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Environmental equity.

Someone once said that no one is safe from the many environmental problems that threaten our planet and our health; but, we are not all endangered equally.

Over the last five years, the civil rights movement has voiced concern over the likelihood that low-income groups and people of color are more subject to environmental hazards than their white and more affluent counterparts. The traditionally white, middle class environmental movement has begun to support this claim, and what has resulted is evidence of growing cooperation between those committed to protecting nature and those committed to correcting problems of social justice.

Political activity resulting from such cooperation has materialized only recently. Most observers point to the 1982 demonstration against the siting of a PCB landfill in Warren County, North Carolina as the watershed event in the mobilization of environmentalists and social justice activists (the so-called "Merger of the Environmental and Civil Rights Movements"). While protests of siting decisions have been common in white, middle-to-upper income neighborhoods ever since Love Canal, NIMBY ("Not-in-my-back-yard") opposition in low-income areas with high populations of African Americans, Latinos and other nonwhite racial and ethnic groups has been rare, or at least not publicized. With this in mind, the Warren County protests symbolized unprecedented levels of environmental awareness among peoples typically perceived to be apathetic with respect to natural resource and pollution issues.

In response to the protests, District of Columbia Congressional Rep. Walter Fauntroy (who was one of the 500 demonstrators arrested) requested that the U.S. General Accounting Office (GAO)investigate the siting question. GAO's response was entitled "Siting of Hazardous Waste Landfills and their Correlation with the Racial and Socio-Economic Status of Surrounding Communities," published in June 1983. GAO reported that blacks were disproportionately represented in three of the four sites surveyed. In an effort to expand on this finding, the United Church of Christ Commission for Racial Justice (U.C.C.) contracted with the consulting firm Public Data Access, Inc. to examine the statistical relationship between hazardous waste site location and racial/socioeconomic composition of host communities nationwide. The resulting study was called, "Toxic Waste and Race in the United States: A National Report on the Racial and Socio-Economic Characteristics of Communities with Hazardous Waste Sites."

The report's specific claim that "race proved to be the most significant (factors) among (the) variables" correlated with hazardous site location has yet to be positively confirmed by the academic community. However, the study's more general argument--that the poor and people of color are more likely to live in communities which host hazardous waste facilities and/or uncontrolled hazardous waste sites than affluent whites--has been generally accepted. If nothing else, Toxic Waste and Race has helped to strengthen this new and delicate link between environmentalists and civil rights activists in efforts to highlight instances of dumping on the poor and people of color.

"Environmental justice" research has taken many forms, from sociological texts to pure economic analyses. The following is a review of a number of papers, articles and texts concerned with equity implications of environmental policy. Sources have been broken down by environmental medium rather than by type of research. These media are consistent with the organizational breakdown of EPA into program offices.

Water quality

The distributional implications of EPA's water pollution abatement efforts are quite serious. The Agency allocates billions of dollars each year for municipal water pollution control in the form of construction grants (and other government cost sharing programs) for publicly owned treatment works (POTWs) and other forms of pollution abatement. No research into whether such monies have been (or continue to be) distributed equitably across population subgroups and geographic regions was found in this literature search. It should be noted that the construction grant program is currently being phased out in favor of State Revolving Loan Fund program (SRF). The financial ability of many lower-income communities to deal with loan programs in the absence of grant monies is subject to question. Two questions should be resolved. The first relates to how construction grants have been distributed, and which communities received the grants and for what reasons. The second question delves into the potential impacts of the transition from Construction Grants to State Revolving Funds on low-income communities which may have minority populations.

Fish consumption and water quality

When writing its toxic standards, the Michigan Department of Natural Resources assumes consumption of 6.5 grams per person per day, a level far below those anglers of any subgroup in a survey by Patrick C. West, et al. However, a number of neighboring states have standards up around 20 grams per person per day--sufficient to protect white anglers, but not a number of minority subgroups. Only New York was identified to have a standard high enough to cover all population subgroups.

A similar study for the city of Detroit is reported by Patrick West in Invitation to Poison: Detroit Minorities and Fish Consumption for the Detroit River. West surveyed Detroit residents by phone (accounting for the underrepresentation of poor households due to their lower probability of having a telephone) and found that people of color were nearly three times as likely as whites to mention food as one of their uses of the Detroit River.

