Environmental Protection
1 Policy t%nn!rig,
And'EvaSu^tion
EPA230-R-S2-00&4
June 1992
v>EPA Environmental Equity
Reducing Risk for
All Communities
Volume 2:
Supporting Document
Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)
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CONTENTS
1.0 Introduction . ........... ........ .. 1
2.0 Findings c.n Health and Exposures . 4
2.1 Background Health and Socioeconomic Data 4
2.1.1 Health Data ... 4
2.1.2 Socioeconomic Data 6
2.2 Exposures ...... — .. 7
2.2.1 Residence Near Waste Sites '... 7
2.2.2 Lead Exposure .. 9
2.2.3 Pesticide Exposure 10
2.2.4 Air Pollution Exposure ....... .i. . . 10
2.2.5 Dietary Exposure Through Fish Consumption 12
2.3 Environmental Health Effects 14
2.4 Conclusions — 15
3.0 Evaluation of EPA Programs 16
3.1 Office of Solid Waste and Emergency Response 17
3.1.1 General Conclusions of Awareness Workshop Participants ..'... 17
3.1.2 Specific Problem Areas 18
3.2 Office of Air and Radiation 20
3.2.1 Composition of Populations Sensitive to Air Pollution 21
3.2.2 1990 Clean Air Act Amendments 22
3.Z3 Conclusions ., 26
4.0 Native Americans: Distinct Issues . 27
4.1 Regional Indian Coordinator Concerns 27
4.2 Wisconsin Tribes Comparative Risk Study ........ 28
5.0 Risk Assessment and Risk Management — .- 30
5.1 Principle Findings , 31
5.2 Evidence of Increased Risk • • • • 32
5.3 Findings on Components of the Risk Assessment Process 33
5.3.1 Hazard Identification 33 .
5.3.2 Exposure Assessment .34
5.3.3 Risk Characterization 36
5.4 Findings on Components of the Risk Management Process ...•"." 36
5.5 Conclusions 36
6.0 Risk Communication '....... 37
6.1 The Risk Communication Program 37
6.2 Guidance from Seminal Risk Communication Documents 38
6.2.1 Goals ; 39
6.2.2 Process 39
6.2.3 Content ..., 40
6.2.4 Summary . „ 41
6.3 Risk Communication in Regulatory Programs 41
63.1 Radon .... 41
6.3.2 Community-Right-To-Know ..... 44
6.3.3 Air Toxics . 45
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6.3.4 Pesticides 46
6.3.5 Lead .48
6.4 Conclusions .50
7.0 Outreach Efforts 51
7.1 National Environmental Equity Network 51
73. Cooperation With Other Federal Agencies .. 52
8.0 Regional Level Equity Perspectives and Efforts 53
8.1 Regional Staff Perspective 53
8.2. Regional Equity Projects 54
9.0 Institutional Model for Addressing Environmental Equity Issues 68
9.1 Background and Rationale 68
9.2 Mission of an Institutional Response 68
9.2.1 Goals 68
9.2.2 Functions 68
93 Implementation Plan 69
93.1 Phase One: Short Term 69
93.2 Phase Two: Long Term .71
10.0 Comments from External Reviewers 72
10.1 Summary of Comments 72
10.1.1 Major Points , 72
10.1.2 Michigan Coalition 73
10.1.3 Southwest Network for Environmental and Economic Justice .... 75
10.1.4 Dr. Robert Bullard 77
10.1.5 Human Environment Center . . . ,. . 79
10.2 Comments from External Reviewers 80
11.0 Bibliography : 122
11
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LIST OF TABLES
Table One Relative Cancer Mortality Rates (1970s) for Females ....... 5
Table Two Relative Cancer Mortality Rates (1970s) for Males ... 5
Table Three Comparison, of Selected Socioeconomic Characteristics by Ethnic
Group 6
Table Four Comparison of Urban Versus Rural Distribution of Population
By Ethnic Group .. .....7
Table Five 1980 Data for Census Areas Where EPA Region IV
Hazardous Waste Landfills Are Located . 8
Table Six Estimated Percentage of Children (Living in Cities with
Population Over a Million) 0.5-5 Years Old with Blood Levels
Greater Than 15 ng/dl By Race and Income 9
Table Seven Percentages of Total U.S. Whites, Blacks, and Hispanics
in EPA-Designated Air Quality Non-Attainment Areas
: By Air Pollutant 11
Table Eight Prevalence of Chronic Respiratory Conditions (per 1,000) for 1985-
1987 By Income and Ethnicity : .,. 15
iii
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LIST OF FIGURES
Figure One Minority Percentage of the Population in U.S. Communities
with Operating Commercial Hazardous Waste Facilities . . .
Figure Two Equity: Institutional Model (Internal)
. 9
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IV
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1.0 INTRODUCTION
Over the past twenty years, the Environmental Protection Agency has made
considerable progress in protecting and cleaning up the environment. Many forms
of air pollution are significantly reduced, many surface water systems have shown
dramatic recovery, and hazardous waste is better managed and contained.
Although the successes are considerable, so are the remaining problems.
Traditionally, many environmental programs at all levels of government have
set universal standards for individual pollutants emitted by specific types of
sources with the goal of protecting the environment and aU people. Recognizing
that not everyone is affected in the same ways by pollution, these standards have
often been set to protect the most vulnerable, such as asthmatics or pregnant
women.
Out of this initial strategy a new approach to environmental protection has
emerged. The EPA Science Advisory Board, in its report Reducing Risk: Setting
Priorities and Strategies for Environmental Protection, urged EPA to target its
environmental protection efforts based on the opportunities for reducing the most
serious remaining risks. Thus, the next refinement to environmental protection is
to examine which environmental problems pose the greatest risks nationwide to
human health and the environment, and to begin targeting new efforts on these
problems.
In targeting its protection efforts to reduce the most serious risks; the Agency
has begun to examine how the patterns of environmental problems converge on
different places, how the people who live in those places are affected, and how
environmental programs should be refined to address identified differences. A
community surrounded by multiple sources of air pollution, ringed by waste
treatment facilities and landfills, and whose residences contain lead-based paint
clearly faces higher than average potential environmental risks. It is in this context
that concerns have been raised about the relative risk burden borne by low-income
and racial, minority communities. Examination of these differences in risk burden
and how government agencies respond is known as environmental equity.
Although there are many types of equity, this report focuses on racial and
socioeconomic equity.
With these concerns and objectives in mind, in July 1990, EPA Administrator
William K. Reilly formed the Environmental Equity Workgroup with staff from
offices and regions across the Agency., Administrator Reilly charged the
Workgroup with four tasks: .
Task One: Review and evaluate the evidence that racial minority and low-income
people bear a disproportionate risk burden. •
' ''
Task Two: Review current EPA programs to identify factors that might give rise to
differential risk reduction, and develop approaches to correct such
problems.
Task Three: Review EPA risk assessment and risk communication guidelines with
respect to race and income related risks.
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Task Four: Review institutional relationships, including outreach to and
consultation with racial minority, and low-income organizations, to
assure that EPA is fulfilling its mission with respect to these
populations.
To perform these tasks, the Workgroup formed seven subgroups: Health
Effects Subgroup, EPA Programs Subgroup, Risk Assessment Subgroup, Risk
Communication Subgroup, Outreach Subgroup, Regional Perspectives Subgroup,
and the Equity Analysis Subgroup. Two other subgroups were formed later in the
process: The Implementation Subgroup (focusing on the implementation of the
report's recommendations), and the Native American Tribal Issues Subgroup.
The report consists of two parts. The first part — the main body — gives the
background and context of the Workgroup, defines the issues, and summarizes the
Workgroup's findings and recommendations. The second part — this document —
is the supporting document to the summary report, contains the complete findings
of the subgroups. The supporting document is designed to be read along with the
main body of the report, not as a separate document. Some repetition of findings
and recommendations between the main-body, this document, and subgroup
reports occurs. This supporting document also includes expanded examples of
regional equity efforts, including projects not discussed in the summary report.
A NOTE ON TERMS
The terms; used to describe racial population groups are continually changing. The
United Church of Christ's Toxic Waste and Race Report defines "minority
populations" to include: Blacks, Hispanics, Asian/Pacific Islanders, American
Indians [and Alaskan Natives] and other "non-White" persons (UCC, 1987).
However, other terms are also in use today. In this report, Black and African
American are used interchangeably, as are Hispanic and Latino, and Indian and
Native American. TO avoid misreporting research, where studies are discussed in
this report, the original classifications are retained. In charts where information is
not provided for all racial groups, it was absent from the original studies.
Furthermore, this report follows the common practice used in demographics: "race"
differentiates among population groups based on physical characteristics of a
genetic origin (i.e., skin color), and "ethnicity" refers to differences associated with
cultural or geographic differences (i.e., Hispanic, Irish).
