United States
                      Environmental Protection
                      Agency
Office of
Communications, Education,
and Public Affairs
Volume 18, Number 1
March/April 1992
175N-92-001
                     L •
                                                                         A
Environmental
Protection-
Has It Been Fair?
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                         ?/EPA  JOURNAL
United States
Environmental Protection Agency

Office of Communications.
Education, and Public Affairs

William K. Reilly
Administrator
Lew Crampton
Associate Administrator
Charles Osolin
Director of Editorial Services
John Heritage
Editor
Karen Flagstad
Associate Editor
Ruth Barker
Assistant Editor
Jack Lewis
Assistant Editor
Nancy Starnes
Assistant Editor
Douglass Lea
Contributing Editor
Marilyn Rogers
Circulation Manager
Editorial Assistance
Leighton Price

Design Credits
Ron Farrah
James R. Ingram
Robert Flanagan
Front Cover:
November 1988: Young activist
in Louisiana Toxics March
protests poJJution from
petrochemical plants along
Mississippi. Copyright Sam
Kiltner.
EPA JOURNAL
is printed on recycled paper.
A Magazine on National and Global Environmental Perspectives

March/April 1992 •  Volume 18, Number 1  175 N92-001
From the Editor
  Is it time that we broadened the definition of environmental protection
  in this country?
   The physical environment of America's minorities—Hispanics, Native
  Americans, Asians, African Americans, the poor of any color—has in
one way or another been left out of the environmental cleanup of the
past two decades. Black children, as a whole, have more lead in their
blood than do white children. Blacks are decidedly overrepresented in
air-pollution nonattainment areas. The environment of migrant farm
workers, particularly in their exposure to hazardous pesticides, has not
been well protected, to say the least. People of color are much more
likely to have hazardous waste sites in their backyards than are whites.
Some environmental problems suffered by minorities are not even in the
standard lexicon: poorly insulated homes that are hot in summer and
cold in  winter; neighborhoods infested with rats.
  The environmental effort launched by Earth Day, 1970, has been
largely defined by middle and upper class whites. It has been
environmentalism with a big E, a specialized activity serving a special
segment of our society. Environmental protection laws have largely
reflected that definition. Ironically, Earth Day, itself, was socially
oriented and broad based, involving tens of millions of people of all
ages, incomes, and regions of the country.
  Some will  argue  that, for the most part, minorities and the poor have
not volunteered for the environmental movement. Agreed; they may
have had more pressing problems. Does  that mean that they should not
share in the benefits?
  A skeptic says, "If you broaden the definition of protection to include
the devastated environment of the inner city, where is the end?" It may
be that there is no end,  only  a goal, one  that we can strive for but never
completely achieve: decency, compassion, hope. It may be that every
social cause should, fundamentally, have this aim. Not simply because it
is right, but because on a planet  with great risks as well as great benefits,
it is realistic, o
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 Contents
THE  ISSUE


C Race, Poverty, and
  the Environment
  by Paul Mohai and
  Bunyan Bryant

Q The Michigan
  Conference: A
  Turning Point
  by Bunyan Bryant and
  Paul Mohai
13

 •
                         EXPANDING THE
                         DIALOGUE

                       fi Environmental Equity:
                       0 EPA's Position
                         by William K. Reilly

                      Ofj The Agency's
                         Workgroup Report
                         by Hober! M. Wolcolt find
                         Reina Milligan

In Our Backyards
by floberf D. Billiard

Farm Workers:
Among the Least
Protected
by Jvette Perfeclo and
Baldemar Velasquez

Health Concerns for
Fish-Eating Tribes?
by Pa I rick C. West

Breathing Polluted Air
by D.R. Wernetle and
L.A. Nieves


The Environmental
Justice Movement
by Dorceta Taylor

The Mainstream
Environmental
Movement
by John H. Adams

A Challenge to EPA
by Deeohn Ferris
                         Ojj A Challenge to
                            Congress
                            by Representative
                            Ronald V. Dellums

                        ;
WHAT'S KNOWN,
WHAT'S NOT

Cause for Immediate
Concern
by Ken Sexton

Research Directions
by Cynthia H. Harris and
Robert C. Williams
                                                   fl/ Lead: Example of the
                                                      Job Ahead
                                                      by Joel Schwartz und
                                                      Ronnie Levin

                            Have Minorities
                            Benefited...? A Forum
                          DEPARTMENTS

                          Newsline—
                          News and Comment on
                          EPA

GRASS-ROOTS
GROUNDSWELL

An Introduction
by Norris McDonald

The Kettleman City
Story
by Jane Kay

The Toxic Avengers
by Linda R. Prout

The Pele Defense
Fund
by Rick Carrolf

The Watchdog
by Michael Novick

Detroit Summer
by Grace Lee Boggs
STEPS AT EPA


CJ In the Regions
   by Deb Martin

     Innovative Housing
      in Atlanta

EC   Lead Cleanup in the
      Midwest

Cl   Enforcing the Law
      in California

 0 Helping Minorities
   Help the Environment
   by Clarice E. Gaylord
   and Robert Knox


M The U.S. Colonias:
 " A Target for Aid
   by Jack Lewis
                                                    :
                                                   On The Move
                                                   New Names in Key
                                                   Agency Posts
 EPA is charged by Congress to protect the nation's land, air, and water systems. Under a mandate of national environmental laws, the Agency strives to
 formulate and implement actions which lead to a compatible balance between human activities and the ability of natural systems to support and nurture life.
   EPA JOURNAL is published by the U.S. Environmental Protection Agency. The Administrator of EPA has determined that the publication of this periodical
 is necessary in the transaction of the public business required by law of this agency. Use of funds for printing this periodical has been approved by the
 Director of the Office of Management and Budget. Views expressed by authors do not necessarily reflect EPA policy. No permission necessary to reproduce
 contents  except copyrighted photos and other materials.
   Contributions and inquiries should he addressed to (he Editor, EPA JOURNAL (A-107), Waterside Mall, 401 M Street, SW., Washington, D.C. 20460

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NEWSLINE
  Phaseout
  of  Ozone
  Depleters
  Accelerated
  President Bush has
  announced (hat the United
  States will phase out most
  ozone depleting substances
  five years ahead of
  international deadlines and
  called on other nations to
  agree to an accelerated
  schedule. Current  U.S.
  production is already more
  than 40 percent below
  levels allowed by the
  Montreal Protocol and more
  than 20 percent ahead of
  Europe's non-aerosol
  production phasedoivn. The
  announcement came as
  recent scientific findings
  indicated faster, more
  widespread ozone depletion
  than was previously known.
  The Washington Post
  reported: "... The
  president's pledge to halt
  production of
  chlorofluorocarbons (CFCs)
  by Dec. 31, 1995, commits
  the United States to a faster
  phaseout schedule than
  most  of the industrialized
  nations that signed the
  Montreal Protocol—an
  international treaty that sets
  a deadline of 2000 for
  elimination of the
  chemicals, which are
  widely used in consumer
  products .... The CFC
  explosion of the past 20
  years has put so much of
  the chemicals into the
  atmosphere that there is  no
  way of stopping continued
  depletion of the ozone
  shield. Even with the faster
  phaseout, the protective
  layer is not expected by
  scientists to be restored to
  its 1970s condition until the
  middle  of the next century.
Last week, NASA scientists
reported that a converted
spy plane flying over New
England and eastern Canada
recorded the highest level of
ozone-threatening chlorine
compounds ever measured
anywhere in the world. The
level was 50 percent higher
than  previously seen over
Antarctica, where an ozone
hole  was first discovered in
1985 .... The Montreal
Protocol of 1987, signed by
71 nations, provides for
regular reevaluations of
whether a faster phaseout is
warranted. A working group
is scheduled in April to set
an agenda for a full meeting
of signatories in November.
Germany has pledged to
eliminate CFCs by Jan. 1,
1995, and one of the most
popular substitutes by 2000.
The European Community
is committed to a deadline
of July  1997

The Wall Street Journal
commented: ". . .  The
action,  which comes in the
wake of data showing that
the problem is worse than
Was believed, reflects a
timetable that producers
and users of the substances
generally accept. 'We think
we can live with it,' said
Joseph McGuire, senior vice
president of the Air
Conditioning and
Refrigeration Institute. 'We
think it's doable.' U.S.
production of
chlorofluorocarbons, CFCs,
which are widely used in
refrigerants and solvents,
and other chemicals that
destroy the stratospheric
ozone layer, will have to be
eliminated  by Dec. 31, 1995,
four years sooner than
required under an
international treaty. Limited
exceptions  will be allowed
for certain medical
equipment  such as dose
inhalers for asthmatics and
other essential uses and for
the servicing of existing
equipment. The president
also is urging producers to
cut output to 50 percent of
1986 levels by year end.
Partly because of a U.S. tax
on CFC production, output
is 42 percent below 1986
levels, as industry has
found it easier than
expected to come up with
safer substitutes ....
Environmental groups
supported the president's
action, but said it falls short
of what is needed.  Liz Cook,
ozone campaign director at
Friends of the Earth, said,
'We're glad the  president
recognized the ozone
problem is a global
emergency. But we think
the crisis is so dire that we
will continue to press for
the U.S. to eliminate all
ozone-depleting chemicals
sooner than the deadline.'
The accelerated phaseout
applies to major CFCs,
halons, methyl chloroform,
and carbon tetrachloride.
Under the 1990 revisions to
the Clean Air Act, the
administration has  authority
to accelerate the phaseout of
these chemicals when data
indicate a need  to do so. . . ."
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                             ANV  ttouE£ IN tire crz£>ne
                                                                               HorJey Schivadron. Reprinted with permission.
                                                                                                  EPA JOURNAL

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Ongoing
Enforcement
Actions

Record $15.7
Million Sought in
Complaint Against
Tennessee Gas
Pipeline
 In the largest administrative
 penalty ever sought by the
 Agency, EPA has filed a
 $15.7 million complaint
 against  Tennessee Gas
 Pipeline Company of
 Houston, Texas, for
 violations of the Toxic
 Substances Control Act. The
 company operates an
 interstate natural
 gas-transmission system that
 extends approximately
 10,000 miles; the complaint
 alleges that it improperly
 used  and disposed of PCBs
 at 26  gas compressor
 stations along the pipeline
 from  1980 to 1990. The
 stations are located in
 Alabama, Kentucky,
 Mississippi, Ohio, and
 Tennessee.
  The company is working
 with EPA and the states to
 clean up its equipment and
 any soil or water
 contaminated by the
 chemical. Last year,  Texas
 Eastern paid a $15 million
 penalty for similar
 violations, and is now in
 the middle of a 10-year
 program to clean up PCBs at
 a cost of $750 million.
U.S. Sugar Guilty
of Felonies; Will
Pay Highest  Fine
Ever Under RCRA


United States Sugar
Corporation has agreed to
plead guilty to eight felony
charges filed by the
Department of Justice and to
pay a criminal fine of
$3,750,000. The crimes,
which occurred at the
company's Bryant plant in
Palm Beach County,
Florida, involve the illegal
disposal and transportation
of hazardous wastes. The
fine is the largest  penalty
ever assessed under the
Resource Conservation and
Recovery Act.
  Three of the eight counts
charge the  company with
illegal disposal of lead
subacetate  during harvests
in the period 1986 through
1989. The chemical was
used in the sugar  mill
laboratory; the used
chemical, which is a
hazardous waste,  was then
disposed of in two forms:
Mixed with sugar cane
juice, it was dumped on the
company's property; as a
contaminant in laboratory
filter papers, it was dumped
in a local landfill.
  The next three counts
charge the company with
illegal disposal of two
solvents,
tetrachloroethylene and
methylene  chloride, which
it used to degrease
mechanical parts. The  used
solvents, mixed with oil
and grease, were dumped in
earthen surface
impoundments at the
Bryant plant.
  The last two counts
charge the company with
illegal transportation of a
solvent that was an
ignitable hazardous waste.
Used to degrease
mechanical parts, and
mixed with waste oil, the
solvent was transported to a
waste-oil recycler without a
manifest. U.S. Sugar did not
inform the recycler that an
ignitable hazardous waste
was mixed with the oil; the
recycler did not have a
permit to treat or to dispose
of hazardous waste.
  The charges derive from
soil, water, and chemical
samples taken by EPA
personnel and FBI agents
during a search of  the
Bryant plant.


Kennecott Utah
Copper Faces
Fines of  More
Than $1.4 Million

EPA has asked for fines
against Kennecott Utah
Copper Corporation totaling
more than $1.4 million:
$1,129,000 for
mismanagement of PCBs,
and $291,850 for failure to
report the release of
hazardous materials to the
environment. The charges
stem from inspections of the
company's smelter, refinery,
Magna concentrator,
Bonneville Plant, and
Bingham Canyon mine.
They allege: 180 counts of
improper use of
transformers containing
PCBs, 16 counts of
improper disposal  of PCBs,
20 counts of failure to
maintain records of PCB
equipment,  and one count
of failure to mark an area
containing a PCB
transformer. They further
allege that Kennecott was
aware of the following
releases of hazardous
materials but failed to
report them to authorities:
approximately 21,000
pounds of corrosive wastes
spilled on the ground;
17,000 pounds of sulfur
dioxide discharged to the
air from smelter wastewater
in an open canal; and sulfur
dioxide and sulfur trioxide
discharged to the air
because of equipment
failures at a substation  and
stack.
  The PCB mismanagement
charges were brought under
the Toxic Substances
Control Act, the
hazardous-material release
charges under the
Superfund law and the
Emergency Planning and
Community Right-to-Know
Act—the former requires
that hazardous material
spills be reported to the
National  Response Center in
Washington, the latter that
local and state emergency
response groups be notified
as well.
 MARCH/APRIL 1992

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NEWSLINE
   Sale  of

   Sterilizing

   Solution

   Stopped

   EPA has ordered that the
   sale of Sporicidin Cold
   Sterilizing solution  be
   stopped, and has requested
   that all stocks of the
   product be recalled. The
   sterilant is used primarily
   in hospitals and in  dental
   and veterinary facilities to
   destroy spores, bacteria,
   fungi,  and viruses on
   delicate instruments and
   equipment. EPA's order was
   based  on test data which
   showed thai the sterilant
   was not fully effective in
   destroying spores, and
   possibly other microbinl
   life, as claimed on the
   product label. The Agency
   has filed a $430,000 civil'
   complaint against
   Sporicidin international for
   making false claims about
   the product's effectiveness.
   Other federal agencies
   joined EPA in its action.
   Administrator Reilly said:
   "Because of the federal
   government's findings, /
   urge health-care providers
   to use  alternative products
   for high-level disinfection
   and sterilizing  needs.
   Products formulated for the
   control of infections are a
   serious concern.
   Consequently, 1 am
   renewing our efforts to
   ensure the products this
   Agency licenses for use in
   sterilizing and  disinfecting
   are effective."
The Washington Post
reported: "• • •  Federal
regulatory officials
yesterday forced a national
recall of one of the most
widely used hospital and
dental sterilizing solutions,
after government laboratory
tests revealed that the
product destroys only a
fraction of the  potentially
dangerous microorganisms
it is supposed  to kill. In a
rare collective  show of
force, the Food and Drug
Administration, the
Environmental Protection
Agency, and the Federal
Trade Commission took
legal and administrative
actions against Sporicidin
Co. yesterday,  requesting
that the Rockville company
order an immediate product
recall, seizing $1 million of
its existing inventory and
enjoining the company  from
promoting its cold sterilant
solution  .... Sporicidin's
main product—Sporocidin
Cold Sterilizing
Solution—is used
principally to sterilize
medical and dental
instruments that cannot be
cleaned using normal
sterilization processes. For
example, a wide range of
fiber optic scopes—like
those used to probe the
gastrointestinal tract and the
bladder—as well as
equipment used in
anesthesia and dental
surgery would be  damaged
if cleaned in standard high
temperature sterilizers.
Instead, to kill the
thousands of potentially
harmful fungi, viruses,
bacteria, and other
microorganisms that
populate hospitals and can
be picked up during
medical procedures,
physicians customarily
bathe their instruments for
several hours in cold
disinfectant solutions .
Sporicidin, which has been
on the market for 14 years,
is one of the most popular
of these products.
According to the company,
it is the principal cold
sterilant used in dental
schools; and federal officials
said that it is widely used
in Veterans Administration
hospitals and has
approximately a 25 percent
share  of the overall cold
sterilant market

The New York Times said:
". . .  Dr. Robert Schattner, a
dentist who is president of
Sporicidin, questioned the
actions against his
company.  There is no
question these products are
safe,'  he said in a telephone
interview. 'I don't
understand what's going on.
For 14 years these products
have been used in hospitals,
and there has not been one
case of infection associated
with them.' Dr. Schattner
said the company would
temporarily suspend
operations to comply with
demands of the regulatory
agencies and 'to vigorously
contest these actions.'
Although no reports of
illness have been associated
with instruments and
devices cleaned with
Sporicidin products, health
officials said they were
concerned about the
potential hazard. 'Sterilizing
and disinfecting agents are
supposed to protect patients
from contact with harmful
microorganisms,' said Dr.
David A. Kessler, the
Commissioner of Food and
Drugs. These products do
not work. Doctors, dentists,
and other health
professionals should stop
using them.' .... The
[Food and Drug
Administration  (FDA)] and
the environmental agency
acted because the sterilizing
solution is regulated by
both agencies. The [Federal
Trade Commission], which
regulates advertising, was
involved because claims of
the products' potency were
inconsistent with
government test results, said
Sharon Snider, an FDA
spokeswoman  .... Seizure
actions were initiated for
inventory at Sporicidin's
headquarters in Rockville,
Maryland; a distribution
warehouse, Multi-Modal
Freight Systems, in
Baltimore, and a contract
manufacturing company,
Chem-Mix Inc., in
Jonesborough, Tennessee.
Other products involved in
the seizure are Sporicidin
Brand Disinfectant Spray
solution, Sporicidin  Brand
Disinfectant, and Sporicidin
Disinfectant Tov/elettes.
                                                                                                       EPA JOURNAL

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Toxic Emissions

from Dry  Cleaners
To Be  Reduced

A regulation proposed by
EPA would reduce
emissions of
perchloroethyline from large
dry cleaning plants. The
solvent, also known as PCE
or PERC, is the most widely
used cleaning agent in the
industry and  is one of 190
toxic air pollutants EPA
must regulate  within the
next 10 years under the
1990 Clean Air Act.
   The proposal is the  first
air toxics rule to be written
under  the Act. It was
prepared with the help of
the International Fabricare
Institute, and reflects an
effort by EPA  to minimize
costs to small businesses.
   Under the rule, operators
would have to install a
carbon adsorber, refrigerated
condenser, or equivalent
device to control vented
PCE emissions. They would
have to practice pollution
prevention procedures,
including good operation
and maintenance, for both
dry cleaning machines and
auxiliary equipment, such
as solvent tanks. And  they
would have to conduct a
weekly inspection to
prevent emissions from
broken or improperly
operating equipment and
keep a record of such  things
as the  amount of PCE  used.
   The rule would apply to
both "industrial" and
"commercial" dry cleaners.
Industrial cleaners,  the
largest, typically supply
rental  uniforms and other
such items to business and
institutional customers.
Commercial cleaners,  the
most common, include the
small, independently
operated neighborhood
shops.
  Of the approximately
25,200 cleaning plants in
the United States, 9,700
currently have no controls
and could be affected by the
rule. However, the Clean
Air Act allows EPA to be
sensitive to economic
impacts on small business,
and the Agency has set a
"consumption cutoff" that
will exempt all but 3,700
plants from having to install
controls. The cutoff is  220
gallons of PCE a year for
cleaners with  dry-to-dry
machines—those that wash
and dry in the same unit; it
is  300 gallons a year for
cleaners with  transfer
machines—washing  is done
in one unit, drying in
another. The cleaners that
would be exempted under
the rule account for only 1.4
percent of total PCE
emissions, so  the effect of
the exemption on public
health would  be negligible.
  The proposed rule would
reduce the total emissions
of PCE by 13 to 26 percent.
The estimated capital cost
for the cleaners that  are
now uncontrolled would be
$63 million by 1996; the
annualized cost in 1996
would be $9 million. The
increased cost of dry
cleaning for customers
would be less than one
percent.
                     PLAZA
                 CLEANERS
All Four New Jersey
Utilities Join
Green  Lights

New Jersey's four electric
utility companies have
joined EPA's Green Lights
program; the state is the
first to have all its electric
utilities join.
  Public Service Electric
and Gas, Rockland Electric,
Jersey Control  Power and
Light, and Atlantic Electric
have  all agreed to survey
their  facilities  and to install
new lighting systems where
energy and cost savings can
be achieved. What's more,
they will aid customers to
do the same. All Green
Lights members can access
an EPA computer-based
support system.
  Twenty to 25 percent of
electricity used in the
United States each year goes
to lighting. Half of that, 250
billion kilowatt hours, at a
cost of $20 billion, could be
saved if energy-efficient
lighting were substituted,
where feasible, for older
systems. Efficient systems
                                           Sieve Deliniry plmto
produce brighter lighting
with less energy, contribute
to a more productive
workplace, and create less
heat, thereby reducing the
demand for air
conditioning.
  EPA launched the Green
Lights Program in 1991 as a
voluntary, non-regulatory
program to encourage U.S.
corporations, utilities,
states, and local
governments to adopt
energy-efficient lighting as  a
profitable means of
pollution prevention.
Several hundred Green
Lights partners have joined
in the program across the
country.
                                                                 ,e«  Li,
                                                             \
                                                                                               '8"tal Prof0
MARCH/APRIL 1992

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                                     he     ssue
The  Disadvantaged  Face Greater Risks
 by Paul Mohai and Bunyan Bryant
    Americans have tended to assume
    that pollution is a problem faced
equally by everyone  in our society. But
awareness and concern about
inequities in the distribution of
environmental hazards have been
steadily increasing. The first event to
focus national attention on
environmental injustice occurred in
1982 when officials decided to locate a
PCB landfill in predominantly black
Warren County, North Carolina.
Protests very similar to those of the
civil rights movement of the 1960s
erupted. They led to an investigation
the following year by the General
Accounting Office (GAO) of the
socioeconomic and racial composition
of communities surrounding the four
major hazardous waste landfills in the
South. The GAO report found that
three of the four were located  in
communities that were predominantly
black.
  The Warren County incident and the
GAO report led the United Church of
Christ's Commission for Racial Justice,
                                                                                            EPA JOURNAL

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                      Housing
                      project is
                      cheek by jowl
                      with oil
                      refinery.
       Copyi
a participant in the Warren County
protests, to sponsor a nationwide study
in 1987. The study used systematic
and statistically analyzable data to
determine whether the distribution of
commercial hazardous waste facilities
in minority communities fit the pattern
found in the South. It found that it
did. Specifically,  it found that the
proportion of minorities in
communities which have a commercial
hazardous waste facility is about
double that in communities  without
such facilities. Where two or more
such facilities are located, the
proportion of minorities is more than
triple.
  In addition, using sophisticated
statistical techniques, this study found
that race is the single best predictor of
where commercial hazardous waste
facilities are located—even when other
socioeconomic characteristics, such as
average household income and average
value of homes, are taken into account.
The report  concluded that it is
"virtually impossible" for this
disproportionate distribution to occur
by chance, and that underlying factors
related to race, therefore, in all
likelihood play a role in the location of
commercial hazardous waste facilities.
At the time the report was  released,
Dr. Benjamin F. Chavis, Jr., Executive
Director of the United Church of
Christ's Commission for Racial Justice,
termed the racial biases in  the location
of these facilities "environmental
racism."  Because of its national scope
and its strong findings,  the
Commission's report became a major
turning point in raising public
awareness about the disproportionate
burden of environmental hazards on
minorities.
  The striking findings  of the United
Church of Christ study led  us to
investigate whether other studies
existed and to determine whether the
evidence from these  studies, taken
together, demonstrated a consistent
pattern of environmental inequity
based on socioeconomic and racial
factors. We also conducted a study of
our own  to examine  the distribution of
commercial hazardous waste facilities
in the Detroit metropolitan area.
Further, to uncover more information
and focus greater attention  on this
issue, in  January 1990 we convened
the Michigan Conference on Race and
the Incidence of Environmental
Hazards at the University of
Michigan's School of Natural
Resources. (See accompanying article.)
  A question often raised is whether
the bias in the distribution  of
environmental hazards is simply a
function  of poverty. That is, rather
than race per se, is it not poverty that
(Dr. Mohai is Assistant Professor and Dr.
Bryant is Associate Professor in (ho
School of Natural Resources at (he
University of Michigan in Ann Arbor.
Drs. Mohai and Bryant u-ere Co-Principal
Investigators of the University of
Michigan's 1990 Detroit Area .Study.
They were also co-organizers of the
University of Michigan Conference on
Race and (he Incidence of
Environmental Hazards held January
1990 in Ann Arbor, Michigan. Both
served  on the National Advisory
Committee of the First  National People
of Color Environmental Leadership
Summit held October 1991  in
Washington, DC.)
 affects the distribution of
 environmental hazards? And are not
 minorities disproportionately impacted
 simply because they are
 disproportionately poor (although orie
 has to ask why minorities are
 disproportionately poor in the first
 place)?
  Classic  economic theory would
 predict that poverty plays a role.
 Because of limited income and wealth,
 poor people do not have the means to
 buy their  way out of polluted
 neighborhoods. Also, land values tend
 to be  lower in poor neighborhoods,
 and the neighborhoods attract
 polluting  industries seeking to reduce
 the costs of doing business. However,
 the mobility of minorities is
 additionally restricted by housing
 discrimination, amply demonstrated by
 researchers to be  no insignificant
 factor. Then, because noxious sites are
 unwanted (the "NIMBY," or
 not-in-my-backyard syndrome) and
 because industries tend to take the
 path of least resistance, communities
 with little political clout are often
 targeted for such  facilities: The
 residents  tend to  be unaware of policy
 decisions  affecting them; they are not
 organized; and they lack the resources
 (time, money, contacts, knowledge of
 the political system)  for taking
 political action. Minority communities
are at a disadvantage not only in terms
of resources,  but also because of
underrepresentation on governing
bodies. When location decisions are
made, this underrepresentation
translates  into limited access to policy
 makers and lack of advocates for
minority interests.
  Taken together, these factors suggest
that race has  an impact on the
distribution of environmental hazards
that is independent of income. Thus,
as part of  our investigation, we
attempted to assess the relative
influence  of income and  race on the
distribution of pollution. We did so by
examining the results of those
empirical  studies which analyzed the
distribution of environmental hazards
by both income and race. We also
assessed the relative  importance of the
relationship of income and race in the
distribution of commercial hazardous
waste facilities in our Detroit area
study.
  From our investigation, we found 15
 studies that, like the  United Church of
 MARCH/APRIL 1992
                                                                                                                   7

