Chelsea River, aka Chelsea Creek, is the site of seven oil storage facilities whose permits, issued by EPA Region 1 under National Pollutant Discharge Elimination Systems (NPDES), are up for renewal this year. These facilities store 70-80% of the New England region’s heating oil and all of the jet fuel for the Boston Logan International Airport. As part of the permitting process, EPA accepted oral and written comments from community members regarding the proposed permits and the environmental justice analysis (EJA) of the areas surrounding Chelsea Creek. EEW, in collaboration with GreenRoots and Dr. Sara Wylie’s research team from Northeastern University, researched and analyzed the proposed permits and EJA over multiple weeks. The following written comment is a critique of the permits and EJA from an environmental and data justice framework.