The term used in this report to describe the equitable distribution of
environmental protection benefits is also the subject of considerable debate.
Environmental equity, as described above, refers to the distribution and effects of
environmental problems and the policies and processes to reduce differences in
who bears environmental risks. An alternate term is environmental justice. Some
use the term environmental racism to refer to disproportionate environmental risks
in racial minority communities (Rees, 1992).
EPA chose the term environmental equity because it most readily lends itself to
scientific risk analysis. The distribution of environmental risks is often measurable
and quantifiable. The Agency can act on inequities based on scientific data.
Evaluating the existence of injustices and racism is more difficult because they take
into account socioeconomic factors in addition to the distribution of environmental
benefits that are beyond the scope of this report. Furthermore, environmental
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equity, in contrast to environmental racism, includes the disproportionate risk
burden placed on any population group, as defined by gender, age, income, as well
as race. „
The Workgroup recognizes the importance and sensitivity of these terms. The
Workgroup also recognizes that combining racial groups into one category, racial
minorities, can lead to overgeneralizations regarding the risk burdens borne by
different communities. Any perceived misuse of these terms is unintentional.
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2.0 FINDINGS ON HEALTH AND
EXPOSURES
Administrator Reilly's first charge to the Workgroup was to review and evaluate
the evidence that racial minority and low-income people bear a disproportionate
risk burden. This section surveys existing scientific information on the distribution
of health effects and environmental exposures across demographic lines. The
central issue is how an individual's identification with a particular ethnic minority
or socioeconomic group might affect his or her exposure and/or susceptibility to
environmental pollutants. Exposure-related attributes (proximity to sources,
occupation, diet) and susceptibility-related attributes (genetic predisposition,'age,
gender) vary according to population factors such as class and ethnicity.
There are two general groups that are considered to be at high relative
environmental/public health risk:
• Populations/individuals who experience the highest exposures.
• Populations/individuals' who are more biologically susceptible to the health
effects of environmental pollution. These people are more likely than the
general population to develop environmentally induced disease or injury, even
at equivalent exposures.
The subgroup at highest risk is composed of individuals who are more biologically
susceptible and who experience high exposures.
A critical point to keep in mind in reading this section is the difficulty in
distinguishing between the possible effects of poverty, ethnicity and race, and
environmental pollution.
2.1 BACKGROUND HEALTH AND
SOCIOECONOMIC DATA
Clear evidence exists documenting dramatic differences in death rates, life
expectancy, and disease rates between African Americans and Whites. Black and
Hispanic Americans are generally poorer, less educated, have higher rates of
unemployment, are less likely to be covered by health insurance, and are less likely
to own their own homes than White Americans. How the combination of
economic, social, cultural, biological, environmental and possibly other unidentified
variables contributes to the health disparities remains less clear.
2.1.1 Background Health Data
According to statistics maintained by the Department of Health and Human
Services (HHS), age-specific death rates are higher for Black males and females
than their White counterparts in all age groups from 0 to 84 years of age (Census
Bureau, 1990). Based on data from 1987, African Americans are dying at a rate 1.5
times that of White Americans (Census Bureau, 1990). The magnitude of this gap
is comparable to the dissimilarity in crude death rate between Haiti and the United
States. Insufficient research has been conducted to fully understand these different
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death rates. Little evidence exists linking the differences in disease and death rates
to environmental factors; and, for the diseases identified as environmentally
induced, little evidence exists identifying the contributions of class, race or
ethnicity.
Cancer provides a prime example of a disease scientists have studied
intensively, yet about which the combined contributions of race, ethnicity, and
environment remain unclear. Cancer will strike one out of every four Americans.
Documented differences between races for cancer incidence (new cases), prevalence
(existing cases), and mortality exist. Understanding why these differences exist
awaits further .research. Tables 1 and 2 provide the relative cancer mortality rates
for all sites combined and for ten specific forms of cancer.
Table 1: Relative Cancer Mortality Rates (1970s) for Females (* Population With Highest Cancer Rate)
CANCER SITE(S)
All Sites
Breast
Lung
Colon
Ovary
Pancreas
Leukemia
Cervix uteri
Corpus uteri
Non-Hodgkin's
Lymphoma
Stomach
WHITE
1.00
1.00*
1.00
1.00
1.00'
1.00
1.00*
1.00
1.00
1.00*
1.00 .
BLACK
1.16*
0.97
1.00
1.06*
0.79
1.33*
0.88
2.78*
1.74*
0.59
1.73
AMERICAN
INDIAN
0.61
' 0.36
0.43
0.41
0.42
0.66
0.43
1.83
0.55
0.43
1.04
CHINESE
0.70
0.45
1.04*
0.61
0.48
0.81
0.66
0.91
0.62
0.61
1.42
JAPANESE
0.61
0.35
0.48
0.57
0.50 .
' 0.83
0.49
0.64
0.48
0.68
3.25*
Source: Fickle et a], (1990)
Table 2: Relative Cancer Mortality Rates (1970s) for Males (* Population With Highest Rates)
CANCER SITE(S)
All Sites
Lung
Colon
Prostate
Pancreas
Stomach
Leukemia
Bladder
Non-Hodgkin's
Lymphoma
Rectum
Brain & CNS
WHITE
1.00
1.00
1.00*
1.00
1.00
1.00
1.00*
1.00*
1.00*
1.00
1.00*
BLACK
1.33*
1.26*
0.93
2.05*
1.26*
1.95
0.83
0.83
0.69
0.95
0.56
AMERICAN
INDIAN
0.49
0.36
0.36
0.58
0.52
0.99
0.38
0.24
0.39
0.47
0.27
CHINESE
0.81
0.73
0.88
0.34
0.70
1.19
0.61
0.47
0.58
1.05
0.36
JAPANESE
0.65
0.46
0.73
0.37
0.74
3.13*
0.47
0.43
0.62
1.19*
0.29
Source Fickle eL iL (1990)
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Black male and females die from cancer at all sites at rates (33% and 16%,
respectfully) greater than Whites. The overall mortality rate for all other ethnic
minorities is lower than for Whites. However, at specific sites, the picture is more
varied. For example, white females have the highest cancer mortality rate for
cancer of the breast, the leading cancer site for females; yet, Chinese American
women have the highest cancer mortality rate for lung cancer. Variations also exist
for men. A comparison of new cancer case (cancer incidence) rates reveals a
similarly varied picture: African American males have the highest incidence for all
sites combined (23% higher than Whites) and for the two most frequently occurring
cancers (lung and prostate). With the exception of cancer of the stomach, Native
American males have significantly lower cancer rates than the general population.
2.1.2 Socioeconomic Data
Social/cultural factors can increase an individual's or population's susceptibility
due to increased potential or actual exposure (live near pollutant source, activity
patterns) or increased susceptibility to develop health effects. Data on selected
socioeconomic parameters are presented in Table 3. The comparison indicates that
Black and Hispanic Americans are on average poorer, less educated, have higher
rates of unemployment, are less likely to be covered by health insurance, and are
less likely to own their own homes than White Americans. Overall, about 32% of
African Americans and 27% of Hispanic Americans have incomes below the
poverty line, compared with approximately 10% of White Americans.
Tfcble 3: Comparison of Selected Socioeconomic Characteristics by Ethnic Group (1988)
PARAMETER
Median Household Income
Households below poverty level
Median years of school complete
Completed 4 +• years of college
Completed < 12 years of school
Percent of workers unemployed
Covered by health insurance (1987)
Live in own home (1987)
TOTAL
$27,225
13.1%
12.7
20.3%
23.8%.
5.5%
86.2%
64.0%
WHITE
$28,781
10.1%
12.7
20.9%
22.3%
4.7%
87.4%
67.0%
BLACK
$16,407
31.6%
12.4
11.3%
36.7%
11.7%
79.6%
49.0%
HISPANIC
$20,359
26.8%
12.0
10.0%
' 49.0%
8.2%
69.9%
40.0%
Source DOC, (1990)
Several recent studies have suggested that much, if not all, of the differences in
cancer rate between African Americans and Whites can be explained by the effects
of poverty (Navarro, 1990; Basquet et. al, 1991). Indeed, some have interpreted the
results to suggest that if differences in socioeconomic characteristics could be
eliminated, then Blacks would actually have a lower overall cancer rate than Whites
(Okie, 1991; Gibbons, 1991). Others suggest that while poverty and lifestyle can
explain a significant portion of the observed difference, there is still a substantial
amount of variation that seems to be explained only by race or ethnicity (Gladwell
1990; Gibbons, 1991).
