for 
existing industrial areas. This approach differs from buffer zones in that buffer zones affect the land use designation of areas 
adjacent to existing or proposed industrial areas. Changing the allowable land uses in existing industrial areas prevents new 
industrial land uses from being established and may affect the expansion of existing facilities and uses (depending on how 
local policies treat pre-existing or “legal non-conforming” land uses). 
  An important caveat is to consider what new uses will be allowed in the previously industrial areas. A new environmental 
justice problem could be created if residences and schools are allowed without considering any lingering effects of industrial 
over-concentration. At the same time, where over-concentration is no longer an issue and effective remediation or cleanup is 
possible, so-called “
brownfield
” development is an important tool for a community’s continued sustainable development.

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New Residential Uses and Schools
Although SB1000 does not specifically refer to siting of new residential uses or school siting, but EJ issues may arise and it is 
good practice to consider these issues in the general plan. Policies should provide for the location of new schools and residential 
dwellings in disadvantaged communities in a manner that avoids locating these uses in proximity to industrial facilities, 
agricultural lands, and uses that will contain or produce materials that, because of their quantity, concentration, or physical or 
chemical characteristics, pose a significant hazard to human health and safety. For areas outside of disadvantaged communities, 
these policies could be set forth in the mandatory land use element, or in an optional equity element.
The location of new residential and school development is a corollary of the problem discussed in the section above. Given the 
need for new housing and schools and given the need to make efficient use of land, how do cities and counties deal with existing 
over-concentration of industrial uses? When designating areas for residential development, the city or county should identify any 
areas of over-concentration. Appropriate buffers should be placed between over-concentrated industrial and agricultural areas 
and new residential areas. Using their authority over the approval and design of subdivisions, cities and counties may develop 
policies and standards related to industrial over-concentration and new residential subdivision approvals. These policies could 
include buffer zones, as well as the criteria to be used for rejecting new residential development (such as standards for risk to 
human health and safety from nearby industrial facilities and uses).
The location of new schools is of particular concern to both local governments and school districts. The general plan should 
identify possible locations for new schools. Such locations may be approximate and need not indicate specific parcels. 
Identifying appropriate school locations as part of the general plan process may avoid project-level problems of proximity to 
certain industrial facilities and uses. Due to the fragmentation of authority in the areas of 
land use
 planning and school siting 
and construction, it is recommended that the planning agency work closely with the school district to identify suitable school 
locations. Before adopting or amending a general plan, the planning agency must refer the proposed action to any school 
district within the area covered by the proposed action (
Gov. Code § 65352
). 
National City 
National City adopted a Health and Environmental Justice element prior to the new statutory requirement.
The element has goals and policies on a range of EJ and Health issues such as:
• Environmental Justice
• Land Use
• Safety
• Open Space and Agriculture
• Education and Public Participation
• Respiratory Health and Air Quality
• Circulation
• Physical Activity
• Healthy Foods
• Access to Health Care
• Lead Based Paint and other contaminants

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