Only 2 days left to submit "Green Jobs Definition" comments to the US Dept. of Labor!!

The Department of Labor, Bureau of Labor Statistics has requested public comment on their proposed definition of green jobs and the approach they plan to use in gathering data about green jobs. April 30th is the last day to submit a comment. To view the proposed language go to: http://edocket.access.gpo.gov/2010/pdf/2010-5705.pdf. To view the list of proposed green job industries go to: http://www.bls.gov/green/industry_by_inclusion.pdf.

Comments may be emailed to green@bls.gov and should be directed to:
Richard Clayton
Office of Industry Employment Statistics
Bureau of Labor Statistics
Room 4840
2 Massachusettes Ave., NE.
Washington, DC 20212

The following is the comment submitted by Grassroots Leadership Network of Marin:

We would like to commend the Department of Labor and Bureau of Labor Statistics for initiating efforts to gather data around green jobs and the burgeoning green economy. We agree that this information will prove vital to policymakers working to protect the environment and conserve natural resources. We do find, however, the proposed definition of green jobs to be insufficient in its current scope. We are thus concerned that it will not adequately serve policymakers and will lead to ineffective policies that fall short of promoting a thriving, green economy.

As we conceptualize it, green jobs and the resulting green economy are about sustainability. Current best practices around sustainability concur that it is comprised of three E’s: Environment, Economy, and Equity. The proposed definition addresses environmental and economic issues, yet does nothing to address equity issues.

According to the current language, the stated goal of the Bureau of Labor Statistics is to “develop information on: (1) the number of and trend over time in green jobs, (2) the industrial, occupational, and geographic distribution of the jobs, and (3) the wages of the workers in these jobs.” The language later states that, “The Bureau’s definition of green jobs is based on economic activity, and does not consider job aspects unrelated to the work itself, such as wages, union membership, benefits, or career ladders. However, BLS will produce data on occupational wages . . .” These statements are incongruent and reflect the problems inherent in attempting to oversimplify the definition of green jobs by neglecting to address equity.

To assert that wages or career ladders are “unrelated to the work itself” is a fallacy that should be rectified before it leads to flawed policies and practices. To state the obvious, a job is that which enables a person to exchange labor for a wage. The nature of the “work itself” is the strongest determining factor of the wages attached to that work. Were this not the case, all jobs would have the same wage for entry level workers. For example, the “work itself” performed by an MD requires specific education and experience, which is distinct from the specific education and experience necessary to the “work itself” performed by a Landscaper. For this reason, the Landscaper and the MD will receive very different wages and will have very different opportunities for advancement, and by advancement we mean increased responsibility and increased wages.

The above example may appear elementary, but we believe that it points to equity issues that represent significant pieces of the data puzzle. Access to education, experience, and opportunity is not equal for all residents of this great nation and tends to break down along lines of race, gender, and socioeconomic status. Ignoring the disparities will only serve to exacerbate them and will undermine sustainability.

A green economy is also a sustainable economy. A sustainable economy should maximize economic opportunity for all and thereby reduce poverty. According to a recent report published by The Greenlining Institute, entitled “Race Still Matters” (October 2009), “one in four Blacks, and one in five Latinos lives in poverty, compared to less than one in ten Whites.” The report further asserts that “race and poverty are heavily intertwined, and thus race is implicit in a host of pressing policy arenas. Failing to report and collect data on race and ethnicity obfuscates the disproportionate impact of poverty on people of color.”

Equity is about ensuring that the benefits and burdens of society are equally shared by all. If green jobs are about protecting the environment and preserving natural resources, how can we adequately measure the extent to which they achieve their purpose without tracking the equity indicators that account for the distribution of the benefits and burdens associated with protecting the environment and preserving natural resources?

We therefore recommend that the definition of green jobs be amended as follows (the amendment appears in bold): “Broadly defined, green jobs are jobs involved in economic activities that help protect or restore the environment or conserve natural resources, thus promoting sustainability.” We also recommend that in addition to producing data on occupational wages, BLS produce data on race, gender, and socioeconomic status.

We appreciate the opportunity to comment on the Department of Labor, Bureau of Labor Statistics proposed definition of green jobs. We trust that the public comments will help to ensure that the BLS definition will produce comprehensive data sets that will serve as the baseline for sound policies that further the common good.