-------
 Christ study, provide objective and
 systematic information about the social
 distribution of environmental hazards.
 A number of interesting and important
 facts emerged.
   First,  an inspection of the
 publication dates revealed that
 information about environmental
 inequities has been available for some
 time.  Rather than being a recent
 discovery, documentation of
 environmental injustices  stretched
 back two decades. In fact, information
 about inequities  in the  distribution of
 environmental hazards was first
 published in 1971 in the  annual report
 of the Council on Environmental
 Quality. This was only one  year after
 EPA was created, one year after the
 National Environmental Policy Act
 was passed,  and  only one year after
 the first Earth Day—an event viewed
 by many as a major turning point in
 public awareness about environmental
 issues. There were nine other such
 studies published in  the 1970s.
 Clearly,  it  has taken some time for
 public awareness to catch up to the
 issues of environmental injustice.
   It  is worth noting that most of the
 studies conducted in  the past two
 decades  focused  on the distribution of
 air pollution and hazardous waste.
 Clearly,  systematic studies of the social
 distribution of other types of
 environmental hazards, such as water
 pollution,  pesticide exposure, asbestos
 exposure, and other hazards are
 needed.  Also worth noting is that these
 studies vary considerably  in terms of
 scope. Some focused  on single urban
 areas, such as Washington, DC, New
 York City,  or Houston; others focused
 on a collection of urban areas; while
 still  others were national in  scope.
 This is important in that it reveals that
 the pattern of findings is not an artifact
 of the samples selected: Regardless of
 the scope or of the methodologies
 employed,  the findings point to a
 consistent  pattern.
   In nearly every case, the distribution
 of pollution has been  found  to be
 inequitable by income. And, with only
 one exception, it  has been found to be
 inequitable by race. Where the
 distribution of pollution has been
 analyzed by both  income and race, and
 where  it  is possible to weigh the
 relative importance of each,  in five out
of eight cases race has been found to
be more strongly related than has
 Abandoned industry site abuts on
 residential neighborhood in southeast
 Chicago.
 income. Also noteworthy is the fact
 that all three national studies which
 looked at both income and race found
 race to be more importantly related to
 the distribution of environmental
 hazards than income.
  In our own Detroit area study, we
 found that  minority residents in the
 metropolitan area are four times more
 likely than white residents to live
 within one mile of a commercial
 hazardous waste facility. We also
 found that  race was a better predictor
 of residents' proximity to such
 facilities than income.
  Taken together, the findings from
 these studies indicate clear and
 unequivocal class and racial biases in
 the  distribution of environmental
 hazards. Further, they appear to
 support the argument that  race has an
 additional effect on the distribution of
 environmental hazards that is
 independent of class.  Indeed, the racial
biases found in these studies have
 tended to be greater than class biases.
  Ultimately, knowing whether race or
class has a  more important  effect on
the  distribution of environmental
hazards may be less relevant than
understanding how the conditions that
 lead to it can be addressed  and
 remedied. Currently, there are no
 public policies in place which require
 monitoring equity in the distribution
 of environmental quality. Hence,
 policy makers have  little knowledge
 about the equity consequences of
 programs designed to control pollution
 in this country.
   Are some groups receiving tewer
 environmental and health benefits than
 others from existing programs? Have
 the risks to some actually increased? If
 the social, economic, and political
 disadvantages faced by the poor and
 minorities are unlikely to be
 compensated  any time soon, then
 proactive government policies will be
 needed to address the issue of
 environmental inequity. The
 distribution of environmental hazards
 will need to be monitored, existing
 policies and programs adjusted,  and
 new programs designed to ensure that
 all groups share equitably in the efforts
 to control pollution.
  A quarter of a century ago, the
 Kerner Commission  warned, "To
 continue present policies is to make
 permanent the division of our country
 into two societies: one largely Negro
 and  poor, located in the central cities,
 the other predominantly white and
 affluent,  located in the suburbs and in
 outlying areas." When that warning
 was  made, EPA had  not yet been
 created and the nation's major
 environmental laws had not yet been
 passed. The terms "environmental
 racism" and "environmental justice"
 were unheard  of. Our study and  those
 of others indicate that current
 environmental policies have
 contributed to the division. To know
 that environmental inequities exist and
 to continue to do nothing about them
 will  perpetuate separate societies and
 will  deprive the poor, blacks, and
 other minorities of equitable
 environmental protection,  n
Note: This article is adapted from a
longer paper entitled "Environmental
Racism: Reviewing the Evidence,"
forthcoming in B. Bryant and P.
Mohai. eds., Race and the Incidence of
Environmental Hazards: A Time for
Discourse (Boulder, Colorado:
Westview Press,  1992).
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                                           by Bunyan Bryant
                                           and Paul Mohai
   The Majority of Presenters Were People of Color
    For the last 15 years or so, the civil
    rights movement has faltered as
government and corporate America
have reordered their priorities and as
civil rights leaders have struggled in
vain to bring currency to a movement
that has  lost momentum. Both the
death of prominent civil rights leaders
and the benign neglect of policy
makers have blunted the edge of the
movement, even though the conditions
that spawned it are, in many instances,
worse now than they were three
decades ago. Today, we  have more
segregated schools, segregated housing
patterns, and homeless people, and the
economic gap between people of color
and whites has increased significantly.
  However, a resurgence of that
movement may be taking place as
people of color  and oppressed
communities across the nation begin to
redefine their struggle  in terms of a
safe and clean environment as a basic
right for all, regardless of race or color.
Each day, people of color are becoming
more aware of the millions of inner
city children who are being exposed to
lead poisoning,  causing irreversible
mental retardation and impaired
growth. As they eke out a living from
the land, pregnant farm workers
exposed to pesticide sprays are prone
to have offspring deformed at birth.
Prenatal exposure to dangerous
chemicals in the high-tech industries
contributes to numerous  birth defects
and premature births.
Uranium-contaminated Navajo land
and water are believed to contribute to
the high incidence of organ cancer in
Navajo teenagers—17 times the
national average.
  As indicated in the preceding article,
we became involved with issues of
environmental equity after becoming
acutely aware that communities of
color were disproportionately exposed
to environmental hazards, more so
than affluent white communities, and
that a struggle was being waged in
minority  and low-income communities
across the country. Based upon the
evidence, we decided to  organize a
working conference, national in scope,
at the University of Michigan School
of Natural Resources to bring further
attention to this most pressing issue.
  Nine of 12 scholar-activists who
MARCH/APRIL 1992

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                                          The
   presented papers at the Conference on
   Race and the Incidence of
   Environmental Hazards were people of
   color. Robert Bullard, Professor of
   Sociology at the University of
   California at Riverside,  Beverly Wright,
   Associate Professor of Sociology at
   Wake Forest University, and Charles
   Lee, Director of Special Projects on
   Toxic Justice of the Commission of
   Racial Justice of the United Church of
   Christ, were key in helping us identify
   other scholars and activists. We also
   invited a number of participant
   observers from federal and state
   agencies, such as EPA, the Agency for
   Toxic Substances and Disease Registry,
   the Governor's Office of the State of
   Michigan, the Michigan State
   Department of Minority Health, the
   Michigan Department of Natural
   Resources, and others.
     This was the first time that a
   retrieval/dissemination conference on
   race and the incidence of
   environmental hazards was held where
   the majority of presenters of scholarly
   papers were people of color. Although
   scholars had worked on various
   aspects of this issue, the conference
   enabled scholar-activists to come
   together to share their research
   findings and to take steps to
   disseminate information about this
   most important issue. The conference
   was not only a major step forward in
   getting scholar-activists  to focus their
   attention  on this issue as a group, but
   it gave national visibility to the debate
   on environmental equity, thus
   increasing the awareness of
   government policy makers and lay
   people alike. As a result, we expect
   other scholars of color to take this
   issue on as a legitimate  area of inquiry.
   (For more information about the
   outcomes of this conference and the
   environmental equity movement, see
   our forthcoming book, Race and the
   Incidence of Environmental Hazards:
   A Time for Discourse.)
     Although race and the incidence of
   environmental hazards was seldom an
   issue for policy makers  before the
   conference, this is no longer the case;
   policy makers at multiple  levels of
   government are involved in
   environmental equity discussions. And
   while these discussions may be
   provocative, they still will have to
 work their way into policies that
 ensure that all Americans can live in
 safe, clean, and decent environments.
 Environmental equity should be the
 highest priority for policy makers if
 they are indeed interested in
 alleviating much  of the
 disproportionate  amount of pain and
 suffering experienced by people in
 minority and low-income
 communities.
  A follow-up strategy of the Michigan
 conference was a meeting with key
 government officials in Washington,
 DC. A subgroup of conferees sent  a
 memo requesting a meeting with Louis
 W. Sullivan,  Secretary, Department of
 Health and Human Services; William
 K. Reilly, Administrator, EPA; and
 Michael R. Deland,  Chairman, Council
 on  Environmental Quality. Copies
 went  to all governors, various state
 legislators, and the Congressional
 Black Caucus. In  this memo, we
 proposed to discuss the  agencies'
 involvement  in:

 *   Undertaking research towards
 understanding the environmental risks
 faced by minority and low income
 communities
 •   Initiating projects to enhance risk
 communication targeted to minority
 and low-income population groups
 •   Requiring, on a demonstration
 basis, that racial and socioeconomic
 equity consideration be included in
 Regulatory Impact Assessments
 •   Ensuring that a racial and
 socioeconomic dimension is  overlaid
 on present and future geographic
 studies of environmental risk
 •   Enhancing the ability of
 "historically black colleges and
 universities"  (HBCUs) and other
 minority institutions to participate  in
and contribute to  the development  of
 environmental equity
*   Appointing special assistants for
 environmental equity at
 decision-making levels within agencies
•   Developing a  policy  statement on
 environmental equity.

  We met with William  Reilly and an
 assistant to Michael Deland on
 September 13, 1990. Because of
 scheduling problems, we were unable
 to meet with  Louis Sullivan. Of all the
people we met with in Washington,
including Congressman John Lewis
(D-Georgia), and staff members of
Congressmen John Conyers
(D-Michigan) and Ron Dellums
(D-California), the representative for
the Council  on Environmental Quality
was least familiar with this issue. By
the time we arrived in  Washington,
William Reilly had already sent a
memo to his 12,000 EPA employees
recognizing  Black History Month and
stating more specifically the inherent
value of having a multi-cultural
workforce reflective of  American
society to help ensure an equitable
environmental policy. He also put
together an internal workgroup to
study and report to him on the issues
raised at the Michigan  conference.
And,  on April 9, 1990,  at the National
Minority Environmental Career
Conference at  Howard University, he
stated:
   Participants in the January 1990
   University of Michigan
   Conference on Race  and  the
   Incidence of Environmental
   Hazards conducted an intensive
   review of environmental risk
   from  a socioeconomic
   perspective. This review pointed
   out significantly disproportionate
   health impacts on minorities due
   to higher  rates of exposure to
   pollution.

  To our knowledge, this was the first
public recognition by EPA that
environmental hazards
disproportionately impact people of
color  and the first time the
Administrator had agreed to meet with
any group made up primarily of
people of color to discuss
environmental equity issues. It was
also the first time that an EPA
Administrator put together an internal
workgroup to focus directly on these
issues.
  While William Reilly has recognized
the disproportionate impact of
environmental hazards  on people of
color, and has directed  the Agency to
address  this issue, the proof of the
pudding will be not in  the discourse or
in the report itself, but  in tangible and
productive outcomes, n
10
                                                                                                         EPA JOURNAL

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                                                       by
                                                       Robert D.
                                                       Bullard
Minority Communities Get Most of the Dumps
Superfund .s/le in rural Louisiana.
(Dr. BuJlard is a professor of sociology
at the University of California,
Riverside, and author of Dumping in
Dixie: Race, Class, and Environmental
Quality (Westvievv Press, 1990).
Research for this article was supported
in part by a grant from the Fund for
Research on Dispute Resolution.)
    Despite the numerous laws,
    mandates, and directives by the
federal government to eliminate
discrimination in housing, education,
and employment, government has
made few attempts to address
discriminatory environmental
practices. People of color (African
Americans, Latinos, Asians, and Native
Americans) have borne a
disproportionate burden in the siting
of municipal  landfills, incinerators,
and hazardous waste treatment,
storage, and disposal facilities.
  Environmental inequities do not
result solely from social class factors.
The ability to escape a
health-threatening physical
environment  is usually correlated with
income; however, racial barriers
complicate this process for millions of
Americans. African Americans, no
matter what their educational or
occupational  achievement or income
level, are exposed to  greater
environmental threats in their
neighborhoods because of their race.
  An African American  family with an
income of $50,000 is as segregated as
an African American family on
welfare. Institutional racism influences
local land-use policies, industrial
facility siting, and where people of
color live, work, and play.
  Waste sites and other noxious
facilities are not randomly scattered
across the landscape. Waste generation
is directly correlated  with per capita
income, but few garbage dumps and
toxic waste sites are located in affluent
suburbs. Waste facilities are often
located  in communities that have high
percentages of poor, elderly, young,
and minority  residents.
  The first major empirical study that
linked municipal solid waste siting
with the race of surrounding residents
was conducted in 1979 and chronicled
in Invisible Houston: The Black
Experience  in Boom and Bust.  From
the early 1920s to the late 1970s, all of
the city-owned municipal landfills and
six of the eight garbage incinerators
were located in African American
neighborhoods.
  From 1970  to 1978, three of the four
privately owned landfills that were
used to dispose of Houston's garbage
were located in African American
neighborhoods. Although African
Americans made up only 28 percent of
  MARCH'APRIL 1992
                                                                                                               1 1

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Houston's population, 82 percent of
the solid waste sites (public and
private) were located in African
American neighborhoods.
  African American neighborhoods
from South Central Los Angeles to
Southeast-side Chicago to Railway,
New Jersey, are vulnerable  to waste
facility siting. As recently as 1991,
Residents Involved in Saving the
Environment, or RISE (a biracial
community group), challenged the
King and Queen County (Virginia)
board of supervisors for selecting a
420-acre site in a mostly African
American community for a regional
landfill. From 19 to 1990. all three
of the county-run landfills  had been
located  in mostly African American
communities.
  Siting inequities are not unique to
facilities where household  garbage is
dumped. The findings I recently
published in (Jumping in Dixie
revealed that African Americans bear a
disparate burden in  the siting of
hazardous waste landfills and
incinerators in  South Louisiana's
"Cancer Alley" and Alabama's
"blackbeh." The nation's largest
commercial hazardous waste landfill.
the "Cadillac of dumps," is located in
Emelle, Alabama. African Americans
make up 90 percent of Emelle's
population and 75 percent  of the
residents in Sumter County. The
Kmelle  landfill receives wastes from
Superfund sites and from all 48
contiguous states.
   Few government studies  have
examined siting inequities. A notable
exception is a 1983 U.S. General
Accounting Office (GAG) study. GAO
found four off-site commercial
hazardous  waste landfills in EPA's
Region  4 (Alabama.  Florida, Georgia,
Kentucky. Mississippi, North Carolina.
South Carolina, and Tennessee). Three
of the four landfills were located  in
mostly African American communities,
although African Americans made up
only one-fifth of the population in the
region.
   Siting inequities in EPA's Region 4
have not disappeared. In 1992,  African
Americans still make up about
one-fifth of the population  in the
region.  However, the region's two
currently operating off-site commercial
hazardous waste landfills are located
in zip codes where African Americans
are a  majority of the population.  For
those who would dismiss this pattern
as a function of social class, it is
important to note that there has never
been a shortage of poor white
communities in Region 4 (not that
anyone is advocating siting waste
facilities in low-income white areas).
  Siting disparities are not unique to
African American communities. In
California, the mostly Latino East Los
Angeles and Kettleman City have come
under siege from companies trying to
site hazardous waste incinerators.
Kettleman City, a rural farmworker
community of perhaps 1,500 residents,
of which 95 percent are Latino, already
has a hazardous waste landfill. With
the aid  of the California Rural Legal
Assistance Foundation, local residents
have contested  the construction of the
hazardous waste incinerator. (See
article on page  47).
  Siting inequities are national in
scope. The Commission for Racial
Justice's landmark Toxic  Wastes and
Race study found race to be the single
most important factor (i.e., more
important than  income, home
ownership rate, and property values)
in the location  of abandoned toxic
waste sites. The 1987 study also found
that:
•   Three out of five African
Americans live in communities with
abandoned toxic waste sites
•   Sixty  percent of African Americans
(15 million) live in communities with
one or more abandoned toxic waste
sites
•   Three of the five largest
commercial hazardous waste landfills
are located in predominately African
American or Latino communities and
account for 40 percent of the nation's
total estimated  landfill capacity in
1986
•   African Americans are heavily
overrepresented in the population of
cities with the largest number of
abandoned toxic waste sites, which
include Memphis,  St. Louis, Houston,
Cleveland, Chicago, and Atlanta.
  Communities with hazardous waste
incinerators generally have large
minority populations, low incomes,
and low property values.  A 1990
Greenpeace report, Ploying with Fire,
confirmed what many environmental
justice activists had suspected all
along:
 •  The minority portion of the
 population in communities with
 existing incinerators is 89 percent
 higher than the national  average
 •  Communities where  incinerators
 are proposed have minority
 populations 60 percent higher than the
 national average
 •  Average income in communities
 with existing incinerators is 15 percent
 less than the national average
 •  Property values in communities
 that host incinerators are 38 percent
 lower than the national average
 •  In  communities where incinerators
 are proposed, average property values
 are 35  percent lower than the national
 average.

  Native American lands have become
 prime targets for waste disposal
 proposals. More than three dozen
 reservations have been targeted for
 landfills and incinerators. Because of
 the special quasi-sovereign status of
 Indian nations, companies have
 attempted to skirt state regulations.
  In 1991, the Choctaws  in
 Philadelphia, Mississippi, defeated  a
 plan to locate a 466-acre  hazardous
 waste landfill in their midst.  In the
 same year, a Connecticut company
 proposed to build a 6,000-acre
 municipal landfill on the Rosebud
 reservation in South Dakota—a project
 dubbed "Dances with Garbage." The
 Good Road Coalition, an  alliance of
 grass-roots groups, blocked the
 proposal to build the giant municipal
 landfill on Sioux lands.
  A new form of environmental
 activism has emerged in communities
 of color. Activists have begun to
 challenge discriminatory  facility siting,
 biased  local land-use policies, illegal
 redlining practices, housing
 discrimination, and other problems
 that threaten public safety. People of
color have formed groups and begun to
build a national movement against
 what they defined as environmental
 injustice. A national policy is needed
to begin addressing environmental
 inequities, a
 12
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                                                                                 by Ivette  Perfecto
                                                                                 and  Baldemar Velasquez
                                                                                They Suffer the Most
                                                                                from  Pesticides
      While many people are aware of
      the dangers of pesticide residues
 in food and the detrimental effects of
 pesticides on the environment, few
 appreciate the serious health hazards
 that pesticides  pose to farm workers
 and their families. The fact is that farm
 workers are disproportionately affected
 by the pesticides that characterize
 agriculture in the United States.
   The United States is the largest
 single user of pesticides in the  world.

 (Dr. Perfecto is an Assistant Professor
 at the University of Michigan's School
 of Natural Resources. Velasquez is
 President of the Farm Labor
 Organizing Committee in Toledo,
 Ohio.J
World Resources Institute estimates that
3/3,000 (arm workers in the United States
suffer from pesticide-related illnesses each
year.
By EPA's own estimate, each year U.S.
farmers use about 1.2 billion pounds of
pesticides at an expenditure of $4.6
billion. More than 600 active
ingredients are combined with other
ingredients to form approximately
35,000 different commercial
formulations. Yet, full evaluation of
their hazards lags far behind the
development of new products. Less
than 10 percent of the products in
current use have been fully tested for
potential health effects; of the 600
active ingredients in these products,
                                                                                                             m
EPA was recently able to provide full
safety assurance for only six.
  Those who suffer most directly from
the chemical dependency of U.S.
agriculture are farm workers, who are
working in the fields while some of
the most toxic substances known to
humans are sprayed. The World
Resources Institute has estimated that
as many as 313,000 farm workers in
the United States may suffer from
pesticide-related illnesses each year.
Another source estimates that 800 to
1,000 farm workers  die each year as a
direct consequence of pesticide
exposure.
  Ninety percent of the approximately
two million hired farm workers in the
United States are people of color: The
MARCH/APRIL 1992
                                                                        13

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                                       The
 majority are Chicanos, followed by
 Puerto Ricans, Caribbean blacks, and
 African Americans. This primarily
 minority population has among the
 least protected jobs of all workers.
 Farm workers are intentionally
 excluded from the Occupational Safety
 and Health  Act (OSHA), which
 governs health and safety standards in
 the workplace; from the Fair Labor
 Standards Act, which governs
 minimum wages  and child labor; and
 most importantly, from  the National
 Labor Relations Act, which guarantees
 the right to  join a union and  bargain
 collectively.
  The exclusion of farm workers from
 OSHA regulations has particular
 relevance to the pesticide issue. Under
 OSHA's principles of environmental
 hygiene, when workers  are exposed to
 a toxic substance in the workplace the
 priority course of action is to eliminate
 the substance from  the workplace
 altogether or to replace  it with a
 non-toxic or less  toxic substitute. If
 this is impossible, the option next in
 priority is to separate the workers from
 the toxic substance. The last option
 usually involves provisioning workers
 with some protective measures  (e.g.,
 protective clothing, masks, glasses,
 etc.).
  Not being covered by  OSHA,  and
 therefore not able to legally petition
 the Occupational  Safety and Health
 Administration, farm workers are
 forced to petition EPA, which is the
 agency in charge  of regulating
 pesticides. But such petitioning offers
 few formal legal remedies, leaving
 farm workers virtually unprotected
 against pesticide hazards. Under the
 Federal  Insecticide, Rodenticide, and
 Fungicide Act, which is intended to
 regulate pesticide use, "re-entry" times
 (the interval that  must elapse between
 the application of a pesticide and
 workers' re-entry  into the fields) have
 been set for  just 12 pesticides,
 Moreover, there is no provision to
 assure that these regulations specifying
 re-entry times of either 24 or  48  hours
are  enforced.
  In fact, it is  not uncommon to see
farmers spraying while workers are in
the  field. A study conducted by the
Florida Rural Legal  Service in 1980
reported that 48 percent of more than
400 farm workers interviewed had
been sprayed at least once while
harvesting. Seventy-five percent of the
 workers surveyed said they had
 experienced one or more symptoms of
 pesticide poisoning while at work. In
 addition, many growers do not provide
 workers with protective masks or
 gloves and do not inform workers
 when and what chemicals are being
 used.
  Furthermore, evidence indicates that
 for some acutely toxic pesticides,
 extant protective measures are
 ineffective. A case in point is  the
 deadly  pesticide ethyl parathion, a
 leading cause of farm worker
 poisoning in the United States and
 worldwide. In 1986, EPA found that
 parathion caused poisoning among all
 categories of workers who came in
 contact with it. In addition, EPA
 admitted that parathion was associated
 with unacceptable risks to farm
 workers and that poisonings occurred
 even under the most stringent
 protective conditions. In other words,
 little or no margin of safety exists for
 parathion use. Nevertheless, it is still
 legally used on nine major crops in the
 United  States.
  Parathion is only one of many
 acutely toxic pesticides belonging to
 the organophosphate family, These
 pesticides came into wide use
 approximately 20 years ago, when
 environmental awareness called for
 limitations on persistent pesticides
 that were contaminating the
 environment and damaging wildlife.
 Many of the persistent pesticides
 belong to the organochloride family
 and have been associated with chronic
 health effects,  including cancer,
 reproductive malfunctions, birth
 defects, and a broad range of
 developmental and  behavioral growth
 problems. The organophosphates, on
 the other hand, degrade much faster
 and therefore reduced the risk for
 wildlife and for consumers.
  However, for farm workers the
 switch from organochlorines to
 organophosphates meant exposure to
 more acutely toxic pesticides,  since
 many of these  rapidly degradable
 pesticides (parathion is one of them)
are  characterized by acute toxicity,
which can cause dizziness; vomiting;
 irritation of the eye, upper respiratory
tract, and skin; and  death. There is an
 irony here that has not escaped the
attention of farm workers: The new
wave of environmental consciousness,
which forced welcome changes in
 production technologies, may have
 actually made things more precarious
 for farm workers, substituting acute
 symptoms for chronic ones.
   In the past, the EPA has operated
 under the assumption that these
 chemicals are essential for high
 productivity in U.S. agriculture. This
 notion was recently challenged by a
 1989 report of the National Research
 Council, which concluded that low
 input agriculture was not significantly
 less productive than chemically
 intensive agriculture. As noted in this
 report, pesticides are not the only
 option for pest control. Integrated Pest
 Management, for example, is a strategy
 that combines alternative methods of
 pest control (including biological and
 cultural controls) to achieve a
 significant reduction in chemical
 pesticide applications.
   Public awareness of these issues is
 burgeoning, and, consequentially,
 pressure on agencies like EPA is likely
 to intensify. Farm workers, the vast
 majority of whom are people of color,
 are building their consciousness and
 are taking their place alongside
 industrial workers in demanding a safe
 workplace. Environmentalists, heeding
 the call for environmental justice, are
 being challenged not to stand by and
 allow environmental policies that
 solve problems for some, yet leave
 others at risk—and they are
 responding. Consumers, while
 insisting on safe produce,  are
 increasingly unwilling to allow others
 to be poisoned in their stead.
   All this is occurring in the context of
 new revelations that chemical
 pesticides have not been all that
 successful in the first place and that
 alternatives are already available
 which could lead to  a new agriculture.
 Such an agriculture—call it sustainable
 or ecological or low input or simply
 rational—is  now on the horizon. The
 time seems ripe to reject the
 anachronistic notion that chemical
 poisons must be part and parcel of
 modern agriculture and redefine the
meaning of "modern" to include the
health and safety of farm workers,
farmers, consumers, and the
environment,  a
14
                                                                                                    EPA JOURNAL

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                                                           by
                                                           Patrick C.
                                                           West
Government Assumptions Are Much Too Low
                                                             Ottavva/C/i/ppewa
                                                             Indians, members
                                                             of the Grand
                                                             Traverse Band,
                                                             net fish in Lake
                                                             Michigan.
  There is concern that Native
  i Americans may consume much
 greater amounts of Great Lakes fish
 than the general population and  hence
 be at greater risk for dietary exposure
 to toxic chemicals.
   To date, most studies of fish
 consumption have looked at licensed
 sport fishermen; they inadvertently
 exclude reservation-based Indian
 subsistence fishermen, who, by treaty
 rights, are not required to obtain state
 fishing licenses. The few studies that
 have been completed so far  provide
 only indirect evidence that Michigan
 Great Lakes reservation Indians may