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The percentage of Whites and ethnic minorities living in urban versus rural
areas provides an interesting comparison. As presented in Table 4, a much higher
proportion of Blacks,
Hispanics, and other minorities live in urban settings and, conversely, a much
smaller percentage live in rural areas. The higher proportion of White Americans
living in rural areas is striking. To the extent that certain environmental problems
can be connected to the rural population, White Americans may be at higher risk
because of their disproportionate residence in the areas;
Table 4: Comparison of Urban Versus Rural Distribution of Population by Ethnic Group
ETHNIC GROUP
White
Black
Hispanic
Other
LIIVEIN
URBAN AREAS
70.3%
86.1%
91.2%
86.5%
LIVE IN RURAL
AREAS (FARM)
2.3% . .
0.3%
0.7%
0.4%
LIVE IN RURAL
AREAS (NON-FARM)
27.0% "
13.6%
.8.1%
12,5%
Source DOC,(1990)
A key question with regard to environmental equity is not just whether
socioeconomic characteristics and ethnicity are associated with an increased
potential for exposure, but whether they systematically result in higher actual
exposure.
2.2 EXPOSURES
Although environmental measurements in air, water, soil, or food represent
"potential" exposure rather than "actual" exposure. For example, the level of
outdoor air pollution in a particular community is a measure of the potential
exposure for the residents. Individuals residing in the community are likely to
have significantly different exposures to air pollution depending on a number of
factors such as occupation, proximity to sources, indoor pollution sources, and
activity patterns (e.g., time spent indoors versus out). Therefore, although the
potential for exposure may be the same, not all potentially exposed persons will
experience the same actual exposure.
To improve exposure estimates, the environment through which people move
during their daily activities is divided into small "microenvironments." In any. or
all of these microenvironments, a person might encounter polluted air, water, or
food that is the critical predictor of his or her exposure. It is becoming increasingly
apparent that a person's activity pattern is the single most important determinant
of environmental exposures for most pollutants.
2.2.1 Residences Near Waste Sites
Evidence indicates that ethnic minorities are more likely to live near a commercial
or uncontrolled hazardous waste site. In 1982-83, the U.S. General Accounting
Office conducted a study of offsite hazardous waste landfills in the eight
southeastern states that comprise EPA's Region IV. The study found that in three
of the four communities where offsite hazardous waste landfills were located,
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Blacks were the majority of the population. In all four communities, at least 26
percent of the population had incomes below the poverty level, and most of the
population below the poverty level (ranging from 90 to 100 percent) was black
(GAO,1983). Table 5 lists the GACXs findings.
Table 5:1980 Data for Census Areas Where EPA Region IV Hazardous Waste Landfills Are Located
LANDFILL
Chemical Waste
Man.(AL)
SCA Services (SC)
Industrial Chemical
Co. (SC)
Warren County
PCB Landfill (NC)
POPULATION
Number
626
849
728
804
% Black
90
38
•52
66
MEDIAN FAMILY
3NCOME ($)
All Races
11,198
16,371
18,996
10,367
Blacks
10,752
6,781
12,941
9,285
POPULATION BELOW
POVERTY LEVEL
Number
265
260
188
256
%
42
31
26
32
% Black
100
100
92
90
In its study, Toxic Waste and Race in the United States, the United Church of
Christ found that the proportion of minorities in communities with the largest
commercial landfills or the highest number of commercial waste facilities was three
times greater than in communities without such facilities (UCC, 1987). The study
concluded that race was more strongly associated with residence near a waste site
than socioeconomic status. Figure 1 presents the UCC's findings.
Another report by the United Church of Christ concluded that the presence of
"uncontrolled hazardous waste sites" (old industrial landfills and waste sites that
arose before EPA or its laws were created) is highly pervasive. More than half of
the total population in the U.S. resides in communities with uncontrolled toxic
waste sites. The report also found that three out of every five African and Hispanic
Americans live in a community with an uncontrolled hazardous waste site.
A study in 1990 by a non-profit organization found that the EPA remediates
National Priority List (NPL) sites among the rural poor at least as quickly as it does
in the country as a whole (Clean Sites, 1990). EPA also evaluates potential NPL
sites among the rural poor as quickly as it evaluates potential sites nationally;
however, potential sites in rural poor counties are listed on the NPL at half the rate
of potential sites nationally. The report conjectures that this difference may be
attributable to the counties' small population size and/or lack of industrial facilities
that generate hazardous waste. (A site is added to the NPL based on severity of
risk and number of people affected). This study suggested that the Hazard
Ranking System, the system for determining whether the risks at a potential site
warrant placing that site on the NPL, be revised to take into account the
dependence of many rural communities on ground-water as a drinking water
source.
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Figure 1: Minority Percentage of the Population in U.S. Communities with Operating Commercial
Hazardous Waste Facilities
45-
40-
35
30
25
20
15
10
37.6
23.7
12.3
22
Group I Group II Group HI Group IV
Source: UCC, (1987)
Groups:
I. Residential 5-digit Zip code areas without
operating commercial hazardous waste
• treatment, storage and disposal facilities.
II. Residential 5-digit ZIP code areas with one
operating commercial hazardous waste
treatment, storage and disposal facility that is not
a landfill.
in. Residential 5-digit ZIP code areas with one
operating commercial hazardous waste landfill
that is not one of the five largest in the U.S.
IV. Residential 5-digit ZIP code areas with one of
America's five largest commercial hazardous
waste landfills or more than one treatment,
storage and disposal facility.
2.2.2 LEAD EXPOSURES
Lead exposures can and often do occur through multiple pathways and routes (e.g.,
air, paint chips, water, soil, food and house dust). Lead has known physiological
and neurobehavioral effects at low levels and children have shown a far greater
sensitivity than adults. Overall, it is estimated that three to four million children in
the United States (approximately 17%) are at increased risk of lead poisoning
(ATSDR, 1988).
The evidence on lead shows that all socioeconomic and ethnic groups have
children with lead in their blood (blood lead) high enough to cause adverse health
effects. As shown in Table 6, however, a higher percentage of African American
Table 6: Estimated Percentage of Children (Living in Cities with Population Over Million) 0.5-5 Years
Old with Blood Levels Greater Than 15 ug/dl By Race and Income
Income Levels
RACE
Black
White
< $6,000
68%
36%
$6,000 - $15,000
54%
23%
> $15,000
38%
12%
Source ASTDR, (1988)
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children compared to White children have unacceptable blood lead levels (ATSDR,
1988). For both Blacks and Whites, increasing family income is associated with
lower blood lead concentrations. The difference is smallest for the highest income
level, yet there is still a large unexplained difference.
2.2.3 Pesticide Exposures
Exposures to pesticides occur in a variety of ways, including occupational settings;
contact with garden, home, and lawn care products; contaminated food or soil; and
even mother's milk. It is believed by many that racial minorities, especially
Latinos, are at increased risk because of their high representation in the agricultural
workforce (EPA, 1990b).
It has been estimated that farm work not done by farm families is done
primarily by ethnic minorities. 80 to 90% of the approximately two million hired
farmworkers are Latino, followed in order by African Americans, Black Caribbeans,
Puerto Ricans, Filipinos, Vietnamese, Laotians, Koreans, and Jamaicans (Martin et
al.,1985).
For a number of reasons, it is difficult to document the link between pesticides
and health (Perfecto, 1990). However, it is estimated that as many as 313,000 farm
workers experience pesticide related illnesses each year (Wasserstrom and Wiles,
1985; Perfecto, 1990). Another study failed to find significant differences between
Black and White field workers in Florida (Griffith and Duncan, 1983), while data. •
from the National Adipose Tissue Survey for 1982 found that Whites had
significantly higher concentrations of pesticides in adipose tissue than minorities for
five pesticides (Unger and Mack, 1989). No compounds measured in the study
were higher in Non-Whites.
Results from a nationwide study of selected organochlorine pesticides in the
milk of 1,436 mothers found that Hispanic women in the study had higher levels of
dieldrin and oxychlordane, while heptachlor epoxide levels were similar for Whites
and Hispanics (Savage, 1976): However, these data were not adjusted for the fact
that most Hispanic mothers were from the Southwest, where pesticide use tends to
be higher.
EPA's Science Advisory Board (SAB) identified worker exposures to chemicals
in agriculture as a high human health risk due to the large numbers of workers
directly exposed to a range of highly toxic chemicals. "[A]gricultural workers are
exposed to many toxic substances in the workplace. Such exposures can cause
cancer and a wide range of non-cancer health effects" (SAB, 1990). While there is
very little published information on pesticide exposures in general and almost none
at all on differences by call, race or ethnicity, it is clear that since racial and ethnic
minorities comprise the majority of the documented and undocumented farm
workforce, they may experience higher than average risk from agricultural
chemicals.
2.2.4 Air Pollution Exposures
Air pollution is primarily an urban phenomenon. Concentrations of some
pollutants are elevated in large urban areas where emission densities are highest.
As noted earlier, a large proportion of ethnic minorities reside in metropolitan areas
(Table 4, above) and therefore may be systematically exposed to higher levels of
certain air pollutants.
