Race and the Incidence of Environmental Hazards: A Time for Discourse.

It's clear that low-income and minority communities have been asked to bear a disproportionate burden of this country's industrial lifestyle.... They're angry and rightfully so. To solve this, we have got to incorporate environmental justice concerns into everything we do."(1)

I. Introduction

Declaring an end to "environmental racism" is an integral pad of the national environmental agenda in 1994.(2) Long held suspicions that minority communities are disproportionately affected by environmental hazards have been validated by two landmark national studies," the introduction of an eco-justice bill(4) and continued attention by both the Environmental Protection Agency(5) (EPA) and the Clinton administration.(6) Despite national recognition, however, policy makers continue to question the breadth of issues contributing to environmental racism. The book delivers the diverse subjects presented at the Conference to a wider audience.

Race and the Incidence of Environmental Hazards: A Time for Discourse,(7) edited by Bunyan Bryant and Paul Mohai,(8) helps fill the current educational void about environmental racism. The book compiles the complete collection of essays presented(9) by scholars(10) at the 1990 Conference on Race and the Incidence of Environmental Hazards (the Conference). The essays document numerous instances of environmental racism. Specific topics range from broadly theoretical to scientifically technical. The issues covered include: toxic waste and race in the United States, minority support for the environmental movement, environmental voting records of the Congressional Black Caucus, modeling "environmental discrimination," environmental blackmail in minority communities, studies on toxic fish consumption, the disproportionate effects of occupational injury, hazardous waste incineration in minority communities, environmentalism and civil rights, the international impact of pesticides on farm workers, and political factors which influence African policies on international toxic waste dumping.

II. Issues Presented

The book contains chapters discussing the impact of politics, economics, public health, and international policy on the environmental racism debate. Additionally, the book includes chapters presenting case studies and empirical data documenting the effects of environmental racism on minority communities. These studies add a technical, scientific dimension to the subject. Overall, the diversity of topics presented reinforces the breadth of the environmental racism agenda.

Chapter by chapter the book exposes the interdisciplinary thinking typical of scholars working on environmental racism issues. The reader is repeatedly bombarded with the message that any solution to the environmental racism problem is rooted in education, political empowerment, economic foresight, and sound policy creation. While each chapter focuses on its own piece of the environmental racism problem, the interdisciplinary message permeates the entire book.

The introduction and summary, written by the editors after the Conference, provide context for the issue as a whole. The introduction briefly summarizes the material contained in each chapter, however, the editors fail to provide any additional background or insight about the environmental racism movement. The summary stretches a bit further than the introduction by providing a short chronology of events since the Conference. However, the summary, like the introduction, fails to communicate the fervor of the movement or the rapid rise of the environmental racism agenda to a level of national prominence.(11) By failing to put the book in a historical context, the editors lost an opportunity to comment on both the importance of the environmental racism movement and the way national policy makers are addressing the complex issues embodied in the environmental racism agenda.

The individual chapters tell the following stories. In Chapter Two, Charles Lee summarizes the impact of the landmark 1987 report on race and toxics,(12) touching on the interrelationships between government, academia, grassroots communities, and the environmental and civil rights movements.(13) Lee describes the events that led to the publication of the 1987 report and discusses what he views as the most significant change since the report was published: "the increasing activism of minority communities."(14)

In Chapter Three, Dorceta Taylor discusses why the national environmental movement continues to exclude minorities.(15) Taylor challenges the assumption that minorities care less than whites about the environment.(16) She notes, however, that the structure of the national environmental movement must change to make room for minority interests.(17)

In Chapter Four, Henry Vance Davis discusses the Congressional Black Caucus' (CBC) role in supporting conservation issues.(18) According to the League of Conservation Voters annual scorecard,(19) the CBC has the strongest conservation voting record in Congress. Davis argues that the CBC's support should be applauded but cautions that "[b]lind support is not enough."(20) Davis concludes that for conservation efforts to continue the CBC must educate itself about the interrelationship between legislative motive, economic interests, and environmental issues.