 (Dr. West is Associate Professor of
 Natural Resource/Environmental
 Sociology and Samuel T. Dana
 Professor of Outdoor Recreation  at the
 School of Natural  Resources,
 l/niversity of Michigan.)
                                          :mcl Assessment Program phnlo.
have disproportionally high fish
consumption levels.
  One study of a traditionally oriented
subsistence tribe in Alaska indicates
high levels of fish consumption; and a
fine study of the Grassy Narrows band
of Ojibwa in Ontario, Canada,
indicates that they were exposed
through fish  consumption to higher
levels of mercury from a spill than was
the surrounding white community.
However, there is scant evidence on
the fish consumption patterns of
Native Americans in the lower 48
states, and the applicability of these
northern-tribe studies to southern
tribes could be questionable.
  Not all tribes may be as traditionally
resource based as the Alaska and
Ontario tribes studied, and certainly
not all are fishery based. The Blackfeet
in Montana,  for example, traditionally
refuse to eat  fish. But others, such as
certain Northwest tribes, and Michigan
and other Great Lakes based tribes,
have a long cultural tradition of
fishing-based economies similar to the
tribes discussed above. For these
tribes, we might expect  higher than
average fish consumption.
  The Michigan Great Lakes tribes of
the Bay Mills, Grand Traverse, and
Sault Ste. Marie bands of Chippewa all
have a long and well documented
fishing culture. When they ceded  the
lands of Michigan in the Treaty of
1836, they carefully reserved their
most important resource, the Great
Lakes fishery. (These rights were
recently upheld by the courts.)
  With this resource so  highly valued
both culturally and economically by
these tribes, we would expect to find
high levels of fish
consumption—especially on the Bay
Mills reservation, where high levels of
poverty prevail and subsistence
small-skiff fishermen are common.
Even for  the commercial fishing sector
of the economy, it has been well
established that much extra fish is
distributed among crew  members for
subsistence consumption (as part of
labor compensation) and as part of
cultural ritual and tradition.
  In addition to these historical and
cultural indicators, we have  evidence
that off-reservation Native  Americans
in Michigan consume  more than
whites or than other minorities.
Off-reservation Indians do  need state
fishing licenses, and in our recent
statewide survey of consumption by
Michigan sport fishermen,  we picked
up a significant subsample of
off-reservation Native Americans. The
sample was spread over  18 randomly
drawn cohorts, from mid-January to
early June 1988; respondents were
asked to recall detailed
fish-consumption patterns  for the
seven-day period prior to filling out
the survey.
  The current State of Michigan
standard  used to regulate point
discharge of toxic chemicals into
surface waters (Michigan Rule 1057)
assumes a fish consumption  rate of 6.5
grams/person/day. The formula is very
complex. However, the important  thing
to emphasize  here is that the greater
the fish consumption assumed in the
formula, the tighter the standard
becomes—in  other words,  the lower
the levels are set for toxics permitted
MARCH/APRIL 1992
                                                                                                               15

-------
to be discharged by industrial and
municipal drain pipes. If assumed
consumption is too low, toxic
emissions may be  permitted that are a
danger to public health.
   In our study, the average
consumption for the full sample was
18.3 grams/person/day, quite a bit
higher than  the 6.5 gram assumption
currently used in Rule 1057. Further,
when the sample was broken down by
ethnic groups, non-reservation Native
Americans consumed 24.3
grams/person/day compared to 20.3
grams/person/day for other minorities,
and 17.9 grams/person/day for whites.
In an analysis involving multiple
variables, we found that middle-age
Native Americans  had the highest rates
of consumption of all Native
Americans,  or 30.6 grams/person/day.
   We would expect on-reservation
subsistence  fish consumption to be
even higher than these levels,
especially on poorer reservations, such
as Bay Mills, where poverty dictates
subsistence  fishing as a protein source
that is also sanctioned by traditional
culture. For  all Great Lakes tribes with
high fish consumption levels, there is
strong reason for concern for the
public health of the reservation.  By
way of illustration, studies have found
a high correlation between  high levels
of consumption of Great Lakes fish and
high levels of PGHs in the  blood of the
consumers.
   In sum, a  great deal of concern is
warranted for the health of Michigan
Great Lakes  Indians based  on  studies
done elsewhere; bused on our sport
fish consumption study that includes
off-reservation Indians in Michigan;
and based on studies tying  high Great
Lakes fish consumption with high
toxic loads in the human body.
However, direct studies of
on-reservation fish consumption are
badly needed for Great Lakes tribes as
well as for those in the Pacific
Northwest and elsewhere.  A major
study is about to get underway in the
Pacific; Northwest,  and Michigan tribes
have approached HPA about (lie need
for studies on their reservations.  These
will be key studies not only for
assessing the potential impact of fish
consumption on the health  of Great
Lakes tribes  but also  in terms  of
protecting their Great Lakes fishing
rights.  U
              by
              D. R. Wernette
              and
              L. A. Nieves
Minorities Are
Disproportionately
Exposed
    At Argonne National Laboratory,
    scientists have been studying the
relative potential for exposure of
minority population groups to
substandard outdoor air quality. The
studies have focused  on areas
identified by EPA as failing to attain
national ambient air quality standards.
  Under the Glean Air Act, EPA has
established standards for ground-level
ozone, carbon monoxide, sulfur
dioxide, nitrogen dioxide,  lead, and
particulate matter and annually
identifies  areas having excess levels of
these pollutants. These so-called
"nonattainment" areas generally
consist of counties of many square
miles, and residents'  exposure to air
pollution  surely varies depending on
where individuals live and work
within an area. Nevertheless, the racial
and socioeconomic makeup of the
population in these areas can imply
differences in potential exposure to
pollutants and may suggest directions
for research and remedial action. So

(Wernette is a  sociologist and Nieves is
an economist in the Environmental
Assessment and Information Systems
Division at Argonne National
Laboratory. The research described in
this article has been supported under
contract with the U.S. Department of
Energy, Office of Minority  Economic
Impact.]
far, scientists have examined these
differences for African Americans,
Hispanics, and  whites (non-Hispanic).
  In the United States, excluding
Alaska and Hawaii, higher percentages
of both African Americans and
Hispanics live in areas with reduced
air quality than do whites. For
instance, 52 percent of all whites live
in counties with high ozone
concentrations; for African Americans,
the figure is 62 percent, and for
Hispanics, 71 percent. Population
group distributions were found to be
similar for the other pollutants cited
above.
  These differences in potential
exposure to  pollutants may be due in
part to minority population
distributions across regions.  Hispanics,
for example, are more concentrated  in
the West,  where there is a greater
tendency than elsewhere for the
population as a whole to be  exposed to
high levels of ozone. However, the
different regional concentrations of
population groups do not account for
all of the differences in their potential
exposure to reduced air quality. Not
only are percentages of minorities
living in substandard  air quality  areas
higher for the country as  a whole, but
they are higher when  the four U.S.
census regions are considered
separately.
  For example, 50 percent of whites  in
the Northeast census region  live  in
areas with excessive carbon  monoxide.
In contrast, 85 percent of northeastern
African Americans and 88 percent of
northeastern Hispanics reside in  those
areas.
  In 1990. 437 of the 3,109 counties
and independent  cities in the United
States failed to  meet at least  one  of the
EPA ambient air quality standards. Of
these counties,  136 had excessive
levels of two or more pollutants, 29
exceeded standards for three or more
pollutants, seven  exceeded standards
for four or more pollutants, and one
exceeded standards for five pollutants.
  To what extent do the proportions  of
whites, African Americans, and
Hispanics living in these  counties
differ? As  the bar chart shows, 57
percent of all whites, 65 percent  of
African Americans,  and 80 percent of
Hispanics live in  the 437 counties with
substandard air quality. Out  of the
whole population, a total of  33 percent
of whites, 50 percent of African
    16
                                                                                                         EPA JOURNAL

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                             Substandard Air Quality Areas
    Ozone Qcarbon Monoxide   • Particulates      OSulfur Dioxide  «Lead  ONitrogen Dioxide
   Americans, and  60 percent of
   Hispanics live in the 136 counties in
   which two or more air pollutants
   exceed standards. The percentages
   living  in the  29 counties designated as
   nonattainment areas for three or more
   pollutants are 12 percent of whites, 20
   percent of African Americans, and 31
   percent of Hispanics.  Finally, 5
   percent of whites, 10 percent of
   African Americans, and 15 percent of
   Hispanics live in the seven counties
   that exceed standards for four or more

    Percentage of Population Groups Living
    Where Air Quality Standards are Exceeded
100%f
       Number of Air Quality Standards Exceeded
         •1    02    r~]3
D4
   or more
      White     African    Hispanic     Poor
              American
pollutants. In short, the percentage of
minority populations in these areas is
consistently greater than the
percentage of whites as the number of
air pollutant criteria that are exceeded
increases from  one to four or more.
  The rightmost bar of the chart shows
the percentages of the population with
incomes below the poverty level in
relation to  the number of pollutants
that exceed standards. Regardless of
the number of pollutants that exceed
standards,  lower percentages of poor
people (from all population groups)  are
potentially exposed to substandard air
quality than percentages of either
African Americans or Hispanics. This
is the case for one or more pollutants
as well as for four or more pollutants.
  This is noteworthy because both
African Americans and Hispanics have
above-average percentages of their
populations with incomes below the
poverty line. One might expect such
income differences to cause the
differences in percentages of the
population living in substandard air
quality areas shown here—and,
indeed, low income  may contribute to
the patterns observed. However, a
comparison between poor, African
American,  and  Hispanic percentages
shows that these minority groups are
more concentrated in such counties
than the poor population  in general.
This suggests that  more than low
income is a factor  in the above-average
percentages of African Americans and
Hispanics in areas with reduced air
quality.
  Air pollutants that cause
substandard air quality come from
many and varied sources including
traffic, industry, and even that cozy
fire in the fireplace. Industrial and
electricity-generating facilities are
major sources of some of the
contaminants of concern. For that
reason, the relationship between
minority population percentages and
concentrations of such facilities is also
of interest.
  Air-polluting facilities are not evenly
distributed over the four regions of the
country or between urban and rural
counties. Almost half of the nearly
3,000 major air-polluting facilities
nationwide are in the South, followed
in order by the North Central, West,
and Northeast regions. Likewise, 63
percent of the facilities are in urban
(Metropolitan Statistical Area)
counties. Of all U.S. counties
considered urban, only 12 percent
have high percentages  of minorities
(greater than 31  percent), but these
high-minority counties contain 21
percent of all urban facilities. Thus,
the air-polluting facilities are
disproportionately concentrated in
counties with high percentages of
minorities. Specifically, among urban
counties, those with high minority
population concentrations have more
than twice as many air-polluting
facilities as those with below-average
(less than 14 percent) minority
populations.
  We find  that air quality trends and
the distribution of air-polluting
facilities analyses tell the same story:
Minorities  live in greater
concentrations both in areas with
above-average numbers of air-polluting
facilities and in air-quality problem
areas. Why this is the case  is the focus
of our continuing research.
  Whatever the reason(s). these
patterns have important implications
because of the different distribution  of
the costs and benefits of these
facilities. The gasoline, electricity.
chemicals, and other goods from these
facilities may benefit individuals
around the world, but  the
pollution-related health and economic
costs  of the facilities are more likely to
be borne by the people in the adjacent
areas, who are identified by this
research as disproportionately African
Americans and Hispanics.  a
     MARCH/APRIL 1992
                                                                                                                     17

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Expanding  the  Diaogue
                    —g—                     -g-
 EPA'      POS
         by William K.  Reilly
 Protection Should be Applied Fairly
I   have a certain idea about
   environmental protection: It is about
 (i/l of us; it benefits ciJI of us. In fact, it
 improves our health, defends our
 natural systems, and involves us in the
 humanly defining enterprise of
 stewardship. That's why talk of
 environmental racism at EPA and
 charges that the Agency's efforts pay
 less regard  to the environments of poor
  IS!
people infuriate me. I am determined
to get to the bottom of these charges, to
refute or respond to them.
  At its core, environmental equity
means fairness. It speaks to the
impartiality that should guide the
application of laws designed to protect
the health of human beings and the
productivity of ecological systems on
which all human activity, economic
                                                               Burbnrn H. fiuscher pholo. /uc;ksr>n. Mississippi. Cla
activity included, depends. It is
emerging as an issue because studies
are showing that certain groups of
Americans may disproportionately
suffer the burdens of pollution. And it
is emerging because across America
people of color are forging a
constituency to put this issue squarely
on the national agenda.
  The debate surrounding equity is
deeply rooted in American history, for
our tradition suggests, as Alexander
Hamilton stated, "that every individual
of the community at large has an equal
right to the protection of government."
Despite notable gaps between ideal
and practice, this principle continues
to undergird our notions of proper
governance.
  A conference in Michigan and a
report by the United Church of Christ
raised my concern about the equity
issue. They indicated that certain
                                                                   (Reilly is Administrator of EPA.)
                                                                                        EPA JOURNAL

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Mississippi Choctaws protest proposed
toxic waste dump.
waste facilities tended to be sited
disproportionately in poor and
minority communities. I formed an
Environmental Equity Workgroup,
comprised of 40 professionals from
across the Agency who were tasked
with assessing the evidence that racial
minorities and low-income
communities are exposed to higher
environmental risks than the
population at large. I also wanted to
know: What could EPA do to address
any disparities that were identified?
  It was already clear that EPA had
entered a pivotal period in our history,
a timeuof transformation, formidable
challenges, fresh directions. The
concept of risk—its assessment and
management—is a pervasive theme.
This follows more than two decades of
doggedly pursuing an improved
environment. The United States has
spent approximately $1.5 trillion to
attack contamination of the air, water,
land, and food supply, registering, in
many cases, substantial progress and
more than a few triumphs. No other
country comes close to this record.
  In one of my first actions as
Administrator, I asked EPA's Science
Advisory Board (SAB) to suggest ways
to improve the process of identifying,
assessing, and comparing multiple
risks. The SAB report, published in
1990 and entitled Reducing Risk:
Setting Priorities and Strategies /or
Environmental Protection, urges EPA
to target the most promising
opportunities for reducing the most
serious risks to human health and the
environment. The health risks
emphasized in the report include
ambient air pollution; exposure to
dangerous chemicals, especially
workplace exposure; indoor air
pollution; and contamination of
drinking water, particularly by lead.
  Risk is central to equity, and the
Environmental Equity Workgroup
started with some basic questions:
How is environmental risk distributed
across population groups? How have
EPA programs addressed differential
risks in the past? How can we do so in
the future?
  Of course, these questions are not
new. Over 20 years ago, a group of
African Americans inhabiting South
Carolina's Gullah Islands sent an early
warning signal through the
environmental movement. Although
living at subsistence levels on fish and
garden produce and still speaking a
Creole dialect deeply enriched by
African words, the Gullah community
showed great skill in mobilizing public
opinion and using the legal system to
defeat a German chemical company's
efforts to build a major processing
plant that would have disturbed the
delicate ecology of the wetlands and
shallow seas around their islands.
  In 1982, a demonstration  against the
siting of a polychlorinated biphenyl
(PCB) landfill in predominantly black
Warren County, North Carolina,
became a watershed in the movement
to link environmental issues with
social justice. In response to the
protests, Representative Walter
Fauntroy (DC) requested the General
Accounting Office (GAO) to investigate
the race and income dimensions of
locating dangerous and dirty facilities.
Answer: Blacks were
disproportionately represented in three
of the four sites that were surveyed.
  By January 1990, the debate over
environmental equity had progressed
sufficiently for the University of
Michigan's School of Natural
Resources to hold a conference on the
relationship between race and the
incidence of environmental  hazards. In
its aftermath, a group of social
scientists and civil rights leaders
informally joined together as the
Michigan Coalition. It was the
arguments of this group that prompted
me to create the Environmental Equity
Workgroup.
  At EPA, our approach to
environmental equity is drawing on
three interwoven strands: the Agency's
strengthened relationship with
minority academic institutions;
ambitious goals we have for hiring
many more racial minorities in policy
and decision-making positions at the
Agency; and plans to address the
distribution and management of
environmental risk. Prior to the
workgroup's appointment, EPA had
developed specific programs to
increase employment opportunities
and reach out to minority academic
institutions. The workgroup,
consequently, focused on the
distribution of risks.
  In my charge to this workgroup, I
emphasized EPA's basic goal of
making certain that the consequences
of environmental pollution should not
be borne unequally by any segment of
the population. EPA has a
responsibility to identify such risks
and target our scarce resources to
address them.
  The workgroup's draft report has
now been published. It found that data
on the incidence of health effects
among different race and income
groupings are poor—with one notable
exception, lead poisoning. A much
higher percentage of African American
children have unacceptably high levels
of lead in their blood. Moreover, our
analyses suggested, some low-income
and minority communities may
experience greater exposure to other
pollutants.
  Using what data are available, then,
the task force on environmental equity
has turned up only one instance of
environmental contamination that
correlates with race: high blood lead in
African American children.
  Income levels are a somewhat
clearer case, although again data from
systematic studies are lacking.
Property values and rentals are
generally higher in less polluted areas.
Supply and demand EPA cannot
reverse. But we can improve the
overall quality of air in cities.
  What about poor rural areas? A
March 1990 study by Clean Sites, Inc.,
a private nonprofit group, identified
470 rural poor counties in the United
States. Although 15 percent of all
counties in the United States are rural
and poor, these counties contain only
4 percent of the total sites
contaminated by hazardous waste, 2
percent of the active hazardous waste
storage and treatment facilities, and 2
percent of the nation's Superfund sites.
The study concluded that when
Superfund sites are identified in rural
poor counties, they receive about the
same level of federal attention as
Superfund sites nationally.
  EPA's workgroup on environmental
equity made several recommendations
to elevate and improve the Agency's
 MARCH/APRIL 1992
                                                                                                              19

-------
              log  Ihe Dia
response to environmental equity
issues (see box). Informed decisions
about environmental equity require a
better database, one that should
provide an objective basis for
assessment of risks by income and
race. The Agency should also move to
integrate considerations of equity in
risk assessment. EPA should employ
creative measures to address equity
issues and target high-risk populations.
Mechanisms should be established to
ensure that equity is incorporated into
long-term planning. Finally, the
Agency must significantly improve its
ability to communicate with racial
minority and low-income
communities.
  EPA alone cannot correct whatever
imbalance has developed in the
application of environmental
protection. By way of example, while
the Agency sets technology standards
for what comes out the stacks, or what
type of liner must be used to protect
ground water, the siting of landfills
and incinerators is largely the function
of private firms, state regulators, and
local zoning boards. Addressing equity
issues will need the concerted efforts
of state and local governments and of
the private sector, as well.
  EPA is not wasting any time,
however, waiting on the efforts of
others or even on the results of the
changes we, ourselves, are making. We
have active programs underway to
increase the hiring of minorities and to
involve minority academic institutions
in environmental research. And over
the past two years, each of EPA's 10
regional offices has launched one or
more special projects to investigate
problems of environmental inequity
and to take steps to remedy them.
From bringing enforcement actions to
improve drinking water in migrant
farm worker camps in California to
assuring equitable enforcement across
communities regardless of income
level to  targeting lead for aggressive
reduction efforts, many EPA offices
were well engaged in equity issues
even before the task force convened.
(See the article on pages 54-57.)
  In the final analysis, lasting progress
will depend on having the right people
in the right place. In the case of
environmental equity, this means
having more representatives from
minorities making decisions and
managing programs. At EPA, we are
committed to hiring and promoting
minorities and to encouraging young
people to pursue education and choose
careers in environmental disciplines.
As a start, I note that over  the past
three years, a time in which President
Bush has proposed and Congress has
provided funding to add 23 percent to
EPA's personnel, new minority hirings
accounted for almost 25 percent of  the
total. Nevertheless, only 10 percent of
our managerial staff is drawn from
minority groups, and in the executive
  Hazardous cargo
 sign directs trucks
     through poor
    community in
 Texas City, Texas.
                                                        Copyright Sum Kiltner.
  Findings and
  Recommendations of
  EPA's Environmental
  Equity Workgroup

  Convened by Administrator Reilly.
  EPA's Environmental Equity
  Workgroup was asked to assess the
  evidence that racial minority and
  low-income communities bear a higher
  environmental  risk burden than the
  general population and  to consider
  what EPA might do about any
  identified disparities.
    The workgroup  prepared a report to
  the Administrator which was
  submitted to him in  February 1992 and
  made public. The  report reviewed
  existing data on the distribution of
  environmental  exposures and risks
  across population  groups. It also
  examined EPA programs with respect
  to racial minority  and low-income
  populations.
    It should be  stressed that the
  findings and recommendations in the
  workgroup report—summarized
  below—constitute only  a first step in
  the Agency's response to
  environmental  equity concerns. They
  are intended to contribute to the
  national dialogue  on environmental
  equity and to suggest further steps for
  EPA. There is much that we still need
  to learn, through both internal  study
  and public debate.
Summary of Findings

• There is a general lack of data on
environmental health effects by race
and income. Although there are clear
differences 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
socioeconomic group. The notable
exception is lead poisoning. (See  story
on page 42.)
• While there are large gaps in data on
actual health effects, it is possible to
document differences in observed and
potential exposure to some
environmental pollutants by
socioeconomic factors and race.
Exposure is not the same as health
effects, but this finding is nevertheless
a clear cause for concern.
• Environmental and health data are
not routinely collected and  analyzed
by income and race. Nor are data
routinely collected on health risks
posed by multiple  industrial facilities,
cumulative and synergistic  effects, or
multiple  and different pathways of
exposure. Risk assessment and risk
management procedures are not in
themselves biased against certain
income or racial groups; however,
improvements can be made in data
collection procedures.
20
                                                                                                  EPA JOURNAL

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        HAZARDOUS
           CARGO
                                        ranks minorities are just 4 percent. We
                                        have a long way to go.
                                          To achieve better results in the
                                        future, our Minority Academic
                                        Institutions Task Force, comprised of
                                        senior managers and presidents of
                                        Historically Black Colleges and
                                        Universities (HBCUs) and Hispanic
                                        Associated Colleges and Universities
                                        (HACUs), has developed an action
                                        plan to strengthen EPA's relationships
                                        with their institutions. (See separate
                                        article on page 58.) In line with the
                                        task force's recommendations, EPA's
                                        undergraduate scholarship program
• Great opportunities exist for EPA
and other government agencies to
improve communication about
environmental problems with members
of low-income and racial minority
groups. The language, format and
distribution of written materials, media
relations, and efforts in two-way
communication all can be improved.
In addition, EPA can broaden the
spectrum of groups with which it
interacts.
• EPA's program and regional offices
vary considerably in  terms of how they
address environmental equity issues.
Case studies of EPA program and
regional offices reveal that
opportunities exist for addressing
environmental equity issues and that
there is a need for  environmental
equity awareness training. A number
of EPA regional offices have initiated
projects to address high risks in
minority and low-income communities.

• Native Americans are a unique
racial group with a special relationship
with the federal government and
distinct environmental problems.
Indian  tribes often  lack the physical
infrastructure, institutions, trained
personnel, and resources necessary to
protect their members.
Summary of Recommendations
Despite data gaps, the workgroup
believes that enough is known with
sufficient certainty to make several
recommendations to the Agency. These
recommendations are also applicable
to other public and  private groups
engaged in environmental protection
activities. The job of achieving
environmental equity is shared by
everyone.
  Our working principle in developing
the following recommendations was
succinctly stated in  a memorandum
from the Administrator: "The
consequences of environmental
pollution should not be borne
disproportionately by any segment of
the population."
• EPA should increase the priority
that it gives to issues of environmental
equity.
• EPA should establish and maintain
information which provides an
objective basis for assessing risks by
income and race, commencing with
developing a research and data
collection plan.
• The Agency should incorporate
considerations of environmental equity
into the risk assessment process. It
should revise its risk assessment
procedures to ensure, where practical
and relevant, better characterization of
risk across populations, communities,
or geographic areas.  In some cases it
may be important to know whether
there are any population groups at
disproportionately high risk.
• EPA should identify and target
opportunities to reduce high
concentrations of risk to different
population groups, employing
approaches developed for geographic
targeting.
• Where appropriate, EPA should
selectively assess and consider the
distribution of projected risk reduction
in major rule makings and Agency
initiatives.
• EPA should selectively review and
revise its permit, grant, monitoring,
and enforcement procedures  to address
high concentrations of risk in racial
minority and low-income
communities. Since state and local
governments have primary authority
for many environmental programs,
EPA should emphasize its concerns
about environmental equity to them.
• The Agency should expand and
improve its communications  with
racial minority and low-income
communities and should increase
efforts to involve them in
environmental policy making.
• EPA should establish mechanisms to
ensure that environmental equity
concerns are incorporated in  its
long-term planning and operations.
             —Robert M. Wolcott and
               Reina Milligan
MARCH/APRIL 1992
                                                                                                               21

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has been expanded, and a new
graduate fellowship program has been
added for students from HBCUs and
HACUs pursuing advanced degrees in
environmental fields. The first of these
multi-year, $20,000-a-year fellowships
is being awarded in the spring of 1992.
In the current fiscal year, EPA has
allocated $1.4 million—$1 million
more than was available last year—to
provide 40 new  minority graduate
fellowships each year, starting with the
school year that begins next
September, and  to encourage
employment at  EPA  after graduation.
  Another effort that warrants
attention is  our new Environmental
Science and Management  Fellows
Program. In 1990, EPA awarded
National Urban Fellows a planning
grant to establish a mid-career program
for a Masters of  Environmental Science
Management degree  that includes a
year at Tufts University in
Massachusetts and a 12-month
mentors hip at either EPA  or another
environmental organization. In
addition to  fully paid tuition,  students
receive stipends during the two years
of the program. EPA will spend
approximately $80,000 for each fellow.
Already enrolled are the first eight
students at Tufts; this year, another 10
start the program, with 15 more joining
the team next year. In another
program, an Environmental Science
Scholarship of $120,000 was granted to
the American Indian Science and
Engineering Society  for awarding
competitive scholarships to Native
Americans interested in following
studies in the environmental sciences.
The interest is strong: Over 450
students attended the first conference
on career opportunities for minority
students that EPA co-sponsored at
Howard University in 1990. Last year,
a second conference in Oakland,
California, attracted  300 participants;
this year, another was held in March
in Atlanta, Georgia.
   Meanwhile, we are trying to improve
the opportunities for those already in
the workforce. Since 1986, EPA has
awarded almost $3 million in  grants to
the National Association of Minority
Contractors to train firms  run  by
minorities and  women in the fields of
hazardous waste removal and
management, asbestos abatement,

 22
removal of leaky underground tanks.
and radon mitigation and remediation.
This year, the Agency will start a new
training program in the removal of
lead-based paints. And, acting through
its small and disadvantaged business
office over the past  two years, EPA has
awarded more than $915 million in
contracts, grants, and cooperative
agreements to companies owned by
minorities. This program provides jobs
in minority-owned firms to help clean
up the environment, and it constitutes
a singularly  effective, practical, and
tangible way to broaden the
constituency for environmental
improvement.
  It is also undeniable that minorities
usually benefit from—are, indeed,
sometimes the chief beneficiaries
of—more general efforts to protect the
environment. New pesticide
regulations,  for example, will soon be
in effect to protect farm workers and
others exposed to these compounds
from  unsafe uses and storage practices.
In 1991, we issued  a final rule
reducing the amount of lead in
drinking water, with the highest risks
being targeted for treatment first. We
expect that neurological threats to over
20 million children will be reduced
and that about  100,000 additional
children will avoid detrimental effects.
This  year, EPA will propose banning
lead solder and limiting lead in
plumbing fixtures. We also expect to
propose tightening  the national
ambient air  quality standard for lead  in
the atmosphere.
  The border zone  between the United
States and Mexico is an environmental
hot spot, and the inevitable result is a
rather severe set of environmental
threats to the Hispanic populations
there. Dysentery and hepatitis levels
are high. In fact, these areas may be
among the highest risk environments
in the country. According to a  new
bilateral plan for the area, EPA and its
Mexican counterpart are jointly
expanding efforts to ensure adequate
wastewater  treatment and drinking
water facilities where none now exist
in poor border settlements, commonly
called "colonias."  Mexico is committed
to providing $460 million over the
next  three years to  environmental
improvements  in the region. In the
next  fiscal year, EPA, in addition to its
substantial sewer and water projects
(see article on page 61), will invest
over $200 million implementing the
border plan.
  The whole country, meanwhile,
stands to reap enormous health
benefits from the historic Clean Air
Act of  1990, which promises cleaner,
clearer skies for all Americans—and
especially for those who live in our
largest and smoggiest cities. According
to the South Coast Air Quality
Management District in Los Angeles,
California, children in the smoggiest
areas suffer a 10- to 15-percent
reduction in lung function compared
with those in less polluted areas. Some
15 million African Americans (50
percent of the total) will be winners
because of EPA's efforts to bring the
most severely affected areas into
compliance. Over 8.5 million
Hispanics (60 percent of the total) will
similarly gain from a vigorously
implemented Clean Air Act.
  Failures to achieve perfect equity in
environmental matters are woven,
along with other threads of triumph
and defeat, into the full tapestry of
American history. They are, in fact
symptomatic of larger patterns of
industrial growth and neglect and of
sad legacies of inherited poverty and
discrimination. It will  take time and
hard work to mend the fabric.
Restrained by resources, jurisdiction,
and knowledge, a government agency
is necessarily limited in  its capacity to
affect larger cultural and social trends.
Yet, within its domain, an agency of
the United States
government—situated as it is in long
traditions of governance that compel
close attention to questions of
equity—must make every possible
effort to redress obvious wrongs.  At
EPA, although we have just begun, we
are well begun, n
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                                                           by Dorceta Taylor
                                                           No Shortage of Minority Volunteers
    For decades, many researchers and
    environmentalists argued that
 minorities were not involved in the
 environmental movement because they
 placed a low priority on environmental
 issues or they were not as
 knowledgeable as whites about the
 environment.  However, minorities
 have changed that debate.
   Since the late 1980s, large numbers
 of minorities have become involved
 with the environmental movement.
 (Dr. Taylor, Ph.D graduate of the Yale
 School of Forestry and Environmental
 Studies and the YaJe Department of
 Sociology, has written often on the
 environmental justice movement.]
Crass-roots activists in Louisiana take to
the streets (o protest pollution in their
neighborhood.