10
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A range of studies argue that air pollution disproportionately impact the poor
and racial and ethnic minorities. One study (Zupan, 1973) found that three of the
major indicators of unhealthful outdoor air quality (i.e., carbon monoxide, sulfur
dioxide, particulate matter) were positively correlated with low-income areas. In a
national study of carbon monoxide in the blood, African Americans were shown to
have higher levels than Whites (DOE, 1982). An examination of nitrogen dioxide
concentrations inside houses of poor minorities in Harlem and Washington Heights
(New York City) found 48-hour average values that exceeded the national standard.
The high nitrogen dioxide levels in these homes of Black and Hispanic families
resulted from almost continuous use of gas-fired cooking stoves, often to heat the
structure during cold weather (Goldstein et. al, 1986).
A study of the distribution of total suspended particulates from 1970 to 1984
found that Blacks experienced higher average exposures and higher average risk
reduction benefits (from air pollution controls). The poor experienced a much
lower relative decrease in exposure than the rich (Gelobter, 1990).
Researchers at the Argonne National Laboratory have found that higher
percentages of Blacks and Hispanics live in EPA-designated non-attainment areas,
relative to Whites, for particulate matter, carbon monoxide, ozone, sulfur dioxide
and lead (Wernette and Nieves, 1991). Table 7 summarizes their findings. Some of
the differences in potential exposure to air pollutants can be explained by regional
variations in demographics and non-attainment statistics. However, the differences
between Blacks and Whites are very surprising given the over-concentration of
Blacks, relative to Whites, in the South (where air pollution is lowest). Also, it is
important to note that Hispanics experience the highest exposure rate nationally for
all pollutants except sulfur dioxide. Because county-level data are used in the
analysis, the authors of the study suggest that they may be either overestimating or
underestimating the population subgroup differences in exposure to air pollutants,
but that underestimation is more likely.
Nieves and Wemette found several patterns in conducting the regional level
analysis. First, the differences in exposure levels between percentages of racial
groups residing in non-attainment areas are generally greatest in the Northeast and
North Central Regions, with the West and the South following. Second, differences
in potential exposure between Blacks and Whites are generally greatest for carbon
monoxide and ozone, and least for lead and sulfur dioxide. Third, in no case are
Blacks and Hispanics to any great degree underexposed to air pollution, relative to
the majority. <
Wernette and Nieves conclude that millions of racial minorities are at increased
relative risk of air pollution exposure, compared to the majority population, using
residence in non-attainment areas as a surrogate for risk
fable 7: Percentages of Ibtal U.S. Whites, Blacks and Hispanics in EPA-Designated Air Quality
Non-Attainment Areas, By Air Pollutant*
AIR POLLUTANTS
Particulate Matter
Carbon Monoxide
Ozone
Sulfur Dioxide
Lead
WHITES
14.7
33.6
52.5
7.0
6.0
BLACKS
16.5
46.0
62.2
12.1
9.2
HISPANICS
34.0
57.1
71.2
5.7 . ,
18.5
*• Hispanics may be of either race, since Hispanic is an ethnic, not a racUl, category.
Source: Wemette and Nieves, (1991)
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2.2.5 Dietary Exposure Through Fish Consumption
Consumption of fish can be an important route of exposure for certain pollutants,
such as PCBs, dioxins, and furans (classes of toxins), which can bioaccumulate in
fish tissues to high concentrations, even when the concentrations of these chemicals
in water are below detection limits. Many variables affect exposure rates to
different pollutants and hence health risks. These variables include: amount of
fish ingested, origin and type of fish, pollutant concentrations in the water body in
which the fish lived, the age of the fish, parts of the fish eaten, the percentage of fat
of the fish, and the way the fish was prepared. Some populations, such as
subsistence fishers (individuals who depend on fish for much of their dietary
protein) and some cultural groups, consume much more fish than the average
population. In addition, evidence suggests that certain populations of recreational
anglers may consume fish at a greater than average rate.
Nearly 20 local and national surveys and reports have examined aspects of
fishing and fish consumption, and several have noted differences based on race and
ethnicity. A recent survey of licensed anglers in Michigan, for example, found that
Native Americans consumed 36% more fish and African Americans 13% more fish
than the Caucasian population (West et al, 1990). Another survey, a California
study of sport fishers, indicates that Asians/Samoans eat the most fish followed in
order by Caucasians, Hispanics, and African Americans (Puffer, 1981). National
surveys also support these findings. The National Purchase Diary (NPD) Survey, a
national survey of 25,000 individuals, found Asians to have the highest fish
consumption rate (SRI, 1980).
Other socioeconomic factors may also play a role in rates of fish consumption.
Several studies found that fish consumption generally increases with increasing age
(West et al 1990; SRI, 1980; NYDEC, 1988). In addition, both the Michigan and
NPD surveys found a correlation between lower education level and higher fish
; consumption. However, studies have generally not found a correlation between
income and fish consumption (SRI, 1980; West et. al, 1990). The one study that did
find a correlation found that fish consumption actually increased with increasing
income (NYDEC, 1988). These studies, however, most often focused on licensed
fishers and may not be accounting for lower-income anglers who do not purchase
licenses but continue to catch and consume fish.
In addition to the quantity of fish eaten, fish preparation and species of fish
eaten can also affect exposure to contaminants and may vary by socioeconomic
factors. Lipophilic (fat-loving) compounds that bioaccumulate, such as PCBs,
dioxins and furans, tend to accumulate in the fatty portions of the fish and
accumulate to a higher degree in bottom feeding species. Eating fish with the skin
and the fatty portion underneath the skin is more likely to lead to higher exposures
of these contaminants than eating skinless, trimmed fillets, as is eating more of the
bottom feeding species. Most risk assessments assume that the population
consumes skinless, trimmed fillets, yet some studies have pointed to differences in
fish preparation by ethnicity. The evidence suggests that ethnic minorities are
more likely to eat fish with the skin, may be less likely to trim the fat, and are
more likely to eat the whole fish (NOAA, 1985; West et. al, 1990). In addition,
preferred fish species differ for different populations. The Michigan study found,
for example, that Great Lakes bottom dwellers were consumed exclusively by non-
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white, low-income populations. A study of anglers in Puget Sound found that
Asians disproportionately consumed clams and the hepatopancreas of crabs
(McCallum, 1985), both practices that might lead to higher relative exposures to
pollutants.
This evidence suggests a greater potential for contaminant exposure to certain
populations through the fish ingestion route. However, these studies were not
designed specifically to address these concerns. Additional studies are needed
before these differences can be consistently and conclusively validated. In this
regard, EPA, in conjunction with the Indian Health Service, is sponsoring a fish
consumption study of four Pacific Northwest Indian tribes which is being
conducted by the Columbia River Inter-Tribal Fish Commission.
EPA's authority to address fish consumption is limited to the section of the
dean Water Act that gives EPA responsibility for setting water quality criteria for
protecting human health. EPA develops its water quality criteria and encourages
the states to set water quality standards assuming consumption over a 70-year
period of two liters per day of ambient, untreated water and 6.5 grams per day of
fish caught in the same body of water. States use their water quality standards as a
basis for determining allowable stream/river loadings for contaminants discharged
from industrial facilities and from other sources.
In order to determine the average amount of fish consumed, EPA examined
available studies and decided to use the 1977-78 survey conducted by the United
States Department of Agriculture (USDA). All the studies examined had
shortcomings. EPA decided to use the USDA survey because, at the time, it was
the most recently completed study and because it was a large, broad-based national
survey. That survey indicated that the average individual consumed 6.5 grams of
estuarine fish per day and 14.3 grams of all types of fish per day.
In 1988, the Office of Waiter (OW) became concerned that the fish consumption
rates it was using might not be adequate to protect human health when they noted
that the number of fish advisories was increasing. With the exception of Fish and
Wildlife Service's responsibility for issuing fishing advisories in Federal Wildlife
Refuges, states are responsible for issuing fishing advisories when fishjn a
waterbody are unsafe to eat. OW gave the American Fishing Society a grant to
collect information regarding state practices and criteria for issuing fishing
advisories and their recommendations for technical assistance they needed from
EPA.
EPA has implemented the three activities the states identified as being most
useful to them. First, OW developed uniform procedures for sampling and
analyzing fish species to determine pollutant concentration levels occurring in fish,
including information on which species to analyze, the age/size of fish to consider,
the fish parts to include in the measurement, and the contaminants to be analyzed.
OW worked with the states to develop guidance to address these issues arid
expects to release it in November 1992. OW plans to hold workshops in Fiscal Year
1994 to train the states on use of these guidelines.
EPA is also developing guidance for states to use in implementing fish
consumption surveys to determine site specific consumption rates f pr use in
developing state water quality standards. OW started work on these guidelines in
1988 and held a workshop for national experts on this subject in December 1991.
