The Citizens' Environmental Integrity Act (Part 1 of 3)
Local & National News | May 14, 2025
The Citizens' Environmental Integrity Act Ordinance is a citizen-centered piece of legislation that must be used to establish new local environmental safeguards and undo widespread legacy pollution.

Written by: Gilbert Barnes Carter III

The Citizens' Environmental Integrity Act Ordinance is a citizen-centered piece of legislation that must be used to establish new local environmental safeguards and undo widespread legacy pollution.

The local resistance against CTC Property, LLC and xAI is becoming increasingly pivotal.

Recent Advocacy and Community Action

Tennessee State Representative (District 86) Justin J. Pearson led a spirited demonstration and press conference directly outside of the Shelby County Health Department headquarters on May 9. He listed 17 high impact / toxic release inventory company / corporation facility locations during his address that are currently in the 38109 zip code area across Southwest Memphis. Ms. Sam Supan, a senior at Rhodes College, listed a total of 58 TRI sites in Shelby County during her "Mapping Toxic Release Sites in Southwest Memphis: An Accessible Approach" presentation via YouTube on May 12. 25 of those sites, all in the 38109 zip code area, are disproportionately located across Southwest Memphis.

Ten of those companies / corporations are listed below.

Research and Legislative Models

Collective research results between Memphis City Councilwoman Yolanda Cooper-Sutton, myself, other concerned citizens, and Shelby County Commissioner Erika Sugarmon have revealed that there are several locations across the United States where legislation for the regulation of category-specific and commercial data center operations is currently comprehensive. Environmental Protection Agency (EPA) officials have categorized the respective pieces of legislation as "recommended model ordinances."

Five of those locations are listed below.
Note: I had the pleasure of speaking with Mr. Richard W. Hancock, the Principal Planner at the Loudoun County (Virginia) Department of Planning and Zoning, on April 24. He graciously provided an update and technical assistance. Loudoun County officials are bolstering their legislation that is already effective.

"Loudoun County officials are currently undergoing a Comprehensive Plan Amendment (CPAM) and an associated Zoning Ordinance Amendment (ZOAM) to update the policies and standards for data center and electrical substation uses."

Legislative Intent

I drafted the Citizens' Environmental Integrity Act Ordinance to have a solution based approach. I am confident that it will be passed and utilized to generate more favorable environmental justice outcomes for the citizens of Memphis and Shelby County for the foreseeable future. The earliest possible date for me to present the legislation before the Shelby County Board of Commissioners Committee is June 18. Three readings by the Shelby County Board of Commissioners are mandatory ahead of the legislation being officially passed.

SECTION I - INTENT AND PURPOSE
WHEREAS, the citizens of Memphis and Shelby County demand and deserve to always maintain and protect the physical environmental integrity of all natural features, resources, and organisms, such as, but not limited to, air, soil, water, wetlands, and wildlife, within the defined corporate limits of both…

WHEREAS, the citizens of Memphis and Shelby County demand and deserve to always receive advance notice of the consideration of category-specific and commercial data center and high impact / toxic release inventory project development plans that have the potential to not be conducive to (a.) maintaining and increasing public health equity and (b.) maintaining and protecting the physical environmental integrity of the natural environment during forums such as, but not limited to, public hearings…

WHEREAS, the citizens of Memphis and Shelby County demand and deserve to undo the environmental degradation and legacy pollution that has been proliferated from existing high impact / toxic release inventory facility locations for decades…

WHEREAS, there is no legislation for the regulation of category-specific and commercial data center and high impact / toxic release inventory operations in Memphis and Shelby County…

WHEREAS, T.C.A. Title 6, Chapter 54, allows for the “legal authority for jurisdictions to create, edit, or change local ordinances to protect air quality, that it complies with state and federal laws, and cannot conflict with those standards”…

(E.g., The Clean Air Standards Act…)
For a copy of the current draft of the ordinance, please send an e-mail message with the keyword "CITIZENS" on the subject line to gil@ctcmidsouth.org

Learn more about Gilbert Barnes Carter III

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