They are participating in a sector of
the movement called environmental
justice. Why are minorities
participating so actively now? Why do
they participate in the environmental
justice sector and not in the traditional
or well-established sectors of the
movement? What have been the effects
of minority activism? Are minorities
likely to participate in large numbers
in the traditional and well-established
sectors of the movement?
  Several factors account for the surge
in minority environmental activism.
Here are some  of the most important
ones:
•  The discovery of toxics in many
minority communities
•  The publication of research linking
race, class, and disproportionate
exposures to toxins
•  The revelation that minority
communities were targeted for the
siting of hazardous environmental
facilities
•  The revelation that minorities were
more  likely to suffer from
life-threatening environmental health
probiems than whites
•  A response to NIMBYism, which
said "not in my backyard" without
asking whose backyard the problem
ended up in
•  The organization of conferences  and
MARCH/APRIL 1992

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Expanding Hie  Dia
workshops on the issue of
environmental and social justice
•  A redefinition of what issues were
considered "environmental"
•  The linkage of civil rights issues
with environmental issues
•  The emergence of committed
activists and leaders.

  As many communities woke up to
the reality that they were contaminated
or had hazardous facilities in them,
some organized to prevent further
exposures and sitings. About the  same
time, research revealed that black,
Hispanic, Native American, and Asian
communities  not only were more
likely to have hazardous facilities, but
that the facilities were deliberately
sited in these communities because
they were seen as "paths of least
resistance." As minorities began
paying increased attention to health
risks and disproportionate exposure,
environmental activism intensified.
  This increased activism manifested
itself in the call for environmental and
social justice  for people of color and
the poor. It linked civil rights  with
environmental rights and re-introduced
civil rights campaign strategies into
environmental campaigns. So,
although many researchers have
argued that minorities are too  busy
struggling to meet basic needs to  be
concerned with environmental issues,
minorities have redefined
environmental issues as survival  issues
and have been organizing around them
at unprecedented rates.
  The environmental justice movement
is a sector in which blacks, whites,
Native Americans, Hispanics, and
Asians from various social classes and
ethnic groups unite to fight a wide
array of issues that affect humans,
flora, fauna, and the physical
environment locally, nationally, and
internationally. It is a movement
which recognizes that injustices have
occurred in the past that stem from
racism and discrimination. Such
practices have put communities of
color at risk. The movement seeks
remedies for these past injustices and
 seeks to promote fairness in future
 environmental actions.
   In contrast to the traditional and
 well-established environmental groups,
 environmental justice groups rely
People of color feel
comfortable participating in
the environmental justice
movement because it is a
movement founded on  the
principles of fairness and
justice.
heavily on volunteer support to carry
out daily operations. They have few, if
any, paid  staff. They are kept going by
the strong moral and political
commitments  of their members and by
the personal zeal that volunteers bring
to the cause, They tend to be informal
and to have a  limited hierarchical
structure.  These groups, which are
often small in  size, rely heavily on
membership donations and on
contributions of time and other
nonmonetary resources like phone
lines, space to store materials, food,
housing for visiting organizers, and
supplies. They run highly symbolic
campaigns in which members and
supporters participate in
demonstrations,  picketing, petition
drives, boycotts, and nonviolent
obstructions. Recruiting is not done
from national  mailing lists; people, on
the spur of the moment, recruit
friends, families, or coworkers  to
participate.
  People of color feel comfortable
participating in the environmental
justice movement because it is a
movement founded on the principles
of fairness and justice. It is a
movement committed to building race
and class coalitions. It is driven by
grass-roots activism, and there  is a
strong articulation  of civil rights  and
social justice. The  movement provides
the political space  to articulate and
work on issues relevant to minority
communities in ways  that encourage
and respect minority participation. In
the environmental justice movement,
minorities can take a leadership role or
they can be equals with whites
interested in the same issues.
  Minority participation has had a
profound effect on the whole
environmental movement. It has
provided the environmental justice
sector with the best and brightest
minority environmental activists,
leaders, scholars, and policy makers. It
has provided the race, class, and
ethnic diversity so sadly lacking in
other sectors of the movement, and it
has provided a platform from which to
articulate the goals and concerns of a
broad-based grass-roots movement.
  In the larger environmental
movement, minority participation has
broadened the debate to include many
issues which were being ignored.
Minority participation has also forced
a dialogue about race, class,
discrimination, and equity. Because of
minority participation,  the plight of
minority communities has been
brought to the  forefront. Minorities
have also brought a new perspective to
the movement  and will be a part of
any future environmental agenda that
is being charted. By participating,
minorities have also been able to show
how distanced most traditional and
well-established  environmental
organizations have become from the
grass roots and the environmental
concerns they  have.
  I predict that large numbers of
minorities will continue to join the
environmental justice sector because
those who already belong are
committed to mobilizing more
minorities around environmental
issues. I also predict that very few
minorities will join the other sectors of
the environmental movement. Unless
the traditional  and well-established
sectors make radical changes to their
agenda, their attitudes towards
minorities, their  coverage and support
of issues affecting minority
communities, their hiring policies,
their analysis of  how and which
communities are impacted by
environmental  hazards, then few

                       EPA JOURNAL

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minorities will find these organizations
attractive enough to join.
  A few predominantly white
environmental organizations, like
Greenpeace and the Center for
Environmental Intern Programs (CEIP
Fund, Inc.), have taken up the
challenge from minority environmental
activists and have collaborated on
many projects with minority groups or
have worked  on the issue of job
preparation and placement.  For the
most part, however, most
environmental organizations not a  part
of the environmental justice sector are
devoid of minority members, staff, or
board members. They complain that
they can't find "qualified" minorities
to fill positions in their organizations.
However, such claims  have  to be
questioned because there seems to be
no shortage of such minorities in the
environmental justice sector.
  Although there has been some
unease between minorities and the
traditional and well-established sectors
of the movement, there are signs that
both groups might be able to work
together in the future. Many
nonminority environmental  groups
sent observers to the First National
People of Color Leadership Summit
last October, and the number of
collaborative  projects is growing. Both
minority and  nonminority
environmental groups have  strengths
that each can benefit from, but if these
two different  groups are to develop a
meaningful relationship, many radical
changes are required, a
                                    by John  H. Adams
Predominately White Memberships Are Not Defensible
  jThe statistics are plentiful and they
  '  are frightening. Three out of four
toxic waste dumps are sited in
predominantly African American or
Latino communities. Two million tons
of radioactive uranium tailings have
been dumped on Native  American
lands. Three hundred thousand Latino
farm laborers suffer from
pesticide-related illnesses. This is a
national disgrace.
  Statistics like these reflect a
nationwide pattern of disproportionate
environmental impact on people  of
color and  the poor. This pattern stems
from a profound flaw in  the structure
of the U.S. economy: Polluters  do not
absorb the costs of the environmental
degradation they create,  and society as
a whole does not confront the
problems  and solve them. Instead, the
problems  are displaced.  It is easier for
a company to locate its factory or
waste facility in eastern  St. Louis than
in the Upper East Side of Manhattan; it
is cheaper for state governments to
disregard  the lead poisoning of poor
children than to test and treat them as
federal law requires. What this means
                                         (Adams is Executive Director of the
                                         Natural Resources Defense Council,
                                         headquartered in  New York City.}
is that we are building our economy
on the backs of people of color and the
poor.
  Not to recognize this syndrome is to
ignore one of the driving forces of
environmental degradation in this
country. The fact of disproportionate
impact demands a disproportionate
effort. Federal and state governments
must direct a disproportionate share of
clean-up  funds and other
environmental funding to these
communities. The national
environmental organizations must
devote a disproportionate share of
their resources to the public health
problems affecting them.
  But this alone is not enough. The
environmental justice movement that
has arisen to address the concerns of
these communities is one of the
strongest new forces for environmental
reform to emerge in years.  If we are to
remain truly effective, the national
environmental groups must strive to
become allies of this movement and of
the communities it represents.
  This  alliance will not take place
overnight. It will require a great deal of
work on the part of the national
groups. We have been criticized by
environmental justice activists, and
there is much to criticize—the
predominantly white staffs, the
cultural barriers that have damaged
and impeded joint efforts with activists
MARCH/APRIL 1992
                                                                                                                  25

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                    the  Dia

   Fighting back.
           The
   environmental
justice movement
    i\ one of (he
   strongest new
forces for reform.
                                            TOXICS
                                           COALITION
                                                                           of color. The history is well
                                                                           documented: The mainstream
                                                                           environmental movement grew out of a
                                                                           white, middle-class effort to preserve
                                                                           the world's natural wonders. It is still
                                                                           true that the staffs of the major
                                                                           national organizations are
                                                                           disproportionately white and middle
                                                                           class, and it is not defensible.
It is critical  that the national
en vironm en tal gro ups Us ten
to people of color on their
own terms.
  Environmental justice activists have
also criticized the priorities of the
mainstream environmental movement.
The movement began with wilderness
conservation, and there is no question
that, in its early life, its work and
vision only rarely encompassed the
protection of human beings.  But there
is also no question that this is a
movement that has matured far beyond
its origins. I speak for NRDC, and 1
know I speak for many others, when I
say that for mainstream
environmentalists today the two
critical issues—environmental
violation of the Earth and
environmental violation of its human
inhabitants—are inextricably
intertwined.
  The record speaks  for itself. It is a
record of commitment to clean air,
clean water, land that is safe to  live on
and work on. These are not abstract
values or values limited to national
parks and wildlife preserves. They are
values that have led  NRDC to dedicate
the bulk of our resources to the  very
public health problems that impact
communities of color
disproportionately.
  For two decades, we have been
working to clean up  the smog that
concentrates in the inner city and that
can cause long-term  lung damage. We
have been striving to end toxic
pollution of drinking water supplies.
Our efforts helped lead to the phaseout
of  leaded gasoline, which was

                      EPA JOURNAL

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poisoning the air in inner cities and
the children who breathed it, and we
are still fighting to end lead poisoning
from every source. We are striving to
end unsafe incineration and
landfilling, which can contaminate the
water people drink, the land their
homes are built on, and the air they
breathe. We are working to reduce
pesticide use and eliminate the most
toxic pesticides, so that people can eat
safe food and farmworkers will  not be
poisoned.
  This is not to say that there is no
room for improvement. The point is
that the two movements are not so far
apart as to be irreconcilable. The
possibility for partnership exists, and
not only in the  arena of public: health,
but also in that  of conserving natural
resources. Many of the ethnic cultures
of this country have deep and
longstanding traditions of reverence for
the natural world and an abhorrence of
the exploitative practices  that the
mainstream environmental groups are
fighting.
  And such partnerships can be
enormously effective.  The
environmental justice movement has
vital site-specific information,
tremendous organizing ability,  and
expertise on questions of social justice.
The national environmental groups
have substantial technical, legal, and
lobbying experience in environmental
advocacy. The combination of these
complementary skills  can create a
powerful synergy.
  Some recent examples from NRDC's
experience: Joint efforts with the
Mothers of East Los Angeles and
Concerned Citizens of South Central
Los Angeles effected the cancellation
of plans to build California's first
large-scale toxic waste incinerator in a
low-income, primarily Hispanic
community. Our work with West
Harlem Environmental Action
regarding foul odors emitted by a
nearby sewage plant has helped build
press attention to the  problem, and we
expect soon to file a lawsuit.
  With the Cree nation of northern
Quebec and with other organizations,
we are beginning to articulate to the

MARCH/APRIL 1992
public and decision makers that the
James Bay II hydroelectric project,
which would flood an area in Quebec
the size of Vermont, is unnecessary
and vastly more expensive than the
energy-efficiency alternatives. With
People United for a Better Oakland.
the NAACP Legal Defense Fund, the
ACLU, and the National Health Law
Program, we won a commitment from
 What this means is that we
 are building our economy on
 the backs of people of color
 and the poor.
the state of California to establish a
state-of-the-art mandatory lead testing
program for poor children.
  All of us in the national
environmental groups need to broaden
and deepen our alliances with  the
environmental justice movement. To
accomplish this, we must do two
things.  First, we must diversify our
staffs to better reflect the heterogeneity
of environmentalism in its totality, and
of humankind itself. The fact of
disproportionate impact means that
different communities experience the
environment in different ways—and
therefore have differing insights and
objectives. To the degree that our staffs
are limited in their economic, cultural,
and ethnic origin, the perspectives
they bring to their environmentalism
will also be  limited. Our work is the
poorer for it.
   Second—but by no means second in
priority—the national groups must
listen to the environmental justice
activists and engage them as partners.
Their priorities and perspectives must
be among the factors shaping our
agenda. The issues of racism, poverty,
and environmental degradation are
intertwined, and we cannot solve one
without addressing  the others. What
this means is that the mainstream
environmental movement must learn
from those who have experience  in
social justice issues where we are
novices. Moreover, we must come to
recognize and respect the traditions of
reverence for the Earth that so many
communities of color have fostered,
and learn from them to enrich our own
perspective.  And we must support the
continuing growth of the
environmental justice movement  by
sharing our resources in technical
analysis, legal work, lobbying strength,
and fund-raising capability.
  And so our most urgent need is for
dialogue. It is critical that the national
environmental groups listen to people
of color on their own terms.
Correspondingly, my plea to the
environmental justice movement  itself
is for continued communication and
participation in this dialogue. We
stand ready to work with you. We
have made mistakes and no doubt we
will continue to make them, but we
are willing to learn and trying to
change. If our two movements can join
forces effectively on our common
issues, we will be a formidable force
for genuine and lasting protection of
the human environment, a
                                                                         27

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Expanding  the  Dia
                 V
                               E  ID  EPA
An  Environmental Justice Office is Needed
                         by Deeohn Ferris
    The environmental justice
    movement forged by activists such
as the Gulf Coast Tenants Association,
the Southwest Organizing Project, the
Panos Institute, the United Church of
Christ, and other grass-roots
organizations impels governments,
environmental groups, and social
justice organizations to question the
effects of their programs and policies
on people of color. EPA should not
only join this dialogue but, in
partnership with these groups, assume
a leadership role in correcting the
status quo.
  The keystone of this quest for justice
is equal protection, not equal
pollution. To adopt this justice agenda.
EPA must revise its policies  in the
interest  of protecting everyone's
quality of life. Addressing the impact
of lead on African American children
and the  effects of pesticides on
Chicano farm workers is no less
important than addressing Alar
residues on apples eaten by
middle-class kids.
  Whether or not government
programs are  intended to foster
disproportionate impact on people of
color, the results are the same. EPA
should recognize that harm
perpetuated by benign inadvertence is
as injurious as harm by purposeful
intent. Regardless of guilt, blame, or
politics, EPA  should seek justice by
initiating an Agency-wide priority
investigation to reveal which practices,
programs, and policies nurture
inequality. Based upon these findings,
the Agency can establish a major effort
to remedy data gaps, establish
long-term plans to minimize levels of
exposure in communities of color, and
institute environmental protection for
everyone.

(Ferris is Director of Environmental
Quality for the National Wildlife
Federation.)
  Latinos, Native Americans, Asian
Pacific Islanders, African Americans,
Chinese Americans, other people of
color, and people with low incomes
constitute the broadest and most
complex constituency that the Agency
has to serve. What they have in
common, what unites them, is that
they are systematically subjected to
higher doses of pollution than are
other segments of society. Remedying
this disparity is the foremost challenge
that the Agency confronts.
  Consider the example of Richmond,
California, a heavily minority
community where nearly 400
industrial facilities store and release
into the environment over 200
hazardous and toxic chemicals.
According to one grass-roots group,
Citizens for a Better Environment,
annual air emissions from these plants
total 800,000 pounds, and annual
hazardous waste production totals
179,000 tons. African American  and
Latino  residents  who live closest to
these facilities have organized with the
goal of reducing  emissions and
improving monitoring and health risk
assessments, but there has been  no
meaningful federal response to aid
their efforts.
  Last summer, a railway-car herbicide
spill in the Sacramento River, which
killed several thousand fish, received
more attention than the estimated
300,000 farm workers, most of whom
are people of color, who may be
poisoned every year by pesticides.
Migrant workers  face the toxic triple
threat of pesticides, dump sites,  and
contaminated drinking water.
Meanwhile, EPA's long-awaited
farm-worker protection rules
continually are postponed.
  Louisiana residents located in the
heavily minority corridor between
New Orleans and Baton Rouge have
experienced the inequitable
distribution of pollution since plants
were built up and down the river
beginning in the 1950s. The water is
contaminated soup, the air is fouled,
ailments and disease levels are high.
Since many residents depend on the
companies for their livelihood, they
suffer the combined consequences of
exposure both inside and outside the
plants. For decades, this dual
environmental contamination has
threatened  their quality of life without
respite, but government has paid no
attention.
  Across the nation, similar
circumstances continue unabated.
Clearly, EPA and other federal
agencies need  to form a partnership to
address the relationship between
pollution and minority
communities—from lead risks
associated with paint, drinking water,
and combustion to those risks caused
by polluting industries, whose
operations and discharges cause
enormous harm to human health,
wildlife, and the environment.
  EPA can  develop a model program,
and the time for action is now. The
first step is to establish a high-level
Office of Environmental Justice with
functional responsibilities and a
budget sufficient to  implement  them.
EPA spending should match its
commitment to parity.
  As a principal objective, this office
could develop an environmental policy
that creates a  presumption of justice by
requiring equity impact analyses as
part of the process for promulgating
major regulations, issuing key policies,
and conducting programmatic reviews.
  The Office of Environmental Justice
would integrate its theme into EPA's
operating guidance and strategic plans,
as well as the Agency's research and
data collection agendas. The office
could spearhead formation of
consortiums with academic
institutions for people of color,
including Historically Black Colleges
28
                                                                                                   EPA JOURNAL

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                                       Everyone's qualify oi lite is at stake.
                        C.'npvngiit -Sin:) Killm
and Universities (HBCUs), focusing on
risk assessments, research, and
development needs.
  Widespread changes are needed in
EPA's institutional focus. Working
closely with community leaders and
building bridges to grass-roots groups,
the office could facilitate the Agency's
progress in relieving the enormously
high environmental impact
experienced by people of color. Under
the auspices of this office, EPA should
embark on  an aggressive outreach
effort centered on education,
information exchange,  and problem
solving.
  The Environmental Justice Office
should also have an active role in
states' implementation of delegated
programs, reviewing state/EPA
agreements to ensure that these
relationships will be administered in a
socioeconomically race-neutral manner
that results in equal protection.
Compliance and enforcement
initiatives should target facilities and
sites that foster the adverse conditions
occurring in minority communities.
  EPA's current guidelines for cancer
risk assessment, and the way that they
are used in many programs,  protect the
average white adult male but ignore
populations that are more at risk
because of  increased exposure or
special vulnerabilities, such  as Native
Americans who fish to put protein on
the table and nursing mothers. The
Agency needs to adopt risk assessment
guidelines that consider economic
status, cultural factors, synergistic;
effects of exposure to multiple sources
of pollution, and other distinctive
characteristics that, cumulatively, can
result in disproportionate impact.
  In the routine course of seeking
amendments to improve environmental
statutes, EPA can support provisions
that ensure adherence to an  evaluation
process that would preclude any single
area from being burdened with an
undue share of polluting facilities or
sites. Pursuant to these amendments,
EPA would authorize only those state
programs that are designed to  remedy
disproportionate effects.
  An integral component of  any
Agency plan to execute these changes
in direction is overcoming the
perception commonly held by people
of color that EPA values corporate
interests and white middle and upper
classes over the lives of people of
color. Inevitably, for example, EPA's
response in relocating residents of
dioxin-contaminated Times Beach  and
Love Canal invites contrast to the
action taken by the Agency when
subsistence anglers in communities of
color around this nation were
discovered to be eating fish
contaminated by dioxin from nearby
pulp and paper mills. Instead of
becoming directly involved and taking
preventive action to end the pollution,
EPA adopted a hands-off attitude,
deferring action to the states. This
laissez faire approach allows states to
take actions that are often
contradictory and, at best, do no more
than simply warn these  people not to
eat the fish.
  Integrating the concerns of people of
color into the Agency's regulatory
process will lessen the sense that EPA
pursues a biased approach to resolving
risk. A key element of this integration
involves recruitment and promoting
workforce diversity. Segregation in the
EPA workforce fosters bias in decision
making.
  What is ultimately at stake in the
environmental justice debate is
everyone's quality of life. The goal is
equal protection, not equal pollution.
Daily, Americans are subjected to
harmful contamination—sometimes at
highly toxic levels—wildlife is
disappearing, and entire ecosystems
are being destroyed. In the metaphor of
a rapidly sinking ship, we're all in the
same boat and people of color are
closest to the hole. EPA and other
federal agencies must concentrate
foremost on saving those around the
hole; then, plug the leak and save us
all. a
MARCH/APRIL 1992
                                                                                                                 29

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                                                                           by Representative
                                                                           Ronald V. Dellums
The Need for New Legislation
I  find it very interesting that when
  Americans discuss the issues of the
environment, we tend to mean the
pristine air of Montana, the beautiful
waters of Crystal Lake, and the
spiraiing mountains of the High
Sierras. Still others may think about
the impending effects of global
warming, the necessity of recycling, or
preserving ancient forests as the
critical environmental issues of our
time. Conspicuously absent from the
discussion are the issues that concern
minority communities throughout
America.
  African Americans and other
minority peoples are now suffering
severely from the effects of
environmental degradation. Recent
studies indicate a sharp rise in health
problems caused by polluted air,
ingestion of lead, and polluted water;
they point to cancers possibly caused
by toxic and hazardous wastes. At the
same time, minority communities
suffer from other environmental
problems. The problems of drug abuse
and poor housing must be addressed.
  As America moves into the 21st
century, environmental concerns
become an imperative for constructive
legislative and citizen action. I am
dismayed by the fact that,  although
Americans are very concerned  with
environmental policy in general,
insufficient attention is paid to the
environment and its effects on
minority communities.
  In light of these circumstances, last
October in Washington, DC, the first
National People  of Color
Environmental Leadership Summit
was organized to focus specific
attention on environmental problems

(DelJums (D-California) is Chairman of
the Committee on the District  of
Columbia and a member of the Armed
Services Committee and the House
Select Committee on Intelligence.)
and their effects on "people of color."
The conference was the culmination of
work and research that started with the
release of the report called Toxic
Wastes and Race, published by the
Commission for Racial Justice in  1987.
As described in earlier articles, this
report revealed several startling
statistics which indicated that
minorities were disproportionately
affected by environmental problems.
The report, in turn, was followed in
1990 by the published Proceedings of
the Michigan Conference  on Race and
the Incidence of Environment Hazards,
which further revealed that little
attention was given to the
environmental concerns of minorities.
  The conveners of the conference,
known as the Michigan Croup,
subsequently approached my  office to
suggest that the Congressional Black
Caucus (CBC) convene a workshop at
its annual Legislative Weekend to
discuss problems  of the environment
and its impacts on the minority
community.  I agreed, along with
Representatives Towns of New York,
Conyers of Michigan, and Lewis of
Georgia, to sponsor a workshop to
begin the process  of finding strategies
to combat situations that exist in
minority communities across America.
  Simultaneously, the Michigan Group
approached EPA,  requesting that  the
Agency establish an initiative to
address  environmental justice (equity)
issues. Upon learning of the Michigan
Group's effort, 1 joined several of my
CBC colleagues in a letter to
Administrator Reilly, requesting that
he respond favorably to their  request.
  For many  years I have expounded
my belief that environmental concerns
are not solely the  interest of white,
middle-class America. Toxic waste and
pollution, like nuclear weapons, are
equal-opportunity killers.
Unfortunately, minorities are now
coming to believe that the environment
is of interest because of the
disproportionate impact  it is having in
our communities. I look  at report after
report that outlines the health
problems faced by minorities because
of lead poisoning, toxic and  hazardous
waste problems, polluted air, and
pesticides. I am now encouraged
because many efforts to correct the
prevailing situation are being
undertaken.  Grass-roots organizations
throughout the country are also  raising
issues of environmental  improvement.
EPA's February 1992 report on
environmental equity is  only a first
step toward  examining and resolving
these critical issues.
  I  believe that Congress must act now
to ensure that the disproportionate
impact of environmental degradation
upon minority communities  is
addressed. The reauthorization of the
Resource Conservation Recovery Act
(RCRA) provides an excellent
opportunity to strengthen the country's
toxic and hazardous waste law.  There
are  additional proposals  that will
further strengthen toxic and  hazardous
waste laws. The Community Right to
Know More  Act of 1991  would amend
RCRA to expand public reporting on
toxic chemical use and emissions and
require companies to develop
use-reduction plans. The Pollution
Prevention, Community  Recycling, and
Incinerator Moratorium Act would
amend RCRA to place a  moratorium on
the  construction of new  incinerators
until waste prevention programs are
fully implemented. I  support both
these bills because I believe  that they
can help reduce the incidence of
environmentally related  health
problems in minority communities.
  In addition, I have introduced the
Emergency Climate Stabilization and
Earth Regeneration Act of  1992.  This
bill provides a new impetus  to develop
a U.S. integrated jobs program covering
social,  pollution, and climate
 30
                                                                                                     EPA JOURNAL