In Chapter Five, Michel Gelobter uses an economic model to discuss the relationship between environmental regulation and discriminatory outcomes.(21) Government may "aggravate the regressive and discriminatory distribution of pollution" already faced by minorities(22) if it ignores certain variables. Some variables Gelobter believes the government should consider are: the definition of discrimination;(23) the physical measure of discrimination; the economic measure of discrimination; the comparison of cost measures and physical measures; time and space dimensions of discrimination; and the residual proof or description of discrimination.(24)

In Chapter Six, Robert Bullard examines "institutionalized discrimation"(25) and its role in environmental elitism and job blackmail. Bullard notes that "[t]here is inherent conflict between the interests of capital and those of labor."(26) Many of the conflicts stem from the fear that "environmental regulations are automatically linked to job loss."(27) Bullard argues that the only solution to environmental elitism and job blackmail is diversification of the national environmental agenda.(28) Diversification in this context means broadening the environmental racism movement to include more minority, low income, and working class participants.(29)

Chapters Seven, Eight, and Nine discuss health, beginning with the effects of eating fish caught in polluted urban rivers. In a pilot study on fish consumption, Patrick West found that fifteen percent of Detroit residents catch and eat fish from the Detroit River.(30) Moreover, the study indicated that "whites tended to fish primarily for recreation, while minorities tended to fish for both recreation and food."(31)

Chapter Eight expands on West's previous findings by using a state-wide sample. The authors found that minority sport anglers and their families consume twenty percent more fish than white anglers and their families.(32) The authors conclude that regulations governing the discharge of toxic chemicals into Michigan surface waters must be changed.

In Chapter Nine, Beverly Hendrix Wright analyzes why blacks "have a thirty-seven percent greater chance of suffering an occupational injury or illness and a twenty percent greater chance of dying from an occupational disease or injury than do white workers."(33) Wright examines socially-induced, physically-induced, and environmentally-induced diseases. She concludes that "[b]ecause blacks have been assigned a lower social status within American society, black citizens have historically been relegated to the most hazardous jobs in dangerous industries with no possibility of advancement or improvement."(34)

In Chapter Ten, Harvey L. White explores the dangers of hazardous waste on human communities:

In at least one respect, it represents a more imminent danger than he deadly AIDS virus. An individual can take steps to control or limit his or her exposure to AIDS. However, an individual has virtually no control over the quality of the air breathed, water drunk or food consumed.(35)

Specifically, White documents how environmental hazards emanating from the Rollins incinerator affect a n-middle class black community in Alsen, Louisiana.

Chapters Eleven and Twelve are case studies. Conner Bailey and Charles E. Faupel use the Emelle Landfill located in Sumter County, Alabama as an example of how economic considerations encourage the placement of environmental hazards in minority communities. The authors explain how the "black, rural, and poor" area of Sumter County became dependent on the Emelle Landfill for economic survival.(36) Emelle Landfill's owner was the County's largest employer, and in 1989 the landfill generated $3.8 million dollars in revenue for the County.(37) The case study shows that Sumter County's depressed economy prevented citizens from organizing an aggressive opposition to the placement of the environmentally hazardous landfill in their community.

Wm. Paul Robinson uses the Rio Puerco in New Mexico to illustrate the diverse long-term effects of uranium mining on Native Americans.(38) Robinson documents the cultural relationship between the Navajo Nation and their natural environment. When environmental hazards affect environmental resources they also affect the Navajo's cultural heritage. In the case of Rio Puerco, both the initial mining and resulting contamination have forced the Navajo Nation to organize in ways inconsistent with its historical design.(39) Such organization has affected the tribe as a whole.(40)

In Chapter Thirteen, Mohai and Bryant review fifteen empirical studies about the social distribution of environmental hazards.(41) AlthoUgh they wrote the chapter after the Conference, the editors include it for its "clear and unequivocal evidence that income and racial biases in the distribution of environmental hazards exist."(42) The authors argue that we should use the knowledge from these studies to create more effective environmental policy.

Ivette Perfecto and Mutombo Mpanya present an international perspective in Chapters Fourteen and Fifteen. Perfecto documents how pesticides that are banned in the United States end up in the American food supply.(43) American pesticide manufacturers export pesticides banned from use in the United States to foreign nations with fewer environmental regulations.(44) The exported pesticides return to the United States when produce is imported for consumer consumption.(45)

In Chapter Fifteen, Mpanya discusses the incidence and political reasoning involved in the disposal of foreign toxic waste in African countries.(46) Mpanya stresses the importance of broadening the concept of environmental racism to incorporate a global perspective: "The issue of toxic wastes in Africa presents a challenge to the world, a challenge of equality, reciprocity, and a truly global perception of humanity."(47)

III. Conclusion

Overall, the book provides a strong voice to the cause of environmental justice. Both the Conference on Race and the Incidence of Environmental Hazards and Bryant and Mohai's book demonstrate ambitious efforts to increase public awareness about the problem of environmental racism. The individual essays successfully communicate the urgency and breadth of the problem, but the editors lost the opportunity to explain the power of the environmental racism agenda by failing to place the book in a historical context.