EPA announced the availability of a document to help states develop consumption
rates in April 1992 to ensure adequate protection of local populations consuming
more fish than the national consumption rates. The office distributed copies of the
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guidance to the states and others who had participated in its development and has
been filling about 30 requests a day for it ever since.
OW also established an electronic bulletin board to help states share
information on fishing advisories. The bulletin board was initiated about 11/2
years ago and includes all currently effective fishing advisories and an annotated
bibliography of all documents related to the consumption rates and advisories. The
bulletin board allows users to query other users for useful information they may
have.
2.3 ENVIRONMENTAL HEALTH EFFECTS
The difficulty in establishing a causal relationship between health effects and
environmental exposures stems from a multitude of factors. First, the etiology of
many diseases has not been fully elaborated. Second, most diseases to which
environmental exposures may contribute have a plethora of possible causes. People
are also routinely exposed to a vast array of environmental agents—few of which
are quantified. Fourth, the latency period for health effects from long-term, low-
level exposures may be 20 years or more. Fifth, environmental pollutants may
cause multiple health effects. Finally, a single health effect may result from
multiple exposures.
Relatively little information exits on the influence of class, race or ethnicity on
environmentally induced disease. Most of the work has emphasized differences in
disease rates between various groups where a strong likelihood exists that
environmental exposure plays a causative role. Lung cancer and Chronic
Obstructive Pulmonary Disease (COPD) are two health outcomes for which
environmental exposures may have a causal effect.
Lung cancer accounts for about 14% of all cancer incidence and 23% of all
cancer deaths (NCI, 1989). The incidence of lung cancer in Black men is
significantly higher than any other ethnic group, 0.5 times higher than Whites,
more than 2.5 times higher than Hispanics, 1.5 to 3.5 times higher than Asians, and
more than 8.0 times higher than Native Americans (NCI, 1984). It is estimated that
cigarette smoking is responsible for about 85% of lung cancer eases (NCI, 1984).
Other risk factors that can contribute to the disease are exposure to asbestos,
ionizing radiation, and a number of chemicals, including benzene and inorganic
arsenic.
The higher smoking rates among Black men (34% who smoke compared to 28%
for Whites) is undoubtedly responsible for much of the difference (NO, 1984).
Nevertheless, it is not clear that smoking can explain all of the variability,
especially the eight-fold difference between Blacks and Native Americans. Air
pollution, along with other pollutant exposures, may play a role in this disparity. -
COPD, which includes emphysema, chronic bronchitis, asthma, and allied
conditions, accounted for about 3.5% of all deaths in the United States in 1987, up
from 1.6% in 1970. An estimated 10% of all Americans are afflicted with COPD,
with asthma alone affecting as many as 20 million people (NCHS, 1990).
When viewed as a single entity, COPD is more prevalent in Whites than Blacks
and more prevalent among Blacks than other ethnic minorities. Both African
Americans and Whites exhibit a significantly higher incidence among poor people.
A comparison of COPD by ethnicity and income is given in Table 8.
The implications of COPD'for environmental equity are not
entirely clear. It is not yet possible to separate the effects of smoking and
occupational exposures from environmental exposures or to assess the role of
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varying susceptibility. However, the effect of exposures to environmental
pollutants on the prevalence;, morbidity, and mortality of COPD is believed to be
Table 8: Prevelance of Chronic Respiratory Conditions (per 1,000) for 1985-1987 by Income and Ethnicity.
FAMILY INCOME
Total
Chronic Bronchitis
Asthma
Emphysema
WHITE
Total
102.7
53J5
39.6
9.6
<$20,000
125.8
64.6
42.7
18.5
>$20,000
95.0
50.1
39.7
5.2
BLACK
Total
81.0
35.3
423
3.5
<$20,000
97.1
42.6
49.9
4.6
>$20,000
58.0
28.1
29.2
,0.7
OTHER
Total
53.0
27.1
22.6
33
<$20,000
51.3
27.0
21.1
33
>$20,000
53.3
24.6
24.6
4.1
Source NCHS, (1990)
greater than on cancer rates (Becklake, 1990; Poll and Peto, 1981). One hypothesis
is that air pollution exposures vary by race, ethnicity, and class, explaining part of
the variability in COPD.
2.4 CONCLUSIONS
There are clear and dramatic disparities among ethnic groups for death rates, life
expectancy, and disease rates. There is also a surprising lack of data on human
exposures to environmental pollutants for Whites as well as for ethnic and racial
minorities. One exception is lead exposures in children, and there the data are
unequivocal: Black children have disproportionately higher blood lead levels than
White children even when socioeconomic variables are factored in. For other
pollutants, available information suggests that racial minorities may have a greater
potential for exposure to some pollutants because they tend to live in urban areas,
are more likely to live near a waste site, or exhibit a greater tendency to rely on
subsistence fishing for dietary protein. ,
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3.0 EPA PROGRAMS
EPA programs are devoted to the control of pollution in specific environmental
media (e.g., air, surface water, drinking water); the manufacture, distribution and
use of hazardous substances in commerce and agriculture; and the management
and clean-up of solid and hazardous wastes. The legislation authorizing these
programs gives EPA, the States, and municipal governments different regulatory,
implementation, and enforcement powers and responsibilities in each of these
program areas. Administrator Reilly charged the workgroup with reviewing
current EPA programs to identify factors that might give rise to differential risk
reduction, and to develop approaches to correct such problems.
A general review of EPA programs reveals variations, within and among the
program offices, in addressing the distribution of risks across population groups.
Some offices explicitly consider the distribution of risk and high risk populations in
their decision-making processes. For example, the Office of Pesticide Programs
(OPP) identifies and addresses risks to population groups, particularly agricultural
workers, through the special review, reregistration and registration programs. For
dietary exposure, OPP has a system in place that can examine consumption of
various commodities based on gender-, ethnic- and age-specific patterns. OPP uses
the system to examine exposure of 22 population groups. In addition, OPP
routinely uses "safety factors" and specialized risk assessments to address equity
issues. Another example is the Office of Water's drinking water program which
considers exposure from all sources and to the most exposed and sensitive
individuals. However, there has never been a consistent EPA policy to address
equity issues.
Some of the variation between EPA program treatment of environmental equity
may be because equity issues may be more prevalent with respect to some
environmental problems, which may be reflected in the EPA programs. Also,
statutory authority and state responsibilities affect the degree to which EPA
programs (as opposed to state and local programs) address equity concerns.
The Task Two Subgroup had two different projects that focused on
environmental equity in EPA program offices. The first project was in the Office of
Solid Waste and Emergency Response (OSWER). OSWER held workshops for staff
members and management that were designed to identify possible environmental
equity problems and develop solutions. The second project focused on
environmental equity issues within the Office of Air and Radiation (OAR). For this
project, the Office of Policy Analysis and Review within OAR conducted an
analysis of their programs with respect to environmental equity issues. A report of
their analysis was then written and circulated to OAR staff.
These two projects provide program staff with examples of how environmental
equity issues can be approached within their programs. These are only two of the
many approaches which can be used in evaluating and dealing with environmental
equity issues within EPA programs. As awareness of environmental equity issues
increases and as the Workgroup's recommendations are carried out, the program
offices will undoubtedly refine methods for identifying possible equity problems,
developing solutions and adopting measures of success.
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3.1 OFFICE OF SOLID WASTE AND EMERGENCY
RESPONSE
The subgroup decided that its review of EPA programs needed the involvement of
program managers: Identifying factors that might give rise to a differential
distribution of program benefits and developing solutions to any identified
problems requires knowledge of the governing laws and regulations, and the
processes that are used to keep these programs functioning. In an early effort to
involve program managers, the subgroup found that most program managers were
not aware of the Environmental Equity Workgroups efforts to examine these issues
in EPA programs. Unless program managers were familiar with the data,
information, and concerns regarding environmental equity, they could not be
expected to examine their programs thoughtfully and carefully. To introduce
program managers to equity issues, the Subgroup held four Environmental Equity
Awareness Workshops. These workshops were held for OSWER program
managers.
3.1.1 General Conclusions of Awareness Workshop Participants
OSWER managers were chosen as the participants in the pilot workshops for
several reasons:
/ -••,•' ' •
' . •', Much of the equity literature involves the siting of hazardous and solid
waste management feicilities in minority and low-income communities.
• Environmental equity may become an issue in die impending
reaufliorization of the Resource Conservation and Recovery Act (RCRA).
In each of the workshops, participants expressed the following general views
with respect to the ability of program managers to identify and address the
potential equity concerns in their programs:
• Environmental equity awareness workshops or similar forums are necessary
J- to help program managers identify equity issues.
• The scope of the environmental equity problem is still unknown, and
further research is needed to understand the magnitude and elements of
equity problems.