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                                                                                             Leaders rally on Capitol
                                                                                             Hill during the First
                                                                                             National People of Color
                                                                                             Environmental Leadership
                                                                                             Summit.
                                                                             ttabf.il 13. Dullard photo.
emergencies. It would also reduce the
level of carbon dioxide in the Earth's
atmosphere through a massive jobs
program that would address all areas
of pollution in America.
  I will also consider supporting or
introducing legislation to address the
issue of the disproportionate numbers
of toxic and hazardous waste facilities
located in or near communities of
color. I am currently in the process of
examining several proposals that will
suspend the placement of toxic waste
facilities in minority communities.
  We must allocate funds to problems
where  they are most severe. I support
efforts  to expand Technical Assistance
Grants that encourage the growth and
expansion of grass-roots organizations
which  provide education and
information on environmental hazards
to communities of color. Grants  should
also be made available to Historically
Black Colleges and Universities  to
foster research and development in
areas of concern and for other
purposes.
  It is imperative that EPA establish a
department-level office that can
coordinate and enforce the issues of
environmental equity. The Agency
announced in its recently released
report that the issues of environmental
equity are a priority. If so, then
adequate funds should be requested to
set up an office that can be responsible
for issues of environmental concern.
  As I said earlier, the issues of the
environment are among the most
critical for our nation as we approach
the 21st century. We are all familiar
with the problems of global warming,
climate  change, clean air, clean water,
and safe drinking water. It  is time the
nation woke up to the reality that
minority communities are suffering
greatly at this moment from the
adverse effects of pollution,
unrestrained  development, and false
progress.
  America has a serious job to do if it
is to ensure that all of its citizens
benefit from efforts to enhance
environmental quality. We must begin
immediately to address all the
problems caused by environmental
degradation. I am calling upon all the
major environmental organizations to
get involved in the environmental
justice movement so that we can
ensure a healthy, sound America for
all citizens. I am hopeful that one day
soon the term "environment" will no
longer be considered just a term of,
and for, white middle-class America,  n
  MARCH/APRIL 1992
                                                                                                                 31

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                                                                        in
                                                                           Some observers argue that the
                                                                           environmental movement in the
                                                                           United States has not only /ailed to
                                                                           include the participation of people of
                                                                           color but also has /ailed to provide
                                                                           them ivith an equitable share of its
                                                                           benefits. Others maintain that the Jaws
                                                                           enacted in the ivake of Earth Day 1970
                                                                           are colorblind, that the  e//orts to clean
                                                                           up the air and clean  up  the water have
                                                                           bene/itted everyone equally. EPA
                                                                           Journal asked a number  of individuals
                                                                           to respond to the /allowing question:
                                                                           Have minorities benefited equitably
                                                                           from the gains made  by the
                                                                           environmental movement? Their
                                                                           answers follow.
                                                                           Michel  Gelobter
                                                                                Pe answer is clearly no.
                                                                                 There are at least three ways to
                                                                           measure the benefits of the
                                                                           environmental movement to people of
                                                                           color: socially, economically, and
                                                                           environmentally.
                                                          Copyrighl Son, Kitln«r.
                                                                                        aspects of the
                                                                           environmental movement have, almost
                                                                           without exception, systematically
                                                                           excluded people of color. People of
                                                                           color are underrepresented at
                                                                           managerial and decision-making levels
                                                                           of both governmental and
                                                                           nongovernmental environmental
                                                                           organizations, including my own.
                                                                           Academic "feeder" programs in
                                                                           environmental science and policy fail
                                                                           to recruit and retain people of color,
                                                                           and environmental organizations fail to
                                                                           hire those who do pursue such studies
32
EPA JOURNAL

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(primarily Chinese- and
Japanese-Americans). Finally, the jobs
and contracts generated by
environmental activity have fallen
primarily to white workers and
contractors.
•  The economic effects of
environmental policy are almost
always regressive (in that they fall
more heavily on low-income groups
than on people in middle- and
high-income brackets). The lack of
attention to the distributive
consequences of environmental policy
also disproportionately impacts people
of color.
•  Finally, the existing evidence
points to great disparities in the
incidence of environmental quality.
People of color have radically less
access to this country's natural areas,
and, in our urban environments, face
greater pollution. Most disturbing is
the evidence that government
regulation exacerbates rather than
reduces these inequities. In both my
own research on air pollution and the
Commission for Racial Justice's work
on toxic waste sites, regulatory
activity—in its efforts to control and
improve the environment—seemed to
shift the remaining burden of pollution
more heavily on the backs of
communities of color.

   People of color are a  majority on the
globe we all want to save. The
environmental movement  must
radically retool its approach to
understand, to share, and  to address
all our needs.
(Gelobter is Assistant Commissioner of
Environmental Quality for the
Department of Environmental
Protection of New York City.)
Michael Fischer


  It is an incontestible fact that people
  of color and the poor of America
have borne the brunt of suffering from
polluting industries and other
undesirable development. Whether
intended or not (and too often it has
been intended), economic growth and
land use decisions have been based on
environmental racism. Civil rights
have been violated; the quality of
human life in urban communities has
been degraded; adjacent communities
and downstream ecosystems have been
egregiously damaged.
   We at the Sierra Club do know how
to make a difference at the local, state,
and national levels. For 100 years, the
Sierra Club has honed citizen  action
skills to pressure polluters, elected
officials, and government agencies to
pass and enforce environmental
protection laws. The time, though, for
patience, compromise, and "balance"
is long gone.
   Thousands of community-based
grass-roots organizations,  led by  people
of color, have been established in
recent years. They possess a deep and
righteous anger not seen since the
beginning of the civil rights movement.
It is a just passion which  now must
drive the Sierra Club and other
organizations of the established
environmental movement. Our mission
has been broadened, and we have been
pushed to new heights of commitment
and effectiveness in order to meet the
challenges of environmental injustice.
   The environmental  movement of the
1990s will be multicultural. It will
continue to revere and protect natural
and scenic beauties of the Earth. And
it will be driven by a quest for
environmental justice, or it will
become irrelevant. We at the Sierra
Club are committed to beginning our
second century with increased, not
decreased, relevance for all the people
of this  nation.

[Fischer is Executive Director of the
Sierra Club.)
Juana Beatriz Gutierrez
     No, minorities in East Los Angeles
     have not benefited from the
environmental movement. Although
the Mothers of East Los Angeles
participated in the 20th anniversary of
Earth Day, our own environmental
movement is just beginning. The
amount of environmental abuse
suffered by residents of our barrios is
just too great. And the abuse
continues. High  lead levels and high
concentrations of carbon monoxide are
directly attributed to those freeways so
enthusiastically built for "progress."
  Virtually every family in L'os
Angeles can claim  a tragedy of one
form or another. Asthma, leukemia,
lingering coughs, and more serious
illnesses are now believed to be a
direct result of our environment, even
though the government will not admit
to it. Closer to home, three young
women experienced miscarriages in
the last two years—one of them my
  MARCH/APRIL 1992
                                                                                                                33

-------
daughter, another my daughter-in-law.
And the uncle of my daughter-in-law
succumbed to a brain tumor—his
residence was directly next to a
"Superfund"  toxic clean-up site.
  Only recently have we begun to
educate ourselves about the horrors of
environmental racism. With recent
assistance from environmental groups
such as Greenpeace and other
"traditional"  pro-active organizations.
we have begun a crash  course on
environmental impact statements, risk
assessments,  public hearings,  etc. This
knowledge has helped us the  last few
years and  will be invaluable as we try
to right the wrongs of the past. The
fact that this  commentary is written  in
English and not Spanish is an
indication of the exclusive nature of
the environmental movement, but we
are striving to change that.
(Gutierrez is  President of the Santa
Isabel Chapter of the Mothers of East
Los Angeles.)
Gail Small
     Since 1492, little has changed in
     terms of the non-Indian's concept
 of the environment. What they have
 failed to learn over 500 years is that
 there is a profound spiritual dimension
 to the environment. Religion, culture,
 spirituality, environment are one and
 the  same; to Indian people.
   Existing environmental  laws are not
 being implemented to protect the
 sacred places of Indian tribes. Indeed,
 we often find ourselves fighting
 environmentalists to protect our
 ancestral lands and treaty rights. In
 order to protect our sacred places,  we
 are  now asking Congress to amend the
 Indian Religious  Freedom Act, and the
 •LI
environmental movement should be
fighting this battle with us.
  My home, the Northern Cheyenne
Indian Reservation, is being
surrounded by this country's largest
coal  strip mine. The Cheyenne people
have had to forego basic services, such
as schools and roads, because our few
dollars have been used to fight for the
environment of southeastern Montana.
In 1982, when Secretary of Interior
James Watt permitted the largest
federal public coal sale in the history
of America, where were  the big 10
environmental groups? Perhaps it was
because only a few thousand Cheyenne
Indians lived in this area that none of
the "big 10" challenged this giveaway
of public coal.
  White ranchers who proclaim
themselves environmentalists sit  on
the same bank board that refuses  to
provide Cheyennes with loans for
economic alternatives to the strip
mining of our lands.  These white
environmentalists want Cheyenne
water and land to expand their
ranches. And the coal
companies—they just want our coal.
  And where is our federal trustee, the
EPA? It's still trying to figure out
whether Indian tribes have the
jurisdiction to protect their homelands.
That's like asking the Cheyenne who
won the Custer Battle. Such it  is in
Cheyenne Country in 1992.
(Small is the Director of Native Action,
a nonprofit organization to benefit  the
Northern Cheyenne.)
Alex  Varela
several EPA employees wrote a letter
to the Editor identifying major
inequities in EPA policies. With the
advent of a major national summit
conference in Washington in October
1991 on environmental equity (which
EPA declined to attend) and a House
hearing by Henry Waxrnan, the
question  is now beyond my opinion,
or any other, in the Journal
  This issue is now at a juncture
where it will become a moral issue for
the  Agency if EPA declines to
acknowledge the problem, change
inequitable policies and priorities, and
implement appropriate action. If EPA
decides merely  to pursue attempts to
co-opt legitimate civil rights
organizations, offer grants to minority
academics, and  spin-control the issue,
we  will continue to end up in an
ethical struggle  on the wrong end of
the  scales of environmental justice. I
believe our Agency has more sense
than this.
(Varela is in EPA's Office of
Enforcement Policy.]
                                                                             Terry Ow-Wing
     My answer to this question is the
     same now as it was in the May
1988 issue of EPA Journal, when
                                                                                               '
      My first reaction to the question is
      to pose another: Have minorities
shared equitably in any situation
where there is a majority and a
minority culture? The answer is an
obvious no. However, dwelling on the
negative  is not where the real answer
lies. Rather, we must take action  to try
to make life better for all of us.
  From my own story, I decided  to
contribute my talents to Chinatown,
feeling that few outsiders cared about
her. In 1976, through  a University of
California at Berkeley community
design course, I interned with the

                         EPA JOURNAL

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Committee for Better Parks and
Recreation in Chinatown. My first
contact with Sierra Club was through
its support for a new Chinatown park.
The Club's participation was not
earth-shattering, but it showed a
serious commitment to the urban
environment in which the minority
community lived.
  Recently, I became involved with
Sierra Club because it has political
clout, which I intend to use to benefit
Chinatown, and because many Sierra
Club members care about the urban
environment. Further, I wanted to
make important changes within the
organization.
  The long road of change for Sierra
Club is not only in its membership,
which is mostly white upper-middle
class, but in how it handles issues.
The environmental movement needs to
take  into account the needs of the
entire population. It must not shirk
responsibility for a particular
community's environment on the
grounds that "they need" the jobs.
Although it is true that the movement
did not begin with equal  concern
about "wild" versus urban
environments, I am pleased to find
that some mainstream environmental
groups are now working with
communities to eliminate toxins in
urban areas. Because the  air we
breathe is shared equally by all, we
must work together to cleanse our
Earth for everyone and not waste
energy on past inequities. How we
respond to this challenge will
determine whether we preserve the
lifeline of the Earth.
(Ow-Wing, an architect, is co-chair of
Sierra Club's Ethnic and  Cultural
Diversity Task Force and on the
Committee for Better Parks and
Recreation in San Francisco's
Chinatown.!
Senator Daniel K. Inouye
    The civil rights movement gave birth
    to laws intended to grant
minorities the same powers, privileges,
and protections accorded other
Americans. The environmental
movement inspired statutes meant to
benefit all Americans, regardless of
race or income. Despite these
progressive laws, inequities remain.  A
case in point: American Indians lack
the power and means to deal with
solid waste disposal problems on their
own tribal lands.
  Like state and local governments
across the country, tribal  governments
are confronted with a mounting crisis
in solid waste disposal. In Indian
territory, there are  currently 650  solid
waste disposal sites. Of these, 108 are
tribally owned landfills that were
constructed before  Congress
established current standards for
landfills under the Resource
Conservation and Recovery Act
[RCRA); as a result, only two of these
108 are presently in compliance with
EPA requirements  under RCRA.
  Based on a preliminary estimate
made in 1990, at least $68 million
would be required  to upgrade these
tribally owned landfills to meet
current requirements. In addition,
another $45 million would be required
to either upgrade or close, as
appropriate, other solid waste disposal
sites on Indian lands.
  A bill is now before Congress to
amend RCRA and empower tribal
governments to manage solid and
hazardous waste on Indian lands. It is
important to note that other federal
statutes include provisions stipulating
that tribal governments should receive
the same treatment as states, whereas
RCRA currently does not. The
proposed amendments to RCRA would
not only recognize  tribal governments'
authority but also make them eligible
to receive funds to assist them  in
developing solid waste management
regulations. Such regulations would
accomplish several things: provide for
the management  of waste generated on
reservations; authorize the cleanup of
open and unauthorized dump sites;
and enable the development of
regulations governing the operation of
commercial solid waste projects on
Indian lands.
  It is my hope that Congress and the
nation will act to rectify this and other
environmental inequities in the United
States.
(Senator Inouye (D-Haivaii) is
Chairman of the Select Committee on
Indian Affairs.J
Suzanne Olive
                                                                              In its issue commemorating the 20th
                                                                              anniversary of Earth Day, EPA
                                                                            Journal spoke volumes about the state
                                                                            of affairs in 1970. The only people of
                                                                            color in the entire issue were a lone
                                                                            American Indian and the inhabitants
                                                                            of a Chinese village. Change has come
                                                                            slowly. While the environmental laws
  MARCH/APRIL 1992
                                                                                                              35

-------
may be colorblind, many of the
conditions which gave rise to the
disparate impact of environmental
problems on minority communities are
not. Colorblind solutions will not solve
these problems.
  The focus of the civil rights
enforcement effort, from about 1970
until recently, was on problems of
equal access and nondiscriminatory
administration of federally assisted
programs. Although the term was not
in use, the environmental equity issue
was nevertheless there. In the wake of
much criticism, certain federal
agencies began to address, within their
areas of jurisdiction,  the issue of
disparate impacts of  federally funded
programs on minority
communities—e.g., the Department of
Transportation and the location and
impact of the interstate highway
system; the Department of Housing
and Urban Development and the
location of low-cost and subsidized
housing projects.
  Until the mid 1980s, EPA's primary
concern in terms of civil  rights
enforcement was the construction
grants program and the racial
composition of the communities to be
served by wastewater treatment
systems. The problem of  minority
communities' exclusion from that
program due to geographical or
political boundaries  was  largely
eliminated some time ago. However,
other problems, affected by a wide
range of EPA programs, remain.
  As people become more
sophisticated about environmental
issues, they are also  becoming more
aware and more critical of the
disparities in the benefits of
environmental programs. As a result.
EPA is now looking  at the
environmental equity issue and the
impact of environmental  programs
from a broad policy  perspective. EPA's
Office of Civil Rights has a role to play
in exploring ways to use the
crosscutting civil rights statutes to
address the inequitable effects of
environmental policies on minority
communities and bring about
significant change.
(OJive is Acting Director of EPA's
Office  of Civil Rights.)
Beverly Wright
   Just recently, I was asked by the
   U.S. Commission on Civil Rights to
testify at an environmental equity
hearing conducted by the Louisiana
Advisory Committee to the
commission. My charge was to present
an overview of social justice issues
related to the environment in
Louisiana. I was asked specifically to
respond  to the question whether
hazardous waste storage, disposal, and
treatment practices impacted with
greater frequency and intensity on
minority communities. The difficulty
in answering this question—indeed,
the fact that the question was being
asked—reflects the relative lack of
attention government has given to
possible  environmental effects on
minority communities.
  A similar dilemma presents  itself
when I attempt to answer the question
posed for this forum: Have minorities
shared equitably in the benefits
resulting from the environmental
movement? If the answer lies in the
present state of affairs for minority
communities as to exposure to toxics
in the environment, the answer must
be a resounding "NO."
  As most of us are already aware, the
1983 Ceneral Accounting Office report
and the 1987 study conducted by the
United Church of Christ  strongly
suggest that minorities (blacks and
Hispanics) are disproportionately
impacted by the siting of hazardous
waste landfills. It does not take an
extraordinary intellectual effort to
surmise  that this  pattern may be
indicative of patterns for other
environmental  pollutants. For a very
long time, minority and poor
communities have been the prime
targets for undesirable byproducts of
industrial society. These
neighborhoods are seen as the paths of
least resistance for such things as
bridge or highway buy-outs, toxic
waste and solid waste landfills,
incinerator and chemical  plant
locations, to name a few.  Unlike the
middle and upper socioeconomic
strata, who possess the resources to
effectuate their opposition to the
placing of pollutants in their
neighborhoods, poor communities
have been less likely to forge
successful battles of resistance against
federal, state, and local agencies and
industries who target their
communities for the siting of
undesirable "but necessary" polluting
facilities.
  A review of the history of
mainstream environmental
organizations and their programs fails
to produce any significant involvement
by them of minority groups or
individuals and almost no attention to
pollution problems specific to minority
populations. Only recently  have we
seen minority groups and communities
embraced (with some difficulty) and
allowed to have a voice in areas
related to the environment. The results
have been that minorities have not
shared equitably in the benefits
resulting from the environmental
movement.
  It is now time to forge an Agenda for
Action. A highly innovative approach
for dealing with  equity issues has
emerged  from a number of minority
researchers and scholars
independently investigating equity
issues. They have proposed the
development of a National Agenda on
Environmental Equity and the
establishment of Environmental Equity
Regional Centers to deal with research
and policy, community assistance, and
education. This would represent a
positive step toward  the development
of a "clean" environment for all, with
the ultimate goal being Environmental
justice.
(Dr. Wright is an environmental
sociologist with the Sociology
Department of Wake Forest University,
North Carolina.]
36
                                                                 EPA JOURNAL

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     lat's
     iat's
                                                                     Inner-city residents may
                                                                     experience elevated
                                                                     exposures (o
                                                                     environmental hazards.
                                                          Steve DeJant;y photo.
MARCH/APRIL 1992
                                                                                    37

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Minorities and the  Poor Clearly Are More  Exposed
EPA lexicologist examines (rout at
f)ukith, Minnesota, research lab.
Roger I^'Pa^e piiufo. AScI Corp
                                                                              by Ken  Sexton
                            The suggestion that social class or
                            race plays an important role in
                        determining the degree to which
                        people  are exposed to environmental
                        hazards, as well as in influencing the
                        effects of those hazards on health and
                        well being, is a disturbing, albeit all
                        too plausible, hypothesis. It does not
                        take much imagination to speculate
                        that poor people, a disproportionate
                        share of which are minorities,
                        routinely encounter elevated levels of
                        pollution in the air they breathe, the
                        water they drink, and the food they
                        eat.
                           Within the field of environmental
                        health,  there are two groups generally
                        considered to be at higher risk: those
                        who experience the highest exposures,
                        and those who are more biologically
                        susceptible to the  effects of a given
                        exposure. The subgroup at highest risk
                        is made up of those individuals who
                        are both biologically susceptible and
                        who also come into contact with the
                        highest pollutant concentrations.
                           Currently, very little  data exist on
                        differences between races according to
                        biological susceptibility to
                        environmental pollutants. There is
                        certainly  evidence of biological
                        differences, but their relationship to
                        susceptibility is not well understood.
                           Further, it is difficult to separate the
                        effects of class (socioeconomic status)
                        from the  effects of race (ethnicity) on
                        environmental health risk. Poor
                        people, typically, are less well
                        informed about environmental health
                        issues,  lack adequate health care, have
                        a substandard diet, and are more likely
                        to have stressful and unhealthful
                        lifestyles. Minority populations may be
                        at higher risk as a result of their
                        genetic makeup, cultural beliefs and
                        practices, and social behaviors. The
                                                                              (Dr. Sexton is Director of EPA's Office
                                                                              of Health Research.)
38
                                                                                                      EPA JOURNAL

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situation is complicated by the fact
that minorities are statistically more
likely to be disadvantaged in terms of
their income, education, and
occupation than their white
counterparts. Consequently, although
there is substantial anecdotal and
circumstantial evidence suggesting that
class and race, "taken together, affect
exposure levels, we do not now have
sufficient data to differentiate between
the two.
  The.calls for public action to
mitigate environmental inequities
present policy makers with a familiar
dilemma. In the face of substantial
scientific uncertainties, they must
decide whether inequities exist, how
serious they are, what are the causes,
and what are the most cost-effective
mitigation strategies.
  As documented elsewhere in this
issue of the Journal, there is clear
evidence that certain groups—as, for
example, subsistence fishermen,
migrant farm workers, and residents of
inner urban  areas—experience elevated
exposures to hazardous environmental
pollutants. It is unclear, however,
whether these exposures account, in
part, for the higher overall rates of
death and disease observed among
disadvantaged groups and ethnic
minorities.
  There are  clear and dramatic
differences between ethnic groups for
both disease and death rates.
Age-specific death rates, for example,
are higher for African American males
and females than for their white
counterparts in all age groups from 0
to 84 years of age. Furthermore, overall
death rates from cancer are greater in
blacks  than whites for both males and
females. For other ethnic minorities,
the overall cancer mortality is lower
than for whites.  There is, however,
substantial variation in the mortality
rates associated with different types of
cancer.
  Surprisingly, very little data are
available on disease and death rates
categorized by important
socioeconomic variables. Closer
examination reveals that the United
States is the only western country with
a high standard of living whose
government does not collect mortality
statistics by class indicators, such as
income, education, and occupation.
  Recently, there has been an
academic  debate about whether the
 With the notable exception of
lead, there is a paucity of
data relating class and race
to specific environmental
pollutants and associated
nealth effects.
differences in cancer rates between
blacks and whites can be explained  by
the effects of poverty. Some scientists
believe that if the differences in
socioeconomic characteristics could be
eliminated, then blacks would actually
have a lower overall cancer rate than
whites. Others suggest that while
poverty and lifestyle can explain part
of the difference, there is still a
significant amount of variation that
can only be explained by race.
  The observed differences in the rates
of disease and death among ethnic
groups are undoubtedly caused by a
combination of factors, including
economic, social, cultural, biological,
and environmental variables. Although
some of the differences are dramatic,
as with cancer rates, for example,  the
contribution of environmental
pollution is unclear.
  With the notable exception of lead,
there is a paucity of data relating class
and race to specific environmental
pollutants and associated health
effects. In the case of lead, the
evidence is unequivocal: A higher
percentage of black children than
white children have elevated blood
lead levels. All socioeconomic and
ethnic groups  have children with lead
in their blood  high enough to cause
concern about adverse health
consequences; however, a significantly
higher percentage of black children
compared to white children, regardless
of socioeconomic strata, have
unacceptable levels of lead in their
blood.
   In general, it is not  possible based
on the existing scientific evidence to
link class and race directly to
differences in  the rates of
environmentally induced disease or
injury. There is evidence, however, as
mentioned earlier, to suggest that
exposures to some environmental
pollutants vary according to
socioeconomic and ethnic variables.
These differences in exposures result
from the fact that disadvantaged
people, including ethnic minorities,
tend to come into contact with higher
pollution levels because of where they
live, what they eat and drink, and how
they earn their living. The available
scientific basis for evaluating the
equity question, although meager, is
sufficient to raise serious and
immediate concerns for researchers,
risk assessors,  and risk managers.
Owing to the complexity of
environmentally induced disease, it is
often difficult  or impossible to
establish a direct causal link with
pollutant exposures. Nevertheless, the
evidence suggesting that poor people
and ethnic minorities  experience
higher exposures to many
environmental contaminants is
compelling, o
MARCH/APRIL 1992
                                                                                                               39

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The Public Health Service Looks at Hazards to Minorities
                                                                             by Cynthia H.  Harris  and
                                                                             Robert C.  Williams
    he Agency for Toxic Substances
  '  and Disease Registry (ATSDR) is a
U.S. Public Health Service agency
headquartered in Atlanta, Georgia.
ATSDR was created to implement the
health-related measures mandated
under the Comprehensive
Environmental Response,
Compensation, and Liability Act of
1980 (the "Superfund" law). As part of
its response to this charge, ATSDR
established a minority health initiative
to address the health impact of
hazardous waste on minority
communities. The  initiative focuses on
four areas: demographics, health
perspectives, health communication,
and health education.

Demographics
To determine the proximity of
hazardous waste sites to minority
communities, ATSDR will utilize the
Geographic Information System (CIS).
A pilot  of five National Priorities List
(NPL) sites has been tested using both
manual and computerized
methodologies for  determining
population densities and
demographics. In addition, ATSDR is
currently using CIS to evaluate a
randomly selected  set of 30 NPL sites.
As a result of our pilot tests, we have
determined the CIS to be the best
methodology for identifying potentially
impacted minority populations.
   In the future, ATSDR will focus on
determining the relative proximity of
minority communities to all sites on
the NPL. Data for each site can then be
integrated into a larger database  and
analyzed using descriptive and
inferential statistical techniques. An
important data source for that
integration is the 1990 Census of
Population and Housing, which
includes 100 percent population and
housing counts and characteristics.
Other possible sources of data that will
be tapped include city directories (the
city directory often lists occupation
and is broken down alphabetically by
name and also by street  address), plat
maps in rural areas (plat maps indicate
ownership of land), the  county
courthouse (mortgage and other
housing information  might help
establish the variable length of
residence), and planning commissions
(building permits).

Health Perspectives
Health status and access to adequate
health care may contribute
significantly to the impact of
environmental contamination on
minority communities. Significant data
gaps exist regarding the relationships
between low-level exposures and
effects. For example, lead is a
pervasive contaminant that has
disproportionately affected minority
communities; however,  additional
research is needed to determine its
bioavailability in various media (water,
soil, slag)  and to further define effects
that may result from low-level
exposures (blood lead levels of less
than 10 micrograms per deciliter
  Through an extensive literature
search and the establishment of a
strong environmental health data base,
we have confirmed the paucity of
information specifically linking
pre-existing health factors and
increased  risk to environmental
contamination. ATSDR is therefore
sponsoring a substance-specific
research program through the
Association for Minority Health
Professions Schools (AMHPS).
ATSDR's public health studies  have
identified  specific sites adversely
impacting minority communities. The
impact of  lead in  soil (as high as
20,000 parts per million (ppm)) on  a
predominantly Hispanic community in
Colorado resulted in ATSDR's issuing
a public health advisory. In addition,
ATSDR and the state of Colorado
collected samples of blood to detect
lead levels in potentially exposed
susceptible populations (i.e., children,
pregnant women).
  ATSDR is currently conducting
various pilot and epidemiological
health studies for Native American
communities. Mercury contamination
in fish is a primary concern in the
Everglades (Florida), in Fond-du-lac
(Minnesota), and with the Puyallup
tribe (Washington).  The prevalence of
PCBs in the breast  milk of Native
American women of the St. Regis
Mohawk tribe (of New York) was
discussed during ATSDR's National
Minority Health Conference held in
December 1990. Consequently, a health
study is being sponsored by the
Agency. In addition, ATSDR has
signed an interagency agreement with
the Indian Health Service to address
the public health needs and concerns
of Native Americans as they relate to
the release of hazardous substances
into the environment.
  Lifestyle and culture can play
important roles. In conjunction with
the Connecticut Department of Health
and the Hispanic Health Council,
ATSDR helped identify the prevalence
of the use of elemental mercury
(azogue) for ritualistic purposes
(Santeria). Specific botanicas that sold
azogue were identified in the Hartford
area, and it was found that the most
prevalent users were within the
Hispanic community. The Connecticut
Department of Health  is determining
[Dr. Harris is Chief of the Community
Health Branch and Williams is
Director of the Division of Health
Assessment and Consultation at the
Agency for Toxic Substances and
Disease Registry in Atlanta, Georgia.]
 .10
                                                                                                    EPA JOURNAL

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how best to convey information
regarding the potential health hazards
associated with the use of the material.