Today, many state and federal bills are beginning to codify the concerns of environmental justice scholars.(48) Additionally, environmental justice organizations exist that exert political pressure on Congress to consider the disproportionate impact of environmental hazards on communities of color. Where the environmental movement is criticized for being divisive, pitting conservationists against industry, the environmental justice movement unifies people in the fight to collectively resolve the issues of environmental degradation.

Because the environmental justice movement can be defined as both an extension of the civil rights movement and the creation of a new environmental movement, the success of the movement continues to challenge traditional theories of political empowerment.(49) As Reverend Benjamin Chavis stated in 1991, the First National People of Color Environmental Leadership Summit held in Washington, D.C. "shattered [the notion] that a multi-racial movement is impossible in the U.S. because of the prevalence of racism which attempts to pit some people-of-color communities against [others]."(50)

Bryant and Mohal's book lays out some of the issues of the environmental justice debate, but fails to discuss the dramatic impact of the movement on the national policy.(51) Without this historical or otherwise unifying context, it is difficult to understand the scope of the problem(52) and to understand the importance of separate studies demonstrating political, economic, public health and international policy effects of decisions to place environmental hazards in communities of color. The power of this seven-year-old movement can only be comprehended by recognizing that it incorporates an innovative interdisciplinary approach to a long suspected problem.(53)

With these fundamental historical facts individual essays make sense. The factual history of the movement demonstrates how environmental racism issues are changing the way environmental regulations are currently being crafted. Without a historical context, however, the book is an odd assortment of articles by an array of authors with no singular focus or conclusion.