• It is difficult to assess how the formal and informal decision-making
processes within a program influence program results in general and with
respect to equity. '
• The Agency should adopt an environmental equity policy or include equity
objectives in program mission statements. _ , • •
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3.1.2 Specific Problem Areas
/
Specific problem areas discussed by OSWER managers involved the siting and
permitting of solid and hazardous waste facilities, risk analysis, and risk
communication. These problem areas and the preliminary recommendations of
OSWER program managers are discussed below. OSWER managers also
recommended that equity training be part of the training received by Agency
personnel and suggested that low-income and racial minority individuals would be
the primary beneficiaries of positive results arising from EPA's pollution prevention
initiative.
. Siting and Permitting of Waste Facilities. OSWER managers recognize that the
siting and permitting of hazardous and solid waste management facilities raise
socioeconomic factors that are distinct from technical concerns (geohydrology,
depth to groundwater, etc.). They also believe that one result of the "not in my
backyard" (NIMBY) syndrome is that such facilities will tend to be located in
communities with the least ability to mount a protest. They pointed out that this
problem is compounded when wastes from Superfund sites are brought to
commercial hazardous waste management facilities as a result of community
opposition to incineration of the hazardous waste at the Superfund site.
In this context, the division of authorities between Federal and state
governments be explained: the siting of waste facilities is controlled primarily by
state and local governments. Land uses historically have been governed by the
states, and attempts by the Federal government to control local land uses have
often been met extreme opposition. EPA's role in permitting comes after the site
has been chosen, and principally involves technical considerations. However, EPA
should assess the feasibility of providing enhanced leadership to states to correct
problems in the siting of waste facilities.
To assist in overcoming the problem of actual and perceived disproportionate
siting in minority and low-income communities, EPA, according to workshop
participants, should exercise increased oversight in the siting and permitting of
hazardous and solid waste management facilities. One possibility would be to
increase EPA's role by conducting case-by-case analyses to determine the risks
these facilities pose to the health of communities in which they are to be located.
To consider these risks, workshop participants suggested that regulators could:
• Add the risks posed by a new facility to the risks posed by polluting
facilities already located in the community to ensure that risk remains
below an acceptable threshold; or
• Characterize the health of community members at the time of siting to
ensure that new threats are not added to the health of populations already
subject to pollution burdens.
Workshop participants stressed that RCRA facilities receiving Superfund
hazardous wastes, like RCRA facilities receiving other types of hazardous waste,
should always be in compliance with applicable Subtitle C (hazardous waste)
regulations. They also suggested that equity awareness be part of the training of
permit writers, and that it would be desirable for communities to take a more
active role in the solid and hazardous waste facility permitting process. They
suggested that making technical assistance grants (TAG) (currently available under
18
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EPA's Superfund program) available to hire outside experts to explain a proposed
facility's risk would help facilitate this process.
Risk Analysis. Workshop participants pointed out that the aggregate human
health risks posed by all types of industrial facilities in a particular community are
not addressed in EPA programs. They believed that this failure can be attributed
partially to the inherent difficulty of performing such analyses and to the Agency's
structure and mission which is fragmented under many different pieces of
legislation into problem-specific program areas.
Workshop participants believed that area environmental studies are necessary
to understand the importance of cross-media environmental impacts in poor and
racial minority communities. They suggested that the Agency perform cross-media
pollution studies for heavily Industrialized areas similar to the study that the
Agency has already performed for the City of Baltimore.1 The findings of such
studies would help to characterize the scope of environmental equity problems and
to develop methods for addressing these problems.
Workshop participants also suggested additional funding to the Agency for
Toxic Substances and Disease Registry (ATSDR) to gather epidemiological data and
to study aggregate risk in heavily industrialized areas of the country, In a specific
example, a workshop participant suggested that the Agency reexamine its
methodology for setting priorities for corrective action at RCRA facilities to
consider a facility's location and surroundings as well as the risk-producing
conditions at the facility itself.
Risk Communication/Outreach. The Agency devotes considerable resources to
risk communication and outreach efforts, especially in the Superfund program.
These efforts include community outreach projects, the use of -TAGs to help
communities hire outside experts to describe the risks posed by Superfund sites in
their communities, and the translation of EPA bulletins and notices into non-
English languages.
Workshop participants believed that these risk communication and outreach
efforts should be evaluated to determine their effectiveness and to ascertain
whether or not these programs reach into poor and racial minority communities.
They noted that the poor and racial minority communities are rarely involved in
Agency rulemakings and seem to be unaware of their ability to use Agency
resources as well as of their ability to petition ATSDR to perform health surveys in
their communities. This underscores the Agency's need to improve its outreach
programs to these communities. Barriers to effective risk communication and
outreach that were identified included the inherent difficulty of making complex
technical material understandable to lay people and the complexity of the TAG
application process. - , '
Workshop participants had the following risk communication
recommendations:
• Risk communication and environmental education projects should be
specifically targeted to poor and racial minorities. Such projects should be
sensitive to the specific needs and cultures of these communities.
1 The Baltimore Integrated Environmental Management Project examined leakage from underground
storage tanks, pollution in Baltimore Harbor, hazards from the abatement of lead paint, indoor air, and
air toxics (EPA 1987a,b,c,d,e,f,g). . '
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• Superfund's strong emphasis on risk communication should be used as a
model for other EPA programs.
• Communities should be informed about the materials and information
available that explain the risks posed by facilities in their communities.
Equity Training for EPA Personnel Workshop participants strongly
recommended that additional equity awareness workshops be held and that equity
training be made a part of existing EPA training programs. They believed that
some kind of training was necessary to be able to identify issues and policies with
equity impacts.
Pollution Prevention. Workshop participants pointed out that EPA's pollution
prevention initiative, to the extent that it is successful, should help to mitigate the
adverse health impacts experienced by racial minority and low-income individuals
as a result of exposure to pollution and polluting facilities. Reducing the quantity
and toxicity of waste should result in smaller quantities of waste and less toxic
waste being sent to the hazardous and solid waste management facilities s(often
located in racial minority and low-income communities). Fewer and less toxic
emissions to the air should help to improve air quality in urban areas where racial
minorities live in high numbers. Fewer and less toxic emissions to surface waters
reduces the risk to racial minorities and the poor who depend on fishing as an
important source of food. Protection of groundwater benefits the rural poor
communities in the U.S. that depend on groundwater as their primary drinking
water source.
3.2 OFFICE OF AIR AND RADIATION
The Office of Air and Radiation (OAR) has responsibility for environmental and
pollution policy, standards development, and implementation programs pertaining
to air and radiation. Currently the bulk of OAR's resources are focused on
implementation of the Clean Air Act of 1990. This section examines equity issues
relevant to OAR by asking two questions:
• What evidence exists that communities susceptible to particular health
problems may be disproportionately exposed to pollutants?2
• What types of impacts bearing on the issue of environmental equity
could be produced by the 1990 Clean Air Act Amendments?
Intertwined with these questions are suggestions for changes in Office of Air and
Radiation programs.
A'R alSO examined C5dstinS evidence of disproportionate exposures. See the
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3.2.1 Composition Of Populations Sensitive To Air
Pollution
Based on the limited data available, several population groups identified as being
sensitive to the health effects of air pollution seem to be disproportionately
comprised of low-income or racial minority individuals. These groups include
asthmatics, people with certain cardiovascular diseases or anemia, and women at
risk of delivering low-birth-weight fetuses.
EPA staff have identified asthmatics as particularly sensitive to the effects of
carbon monoxide (OAQPS, 1984), sulfur oxides (OAQPS, 1982a), particulate matter
(OAQPS, 1982b), ozone (OAQPS, 1988), and nitrogen oxides (OAQPS, 1982c). The
available literature indicates that African Americans, especially in the lower income
brackets, suffer from asthma at a rate greater than the population as a whole (See
Table 8, in section 2.3).
Schwartz et al. found that, in children between six months and 11 years of age,
asthma prevalence was 73. percent in Blacks versus 3.0 percent in Whites. Even
after adjusting for factors such as young maternal age at birth, low birth weight
and income, Blacks were 'still at higher risk for asthma and frequent wheeze attacks
than were Whites. The authors stated that whether racial genetic differences exist
in susceptibility to asthma is uncertain (Schwartz, 1990). Mak et al. also found a
significantly higher prevalence of asthma among Blacks (Mak, 1982). Goldstein and
Weinstein state that "clinical impressions suggesfasthma prevalence among low-
income nonwhites to exceed by a factor of up to 3-4 the prevalence of asthma in the
population as a whole." (Goldstein and Weinstein, 1986).
Schwartz et al. found that low income was associated with asthma as well.
They refer to other research showing poverty to be a "source of stress, which may
play a role in the etiology and expression of bronchial responsiveness and asthma."
(Schwartz, 1990).