Health Education and Communication
The toxic effects of environmental
contamination and environmental
health issues must be communicated
to minority communities. Such
communication can be aided by
training minority health care providers
in how to address environmental
health concerns.
  ATSDR is attempting to meet those
training needs and has developed and
implemented several health education
activities. For instance, ATSDR is
working closely with AMHPS schools
to identify and conduct pertinent
environmental substance-specific
research. ATSDR has also assisted in
establishing a doctoral program in
environmental toxicology at Florida
A&M University in which ATSDR staff
serve as advisory board members. In
many rural communities, pharmacists
are the first line of health care, so
ATSDR has identified minority
pharmacists as local health
professionals responsible for
identifying populations at risk and
communicating that risk to their
communities. The National Medical
Association (NMA) is one of the oldest
minority health care professional
organizations. ATSDR has become an
active participant in NMA activities by
conducting environmental health
workshops at regional NMA meetings
and presenting at national NMA
meetings.
  ATSDR also realizes that
communities want to be informed and
involved and has established
Community Assistance Panels (CAPs)
in several communities. The purpose
is to provide a forum for exchanging
information between ATSDR and the
affected community during the
preparation of a  public health
assessment or conduct a health  study.
For example, a CAP has been
established to address concerns
regarding environmental
contamination in the Southeast
Chicago area. The CAP members have
been active in assisting ATSDR
determine community concerns,
identify contamination sources,  and
disseminate information about
ATSDR's programs and activities. For
that site, CAP meetings will be held
quarterly throughout the public  health
assessment process. D
                                                                              Fishing opposite a dump in south
                                                                              Chicago. Inner-city residents may
                                                                              find environmental risks at every
                                                                              turn—including, here, a possible
                                                                              dietary risk from contaminated fish.
                                                              Copyright Sam Kiltner
MARCH/APRIL 1992
                                                                                                               41

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OF  I  JOB
Inner City Children
Suffer Most

by Joel  Schwartz and
Ronnie Levin
    To some extent, everyone is exposed
    to lead because industrialized
 society has widely contaminated the
 environment with it. Sophisticated
 geochemical  analyses show that lead
 contamination in the United States is
 hundreds of times higher than in
 pre-industriali/ed times. Moreover,
 lead contaminates every part of the
 environment—air, surface and ground
 water, soil—and each medium serves
 as a potential pathway of human
 exposure. Current body burdens of
 lead, on the average, are estimated to
 be 1.000 times higher than in
 prehistoric humans. Lead exposure
 and uptake are particularly
 problematic in children, who may
 suffer irreversible effects, including
 learning impairment, as a  result.
  But while everyone is exposed to
 some lead, lead has a very skewed

 (Schwartz is a Senior Scientist with
 EPA's Office of Policy, Planning,  and
 Evaluation. Levin is Chief of the Woter
 Staff, Office  of Technology Transfer
 and Regulatory Support,  in  the Office
 of Research and Development.)
profile of exposure and uptake by race
and social class—probably more so
than any of the other major pollutants
to which the general population is
exposed. Lead also differs from most
pollutants in another, more positive
respect: In the last  two  decades, we've
made the greatest progress in reducing
overall lead exposure. Still, while
exposures have been reduced  overall,
minority and  lower income children
retain a higher risk of elevated blood
lead levels, a  disparity  that has been in
evidence for decades.
  In the Second  National Health and
Nutrition Examination  Survey
(NHANES II), conducted between 1976
and 1980,  the average blood lead level
for children aged 6 and under was
found to be 16 micrograms  of lead per
deciliter of blood (jtg/dl)—which is the
most commonly  used standard
 Urban Children 0.5-5 Years Old with Elevated
 Blood Levels, by Race and Income
                       measure of blood lead concentrations.
                       For black children, however, the
                       average blood lead level was 21 (a.g/dl;
                       for children in the lowest fifth of
                       family income, 20 |o.g/dl.  Blood lead
                       levels were notably elevated for
                       children living in  inner city areas.
                       Poor  black children in the inner city
                       had an average blood lead level of 23
    Less than
    $6,000
S6.000 to    More than
$15,000
$15,000
  To put this latter figure in
perspective, consider that the Centers
for Disease Control recommended in
the 1980s that any child with a blood
lead level of 25 |xg/dl or higher be
given  a full-day test to determine
whether hospitalization was needed.
An even more dramatic comparison:
Recently, a child with a blood lead
level of 144 M-g/dl died from massive
brain  damage. In other words, poor
black  children in inner city
neighborhoods in the 1970s had
average blood lead concentrations
amounting  to over 15 percent of a
potentially  fatal dose. For no other
toxic substance in modern times has
the average exposure for a large group
been so close to the fatal dose.
  Fortunately, a great deal of progress
has been made in reducing blood lead
levels in  the United States, due in no
small  part to restrictions on lead  in
gasoline. More than half of the average
blood lead  level in U.S. children  in the
1970s was attributable to lead in
gasoline emissions. When unleaded
gasoline was introduced and the
amount of lead limited in leaded
gasoline, those emissions declined
dramatically. Lead in gasoline today is
less than half a percent of what it was
at its maximum,  and it will be banned
entirely in  1996.
  Other actions to reduce lead
exposures have also had a significant
impact, and continued improvements
are expected. For example, the Food
and Drug Administration (FDA) has
taken  steps to substantially reduce the
use of lead  solder in canned food,
 42
                                                                                                   EPA JOURNAL

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                                                     l-ead Free Kids photo.
formerly a significant source of lead
exposure. At present, average blood
lead level in American children  is
estimated to be under 6 pLg/dl,
considerably lower than found in
NHANES II.
  In addition, EPA recently issued
rules requiring water suppliers to make
their water less corrosive. Lead
contaminates drinking water when the
water corrodes the materials of the
public water system and  the plumbing
within the home; also when lead is
leached from the lead solder used to
join copper pipes, from lead pipes and
connections, and from faucets and
other plumbing fixtures. Therefore,
reducing the corrosivity of the water is
expected to significantly  reduce  lead
levels in drinking water.
  To date, the overall improvement
has been dramatic in that blood  lead
levels in every age, race,  sex, and
income category have decreased
throughout the country. Ironically,
however, the general decline appears
to have increased the disparity in
blood lead levels by race  and social
class. While income and  especially
race have always been  important
variables of exposure, we expect that
the  continuing decline in the blood
lead levels in the general population
will make race and income even better
indicators now than previously of the
likelihood of elevated blood lead
levels.
  The obvious question is, Why?
Gasoline, of course, was a lead
exposure source that affected the  entire
population.  Most of the lead particles
emitted from car tail pipes are quite
small, and their distribution across
urban areas  is relatively uniform.
Everyone breathes the air, and
everyone benefitted when lead was
curtailed in  gasoline. Similarly, most
of the population benefitted  when the
use of lead solder in canned food  was
eliminated.
  In contrast, exposure to lead paint, a
major remaining exposure pathway, is
much less uniform. Housing built
before 1950  is most likely to contain
paint with high concentrations of  lead.
After 1950, the lead content  of paint
declined substantially, and the use of
lead paint for houses was banned  in
the  1970s. Survey data from  the U.S.
Department  of Housing and Urban
Development (HUD) indicate that  90
percent  of housing built before 1940
contains some lead paint, as  does  62
percent  of housing built between 1960
and 1979. The survey assumes that
virtually no  housing built after 1980
                                                                    Normal hand-to-mouth activity of small
                                                                    children can poison them.
contains lead paint.
  Furthermore, older houses tend to
have paint with higher lead
concentrations: 75 percent  of the
pre-1940 housing had paint lead at
concentrations  higher than 2 ing/cm2
(double the level commonly defined as
indicating the presence of lead paint),
compared to only 18 percent of houses
built between 1960 and 1979.
Therefore, the presence of lead
paint—and the  concentration of lead in
the paint—varies widely from house to
house.
  But the mere  presence of lead paint
or even the concentration of lead in
the paint does not tell the whole story.
For one thing, the  condition of the
paint is critical. Lead paint that is well
covered with non-lead paint, and in
good condition, results in much lower
lead exposures  than exposed paint in
poor condition. Everyone knows about
children being poisoned by eating lead
paint chips. But that's not really
common. In fact, most cases of lead
paint poisoning seem to occur from the
ingestion of common household dust
that has been contaminated with lead.
The normal hand-to-mouth activity of
small children results in their
ingesting enough contaminated dust to
raise their blood lead levels and even
to poison them.
  In homes with lead paint in
deteriorated condition, the
concentrations of lead in the dust are
likely to be high. Adults as well as
children are exposed to dust—dust
that settles  on plates and glasses, dust
that contaminates carpets and
furnishings, dust that we breathe, etc.
More dust can mean  higher lead
exposures. Simply put, for the same
presence of lead paint on the wall,  the
degree of risk presented can vary
widely depending on how much
exposure there is—how deteriorated
the paint is, how much lead infiltrates
the house dust,  how much dust is
present, and what the activity patterns
MARCH/APRIL 1992
                                                                                                                43

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                                      For no other toxic substance
                                      in modern times has the
                                      average exposure for a large
                                      group been so close to the
                                      fatal dose.
are for children and other family
members.
  For all these reasons, exposure to
lead  from paint, unlike lead from
gasoline, is highly variable. Some
houses have lead paint; some don't.
Some buildings have lead paint in
poor condition. The more dilapidated
the housing, the higher the lead
exposures are likely to be. Housing
condition is largely a function of
income.
  Lead-contaminated soil is another
source of exposure, but again the
degree of potential exposure is highly
variable. Decades of lead  emissions
from gasoline now contaminate urban
soils, along with some deposition from
other sources of lead.  In older
residential areas, more than a century's
use of lead in exterior house paint has
raised soil lead levels.
  Soil contaminated by lead can be a
significant exposure source, especially
for children. And once more, the
exposure of poor and  minority
children is likely to be higher, both
because lower income and minority
groups are more heavily concentrated
in older urban areas and  because their
yards are more likely to have exposed
soil—in other words, less likely to
have ground cover, lawn  furniture,
swing sets, or other barriers to the soil.
So, again, even for the same
contamination level in the soil, lower
income children are likely to have
higher actual exposures. Of course,
higher lead levels in soils and more
exposed soil also increase the
likelihood of introducing lead into
interior house dust, another pathway
for lead exposure.
  There  are still other lead exposure
sources that disproportionately affect
lower income and minority groups.
One is occupational exposure. Several
surveys suggest that both groups are
heavily represented in jobs at risk of
having high occupational lead
exposures. These occupations include
construction, primary and secondary
smelting, automobile repair, welding,
and salvage work. Occupational
exposures in adults are often linked
with elevated lead  levels in other
family members, especially children.
Unfortunately, occupational!}' exposed
workers have not shown the same
overall decrease  in blood lead levels
that has been seen  in the general
population over  the past 15 years.
  Certain consumer products also
represent exposure sources that are
likely to affect specific ethnic groups.
Several studies have indicated that
some traditional  medicines, cosmetics,
and foods from a range of cultures can
contain high levels of lead, These
goods, along with ethnic and
handmade potteries that leach h;gh
lead  levels, can all be sources ol
increased lead exposure and even
toxicity. Brass and  especially bronze
are used for cooking and eating
utensils in several cultures; both alloys
can contain and  leach high levels of
lead.
  It is important to note that while
FDA has been successful in working
with the U.S. food  processing industry
to eliminate the  use of lead solder in
cans produced domestically, imported
cans are not  currently regulated in this
way. Some ethnic groups consume
significant quantities of imported
canned foods, and they are at risk of
higher lead exposure from  this source.
  These last points raise a  difficult
issue. Children or adults may have
elevated blood lead levels  both
because of higher environmental
exposures and because of behavior
patterns that increase  intake. The use
of certain traditional remedies or
canned foods with lead is one such
behavior pattern. The  degree of
hand-to-mouth activity or the
frequency of hand washing can
modulate exposures. Many other
factors can also affect  a child's
exposure to and  uptake of  lead from
the environment, including nutritional
status, eating habits, adult-to-chiid
ratio, etc. To be fully effective.
successful intervention programs must
target behavior as well as the physical
environment.
  Because of the factors  discussed in
this article, we expect that blood lead
levels have probably fallen by a
smaller than average percentage in
poor inner city neighborhoods and
among certain ethnic racial groups.
Equity considerations  are a major
concern with lead exposure, in part
because such exposure is associated
with increased risk of compromised
cognitive development and abilities
and resulting substandard school
performance. The inequity of imposing
such a burden on children of lower
socio-economic status and/or children
from disadvantaged  ethnic or racial
groups is obvious: It compounds their
burden by leaving them  with fewer
skills to overcome the disadvantages
that face them.
  By design, EPA regulations and
programs have thus  far aimed
primarily to reduce  the general
population's exposure to lead. The
Centers  for Disease Control and other
federal agencies are  now developing a
nationwide strategy  to address  lead
paint exposure, which is currently the
most important  exposure source. This
strategy specifically  targets lead
exposures predominantly affecting
children who are already
disadvantaged.
  EPA is participating in the
development and implementation of
the strategy in several ways: by
helping to design training programs for
lead  paint abatement workers, by
conducting research on innovative
approaches that can reduce the cost of
lead  paint abatement,  and by providing
technical assistance  to CDC and HUD
in designing their programs. If  fully
implemented, these  initiatives should
reduce the disparity in lead exposures
among the U.S.  population,  u
                                                                                                    EPA JOURNAL

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Grass-Roots   Groundswe
 In Detroit, neighborhood organizations plant frees in remembrance of
 young people who /wvo been killed in .street violence.

 MARCH'APRIL 1992
                                                                    by Norris McDonald
   The environmental status of
   minority communities in America
can be defined by the effects of the
dominant culture's practices of
consumption, competition, and
conquest. The dominant culture
conquered the Native Americans,
enslaved Africans, and competed
among its members for ownership and
exploitation of natural resources, thus
setting the tone for minorities'
environmental  circumstances today.
This is the context in which  minority
communities have experienced and
continue to face disproportionate
impacts from environmental  problems.
  Historically, America's dominant
culture has exerted ecological
dominance over minorities including
African Americans, Native Americans,
and Latino Americans. The record of
this dominance is familiar. Moreover,
the general  public is becoming
increasingly aware of the
environmental aspects of this legacy.
Environmental  racism and equity
issues are being articulated,
researched, and documented. The
challenge lies in where minority
communities go from here.
  In recent  decades, minority groups
have competed successfully for some
civil liberties. This achievement
significantly increased their freedom of
movement and  opportunity. However,
African Americans are still reeling
from the  effects of hundreds of years of
degradation. African Americans lead
the nation in virtually every health
risk category. American society is as
segregated as ever: There is a white
side and  minority side of town in
virtually  every major city in the United
States.
  Minority communities have been
                              45

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Grass-Roots  Groundswell
 and remain, in short, environmental
 dumping grounds. Will the dominant
 culture, which has not been known to
 redistribute natural resources to the
 benefit of minority groups, relinquish
 its control of such resources? Will the
 dominant culture clean up minority
 communities? Will it redirect the
 nation's vast resources in a massive
 environmental reclamation program in
 minority communities? Will it embrace
 minority cultures as its own and
 thoroughly integrate itself into these
 communities? History provides no
 precedent  for such occurrences.
 Therefore, minority communities will
 have to take the initiative  to eliminate
 environmental pollution by whatever
 means necessary.
   Some 20 years ago, comedian and
 nutritionist Dick Gregory noted that
 "America is insecure  ....  Americans
 will permit the continuation of a
 polluted system which makes billions
 of dollars through reckless pollution."
 Jazz musician Miles Davis addressed
 environmental issues in his
 autobiography: "[Pollution is
 everywhere. Polluted lakes, oceans,
 rivers; polluted ground,  trees, fish
 everything. I mean they're just ...  so
 greedy. I'm talking about whites who
 are doing this  . . . [to] the ozone
 layer."
   What can minority communities  do
 to reclaim their environmental
 destiny? Ultimately, minority
 communities have one of two choices
 for cleaning up their environments: (1)
 replace the dominant culture; or (2)
 clean up their own environments. The
 first choice is probably not practical or
 possible. The second choice is
 imminently practical and definitely
 possible. In fact, minority  communities
 must lead  the way in cleaning up their
 own communities. To the extent that
 the dominant culture is  willing or able
 to assist, so much the better.  However,
 minority communities cannot afford to
 wait for the dominant culture to "get
 environmental religion," so to speak.
   What will this minority
 environmental clean-up campaign look
 like? Minority communities neod to
 implement an all-out effort,
 comparable to but larger than the civil
rights movement of the 1960s, to clean
up the air, water, food, land, toxic
wastes, and toxic behavior. In addition
to cleaning up the neighborhood, this
effort will provide development,
employment, and economic power
within minority communities.
  Many urban minority communities
are located in areas that are
consistently in violation of the Clean
Air Act. Asthma is killing African
Americans in unprecedented numbers.
Black males in urban areas are five
times as likely to die from asthma as
whites in the same settings. Minorities
must eliminate ground-level ozone and
otherwise clean the air in their
communities. Lead poisoning is
causing  tragic disabilities among
minority children: The sources of this
lead contamination must be removed.
Minorities must clean up polluted
drinking water in their communities in
both urban and rural areas. They must
clean up the land and neutralize toxic
waste sites. Minority communities
must alter their food  consumption
patterns to improve health. Toxic
behavior—drug killings, addictive drug
use, and crime—must be significantly
reduced.
  Minorities do not own the refineries
or chemical facilities that have
produced the pollution dumped in
their backyards. Since they do not
have a vested interest in these
companies, minority communities are
in a unique position to lead the nation
toward implementation of appropriate
energy and manufacturing
technologies. There is an opportunity
to play a leadership role in fostering a
nonpolluting, innovative, competitive
economic renaissance.
  Environmental justice will be
attained as minority communities rid
themselves of pollution problems.
Environmental racism will become
irrelevant as environmental solutions
are adopted and maintained by
minority communities that are now
disproportionately polluted.
  There really isn't an alternative. The
very health and existence of some of
these communities are on the line. The
time has come to seize the
environmental initiative and clean up
minority communities by whatever
means necessary. The stories that
follow provide some examples of what
can be achieved when community
groups take the initiative on behalf of
their own environment,  u
(McDonald is President of the Center
for Environment, Commerce, and
Energy in Washington, DC.j
                                                    L
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By Jane  Kay
    Kettleman City, California. When a
    small group of Latino farm
workers refused to go to the back of a
hearing room to get testimony
translated into Spanish, they took a
first step in combating  environmental
racism.
  Like many other minority
communities around the nation, they
got angry and they got  even. To
anyone who would listen, they argued
that if a little town with a 95-percent
Latino population was  expected to
accept the state's first commercial
hazardous waste incinerator, then
government and industry could damn
well provide the environmental reports
in Spanish.
Copyright John W. h'mnions.
  On December 31, 1991, they won a
civil rights lawsuit filed a year ago in
the Sacramento County Superior Court
by a public-interest anti-poverty law
firm,  the California Rural Legal
Assistance Foundation. Judge Jeffrey L.
Gunther ruled that Kings County, in
the heart of the Central Valley, failed
to follow California law when it
prepared an environmental report on
Chemical Waste Management Inc.'s
proposed incinerator and rushed
approval through the board of
supervisors. The county didn't
properly analyze the impacts on air
quality, agricultural crops, and grazing,
nor did it analyze the cumulative
environmental and health effects from
the proposed incinerator, highway
traffic, and other sources, the judge
ruled.
  It was a strong victory for the little
community: The court agreed that the
Latino community had been left out of
the process that led to county
approval, the first step in siting the
incinerator.
  "The residents of Kettleman City,
almost 40 percent of whom were
monolingual in Spanish, expressed
continuous and strong interest in
participating" in the review process for
the Chem Waste facility, "just four
miles from  their homes," the judge
                                                               Latino (arm
                                                               workers
                                                               display signs.
wrote. "Their meaningful involvement
in the review process was effectively
precluded by the absence of Spanish
translation." Kings County was told to
do the report over, this time following
the law.
  The decision could delay the project
at least a year, even if the county or
Chem Waste appeals it. The facility
still must get state and federal permits.
  "This just goes to show that Latino
farm workers can be heard," said Mary
Lou Mares, a leader of El Pueblo para
el Aire y Agua Limpio (People for
Clean Air and Water), when she heard
the news. "The next step is a voting
drive to flex our muscles and get some
of these supervisors turned out of
office."
  Kings County assistant planning
director Bill Zumwalt was shocked
over the court decision.  "The
legislature has never passed a law that
requires environmental documents  to
be prepared in languages other than
English," he said. But times are
changing, and in many parts of the
country the days of empty hearing
rooms and uncontested decisions are
over. In California, Mothers of East Los
Angeles and Concerned  Citizens of
South Central Los Angeles—Latino and
African American groups—support the
Kettleman City protest, as do the
National Toxics Campaign and
Greenpeace, which first  alerted the
community to the hearings on Chem
Waste's proposed incinerator. In
March, Kettleman citizens hosted
residents of Tijuana who came for
information and  support. {Cattleman's
El Pueblo backs the Mexicans'
opposition to Chem Waste's opening a
new hazardous waste incinerator
across the border in Baja California
this spring.
  Armed with studies, minority
activists say they're bearing the
greatest brunt of  the nation's toxic
waste. And because they're powerless
and many times poor, they don't have
the clout to keep it out of their
neighborhoods or anyone else's. The
town of 1,500 has a 95-percent Latino
population. In 1980, the average family
income was $13,714.
  Chem Waste spokeswoman Sylvia
MARCH/APRIL 1992
                                                                                                               47

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Grass-Roots  Groundswell
 Vickers in Kettleman City says the
 waste sites are chosen because they're
 environmentally sound and not
 because of social conditions. "An
 understanding of the hazardous waste
 business shows that all of our facilities
 are based on environmental reason,
 Kettleman is one of the most ideal
 locations. It doesn't come in contact
 with usable ground water," Vickers
 said.
   The company's three other
 incinerators are located in  poor, black
 neighborhoods—Chicago's South Side,
 Sauget, Illinois, and Port Arthur,
 Texas. It also owns the nation's largest
 hazardous waste disposal and
 treatment facility, in  Alabama's Sumter
 County—nearly 70 percent black, with
 more than a third living in poverty.
   The fourth burner would be built
 here in Kettleman City to take up to
 100 million pounds of chemical wastes
 a year.
   Much of the opposition stems from
 Kettleman City's already playing host
 to the nation's fourth largest hazardous
 waste landfill, which is also operated
 by Chem Waste. Last year, Kettleman
 City residents were disappointed and
 angry when EPA approved a big
 expansion of the facility.
   The people feel they've taken their
 share of toxic garbage. "We don't feel
 that EPA is looking out for our
 interests," said Mares. "They come
 around all cooperative and seem very
 sympathetic. But the EPA  is the one
 that's pushing incineration. They don't
 stop giving out permits. So how can
 we believe them?" D
 (Kay is the environmental writer /or
 the San Francisco  Examiner. In April
 1991, she wrote a four-part series
 entitled "Toxic Racism.")
         by Linda  R. Prout
   They are named after a celluloid
   character of comic proportions, but
for the Toxic Avengers there is nothing
funny or fanciful about their fight  to
clean up their Brooklyn, New York,
neighborhood.
  For the last four years, this group of
Latino and African American high
school and college students has waged
a very real battle to rid Williamsburg,
considered one of New York's most
polluted communities, of hazardous
materials and of a company that
harbors them. They have lectured,
marched, and rallied and, in the
process, inspired other Williamsburg
residents to become environmental
activists.
  "The movement is going strong,"
reports 16-year-old Benny Vasquez, a
dedicated member of the Toxic
Avengers. "A lot more people are
getting involved in environmental
issues."
  The Toxic  Avengers' main target has
been the Radiac Research Corporation,
a company which stores and transports
toxic waste and low-level radioactive
and flammable materials. Their
                                              pholo. N'fiwsrlay.
                                                        Students in
                                                        Brooklyn, New
                                                        York, are waging
                                                        war on hazardous
                                                        wastes.
                                                  (Prout is a Jree-Iance journalist based
                                                  in New York.)
 48
                                                                                                    EPA JOURNAL