For readers with some knowledge of the environmental racism movement, the book serves the important role of delivering the diverse subjects presented at the Conference to a wider audience. The essays articulate an array of issues which must be considered as part of a comprehensive environmental racism debate. In this regard, Bryant and Mohai's book will continue as a useful source for people seeking the publications of selected individuals. Readers without this knowledge will find the evidence of racism interesting but will need to look elsewhere to integrate the information provided in the book into a complete picture of the environmental racism movement. * LL.M. expected 1994, Northwestern School of Law of Lewis and Clark College; J.D. 1991, University of San Diego School of Law; B.S., Cum Laude, 1988, University of Colorado. The author is currently Water Quality Policy Analyst for the Oregon Department of Environmental Quality. Previously, the author worked as a Staff Attorney for the Natural Resources Defense Council and as a Fellow for the U.S. Senate Environment and Public Works Committee, both in Washington, D.C. (1.) Comments of EPA Administrator Carol Browner, quoted in Melissa Healy, Administration Joins Fight for |Environmental Justice,' L.A. Times, Dec. 7, 1993, at A1. (2.) Dr. Benjamin Chavis, Jr., former Executive Director of the United Church of Christ Commission for Racial Justice, coined the phrase "environmental racism" in the 1987 study Toxic Wastes and Ram in the United Stain: A National Report on the Racial and Socio-Economic Characteristics of Communities Surrounding Hazardous Waste Sit". Charles Lee, Toxic Waste and Race in the United States, in Race and the Incidence of Environmental Hazards: A Time for Discourse 10 (Bunyan Bryant & Paul Mohai eds., 1992) [hereinafter Race & Envtl. Hazards]. (3.) The first study was General Accounting Office, U.S. Congress, Siting of Hazardous Waste Landfills and Their Correlation with Racial and Economic Status of Surrounding Communities (1983). 7he General Accounting Office (GAO) report resulted from a Warren County, North Carolina protest opposing the disposal of PCB laden soil in the local landfill The landfill was located in a predominantly black area. Walter Fauntroy, a demonstration participant and a D.C. congressional delegate, seized the opportunity to request that the GAO conduct a study on the incidence of environmental racism. The findings of the study showed that three of the four largest commercial landfills in the South were located in communities of color. Race & Envtl. Hazards, supra note 2, at 2. The second study Was United Church of Christ Comm. for Racial Justice, Toxic Wastes and Race in the United States: A National Report on the Racial and Socio-Economic Characteristics of Communities with Hazardous Waste Sites (1987). This report showed "that among a variety of indicators race was the best predictor of the location of hazardous waste facilities in the U.S." Race & Envtl. Hazards, supra note 2, at 2. (4.) On June 3, 1992, then Senator Al Gore introduced the Environmental Justice Act of 1992. S. 2806, 102d Cong., 2d Sess. (1992). In introducing the bill Senator Gore gave the following remarks: We are introducing today the Environmental Justice Act, and we are purposely introducing it on the first day of the Earth Summit because this legislation addresses in our own country a microcosm of the problems that are being addressed at the Earth Summit in Brazil. .... The linkage between injustice and human suffering on the one hand and environmental degradation on the other hand is firmly established. And because of the landmark study by the United Church of Christ initiated and led by Ben Chavis in 1987, we now know in our country that the single most accurate predictor of whether a community is likely to have an environmental problem like a hazardous waste dumpsite is whether or not it is a minority community and whether or not it is a poor and disadvantaged community. News Conference with Senator Al Gore (D-Tn), Representative John Lewis (D-Ga), and Others Re: Illness Among Minorities Caused by Pollution, Fed. News Service, June 3, 1992, available in LEXIS, News Library, Federal News Service File. (5.) In June 1992, the EPA released a study concluding "that racial and ethnic minorities suffer disproportionate exposure to dust, soot, carbon monoxide, ozone, sulfur, sulfur dioxide, lead, and emissions from hazardous waste dumps." Roberto Suro, Pollution Weary Minorities Try Civil Rights Tact, N.Y. Times, Jan. 11, 1993 at A1. The EPA is expected to review its regulations so that they better protect minorities from exposure to potentially harmful substances such as cancer causing PCBs found in fish. Current EPA standards typically use white men as the models of studies that establish a population's average exposure to such hazards. The agency now wants to take account of how much fish is consumed by minority populations, including poor blacks living in the rural South. Healy, supra, note 1, at A1. (6.) Vice President Gore recently noted: Those who are less able to defend themselves, those who have less economic and political power within the larger community are those most often taken advantage of and victimized with a disproportionate quantity of hazardous waste and pollution and the harmful and unwanted byproducts of production .... It is time for this nation to respond to the crisis ... and we are beginning to respond. Healy, supra note 1, at A1. (7.) Race & Envtl. Hazards, Supra note 2. (8.) Bunyan Bryant and Paul Mohai are, respectively, Associate and Assistant Professors in the School of Natural Resources at the University of Michigan. Drs. Bryant