According to OAR staff papers, individuals suffering from cardiovascular
disease are among those most sensitive to the effects of sulfur oxides (OAQPS,
1982a) and particulate matter (OAQPS, 1982b). A 1987 study argued that the
mortality rate for cardiovascular disease among Blacks was about 37.5 percent
higher than it was among Whites (UCC, 1987).
OAR staff also report that individuals suffering from anemia are particularly
sensitive to the effects of carbon monoxide (OAQPS, 1984). In 1987, Black mortality
rates for anemia (per 100,000) were 2.6 (male) and 2.0 (female). For Whites, the
corresponding figures were 0.8 and 0.6 (HHS, 1991). Morbidity statistics show that
Blacks reported an average of 21.6 incidences (per 1,000) while Whites reported 12.8
(NCHS, 1990).
The underlying causal factors for the difference in disease rates could be: (1)
exposures to air pollution; (2) exposures to other aggravating factors; and/or (3)
innate susceptibilities. Further work is needed confirm these patterns, and, if
confirmed, to untangle which of these factors best explains the differences in health
effects.
If different exposures to air pollution are a factor, then EPA must decide
whether and how to redress those differences. The Agency could consider any
number of steps, from enhanced education for the affected populations (e.g.,
21
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alerting black or low-income populations to their increased risk for asthma and
what to do in case of an attack) to regulatory action. If differences in innate
susceptibility to conditions aggravated by air pollution are established, then OAR
should assess whether it has adequately protected those sensitive populations in
setting air pollution standards.
3.2.2 1990 Clean Air Act Amendments
The 1990 Clean Air Act Amendments potentially can affect the differences in
pollution exposure between ethnic and economic groups. The following analysis
examines the 1990 Clean Air Act and describes the potential equity impacts.
Urban Exposures. The 1990 Clean Air Act Amendments provide powerful new
tools—and strengthen old tools—to ensure that the national ambient air quality
standards (NAAQS) are attained nationwide. Most (although not all) of the
nation's serious non-attainment problems occur in urban areas. To the extent urban
air quality is improved via the Act, a higher percentage of racial minority
populations will experience greater improvements in air quality than Whites
because of their greater representation In urban areas and because of the high levels
of pollutants in these areas (see Table 4, Section 2.1.2).
The central planning mechanism for attaining the NAAQS will be the State
Implementation Hans ("SIPs"). The SIPs could contain simple tracking mechanisms
for evaluating their effect on racial minority and low-income populations relative to
white and higher-income populations. For example, as carbon monoxide ambient
air quality data are collected and submitted, EPA could compare the trends in areas
predominantly occupied by racial minorities or the poor with the trends in other
areas.
Title HI of the Amendments (section 112 of the Act) adds a comprehensive
program to regulate toxic air pollutants, supplementing the more limited toxics
program which had been in place since 1970. Section 112(d) requires EPA to set
national standards requiring Maximum Achievable Control Technology for sources
of 189 listed toxic air pollutants. Section 112(k), entitled "area source program",
directly addresses the problem of long term exposure to toxic air pollutants in
urban areas, which tend to have high minority populations. The express purpose
of section 112(k) is to achieve a reduction of "not less than 75 percentum in the
incidence of cancer attributable to emissions" from urban air toxics sources. To
translate this goal into specific controls, section 112(k)(3) requires the development
of a national strategy for regulating area sources of toxic air pollutants. An EPA
risk approach to this strategy can help address air problems in high-risk
populations, such as those found in many minority communities.
The 1990 amendments also added section 112(r), which is designed to reduce
the risks of accidental releases of toxic air pollutants such as the incident in Bhopal,
India, which resulted in extensive adverse health effects to lower income
communities located near the Union Carbid^ chemical plant. Among other things,
section 112(r) will require businesses using certain toxic pollutants in above-
threshold amounts to develop risk management plans. It also gives EPA new
authority to issue administrative orders to abate substantial and imminent threats
to health or welfare due to accidental releases. This authority will provide EPA
with additional tools to address risks to communities located near hazardous
chemical facilities.
Title V of the Clean Air Act (CAA) establishes the requirements for state permit
programs, describes permit requirements and conditions, defines the sources to be
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covered by operating permits, and provides, for notification to EPA and
surrounding governmental entities of permit applications and actions. This portion
of the Act does not explicitly add new authority to EPA's ability to consider equity
when establishing or implementing regulations. However, the permitting
provisions may provide EPA the opportunity to object to any permit on the basis of
other requirements of the Act which are related to increased environmental risks
associated with exposed communities (Section 505(b)):
"If any permit contains provisions that are determined by the Administrator as
not in compliance with the applicable requirements of this Act...the
Administrator shall...object to its .issuance."
In addition, Section 173(a)(5) gives EPA explicit authority when evaluating
preconstruction permits to examine "social costs imposed as a result of its [a new
major source in nonattainment area] location, construction, or modification." To
the extent that EPA is able to establish clear standards for evaluating the equity
impacts of permits, the Agency may be able to use these sections to raise equity
concerns.
Section 108 of the CAA requires the Administrator to publish air quality criteria
and control techniques that include information on any known or anticipated
adverse effects on welfare. EPA has limited its consideration of welfare to property
and agricultural impacts: More could be done to address socioeconomic aspects.
. Section 110 of the Act gives states a great deal of flexibility in deciding what
control strategies to use to meet air quality standards. EPA could provide more
information on the socioeconomic impacts of different control options to allow
states to evaluate equity concerns.
The flexibility afforded industry may alter emission patterns. It is essential that
OAR examine its programs and policies to a greater extent to determine whether
they place poof and/or racial minorities at greater risk. The emissions trading
program may have important environmental equity consequences, such as the
innovative trading plan proposed for the Los Angeles air basin. There may be a
real possibility of .increasing or decreasing the concentrations of emissions in one
part of a basin through trading pollution credits from another. Outside of the acid
rain provisions, the CAA does not require any emissions trading. These non-acid
rain trading plans will be state or local initiatives and are currently more theory
than real programs. However, EPA will have substantial impact on the structuring
of these programs through guidance issued for State Implementation Plans or
operating permit programs.
Siting of New Major Sources. As raised previously, the siting of hazardous waste
facilities which are stationary sources of air'pollution raises equity concerns (see
Section 2.2.1). The primary Title I provisions addressing siting of new major
sources are: the Prevention of Significant Deterioration (PSD) and visibility
provisions in Sections 165 to 169 for attainment areas, and section 173 for non-
attainment areas.
The PSD and visibility sections, which focus on protecting "clean air" areas and
national resources such as parks, do not explicitly address equity considerations.
The main pressures applied to new sources by these parts of the Act are to apply
Best Available Control Technology (BACT) and to avoid violating certain ambient
air pollution levels. By requiring BACT in all areas where new major sources are
sited, the provisions increase pollution prevention in all communities. Admittedly,
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better organized communities are more equipped to participate in the control
equipment decision process. However,
equipment standards set in these communities will apply in all subsequent BACT
determinations.
Section 173 specifies the requirements for preconstruction permits to be issued
for new major sources locating in areas not attaining any one of the NAAQS—"non-
attainment areas." Discretion in the implementation of Section 173(a)(l) could
impact low-income areas. Section 173(a)(l) provides:
The permit program provides that permits to construct and operate may be
issued if (A) offsetting emissions reductions are obtained; or (B) if the
source is located in a zone identified for targeted economic development
for which a "growth allowance" to accommodate emissions increases from
new sources is contained in the State Implementation Plan for the area.
Thus new facilities could be sited more easily in economically depressed areas.
OAR should pay close attention to the distribution of pollution increases and
offsets to ensure that demographic groups are not consistently targeted for
pollution increases.
Health Effects Associated with Air Pollution. The Act contains several provisions
involving health or risk assessments and setting of health-based standards that
could address potential risk inequities. The Act provides for health-related studies,
clearinghouses, or health standards for which EPA could: (1) analyze in detail the
distribution of the health effects of air pollution; (2) sponsor new research; and, (3)
use this information in setting health-based standards. Several examples are listed
below.
Section 103(d) requires the Administrator to conduct a research program on the
short-term and long-term effects of air pollutants, and specifies that an assessment
be prepared for each of the newly-listed Section 112(b) hazardous air pollutants.
Section 108(a) instructs the Administrator to issue air quality "criteria"
documents for those pollutants for which national ambient air quality standards are
established. The Administrator must include in those documents a description of
the "latest scientific knowledge useful in indicating the kind and extent of all
identifiable effects on public health or welfare which may be expected from the
presence of such pollutants in the ambient air." Studies analyzing the effect of air
pollutants on different population groups (such as African Americans with asthma
or high blood lead levels) could be included in such criteria documents.
Section 109(b) legislates the setting of national primary ambient air quality
standards, which are based on the criteria documents and provide an adequate
margin of safety to protect the public health. If one segment of the population is
more susceptible to health effects associated with the NAAQS pollutants, such
information should be incorporated when the primary standards are set or revised.