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                                                                                1PELE
demonstrations against Radiac have
attracted hundreds of participants.
  Radiac has been in Williamsburg for
more than two decades and has
consistently received a clean safety
report from the state's Department of
Environmental Conservation. But
Williamsburg residents have criticized
its location next to a public school
playground. The Toxic Avengers
contend that Radiac's presence in their
inner city neighborhood is an example
of environmental racism.
  "Most toxic sites are in poorer,
mostly minority communities," says
Vasquez.
  Williamsburg is a working class
neighborhood that shares a peninsula
in northeast Brooklyn with the
community of Greenpoint. Once
predominantly Jewish, today most of
Williamsburg's 40,000 residents  are
Latinos from the Caribbean and Central
America.
  According to  a report released three
years ago by the Community
Environmental Health Center at New
York's Hunter College, at least 28
facilities in the
Williamsburg-Greenpoint area stored
large amounts of toxic waste. Eleven  of
these facilities housed substances
classified by EPA as "extremely
dangerous" in quantities exceeding
government  recommendations.
  Adding to the health risks is
Williamsburg's location. The
neighborhood is crisscrossed by  the
expansive Williamsburg Bridge and an
elevated highway, two roadways
jammed day and night with cars
emitting toxic fumes.
  The Toxic Avengers meet in the
shadow of that expanse, at a
community center called "El Puente"
(Spanish for "the bridge"). The group
grew out of a course in environmental
science that Jose Morales, a lifelong
Williamsburg resident, was teaching
there in 1988. Sent into the streets to
research a class project, Morales'
students discovered an  empty lot
littered with drums oozing toxic
liquids. Environmental  agencies  were
called in to clean up. But there was
much more work to be done. Morales
invited other students to participate,
and the Toxic Avengers were born. He
named the group after a movie
character who fell into a vat of slime
and emerged a mutant crusader against
polluters.
  The group varies in size from a
previous high of 12 to its current eight
members.  But the young activists, aged
16 to  20, are constantly recruiting and
steadily taking on new projects. They
recently started a recycling program at
El Puente  and soon will take that
campaign  throughout the
neighborhood. They are starting
workshops to teach community
members that combating pollution
should be a priority just like fighting
against drugs and crime.
  And they have taken their message
on the road. These "environmental
ambassadors"  have traveled to
conferences around the country,
conducting workshops and serving as
role models for other inner city youth.
  "What we try to tell other young
people is that they have power, they
have the ability to change things,"
stressed Rosa Rivera,  21, a college
student and original member of the
Toxic Avengers.
  Group members are heartened to see
more  people of color  becoming
involved in the environmental
movement. It wasn't always that way.
  "The movement has been very
white," explained Rivera. "We would
go to  conferences and be the only
Latinos there. But slowly that is
changing."
  The Toxic Avengers have helped
that change come about in their own
community by printing all their
literature in both English and Spanish.
For their efforts, they have received
public service awards from the
Citizens' Committee for the City of
New York and from the  New York
Daily  News.
  "Groups like the Toxic Avengers  can
make  a significant difference," said
Democratic state legislator Joseph
Lentol, who represents the
Williamsburg-Greenpoint area.
  By educating their own community
and motivating residents to become
active in environmental  issues, they
already have, a
 by Rick Carroll
     Named for Hawaii's volcano
     goddess and sworn to protect the
 islands, the  Pele Defense Fund is a
 fiery, grass-roots organization with
 impact mighty as its namesake.
  It has thwarted the Aloha State's
 effort to tap  a live volcano and harness
 its steam in  a $4 billion, federally
 funded experiment in a rain forest on
 Hawaii, the  largest tropical island in
 the Pacific.
  Pele (pay-lay) is the legendary
 Hawaiian fire goddess who causes
 volcanoes to erupt. Despite 170 years
 of Christianity, many Hawaiians not
 only believe in Pele's power, they still
 worship her—and for good reason.
  Since January 3, 1983, Madame Pele,
 as she is known, has thrown  up
 enough red hot lava, it is estimated, to
 build a four-foot wide, four-inch deep
 sidewalk from Honolulu to New York
 every two days.
  The eruptions, still in progress,
 began soon after the first drills pierced
 the  east rifjt zone of 13,679-foot Mauna
 Loa; one eruption inundated  10,000
 acres of the original site with lava.
 Madame Pele was angry, Hawaiians
 said.
  A dozen outraged islanders first took
 up Madame  Pele's defense in 1982
 only to be dismissed as pot-smoking
hippies by the local media.
  "Nobody took us seriously at first,"


 (Carrol/, author of Great Outdoor
Adventures of Hawaii (Foghorn Press,
 San Francisco] covers Hawaii and the
Pacific for United Press International.)
MARCH/APRIL 1992
                                                                           49

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Grass-Roots  Groundswell
 said Ralph Palikapu Dedman, the
 founding president.
  Their cause was not immediately
 understood even in Hawaii, where
 fewer than 20 percent of the
 population is Hawaiian, because it
 recalled arcane  Hawaiian religious
 rites many thought abandoned.
  "We worship nature gods, like Pele,"
 Dedman said.
  This native Hawaiian belief, Dedman
 claims, has been "ongoing for
 thousands of years"—much like rites
 of native American Indians who find
 spirituality in nature.
  "The forest is to us like a cathedral
 to Christians," he said. "To poke holes
 in Pele is sacrilegious."
  In 1988, the Pele Defense Fund
 brought its cause to national attention
 in full-page ads in the San Francisco
 Chronicle and the New York Times.
  Claiming Hawaii would become an
 "industrial slum,"  the ads stressed the
 importance of native  religious rites and
 deplored the geothermal plant in the
 27,000-acre Wao Kele O Puna rain
 forest as "Ugly, Toxic, Costly &
 Sacrilegious." An illustration showed a
 "new" Hawaii jammed by high  rise
 hotels, its landscape marred by
 thousands of 10-story electrical towers;
 a geothermal plant pumps out volcanic
 steam to chill Waikiki's 50,000
 air-conditioned tourist hotel rooms 150
 miles away.
  Their mouse roar focused media
 attention on the struggle in the  rain
 forest between native Hawaiians who
 worship a fire goddess and wildcat
 drillers from Wyoming trying to plumb
 the world's most active volcano for
 steam.
  "It really changed the awareness,"
 Dedman said. "We are five thousand
 strong now. People from all over the
 world  support our cause."
  Ecology groups like the Sierra Club,
 Greenpeace, EarthFirst, and the
 Rainforest Action Network took up the
 defense of the Wao Kele O Puna (it
 means "green forest"), which is home
 to endangered Hawaiian birds,  insects,
 plants—and on occasion humans.
  "As  native Hawaiians, we are part of
 the ecosystem of these islands,"
 Dediuan said. "If we  are as important
as an endangered tree, environmental
groups should chain themselves to us
as much as they would a tree."
  For  Pele worshippers the battle to
save what the New  York Times called
"the last big tropical rain forest in the
United States" is still being fought in
state and federal courts.
  With legal  aid from the Sierra Club,
they won a federal court decision last
summer requiring an environmental
impact report before "a single penny of
federal money can be spent." Dedman
said.
  The U.S. Department of Energy
study  may take up to two years.
  The Pele Defense Fund called for a
boycott of Hawaii's products and its  $8
billion-a-vear visitor industry in 1988.
Struggle in (he rain forest.
Palikapu Dedman: "To poke boles in
Pele is sacrilegious."
        Anli-geothermal protests in Ha
                 draw many supporters.
 50
                                                                                                     EPA JOURNAL

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  The boycott fizzled, but the
hypocrisy issue—the United  States
condoned the demise of Hawaii's rain
forest while condemning Third World
nations for similar
destruction—surfaced on the desk of
Hawaii's  governor in the form of Good
Housekeeping Magazine's "Thumbs
Down" award.  "We delivered it
personally," Dedman said. "He was a
little embarrassed."
  An advocate of geothermal for
oil-starved Hawaii, the governor lost
political face again when his own  state
health director called geothermal "the
stupidest thing we could possibly  be
doing ... in the forest."
  Last summer, a test well exploded
and sent  people fleeing noxious gases;
the hazardous conditions forced the
state to shut down operations.
  It was the latest setback for the
haunted geothermal project. Or was
it—as Dedman and other native
Hawaiians believe—only Madame  Pele
voicing her displeasure once again? c

 by Michael Novick
  In March 1990, Dr. Russell Sherwin, a
  pathologist at the University of
Southern California in Los Angeles,
reported a study of autopsies  on 100
youths, mostly black and Latino, who
had died from nonmedical causes.
Eighty percent had "notable lung
abnormalities"; 27 percent had "severe
lesions." Had they lived, in 15 years
they would have been candidates for
lung disease.
  According  to Sherwin, "the danger is
above and beyond smoking or even
respiratory viruses .  . . much  more
severe, more  prevalent. These were
pretty young people  . . . running out
of lung." Sherwin tried to factor out
other elements that would have
contributed to the  lesions besides the
quality of the air. "The majority lived
in central L.A.," he noted, "a  lower
socio-economic area  that might present
other (contributing] factors."
  But the Labor/Community
WATCHDOG, a grass-roots^
multi-racial, working class L.A. group
focusing on air pollution, thinks you
can't isolate chemical factors from
other conditions facing communities of
color and working people. They just
published L.A.'s Lethal Air: New
Strategies for Policy,  Organizing, and
Action, showing how class, race, and
gender oppression intersect with toxic
air-borne chemicals and smog to put
the greatest burden of pollution on the
worst off.
  Recently, the WATCHDOG put
together the Social Equity Coalition to
seek amendments in  regulations of the
South Coast Air Quality Management
District (AQMD). The AQMD, a
regional agency operating under state

(Novick is Los Angeles Bureau Chief
for the Guardian News Weekly.)
and federal mandates to clean up
L.A.'s air, adopted a regulation
requiring employers to limit the
number of individual drives to work
by employees. This "trip reduction"
regulation was meant to reduce smog
from auto emissions. How would this
laudatory goal be reached? Many large
employers would simply impose
parking fees, on the theory that the
"market" would force workers to
carpool (while producing a tidy
income for the employer).
  The Social Equity Coalition
proposed requiring employers  to
consider the  differential impact of
their plans according to race, gender.
and income.  Saying that fixed  parking
fees to discourage driving placed a
disproportionate burden on lower
income employees, especially women
and minorities, they called for crafting
programs, like employer-provided vans
and on-site child care, which would be
more equitable yet more effective in
reducing unnecessary trips.
  At a hearing in December 1991, the
coalition arrived with about 75
demonstrators and close to 20
witnesses. Thanks to months of
previous lobbying by the coalition,
AQMD staff recommended adopting
part of the amendment, focusing on
income criteria. The coalition pressed
for the full package, giving worker
groups defined by race and gender the
standing to appeal discriminatory "trip
reduction" plans. Despite opposition
from employers and from other
environmental groups, the AQMD
Board, composed of representatives of
local governing bodies throughout
southern California, adopted the entire
proposal on a nine-to-two vote.
  Eric Mann, director of the Labor
Community Strategy  Center, of which
the  WATCHDOG is a project, attributes
the  victory to working simultaneously
on "inside" and "outside" tracks. "We
had a mass demonstration in March,
the  first big, noisy rally at the AQMD's
headquarters. Then we knocked their
socks off when we went inside and
presented articulate, scientifically
sound testimony from a broad array of
groups. The AQMD realizes that even
with its regulatory  powers, it depends
  MARCH/APRIL 1992
                                                                                                                   51

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Grass-Roots  Groundswell
on the voluntary compliance of
millions of individuals to make these
regulations work. Our coalition is the
only force organizing at the grass roots
around air pollution."
  The WATCHDOG wants
corporations which have profited from
pollution to pay to restore the air. It
wants the communities affected by
such  economic decisions to have a say
in making them. The project grew out
of the effort to keep General Motors
from  closing its plant in Van  Nuys,
California. According to Chris Matins
of the WATCHDOG, his experience as
an auto worker led him to  see the need
to revitalize the labor movement with
a broader social agenda that spoke to
his full identity as  a black  person, a
worker, and a community resident.
Mann and Mathis were led to focus on
air pollution by the realization that as
auto workers, they  were involved in
the release of toxics and other
destructive chemicals. The
WATCHDOG sees dealing with the
issue as a civic responsibility and as a
steppingstone to the empowerment of
workers and communities of color.
  According to Lisa Duran,
Coordinator of Education Services,
they "put forward a new organizational
model, based on conscious,
well-trained organizers who will
mobilize people into a multi-racial
membership organization" around a
long-range view. Duran emphasizes
they're organizing people around broad
social concerns, not just a desire to
keep toxics out of their own backyard.
"People move off a sense of justice as
well," she says. The group is taking on
the sense of powerlessness which can
grip oppressed communities. "We
emphasize to people that we can make
a difference," says Kikanza Ramsey,
Coordinator of Youth Outreach.
  Mathis  concurs. "We don't have to
tell communities of color, or women,
how they're discriminated against.
They're well aware of that. We're
trying to change people's sense of what
they're capable of, that people can
participate in the decisions of
production. By developing the abilities
of working people and communities of
color to understand politics and
science in all their complexity, we're
expanding their sense of
possibility." a
                                                               Watchdog pjmlo.
by Grace Lee Boggs
     Most Americans picture Detroit
     today as a wasteland. Once a
thriving metropolis, it now resembles
the capital of a Third World nation. In
some sections near downtown, not a
single house still stands.
  Over the last years, hundreds of
thousands of factory jobs have been
exported to Third World countries,
where labor is cheaper.  So young
people who might otherwise have been
working and making enough money to
raise families have been reduced to
hustling for a living. As a result, the
numbers of teenage pregnancies and
single-parent households have soared.
Also, since the invention of crack in
1985, thousands of young people have
become part of the "drug economy,"
bringing a tremendous increase in
violence.
  But out of the depths  of a city in
crisis, a new spirit of struggle and
solidarity is stirring at the grass roots.
The turning point was in 1986-87. In
1986, 43 children were killed and 365
children shot in street violence. As a
result, wherever people  got together
informally in the black community, the
discussion eventually got around to
the question, "What is happening to
our young people?"
  Out of this discussion came the
formation in January 1987 of SAVE
OUR SONS AND DAUGHTERS
(SOSAD) by Clementine Barfield,
whose  16-year-old son had been killed
in the summer of 1986. With the goal
of creating a movement  to do for our
period what the civil rights movement
did for the 1950s and 1960s, SOSAD
organizes memorial services, marches,
rallies, and cease-fire vigils. It also
organizes conflict resolution
 Multi-racial group in Los Angeles won decision against discriminatory plan for
 redwing commuk'r traffic.
                                          (1^5   is active in grass-rools
                                          neighborhood efforts in Detroit.)
                                                                                                     EPA JOURNAL

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Young activists urge The Detroit News to recycle newsprint.
                                                                                                        Detroit N< us.
workshops and urban farm training
programs for young people. Because
SOSAD mothers refuse to be defeated
by adversity, because they refused to
see themselves only as  victims of
racism, because they have been
organizing programs for positive
change for young people, they have
helped to  empower other grass-roots
Detroiters.
  Soon other activities  to reclaim our
city began to emerge. In the fall of
1988, a citywide network of
neighborhood  organizations calling
itself WE-PROS, or WE THE  PEOPLE
RECLAIM OUR STREETS, began
carrying on weekly, anti-crack marches
to break the cycle of fear in our
communities. Consisting mostly of
older Detroiters determined not to
allow their homes and  neighborhoods
to be destroyed by crack dealers,
WE-PROS marchers beat drums and
chant slogans like "UP  WITH HOPE,
DOWN WITH  DOPE!" and "HEY  DOPE
DEALERS, YOU BETTER RUN AND
HIDE; PEOPLE ARE UNITING ON THE
OTHER SIDE."
  To reaffirm the resilience of human
beings in the midst of devastation,
SOSAD, WE-PROS, and the DETROIT
GREENS plant trees at sites where
young people have been slain. On
Earth Day 1990, they sponsored a mass
planting on Belle  Isle in honor of all
children who had been killed in the
last decade.
  Meanwhile, all  over the city
grass-roots organizations and
individuals have been "rehabbing"
abandoned homes. In the process, they
have been helping to beautify
neighborhoods, revive the work ethic,
restore the city's tax base, and give
hope to our young people. One of the
most moving example of this  housing
rehabilitation is the Lawton Street
Project between Muirland and Puritan
on the Northwest  side, where 19
houses were recently renovated
through the combined efforts  of
residents,  the city, and business.
  On  November 16, DETROITERS
UNITING  organized a Peoples' Festival
at the Majestic Theatre to celebrate  the
new spirit of people "putting  our
hearts, minds, hands, and imaginations
than 40 community organizations
participated, and more than 500
people attended this joy-filled,
hope-filled event.  In election years,
DETROITERS UNITING also organizes
town meetings where the people
speak, and the candidates are  invited
to listen.
  Now a broad-based coalition of
Detroiters is organizing DETROIT
SUMMER '92, a project to bring young
people from all over the country to
work with Detroit youth on
community-based projects, such as
rebuilding homes, planting urban
gardens, and building community
parks. Through workshops and
cultural events, participants will have
the opportunity to learn from and
contribute to the rich cultural and
ethnic diversity of Detroit. Here's what
the call for participants says:
   In the spirit of Mississippi Voter
   Registration Project of 1964,
   DETROIT SUMMER  '92 will
   draw national attention to
   "recivilizing" our cities as tin?
   number one priority  of our
   period. It will encourage young
   people at the local and national
   level to take responsibilities for
   our communities, our cities, and
   our country. It will create  a
   fellowship between generations
   and make clear that the
   devastation of American cities is
   not "their" problem but "ours."  It
   will let the world know that
   together we can overcome, n
MARCH/APRIL 1992
                                                                        53

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                                  PA
Issues of environmental equity, like
other fairness issues, suggest that
government can and sometimes does
exacerbate situations where certain
groups of people are left with a lower
quality of life than the mainstream. As
government institutions review their
policies as to whether their effects may
be discriminatory, it is important to
remember that basic issues of fairness
come down to how people treat or
forget to  treat other human beings.
  Confronting and responding to
environmental equity concerns—there
lies a challenge for EPA's 10 regional
offices and the state and local officials
that EPA regional personnel work
with; All have key roles to play in
ensuring that communities subject to
multiple  environmental stresses
receive fair treatment. The challenge
involves  being responsive to citizens
expressing concerns about
environmental hazards in their
communities, and it involves taking
action to enforce environmental
regulations in  communities where
underprivileged citizens may not know
how or where to express their
concerns. The challenge involves being
open to a wide range of approaches,
including community outreach and
education, in cases where
environmental problems can't be
neatly solved with traditional
regulatory tools.
  Nearly every EPA region, working in
concert with state and local
environmental officials, has special
initiatives underway that focus on
minority and/or low-income
communities and are  intended to
promote  environmental  equity in some
way. Following are snapshots of three
of these Kl'A Hegionul projects.

                 —Deb Martin, Chief
                  Regional and State
                     Planning Branch
b4
Low-cost houses are difficult enough
to find in American cities; low-cost
homes that are also energy-efficient
virtually do not exist.  EPA's Atlanta
office is helping to fund a nonprofit
developer who will build houses that
are both; they will be  built in minority
neighborhoods.
  Southface Housing Development
Corporation has  designed a cottage
home for families whose income
ranges from $8,500 to  $18,000 a year.
Ownership will run $270 to $320  a
month, including principal, interest,
insurance, and taxes.
  Projected energy use is 325  to 425
kilowatt hours per month, for an
additional $30. This compares to $60
to $100 per month for standard
low-cost housing units.
  The cottage home is small—about
580 square feet; however, it can be
expanded to 900 square feet. It has a
vertical profile, simple trim, and a
generous porch,  all of which give  it a
traditional appearance.
  The porch enters on an open first
floor (20 feet  by  20 feet) with a living
room, eat-in kitchen, and a full bath.
Space is set aside for a coat closet,
linen  closet, and a laundry. The first
floor is accessible to people with
physical  disabilities.
  A staircase  leads from the living
room  to a second floor sleeping  loft.
This loft extends over the kitchen  and
dining area but allows the living room
to rise 16 feet to the ridge. Care  will be


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This low-cost home is also energy efficient.

taken in siting the houses to provide
this space a southern orientation, so
that it will be airy and sun-filled,
giving the house effective
daytime-lighting and improving its
passive solar performance.
  A second bedroom can be added by
extending the loft  into a complete
second floor, or additional bedrooms
can be attached to the rear of the
house.
  The aspect that makes the cottage
home especially distinctive and
affordable is its energy efficiency.
Energy efficiency often drops out of
the scheme in most affordable housing
programs. The concern for initial costs
that brings this about is
understandable, but the result is often
decreased afforcJability.
  The energy strategy for the cottage
home includes the following measures:
                       South/oce photo.

•  Full ceiling, wall, floor, and slab
insulation

•  The Airtight Drywall Approach and
other measures to reduce air leaks and
moisture problems

•  Efficient heating and cooling
equipment with well sealed and
regulated duct work

•  Double-pane metal windows with a
thermal break

•  Insulated entry doors

•  Ceiling fans for improved
ventilation

•  Energy-efficient lighting: compact
fluorescent lights inside and for
porches; high pressure sodium lights
for yard lighting

•  Energy-efficient water heating

•  Water conservation features
including low-flow  fixtures and
low-volume toilets

•  Passive solar design and window
shading measures
  The first cottage home has been
completed, and eight more are planned
this year. The Southface cottage home
project will not only provide
affordable housing to low-income
families while, at the same time,
conserving energy, it will reduce to a
minimum the environmental effects
usually associated with  low-cost
housing development. Savings on
carbon dioxide emissions should
average 10,000 to 15,000 pounds per
year. Nitrogen oxides and sulfur oxides
emissions will also be at reduced
levels. Smaller lot size will promote
mass transit,  reduce automobile travel,
and help stem urban sprawl.
MARCH APRIL 1992
                                                                                                                 55

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IN  THE  REGIONS:
Lead poisoning of children is
considered by many to be a national
epidemic. EPA estimates that 15
percent of the children in the United
States have elevated blood lead
levels—i.e., levels above 10
micrograms per deciliter of blood (10
fAg/dl). The U.S. Public Health Service
has said that  poor, minority children
in inner cities, who are  already
disadvantaged by inadequate  nutrition
and other factors, are particularly
vulnerable to lead poisoning.  (See
story on lead page 42.)
  As part of an Agency-wide  effort to
rank environmental problems
according to their effects on human
health and the environment, EPA's
Chicago office conducted a
comparative risk study of the region
and selected  lead exposure as one of
its priority concerns. The resultant
Project LEAP (Lead Education and
Abatement Program) is designed to
prevent and abate lead exposure in six
states—Illinois, Michigan, Wisconsin,
Minnesota, Ohio, and Indiana.
  Project LEAP has four components:
data analysis and targeting, pollution
prevention, education and intervention
activities, and abatement. The targeted
population is children under  seven
years and women of child-bearing age
(as surrogates for the fetus). Sixty
Metropolitan Statistical  Areas
(MSAs)—representing 83 cities—are
included. The project will take three
years to complete.
  The first component of Project LEAP
(data analysis and targeting) has
recently been  completed. Computer
modeling was used to estimate the
percentage and number of children in
each city who are expected to have
elevated blood lead levels based on a
combination of real and estimated
contamination levels in air, drinking
water, food, soil, and household dust.
The computer model primarily used
for this work is called the Lead Uptake
Biokinetic Model. Geographic
Information Systems technology was
also used to analyze demographic data.
  The table lists and ranks those 10
cities in the six-state region estimated
to have the highest numbers of
children  under age seven with elevated
blood lead levels. In addition to the
percentage and number of children in
each city anticipated to have  excess
lead  in the bloodstream, the table
shows how many of these children are
estimated to be either African
American or Hispanic.
  As the table shows, Chicago is
estimated to have the greatest number
of children with blood lead levels over
10 |xg/dl: 40,370, considerably more
than half being either African
American or Hispanic. In Chicago,
projected lead exposures come
primarily from contaminated  soil and
dust; lead levels measured in Chicago's
drinking water and ambient air are
low.
  By far the greatest estimated
percentage of children with elevated
blood lead levels is the estimated 85
percent projected for the small city of
Eau Claire, Wisconsin. Wisconsin was
found to differ from the other states in
the region in that several communities,
including Eau Claire, had high
measured levels of lead in drinking
water. Thus, in Eau Claire, lead in
drinking water occurred in conjunction
with high estimated soil and dust
concentrations associated with older
housing, resulting in a very  high
percentage estimate of  children with
blood lead levels of concern. Eau
Claire is something of an anomaly in
that so few of the children estimated to
be at risk are minorities.
  In the 83 cities under study, the total
population of children under age seven
was 1,429,000 in 1988. EPA's analysis
indicates that 12 percent of these
children, or 166,000, could have blood
lead levels of concern.  This  includes
56,000 African American and 12,000
Hispanic children.
  In addition to  community education
and intervention initiatives to reduce
risks to  children from lead exposure,
EPA's Chicago office will be
proceeding with pollution prevention
and lead abatement activities under
Project LEAP.
      Top 10 Midwest Cities by Number of Children with Elevated Blood Levels
CitY
Chicago, IL
Detroit, Ml
Milwaukee, Wl
St. Paul, MN
Cleveland, OH
Cincinnati, OH
Indianapolis, IN
Minneapolis, MN
Toledo, OH
Eau Claire, Wl
%
13
14
20
13
15
13
7
15
12
85
Children
(All Groups)
< 7 Years Old
40,370
19,142
13,878
12,152
9,396
5,415
5,223
4,611
4,515
3,650
African American
Children
< 7 Years Old
18,712
12,409
4,225
785
4,022
1,939
1,740
379
1,157
8
Hispanic
Children
< 7 Years Old
7,888
555
781
138
360
41
52
59
182
13
                                             Note: Percentages and numbers of children with blood lead levels greater than 10 jig/dl are
                                             computer-generated estimates.
l.fi
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the  Law  i
Individuals or companies who supply
drinking water to 25 or more people
for at least 60 days a year must meet
federal standards of water quality. For
years, EPA's San Francisco Office of
Drinking Water Compliance and
Enforcement has taken pains to make
sure that small drinking water systems
meet the standards. During the past
year, the office focused on migrant
labor camps' drinking water systems in
California. Officials knew that migrant
farm workers were especially
vulnerable to environmental hazards,
and they were concerned that the
camps shared many, if not more, of the
problems they'd found with small
systems throughout California.
  From  a list provided by the state of
more than 1,000 labor camps, EPA
sorted out over 300 that  might be
operating drinking water systems as
defined  by the Safe Drinking Water
Act. They were spread throughout 41
of California's 58 counties. Some of
these camps, it was discovered, were
no longer in existence; a few were
served by larger, regulated public
water systems.
  Further investigation  of the camps
that were operating water systems
meeting the definition of a small
public water system revealed  191 to  be
in violation of the law. They served
more than 8,500 people in 20 counties.
Of the 191 systems in violation, EPA
found that 141 were not recognized by
the state as public water systems and,
as a result, weren't tracked or
monitored for any potential violations.
  EPA found that most of these
systems were not sampling their water
sufficiently for contaminants. Some
had often exceeded  limits for coliform
bacteria, and some exceeded limits for
nitrates. The presence of coliform
bacteria in drinking water indicates
that organisms may  be present that can
cause diseases such as typhoid,
cholera, infectious hepatitis, and
dysentery. Coiiform bacteria also can
indicate that parasites are present.
Nitrate, which derives from sewage,
fertilizers, and feedlots, poses a threat
of "blue baby syndrome," a potentially
life-threatening anemic condition in
babies up  to six months of age.
  More than one county contact
warned that strict enforcement of the
drinking water regulations might result
in the closure of many labor camps,
creating additional housing, welfare,
and social burdens for county
administrators, taxpayers, and camp
residents. According to these contacts,
labor camp owners have often chosen
to close their camps rather than
comply with regulations.
  On September 6, 1991, EPA issued
notices of violation to the 191 labor
camp owners and the  California
Department  of Health  Services, Office
of Drinking Water. The notices warned
the owners either to come into
compliance with the Safe Drinking
Water Act or to face further
enforcement action and penalties. The
maximum civil  penalty is $25,000 per
day per violation for each day a system
is in violation.
  With full cooperation from the state
and counties, 49 systems are now
reported to be in full compliance.
Another 79 are in the  process of
permit application and/or conducting
the required sampling under
supervision  from their counties. Nine
labor camps have stopped operating,
eight of them permanently, since
September 1991. It is not clear how
many of the closures were related to
EPA's enforcement. The remaining
systems were not actually public water
systems due to misinformation,
originally received from the counties,
regarding numbers of people housed or
length  of occupancy.
  EPA  will continue to work with the
state Office of Drinking Water and the
affected counties to  identify and
ensure that all applicable migrant labor
camp water  systems are inventoried
and monitored for compliance with the
Safe  Drinking Water Act. a
                                                                   I'.SPA photo
  Migrant farm workers
        art' especially
         vulnerable to
       environmental
            hazards.
MARCH/APRIL 1992
                                                                                                               57

