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Community groups Moms On a Mission Hui and Pō‘ai Wai Ola allege that HDOA and ADC have failed to implement Title VI compliance programs, leading to discriminatory adverse effects on Native Hawaiian populations. The complaint highlights the lack of pesticide registration limits, the absence of mandatory buffer zones, and a failure to enforce federal and state pesticide laws. It specifically points to the high concentration of genetically engineered seed crops in West Kaua‘i and Moloka‘i, where Native Hawaiian populations are proportionally higher than the state average. Additionally, the complaint cites ADC's operation of an unpermitted drainage ditch system on the Mānā Plain that discharges pollutants into waters used by Native Hawaiians. The complainants request that the EPA and USDA conduct compliance reviews and require the agencies to develop implementation plans to mitigate these discriminatory impacts.

The document contends that the U.S. EPA has failed to protect minority and low-income Americans from coal ash pollution, the second largest source of industrial waste in the U.S. It argues that the 2014 coal ash rule is insufficient because it places the burden of enforcement on citizens and allows the continued use of dangerous, unlined coal ash lagoons, which are predominantly located in vulnerable neighborhoods. The text calls for immediate EPA action, including drinking water testing and technical assistance for affected communities, to address these civil rights and public health disparities.