and Mohai were co-organizers of the 1990 Conference on Race and the Incidence of Environmental Hazards held at the University of Michigan. Id. at 1. (9.) The introduction, summary, and chapter entitled Environmental Racism: Reviewing the Evidence were written by the editors after the Conference concluded. Id. at 9. (10.) Conference contributors included Charles Lee, Dorceta Taylor, Henry Vance Davis, Michel Gelobter, Robert Bullard, Patrick C. West, J. Mark Fly, Frances Larkin, Robert W. Marans, Beverly Hendrix Wright Harvey L White, Conner Bailey, Charles E. Faupel, Wm. Paul Robinson, Paul Mohai, Bunyan Bryant, Ivette Perfecto, and Mutombo Mpanya. Id. at v-vi. (11.) See Marc Mowrey & Tim Redmond, Not in our Backyard 431-37 (1993). (12.) See supra note 3. (13.) Charles Lee, Toxic Waste and Race in the United States, in Race & Envtl. Hazards, Supra note 2, at 10. Lee is Director of Research for the United Church of Christ Commission for Racial Justice. He directed the study and wrote the United Church of Christ report on the correlation of race and hazardous waste sites, previously discussed at note 3. Id. at 10-11. (14.) Id. at 16. (15.) Dorceta Taylor, Can the Environmental Movement Attract and Maintain the Support of Minorities?; in Race & Envtl. Hazards, supra note 2, at 28. Taylor was a graduate student at Yale University at the time she wrote this paper. Id. at 28. (16.) Id. at 29. (17.) Taylor cites a January 1988 survey that found that minority organizations would find it easier to work with national environmental groups if the national groups: (1) provided minority groups with more information about their activities; (2) worked on resource issues that were of concern to minority groups; (3) became more active in regional and local issues; (4) had minority representation; (5) made greater outreach efforts to minority communities; (6) joined with minority coalitions; (7) provided funding to minority groups; (8) were committed to treaty rights, and recognized tribal governments; (9) helped to cover the costs of travel to meetings, seminars, etc.; (10) accepted collect phone calls from local groups; (11) helped to develop solutions to local natural resource issues; (12) covered minority resource issues, campaigns, and problems in their publications; (13) helped to develop natural resource management plans; and (14) provided employment opportunities for minorities and the poor in their organizations. Id. at 45-46 (citing American Land Resource Association & Natural Resource Council of America, A Guide to Minority Natural Resource Issues and Organizations (1988)). (18.) Henry Vance Davis, The Environmental Voting Record of the Congressional Black Caucus, in Race & Envtl. Hazards, supra note 2, at 55. Davis is Assistant Professor of History at Western Michigan University. Id. (19.) [The annual] scorecard tabulates votes on a broad range of environmental bills and issues which were deemed most important by the Board of Directors .... In addition to votes case on House and Senate floor, the scores include co-sponsorships of bills and co-signatures of letters on major environmental issues. For example, in 1986-87 the League used 16 bills on which to score Congresspersons. The bills covered issues pertaining to the Clean Water Act, the Clean Air Act, energy conservation, various nuclear questions, the Endangered Species Act, and acid rain. Id. at 56. (20.) Id. at 63. (21.) Michel Gelobter, Toward a Model of "Environmental Discrimination," in Race & Envtl. Hazards, supra note 2, at 65. Gelobter is Assistant Commissioner for Policy and Planning for the New York City Department of Environmental Protection. Id. at 64. (22.) Id. at 63. (23.) Gelobter uses Feagin's broad definition that discrimination constitutes "actions or practices carried out by dominant groups, or their representatives, which have a differential and negative impact on members of subordinate groups." Id. at 65 (quoting J.R. Feagin & C.B. Feagin, Discrimination American Style: Institutional Racism and Sexism 20-21 (2d ed. 1986)). (24.) Id. at 65-73. (25.) Robert Bullard, Environmental Blackmail in Minority Communities, in Race & Envtl. Hazards, supra note 2, at 94. Bullard, an Associate Professor of Sociology at the University of California at Riverside, id. at 82, has been credited with conducting the first study to correlate race with exposure to environmental hazards. Suro, supra note 5. (26.) Bullard, supra note 25, at 83. (27.) Id. (28.) Id. at 92. (29.) Id. (30.) Patrick West, Invitation to Poison? Detroit Minorities and Toxic Fish Consumption from the Detroit River, in RACE & Envtl. Hazards, supra note 2, at 97. West is Associate Professor of Natural Resources/Environmental Sociology at the University of Michigan. Id. at 96. (31.) Id. at 97. (32.) Patrick C. West, J. Mark Fly, Francis Larkin, & Robert W. Marans, Minority Anglers and Toxic Fish Consumption: Evidence from a Statewide Survey of Michigan, in Race & Entl. Hazards, supra note 2, at 100, 104. Fly is Associate Professor of Outdoor Recreation at the University of Wisconsin, Madison. Id. at 100. Larkin is Professor of Public Health at the University of Michigan School of Public Health. Id. Marans is a Professor in the Urban Planning Program and a research scientist at the Institute for Social Research at the University of Michigan. Id. (33.) Beverly Hendrix Wright, The Effects of Occupational Injury, Illness, and Disease on the Health Status of Black Americans: A Review, in RACE & Envtl Hazards, supra note 2, at 115. Wright is Associate Professor of Sociology at Wake Forest University in North Carolina. Id. at 114. (34.) Id. at 125. (35.) Harvey L White, Hazardous Waste Incineration and