These two pieces of research illustrate a potentially dangerous distributional impact of a government (albeit state government) policy. Water quality standards which are based on fish consumption data for a single population subgroup will always be insufficient for protecting all subgroups unless the single group selected is the most consumptive--and therefore the most exposed. For anglers fishing for subsistence, changing behavior to reduce exposure is simply not an option. The point holds even more strongly for those subgroups for which fish possess major cultural significance (native Americans, Asian Americans) and who often eat not only more fish, but also more of each fish--that is the whole thing, including the tail and head, which have the highest bioaccumulation of toxic substances, and for which consumption is not considered in the writing of water quality standards. EPA would do well to address these potential distributional impacts through offering guidance on fish advisories, as well as using its regulatory power delegated to states to enact standards which better reflect consumption patterns for cross-sections of the population.

Another article concerns the impacts of uranium production on water quality in Navajo tribal territory in New Mexico. Written by the education director of a nonprofit environmental/consumer advocacy group based in Albuquerque, this piece gives a synopsis of the events surrounding the dewatering of the Morrison Aquifer, management of production wastes (called mill "tailings") of the uranium operation, and resultant impacts on the Rio Puerco, a major source of drinking water for Navajo residents. This article does not direct any specific criticism at the EPA regarding its handling of the situation--in which high levels of exposure resulted due to consistent DDES permit violations, as well as the collapse of the United Nuclear Company's mill tailings dam--but its tone implies that the Agency was less responsive than it should have been and points to community activism and private litigation as the true driving forces between remediation of environmental damage.

Air Quality

"The Distribution of Air Quality in the New York Region," a study by urban and regional planning specialist Jeffrey Zupan, addresses the physical measures of pollution-specifically, its magnitude and location--so as to examine relationships to income. Zupan's two hypotheses were:

* that air quality decreases with income group ("the lower the income group, the lower the air quality it is exposed to"); and

* that air quality improvements have benefited the poor the least--that is, the distribution of improvements has been regressive.

There is some debate as to whether race or class is the critical variable in predicting the health characteristics of a subpopulation. Regardless, race and class are so closely related that identifying one variable or the other as the root of public health problems may not be necessary.

RCRA/CERCLA and facility siting

Low-income/minority risk issues relative to the activities of the EPA's Office of Solid Waste and Emergency Response (OSWER) are numerous. While the Agency has no control over where illegal dumpers of solid and hazardous waste choose to violate the law, EPA's decisions to pursue administrative and enforcement actions may be reviewed to examine whether factors outside the magnitude and severity of the infraction (i.e., wealth, ethnic makeup, and political power of the community) played a role in the Agency's resolve to crack down on violators. No analyses of this nature were found in the review; however, a number are in progress.

It should be noted that the United Church of Christ's Toxic Waste and Race study included in its analysis of "host" communities not only hazardous waste disposal facilities (landfills and incinerators), but also a category called "uncontrolled toxic waste sites" (referring to Superfund, or CERCLA, sites). This category consists of any documented closed and abandoned waste site (as well as some non-site, or abandoned drums) which may or may not pose a potential threat to human health and the environment. (The study was somewhat flawed, however, by a lack of understanding of CERCLA.) There is some concern that the prioritization of sites targeted to be remediated by Superfund and other cleanup programs may be influenced by the political--as well as the socio-economical racial--"strengths and weaknesses" of the surrounding communities.

The U.C.C. report points out that over half of the total population in the United States lives in communities which host uncontrolled hazardous waste sites.

On the effects side, no studies were found relating to public health risks associated with hazardous waste sites, whether disposal facilities or uncontrolled sites, on a regional or nationwide scale. This is not surprising, judging from the priority structure advanced by the EPA Science Advisory Board's recent report on risk reduction as well as the common claim held by risk experts that the perceived risks associated with such facilities vastly outweigh the actual risks.

EPA Environmental Equity Workgroup Report

On Monday, February 24, 1992 the EPA Environmental Equity Workgroup issued our draft report, entitled "Environmental Equity: Reducing Risk for All Communities" to the EPA Administrator. The Workgroup report was the Agency's first step in response to environmental equity concerns.

Basically, the workgroup used the report to urge the Agency to pay closer attention to how regulatory practices increase environmental health risks to people of color and low-income communities. We did that in the context of a risk-based approach to environmental management: the relative risk burden borne by low-income and racial minority communities is a special concern.