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HELP  IE
The MAI Task  Force Recruits Minority Professionals

by Clarice E. Gaylord and
Robert Knox
  In an article entitled "Shortfall in the
  Workforce" that appeared in the
September/October 1991 issue of EPA
Journal, Maureen Delaney cited
alarming statistics that "labor needs in
science, engineering, and technology
are growing, while at the same time,
there has been a  dramatic reduction in
the numbers of students preparing to
meet the demands of these vital
occupations." By 2010, according to
National Science Foundation
projections, the United States could
suffer a  shortfall  of 560,000 science
and engineering professionals.
  Unfortunately,  the prospects for
minorities joining science and
engineering professions are even more
discouraging. In 1988, the total number
of minorities enrolled  in four-year
colleges and universities was 19.6
percent, compared to 80.4 percent for
nonminorities; minority enrollment in
graduate school was 11.6 percent,
compared to 88.4 percent for
nonminorities. And only 4 percent of
8,262 Ph.D.s awarded  in all natural
sciences and engineering went to
minorities.
  Worse yet are reports from the
Department of Labor indicating that
members of  minority groups are much
less likely to be employed as scientists
and engineers  than nonminorities. In
1988, only 4.4 percent of the 4.5
million  people employed as scientists
and engineers  in  the United States

(Gaylord is Deputy Director o/BPA's
Office of Human Resources
Management. Knox is  Ombudsman for
the Office of Sold Waste and
Emergency Response.)
were minorities. Yet minority groups
are among the fastest growing
segments of the U.S. population. By
the year 2,000, according to the same
report, blacks, Hispanics, and Native
Americans are expected to  comprise 47
percent of all school-age students (up
from 25 percent in 1988) and 42
percent of the new entrants into the
workforce.
   In 1987 Congress established the
President's Task Force on Women,
Minorities, and the Handicapped in
Science and  Technology to address
this emerging national problem.  After
holding several public hearings around
the country,  the Task Force produced
two reports which identified serious
problems with science education and
predicted severe shortages  of scientists
and engineers in the future—due in
part to changing U.S. demographics.
To quote from one of their  reports,
"The factors—racism, sexism, and
prejudice against people with
disabilities—that have limited
opportunities for many in America are
also narrowing access to science and
engineering careers."
Recommendation: "Each federal
agency should provide stable and
substantial support for effective
intervention programs that  graduate
quality scientists and engineers who
are members of underrepresented
groups."
   In response to the findings and
recommendations of the President's
Task Force, EPA created the
Administrator's Workgroup on
Women, Minorities, and the
Handicapped in Science and
Technology to assess EPA's workforce
needs and to develop a comprehensive
strategy for action. In its  1990 report,
the workgroup verified that EPA has
an increasing demand for scientific
and technical professionals. More than
one-third of its 18,000-strong
workforce consists of scientists  and
Worse yet are reports from
the Department of Labor
indicating that members of
minority groups are much
less likely to be employed  as
scientists and engineers than
nonminorities.
engineers, a proportion which has
been constant over a 10-year period.
Moreover, EPA is  likely to lose a
significant percentage of its technical
professionals by the year 2000: The
annual turnover rate is 11 percent for
scientists and engineers, and EPA's
scientific and engineering personnel
are older than the rest  of the workforce
(averaging 50 years versus the Agency
average of 39 years of age). The
workgroup identified a number of
proactive and preventive measures that
EPA needs to take.
  One of these recommendations was
to establish a Minority Academic
Institutions (MAI) Task Force,
comprised of senior managers and
selected presidents of Historically
Black Colleges and Universities
(HBCUs) and Hispanic Associated
Colleges and Universities (HACUs), to
design and implement an action plan
to enhance EPA's  interaction with
58
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                                                                            Graduation at Morgan State
                                                                            University, Baltimore,
                                                                            Maryland.
minority institutions. The MAI Task
Force's action plan, issued in May
1991, is intended to support the
capacity of MAI's to conduct
environmental research, sponsor
environmental fellows and interns,
deliver scientifically trained personnel,
and provide public education and
outreach activities.
  One broad initiative fostered by the
MAI action plan was to build technical
knowledge and support not only for
students but for MAI faculty and
mid-career minority professionals as
well. In this connection, the task force
stressed the importance of providing
continued support to minority students
as they progress in the educational
pipeline from high school through
graduate school. Early and sustained
intervention is essential to develop the
diverse scientific background students
need to prepare for environmental
careers.
                                                              Morgan Sfcitu photo.
  A program to address this "pipeline"
problem was piloted in summer 1991.
The Coop-Progression program, a
modified version of the Office of
Personnel Management's Cooperative
Education program, recruits 10th and
llth grade minority students to be
employed part-time at EPA while
receiving training in science and math
from a local minority institution. On
their graduation from high school, EPA
pays up to $5,000 a year college
tuition and employs  the students as
co-ops during undergraduate and
graduate training. Noncompetitive
conversion to federal employment is
offered at  the completion of college.
This program is being expanded to
include EPA's laboratories and
regional offices during  1992.
  Retaining minority students in
undergraduate and graduate
environmental programs  requires
long-term  financial and mentoring
support. The MAI Task Force
recommended expanding the
undergraduate scholarship program
and creating a new graduate fellowship
program for students from HBCUs and
HACUs pursuing advanced degrees in
environmental areas. These new
multi-year $20,000 per year
fellowships will be awarded in spring
1992.
  Faculty from minority academic
institutions are encouraged to
participate in EPA's Faculty Fellows
program, where they may spend four
to six months in research facilities
working on priority environmental
projects. The objective is for faculty,
enriched by this experience, to return
to their home institutions to continue
relevant research and to mentor and
encourage students in environmental
studies. This program accommodates
15 to 20 faculty from HBCU and
HACU campuses a year.
  Another new program is a two-year
Environmental  Science Management
Training  program based  at Tufts
University. The program offers
rnidcareer minority professionals an
opportunity to earn a  master's  degree
in environmental science management
and to gain work experience at  EPA.
Eight participants are currently
enrolled in this program, which is in
its first year.
  A second broad initiative stemming
from the MAI Task Force action plan
is to build research capacities at
minority  institutions.  From its review,
the task force found that past funding
levels for research assistance at MAIs
had not been adequate to build
research activities in environmental
MARCH/APRIL 1992

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                                      The environmental equity
                                      movement has made
                                      environmental careers more
                                      attractive and more relevant
                                      to minorities.
areas, to develop curricula in sciences
and engineering, or to encourage
faculty participation in these fields.
Recommended remedies included
increasing research dollars to MAIs,
providing technical assistance in the
development of research grants and
environmental curricula, and
purchasing "state-of-the-art"
instrumentation through a proposed
new equipment acquisitions program.
For example, laboratory devices such
as ultracentrifuges, advanced computer
technology, and lasers would help
make  MAIs more competitive for
research funding.
  Strengthening the
environmental-science research center
capability at minority institutions was
definitely a challenge. Prior to 1990,
there was only one EPA-funded
research center at an MAI: at Howard
University in Washington, DC, as part
of a Hazardous Substance Research
Center Consortium with the University
of Michigan and Michigan State
University. Since  the action plan was
issued—and due primarily to a 1991
Congressional  appropriations bill—two
new Academic Centers of Excellence
have been established. Clark Atlanta
University in Atlanta, Georgia, has a
research/training center where faculty
and students can participate in
Superfund emergency
remedial-response research. Funds
have been appropriated for a second
center at Southern University in Baton
Rouge, Louisiana, to begin a statistical
research component in hazardous
waste research. And funds have been
appropriated for a consortium of the
University of Texas at El Paso, Arizona
State University, New Mexico State
University, and the University of Utah
to study air, water, and hazardous
waste problems along the
U.S.-Mexican border.
  The task force also realized the
importance of an effective recruitment
strategy, and this is reflected in a third
broad initiative. While more and more
predominately majority schools are
recruiting minority students and
faculty into their science and
engineering programs, HBCUs and
HACUs still graduate more than half
the minorities who receive college
degrees. Therefore, these institutions
are viewed as the best resources for
increasing minorities' access to
environmental careers and research
opportunities.
  EPA has strengthened its
Agency-wide recruitment strategy by
establishing a National Recruitment
Advisory Committee. One of the
recommendations of this committee
was to establish college relations
programs on several HBCU and HACU
campuses. Senior EPA officials are
now serving as Campus  Executives,
coordinating recruitment activities,
and fostering linkages between these
adopted institutions and EPA.
  As part of its new campus-relations
program, EPA initiated a Memorandum
of Understanding with Morgan State
University in Baltimore. This
comprehensive agreement encourages
personnel exchanges,  curriculum
development in environmental areas,
research support, technical seminars,
etc. The Morgan State program serves
as a model for other MAI/EPA
cooperative arrangements.
  Successful environmental programs
at MAIs can help entice minority
students  to enter environmental fields.
Moreover, the environmental equity
movement has made environmental
careers more attractive and more
relevant to minorities. A recent survey
conducted by the Panos Institute found
that "environment-related issues have
become a high priority among
culturally diverse communities . . .
because the movement takes a  more
holistic approach by integrating the
environment into a broader agenda
that emphasizes social justice and
equity issues  . .  . ." Professor Robert
Bullard, author of Dumping in Dixie:
Race, Class and  Environmental
Quality, explaining why black
minorities have joined environmental
grass-root groups in record numbers,
states, "Black communities, because of
their economic and political
vulnerability, are routinely targeted for
the siting of noxious  facilities, locally
unwanted land  uses and
environmental hazards .... For blacks
this is a life-or-death issue."
  just possibly, MAI  college students
could serve as role models in their
communities and perhaps involve
high-school and junior-high-school
inner city youths in environmental
initiatives, thus fostering an  even
younger generation of future
environmentalists who have a sense of
environmental ethics and
responsibility for the community.
Students concerned about the health of
their communities could be motivated
to learn the skills necessary to take air
and water samples and to help monitor
nearby industrial facilities. Many MAI
students are products of
environmentally troubled communities
and have a special cultural sensitivity
to these communities' concerns. They
have great potential to be employees of
public/private environmental
organizations or to be future
environmental policy and decision
makers with a keen understanding of
community sensitivities on
environmental issues.
   In short, supporting minority
academic institutions by  enhancing the
knowledge and skills of their students
and faculty, building their research
capabilities in environmental areas,
and having an effective recruitment
program will help meet future
demands for a technical workforce.  D
lid
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THE      ,.
A  TARGET  FOR  1
Border Shantytowns Are Separate But Unequal
by Jack  Lewis


      Welcome to the Weslaco colonia in
      Hidalgo County, Texas, 30 miles
upriver from Brownsville, a city of
125,000 people, and an equal distance
down the Rio Grande from McAllen, a
town of 100,000. Weslaco itself has a
population of 25,000 within its city
limits, which currently exclude the
2,500 Hispanic Americans who live
mostly without urban amenities in a
fairly typical "colonia"—a Spanish
term for a  neighborhood or
community—on the outskirts  of town.
  Seventy percent of the  colonia
inhabitants live without access to  any
utility—neither fresh water nor sewage
hookups, neither gas nor electric
power—and their community (largely
flat without drainage infrastructure)
has unpaved roads that flood
frequently, swamping outhouses,
cesspools, and primitive septic tanks.
Houses are self-built shelters
constructed of scrap lumber and other
shoddy supplies, and though tiny, they
are home to large families of mostly
Spanish-speaking farm workers, who
face seasonal unemployment rates as
high as 20 percent and unnaturally
high incidences  of dysentery and
hepatitis A.
  Texas now has laws to prevent new
colonies from cropping up,  but the
existing ones—created by
                                                        Citv of Wftlao
 (Lewis is an assistant editor of EPA
 Journal.)

 MARCH/APRIL 1992
       Typical colonias house comes
       equipped with outhouse privy.
unscrupulous land developers—are
still an eyesore and a burden on the
conscience of Texas and the nation.
For decades these unincorporated rural
slums near the Rio Grande have
provided substandard housing to tens
of thousands of people, most of whom
are U.S. citizens whose families have
been in this country for generations.
Offering no paved roads, little safe
drinking water, few sewer or power
lines, no fire protection facilities, and
only a few community services, these
unplanned, unhealthy shantytowns
exist today in a shadowland far
removed from mainstream America.
  Colonias residents have always been
too  poor to take the initiative on the
problems just listed, and the counties
in which they live have also been too
poor—or too prejudiced—to care.
Nearby cities have been all too willing
to wash their hands of colonias
problems, saying, "They fall outside
our jurisdiction." Finally, at long last,
state government has intervened in a
big way, and so has the federal
government.
  On February 25, 1992, EPA released
a comprehensive  plan for the cleanup
of pollution along the entire
U.S.-Mexico border that will involve
an expenditure of well over $1 billion
over the next several years by the
United States, Mexico, the border
states, and private industry. The
federal government's share in fiscal
year 1993 will be approximately $241
million, of which $75 million has been
earmarked for drinking water and
sewage disposal improvements in the
Texas and New Mexico colonias.  EPA
will administer $50 million for sewage
treatment improvements in these
colonias, while the U.S. Department of
Agriculture's Rural Development
Administration devotes $25 million to
improving water supply infrastructure.
  Commenting on EPA's task in  the
colonias, EPA Administrator William
K. Reilly said, "I don't think there are
higher risks to health anywhere in the
United States  than in these unsewered
communities  .... The health of
thousands of people is at risk in the
colonias due to the absence of
environmental safeguards that most
Americans take for granted. We intend
to correct this."
  The state of Texas has already made
a major commitment of its own. In
                                                                                                           61

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November of 1989, Texas voters
permitted the Economically Distressed
Areas Program to fund its operations
by issuing $100 million in bonds for
construction, acquisition, or
improvements to water supplies,
and/or wastewater collection/treatment
works, including all necessary
engineering work but  not maintenance
or ongoing  expenses. In 1991, Texas
amplified that bond issue fund by
$150 million, creating a total pool of
$250 million for water works  in the
Texas colonias.
  Another resource that should be
mentioned  here is the $15 million EPA
put into a Colonia Plumbing Loan
Program back in 1990; the first
applicants for these internal plumbing
and house hook-up loans are now
awaiting the ruling of the Texas Water
Development Hoard, which will also
manage whatever colonias millions
Congress appropriates in the fall. (New
Mexico's colonias effort is dwarfed by
that of Texas; from 1972 to 1990, the
state's Environment Department gave
out only $12 million in grants and
loans for drinking water and
wastewater  work in the New Mexico
colonias.)
   Discouragingly, some experts have
estimated that extending sewage
treatment to all Texas colonias
residents would cost at least $500
million, while further improvements in
the drinking water supply would cost
$250  million. In other words, total
resolution of the problem, in its
present scale, is still beyond our grasp.
Part of the  rationale for tackling it
gradually is that local institutions do
not yet exist in most of the 918
colonias housing 215.000 Hispanic
farm workers in sixteen Texas and
New Mexico border counties. Until
local governments form or local water
utilities show more  initiative to handle
sewage treatment, it will be difficult to
"micro-manage" large construction
projects.
  Significantly, Lull, Texas—the first
colonia to receive construction money
from the state's Economically
Distressed Areas Program
account—was recently annexed by an
adjacent city, Edinburg, Texas. In
August 1991, the Texas Water
Development Board and the  Edinburg
City Council approved the use of a
$565,000 loan and an $885,000 grant
to finance water improvements and
construction of a wastewater system
for the Lull colonia. Lull is a Hispanic
community in Hidalgo County with
nearly 1,300 inhabitants—all U.S.
citizens in good standing—and a
history dating back  to the 1920s.
  In Lull, as throughout the  U.S.
colonias, few current citizens now
have access to sewage treatment,
except in the form of archaic,
overcrowded, overworked septic tanks,
while roughly 80 percent have some
kind of amateur fresh-water  hookup.
for cooking and bathing, but not
necessarily for drinking and  not
necessarily within the home itself. The
dwelling can range  in quality from a
handsome stucco house with several
bedrooms to a broken-down  hovel
built from cinder blocks, tin sheets,
scrap lumber, plastic, and cardboard.
Most residents use outhouse privies
that flood every time rains inundate
the undrained, muddy streets and
fields of the colonias, where children
and animals are frequently seen
playing the same day.
  Some colonias residents—all of
whom own cars or trucks, and many of
whom own their own land and
dwellings—drive as much as 30 miles
to buy bottles of fresh drinking water.
The poorest of the poor, however,
drink directly from outdoor taps  or
from the  wells feeding those taps, and
the ground water that comes from
these  sources is contaminated with
fecal coliform as a result of the
repeated  sewage floods. Outbreaks of
dysentery and hepatitis A are
commonplace in the colonias, even
though in the rest of the United States
these  severe water-borne afflictions are
considered Third World diseases.
  Some 16 other colonia-related water
and wastewater projects are now in the
Texas Water Development Board
pipeline, which will grow wider and
wealthier in the fall. Six applicants
with completed facility plans have,
like Lull, recently been awarded  cash.
These projects include Socorro in El
Paso County ($1.6  million); Cameron
Park in Cameron County ($6.4
million);  Granjeno and Madero in
Hidalgo County ($2.89 million); areas
outside Eagle Pass in Maverick County
($11 million); Westway in El Paso
County ($100,000); Sebastian and
Lasara in Willacy County ($3 million).
The Hacienda Gardens colonia in
Cameron County has a completed
facility plan that is now being
evaluated, while five other counties
are now preparing their engineering
facility plans, a
                                                                                                     EPA JOURNAL

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 ON  THE  MOVEl
Administrator William Reilly
has announced the creation
of an Environmental Appeals
Board which will replace the
current judicial Officer
function  in hearing  appeals.
The new Board, a three-judge
panel of senior Agency
attorneys, will make final
Agency decisions in appeal
cases contesting the
adjudicatory decisions of
Administrative Law Judges
and  Regional Administrators.
The Administrator has
delegated to the Board the
authority to decide appeals
under all the major
environmental statutes,
including the Clean  Air Act,
Clean Water Act, Toxic:
Substances Control Act, and
Resource Conservation and
Recovery Act (RCRA). At the
request of the Administrator,
the Board will also handle
special assignments  where
extra assurance of the
objectivity of the
decision-making process is
essential.
  To date, two judges,
Ronald L. McCallum and
Edward E. Reich,  have been
appointed to the
Environmental Appeals
Board; the third member has
not been  announced.
  Until recently McCallum
served as the Chief Judicial
Officer in the Office of the
Administrator. McCallum
was  promoted to the position
of Chief Judicial Officer in
1984 after having served as
the sole Judicial Officer since
1978.
  McCallum came to EPA  in
1974 as an attorney-advisor
in what was then the
Pesticides, Toxic Substances,
and Solid Waste Management
Division of the Office of
General Counsel. In  1977, he
was named Senior Trial
Attorney  at the conclusion of
an extended pesticide
cancellation hearing.
  Prior to coming to EPA,
McCallum was an associate
attorney for over four years
in a major law firm in
Indianapolis, Indiana,
                   McCallum
            Reich
specializing in corporate real
estate and tax matters.
  McCallum is a graduate of
Indiana University in
Bloomington, Indiana, where
he received his A.B., M.B.A.,
and J.D. degrees. While
attending law school, he
served on the Law Journal as
a Junior Writer.
  Edward E. Reich's most
recent  position was Legal
Advisor to  the Administrator.
Previously, he was the Acting
Assistant Administrator and
Deputy Assistant
Administrator in the Office of
Enforcement where he was
responsible for management
and oversight of enforcement
litigation under the various
statutes administered by the
Agency.
  Before his appointment as
Deputy Assistant
Administrator, Reich was
Associate Enforcement
Counsel for Waste, with
responsibility for civil
enforcement litigation  under
RCRA and  the
Comprehensive
Environmental Response,
Compensation, and Liability
Act. He has been actively
involved in the enforcement
of environmental laws since
1968. He received his J.D.
from Georgetown University
Law Center in 1968 and is a
member of  the bars of the
Commonwealth of  Virginia
and the District of Columbia.

Bradley F.  Smith has been
named Director of the Office
of Environmental Education.
While assuming his new
duties, he will continue
coordinating activities for the
National Environmental
Education and Training
Foundation until a president
is hired.
  Prior to EPA, from 1983
until 1991, he served as
Executive Director for the
Jennison Nature Center and
Tobico Marsh National
Refuge of Michigan's
Department of Natural
Resources. He was also a
professor in both the Political
Science and Biology
Departments at Delta College
in Michigan from 1975 until
1991.
  Smith was a program
administrator for the
Department of Environmental
Protection, City of Grand
Rapids, Michigan, from 1972
until 1975.
  His extensive related
professional experience
includes participation on
several advisory boards,  such
as member of the
International Advisory Board
of the 1992 Environmental
Education/United Nations
Conference in  Toronto,
Canada, and a past member
of EPA's National Advisory
Council for Environmental
Policy and Technology
Transfer from 1989 until
1991. He also chaired the
Agency's National Pollution
Prevention Education
Advisory Board in  1990 and
currently is a continuing
advisor of the United Nations
Environment Programme.
  Smith has authored and
co-authored several
textbooks, including the
recently published  4th
edition of Environmental
Science: The Study of
Interrelationships, a work
used by many colleges and
  Smith
universities throughout the
country.
  Smith received a B.A. in
political science and
international relations in
1972 and an M.A. in 1974 in
political science and public
administration from Western
Michigan University. He
holds a Ph.D. (1981)  in
natural resource policy and
management from the School
of Natural Resources at the
University of Michigan.

Margo T. Oge is the new
Director of  the Office of
Radiation Programs. The
Office  oversees  radiation
protection programs that
implement  provisions of the
Clean Air Act, the Superfund
Amendments and
Reauthorization Act,  the
Radon Gas  and  Indoor Air
Quality Act, and the Atomic
Energy Act. The programs
span a wide gamut of
responsibilities  that include
environmental monitoring
and surveillance, radiation
protection standards and
guidelines,  compliance
activities, and development
of public information.
  Oge, with EPA since 1980,
has speciali/ed  in policy and
regulatory development.
From 1982  to 1985, she
served as Section Chief of the
New Chemical Section under
the Office of Toxic
Substances. In 1985 and
1986, she was Legislative
Aide to Senator John Chafee
of Rhode Island, the ranking
minority member on the
Senate Environment and
Public Works Committee. She
also served  as Deputy
Division Director of the
MARCH/APRIL 1992
                                                                                                                  63

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        Goodman
Van Heuvelen
Homoki
Economics and Technology
Division under the Office of
Toxic Substances from 1986
though 1988. Prior to her
current  position, she was
Director of the Radon
Division, Office of Radiation
Programs, from 1988 to 1991.
  Oge earned her M.S. degree
from Lowell University in
1975 and her B.S. degree in
chemical engineering from
Lowell Technological
Institute in 1972.

Laurie D. Goodman, the new
Associate Administrator for
the Office of Regional
Operations and State/Local
Relations, comes to EPA after
more than four years with the
U.S. Senate. There, she
served as Deputy  to the Chief
of Staff  in the Office of
Senator Alan K. Simpson
(R-Wyoming). As  Legislative
Assistant, she was involved
in areas of  energy,
environment, science,
commerce, transportation,
public lands, and public
works.
  During 1986, Goodman
developed and  managed
right-of-way acquisition for
the municipal water delivery
pipeline as a consultant for
the Board of Public Utilities
in Cheyenne, Wyoming. She
coordinated and negotiated
extensively with rural
landowners, corporations,
and county, state, and federal
agencies, finalizing the
project without a single
condemnation.
  From 1984 to 1986,  she
owned and managed her own
firm which researched
mineral and surface
      ownership on private and
      publicly held lands and
      negotiated oil and gas leases
      in the Rocky Mountian states.
      She also monitored state and
      federal regulation compliance
      during lease acquisition and
      performed surface
      inspections on proposed
      drilling sites.
        In 1984,she was
      consultant to the A & W
      Production Company, where
      she participated in
      force-pooling hearings at the
      Oklahoma Corporation
      Commission. She also
      designed and organized the
      company lease records
      system and devised a draft
      payment system that
      coordinated bank records,
      land department data, and
      budget figures.
        Goodman received  her B.S.
      degree from the University of
      Oklahoma in 1983. She has
      had additional studies at the
      American  University  in
      Washington, D.C., and the
      University of Haifa in Haifa,
      Israel.

      Robert Van Heuvelen is the
      new Acting Director of the
      Office of Civil  Enforcement.
      For the past two years, he
      served as Deputy Chief of the
      Environmental Enforcement
      Section, U.S. Department of
      Justice (DOJ), which litigated
      nearly 1,000 environmental
      enforcement cases referred by
      the federal government in 88
      of the 94 U.S. federal district
      courts.
        Van Heuvelen, who joined
      the DOJ in 1980, served as a
      trial lawyer until 1985 and as
      Assistant Chief of the
      Environmental Enforcement
          Section from 1985 to 1989.
          He was Acting Chief of the
          Environmental Enforcement
          Section from October 1990 to
          April 1991. While at the DOJ,
          Van  Heuvelen served as lead
          counsel in environmental
          enforcement litigation under
          all major federal
          environmental statutes.
            Prior to his service at the
          Department, Van Heuvelen
          was  Assistant Counsel to the
          U. S. Senate Subcommittee
          on Environmental Protection
          from 1977 until 1980.  He was
          Legislative Assistant to
          Senator Quentin Burdick
          (D-North Dakota) from 1975
          until 1977.
            He graduated cum laude
          from Macalester College with
          a B.S. in  political science in
          1972. He earned a J.D. from
          George Washington
          University in 1979 and an
          M.A. in public policy  from
          the University of Minnesota
          in 1974. He  is a native of
          Bismarck, North Dakota.
          Zeda (Zee) Anne Homoki is
          the new Special Assistant to
          the Administrator and White
          House Personnel Liaison for
          EPA. She  is responsible for
          coordinating special projects,
          implementing policy and
          procedure, and distributing
          and following up on all
          White House information to
          the 60 noncareer appointees
          now at EPA.
            Prior to coming to EPA she
          served as  the Associate
          Director for
          Intergovernmental Affairs
          and Deputy White House
          Liaison for personnel at the
          Interstate  Commerce
Commission (ICC).
  Before joining the ICC staff,
she was the Special Assistant
to the Director of
Congressional Affairs and
State Liaison at the Federal
Energy Regulatory
Commission.
  In 1989 she was detailed to
the White House Liaison
Office in the Office of the
Secretary, Department of
Interior. She served as
Legislative Assistant for
Representative Bill Archer
(R-Texas) from 1986 until
1988.
  Homoki taught first grade
at the Department of Defense
Dependent Schools in
Germany from 1979 until
1981,  where she received the
"Sustained Superior
Performance Award." She
has also done extensive
volunteer work.
  A native Texan, she
received her B.S.  degree from
the University of Houston.
She has lived in Europe and
Asia and now resides in
Burke, Virginia, with her
husband, Steve. Their
daughter Elizabeth is a
sophomore at Sweet Briar
College. D
 64
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                                Earth Day 7990: (Tree
                                Indians and Eskimos
                                paddle to Battery Park,
                                New York City, to
                                protest construction of
                                hydroelectric system in
                                Quebec. New York
                                State has recently
                                canceled $ 17 billion
                                contract for
                                hydroelectric power
                                from Quebec.
                                Back Cover: October
                                1991 rally in Kettleman
                                City, California,
                                protesting proposed
                                hazardous waste
                                incinerator. See article
                                on page 47. Copyright
                                lohn W. F.mmons.
Copyright Mario H. Baslonc. PhotorepOltSfS.

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