Minority Communities, in Race & Envtl Hazards, supra note 2, at 126. White is Associate Professor of Public Management and Policy at the University of Pittsburgh Graduate School of Public and International Affairs. Id. (36.) Conner Bailey & Charles E. Faupel, Environmentalism and Civil Rights in Sumter County, Alabama, in RACE & Envtl. Hazards, supra note 2, at 140. Bailey is an Associate Professor in the department of Agricultural Economics and Rural Sociology at Auburn University. Id. Faupel is an Associate Professor in the School of Social Work at Auburn University. Id. (37.) Id. at 143. (38.) Wm. Paul Robinson, Uranium Production and Its Effects on Navajo Communities Along the Rio Puerco in Western New Mexico, in Race & Envtl. Hazards, supra note 2, at 154. Robinson is the Research Director of the Southwest Research and Information Center located in Albuquerque, New Mexico. Id. at 153. (39.) Id. at 155-56. (40.) Id. (41.) Paul Mohai & Bunyan Bryant, Environmental Racism: Reviewing the Evidence, in Race and Envtl. Hazards, supra note 2, at 165. (42.) Id. at 174. (43.) Ivette Perfecto, Pesticide Exposure of Farm Workers and the International Connection, in RACE AND Envtl. Hazards, supra note 2, at 177. Perfecto has a Ph.D. in Ecology and is Assistant Professor in the School of Natural Resources, University of Michigan. Id. (44.) Id. at 185-88. (45.) Id. at 189. (46.) Mutombo Mpanya, The Dumping of Toxic Waste in African Countries: A Case of Poverty and Racism, in RACE & Envtl. Hazards, supra note 2, at 214. Mpanya is Director of International Environmental Studies at World College West in Petaluma, California. Id. at 204. (47.) Id. at 214. (48.) Many states have proposed or adopted environmental equity laws. These laws address the issues of (1) providing compensation to host communities; (2) enhancing public notice and participation; (3) improving risk assessment methodologies; (4) creating state equity policies; and (5) increasing public communication and information. States that currently have adopted environmental justice legislation include Arkansas, which requires that a twelve mile distance between high impact solid waste disposal sites and that host communities receive economic benefits (1993 Ark. Acts 1263) and Louisiana, which requires three hearings on policy recommendations (1993 La. Acts. 767). States that currently have proposed environmental justice legislation include: California, which has proposed requiring site demographic studies before approving high impact development projects; Georgia, which has proposed publishing an annual toxics release inventory and health risk assessment to pinpointing activities having adverse impacts on human health; New York, which has proposed creating a task force to promote development of environmental equity policy; North Carolina, which has proposed creating an Environmental Justice Commission to examine environmental policies and siting patterns; and South Carolina, which has proposed requiring the identification of 100 environmental high risk areas. Center for Policy Alternative, Policy Alternatives on Environment. A State Report Aug. 1993, at 1-4. (49.) David Pepper, Eco-Socialism: From Deep Ecology to Social Justice (1993). "Radical social change, achieved by confronting people's ideas or their economic organization, means also confronting the political power of those who benefit from present arrangements." Id. at 15. (50.) Karl Grossman, From Toxic Racism to Environmental Justice, E, THE Environmental Magazine, May/June 1992, at 30. (51.) For example, Executive Order 12,898, 59 Fed. Reg. 7629 (1994) focuses federal attention on the environmental and human health conditions in minority and low income communities with the goal of achieving environmental justice. Under the Order, afl federal agencies must determine whether their regulation adversely affects low income or minority communities. The Order further requires that agencies make sure that states and other organizations receiving federal funding for environmental projects do not violate federal civil rights law. In addition to the Executive Order, there are at least nine bills before Congress addressing the issue of environmental justice. One of the most interesting proposals would direct EPA to identify communities with the greatest exposure to toxic pollutants. These communities would be designated "high impact areas.' Once identified, these areas would receive strict regulatory oversight and technical assistance. Additionally, health assessments would be conducted taking into account the cumulative and synergistic effects of multiple land uses and air pollution. H.R. 2105, 103d Cong., 1st Sess. [subsection] 102(a), 201, 301 (1993). (52.) "Political movements can grow by drawing upon the resources of the past. For good or for W, the past can be used as a flag to lead supporters into a new future . . . . To understand the growth and nature of environmentalism we must study its roots." Derek Wall, Green History: A Reader in Environmental Literature, Philosophy, and Politics 2 (1994). (53.) The ideology for the movement can be traced back to the 1987 Church of Christ Report See supra note 2 for further discussion. However, the birth of the "movement" is generally marked by the National People of Color Environmental Leadership Summit held in Washington, D.C. in October of 1991. The author chose to use the 1987 date to mark the beginning of the movement because the Conference predated the Summit. Only time will tell whether the Conference will memorialize the birth of the environmental justice movement the way Earth Day memorialized the birth of modem environmentalism. See Mowery & Redmond, supra note 11, at 13.