The workgroup was charged with determining whether people of color and the poor are experiencing disproportionately greater environmental health problems. They found that there is a general lack of data on environmental health effects by race and income. Even though there is a clear difference between racial groups in terms of disease and death rates, there is an absence of data to document the environmental contribution to these differences--for diseases known to have environmental causes, data are not typically disaggregated by race and income.

The notable exception, however, is lead poisoning--which is irreversible. Lakisa Washington, an African American child with severe learning disabilities and other neurological disorders, was determined to have a blood lead level nine times higher than the national rate.

The Workgroup believes it is possible to document differences in observed and potential exposure to some environmental pollutants by socio-economic factors and race. Of course, exposure is not the same as health effects--but this finding is nevertheless a clear cause for concern.

Our recommendation to the Administrator was that EPA "increase the priority that we give to the issue of environmental equity" by devoting greater resources to this issue; to educate our managers as to what environmental equity is about; and to determine whether the Agency's programs and policies lend themselves to discriminatory environmental protection.

We also recommended that EPA:

* launch a research and data collection plan to develop information providing an objective basis for assessing risks by income and race;

* incorporate environmental equity considerations into the risk assessment process and revise the process "to insure, wherever, practical and relevant, better characterizations of risk across population, communities or geographic areas;

* identify and target opportunities to reduce high concentrations of risk to different population groups, and;

* selectively assess and consider the distribution of projected risk reduction in major rulemaking and Agency initiatives, "where appropriate."

We believe that the Agency should review and selectively revise the permits and grants program and the Agency's monitoring and enforcement procedures to address high concentrations of risk in people of color and low-income communities. Since state and local governments have primary authority for many environmental programs, the Agency should enlist them in environmental equity issues as well.

EPA is in the process of establishing an Office of Environmental Equity with a broad range of functions and responsibilities, including

* providing policy analysis

* technical assistance to EPA programs

* research and risk reduction projects

* program regulation review

* tracking environmental equity implementation

* coordinating Agency environmental equity projects

* engaging in outreach activities

* organizing environmental equity centers

* enlisting state and local governments in environmental equity issues

* maintaining an extensive database of source information on equity issues

* coordinating with community based grassroots organizations

In order to work across program areas we are establishing an Environmental Equity Cluster (Board of Directors of the office of Environmental Equity), which is directed to...

* develop strategies for implementing the Environmental Equity Report

* identify issues not in the report

* focus on research, outreach and enforcement

* identify regulations and policies with equity implications

* promote integrated approaches to equity policy development

* build equity institutional capacity and commitment

* explore multi-faceted enforcement and educational approach.

The Office of Environmental Equity will have as its mission the improvement of environmental conditions in targeted high risk minority and poor communities.

Finally, to some extent environmental injustices may be redressed and prevented through revising our laws and regulations. One example is our proposed amendments to the hazardous waste law, which would minimize the ability of corporations to site hazardous facilities in low-income and minority communities. Yet, in effect, such amendments may make it nearly impossible to site any new industrial facilities in the United States at all, recalling the "BANANA" syndrome--"Build Absolutely Nothing, Anywhere, Near Anybody." This may not only have negative repercussions for our national economy, but it would probably speed up the relocation of toxic industries to communities in the Third World that already are suffering from far worse environmental conditions.

On the other hand, "enterprise zones" and "emissions trading" are likely to shift greater pollution burdens onto neighborhoods seeking economic development in the U.S.--in other words, lower-income, minority communities.

Ultimate solutions require leadership at all levels of society in redefining our economic goals and structures in ways to support more sustainable modes of development in our cities, on our farms, and throughout the country.

Our public policies need to be reoriented to take full account to adjust to human activities, and to take full account of the value of life with which we share this planet.

This means not only disproportional impacts on populations and ecologies that are already at risk, but also rebuilding these communities so that they can survive and flourish.
COPYRIGHT 1993 National Environmental Health Association
No portion of this article can be reproduced without the express written permission from the copyright holder.
Copyright 1993, Gale Group. All rights reserved. Gale Group is a Thomson Corporation Company.

Article Details
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Author:Knox, Robert J.
Publication:Journal of Environmental Health
Date:May 1, 1993
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