Section H2(f) provides for a report which discusses methods of estimating
residual risk to the public health (risk remaining after the technology-based
standards have been set) from hazardous air pollutants. Research could address
the question of whether racial minority or low-income populations have higher
hazardous air pollutant residual risk.
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Section 112(k) directs EPA tp conducta research program on the problem of
toxic air pollutants in urban areas. This program is to include a study of the health
effects of smaller urban sources of toxic air pollutants, and of the chronic and acute
health effects of smog-forming compounds and acid aerosol formation. The
implementation of the urban area focus of this provision has obvious implications
for many areas which have higher exposure or higher risk populations.
Section 112(p) directs the establishment of the Mickey Leland Urban Air Toxics
Research Center. Part of the Center's mission could be to research racial or income
differences in hazardous air pollutant exposure, risk, or health effects.
Furthermore, the Center could study the cumulative impacts of multiple sources
and chemicals, and different pathways of exposure.
The Chemical Safety and Hazard Investigation Board established by Section
112(r) could evaluate, as part of its investigative process, the income and racial
composition of communities in which serious accidental releases occur.
Alternatively, EPA could take on this task as part of its own broader assessment of
accidental releases.
Section 202(1) mandates an EPA study examining the need for emission
'standards specifically aimed at several toxic air pollutants. In conducting this f
study, EPA could also ask the question, are low-income or racial minority
populations differentially susceptible to the health effects associated with mobile
source toxic emissions?
Section 108(e) requires EPA to publish guidance for the states on the
development.of transportation measures necessary to demonstrate and maintain
attainment of the NAAQS. Such guidelines could advise the'states to actively
involve members of minority and low-income constituencies in their planning and
public participation processes.
Section 312 instructs EPA to complete "a comprehensive analysis of the impacts
of this Act on the public health, economy, and environment of the United States."
The first version of this analysis is to be completed in 1991, and updates are to be
submitted to Congress starting in 1992. Such impact assessments could discuss the
Act's effects on racial minorities and low-income populations.
Socioeconomic Effects. Several sections of the Act might allow EPA to examine
how the economic effects associated with the Air Act will be distributed among
different communities and might provide avenues for community involvement in
the decision making process. The limited theoretical and empirical studies
available tell a somewhat mixed story. Only one of the studies examined cost-
benefit distribution of environmental benefits and costs relative to economic level; it
found that average air pollution costs as a percent of income were regressive
(Gianessi et. al, 1979). On the benefits side, low-income and/or minority
populations benefitted as much (and sometimes more) from pollution abatement
efforts as did middle- and high-income groups. However, since low-income groups
often started out with poorer air quality, their greater benefits still resulted in
poorer air quality relative to more affluent groups.
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3.2.3 Conclusions
The literature available illustrates that exposure, siting, sensitivity, and the
distribution of air pollutants raise issues of equity in the Office of Air and
Radiation's programs. Available studies do not demonstrate or raise the suggestion
OAR's policies have resulted in differential allocations of environmental benefits.
However, the literature examined suggests that minority and low-income
populations have experienced poorer air quality because they live in urban areas,
have in some cases lived in closer proximity to air polluting facilities, and been
represented more in groups sensitive to certain air pollutants than have non-
minority and higher-income people. The Clean Air Act of 1990 aims to improve air
quality for all Americans. Provisions in the Act provide opportunities to address
the sensitivities and risks of low-income and racial minority populations. Overall,
the Acf s strict non-attainment provisions should result in improved air quality for
the low-income and racial minority communities.
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4.0 NATIVE AMERICANS: DISTINCT
ISSUES
Administrator Reilly charged, the Workgroup with evaluating the evidence that
racial minority and low-income people bear a disproportionate risk burden. As the
Workgroup began to frame its analysis, it recognized that the trust relationship
between the federal government and sovereign Native American tribal
governments results in distinctive environmental issues. The trust relationship,
based on treaties and legislation, differs greatly from that between federal and state
governments. To address the environmental equity issues facing Native Americans,
the Workgroup formed a Native American Tribal Issues Subgroup.
4.1 REGIONAL INDIAN COORDINATOR
CONCERNS
Currently, Indian reservations are not often considered in risk policy. Only
recently have risk initiatives begun in Indian country. Environmental Equity
Workgroup staff met with Regional Indian Coordinators in May, 1991. The
Regional Indian Coordinators raised several concerns:
• Indian Tribes may be at a higher risk than the average population due to high
wild food consumption, contaminated drinking water sources, high levels of
radioactivity found on reservations and high fish consumption rates. In
addition there is a lack of an environmental protection infrastructure or
organization to carry out the responsibilities associated with environmental
protection on many reservations.
• While individual risks may be high on reservations, Indian Tribes could be
overlooked in EPA's risk-based approach, especially if population risk is the
primary method of risk analysis. Due to the "large land mass — small
population" situations of reservations, population risk will often be small
relative to other, especially urban, population groups.
• EPA's existing risk analysis methodology may not include factors that
accurately assess risk in Indian country.
• There is a perceived inequity by Native Americans in how the Agency funds
Tribal and state governments for the same programs under the same statutory
- authority.
• Indian tribes are substantially behind states in environmental protection
infrastructure development. This may contribute to higher environmental risks
on Indian reservations.
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4.2 WISCONSIN TRIBES COMPARATIVE RISK
PROJECT
In response to these and other concerns, a comparative risk project was initiated to
examine the 11 tribes in Wisconsin. The project is a cooperative effort between:
Office of Policy Planning and Evaluation's (OPPE) Regional and State Planning
Branch, Region V Indian and Planning Staff, and the Office of Water (OW). The
project was initiated to provide preliminary information on the following areas3:
• Determine the highest environmental risk facing the Wisconsin Tribes;
• Learn how the comparative risk framework and methods could be adjusted for
the different cultural and environmental factors that affect Tribes; and
• Determine how the risks facing Tribes compare with those facing America
generally, Region V, and the state of Wisconsin.
For this project, comparative risk methods were adapted to fit tribal conditions.
Wisconsin Tribes are Great Lakes, woodland Indians that rely heavily on a
subsistence lifestyle. The project also took into account the Tribes' fixed land base
and cultural and religious values. Studies were obtained that calculated the
average consumption of local fish, game and other wild foods gathered by Native
Americans. The exposure assessment took into account actual levels of
contamination in fish and game when calculating the intake of contaminants from
these foods. (
The methodology used in the analysis for this study was adapted to include
damages to cultural and religious values and subsistence lifestyles. This is a
deviation from existing EPA comparative risk methodology. Interestingly, it
showed some significant damages and changed the ranking of traditional
environmental problem areas.
Food contamination was added to the list of problem areas analyzed. In
previous comparative risk projects .not focused on Native Americans, food
contamination was not determined to be a high risk. Although pesticide residues
on commercially prepared foods have been found to be a high risk in other
projects, food contamination would have ranked as a high risk in this project even
if pesticides were excluded: Nearly all of the risk was found to result from PCB
and mercury contamination. Food contamination, in fact, was among the highest
health risk.
In the analysis, industrial activity ranked lower than in other projects. Tribes in
the region have avoided industrial development in order to preserve the local
environmental quality. This is in direct contrast to the problems characterized for
Region V.
The project also revealed that criteria air pollutants ranked much lower than in
other projects. However,, acid deposition (SOx and NOx) was the exception,
It must be noted that this comparative risk project analysis was accomplished within a very short time
frame and with limited funding.
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ranking in the top three problems in the Ecological Risk category, along with point
sources and physical degradation of aquatic habitat.
Along with food contamination, the highest ranked problems in the Health Risk
category were non-point sources (non point source excludes runoff of pesticides,
but includes air deposition of pollutants), indoor air, and radon.
The rankings for the Economic and Social risk were: Non point sources,
physical degradation of aquatic habitat, food contamination, physical degradation
of terrestrial habitat, urimanaged waste, and acid deposition.
One of the projects most significant findings was the need for environmental
protection infrastructure for tribes. The lack of an environmental protection
infrastructure—laws, standards, laboratories and other facilities, enforcement
authorities and the professional, staff to implement programs—can significantly
increase the environmental risks that tribes face. Many tribes do not have staff
who are knowledgeable enough on environmental matters to: (a) implement an
environmental protection program; (b) represent the Tribe's environmental interests
during decision-making, either on or off the reservation, and -
(c) interpret or communicate,environmental risks to the Tribe. This lack of
infrastructure leaves the Tribes without an effective way to manage environmental
risks, leaving Tribe members extremely vulnerable to these risks.
Several key findings emerged from the project: '
• Pollutants travelling long distances, especially those that bioaccumulate, can
cause high risks.
• Air deposition of pollutants can be a source of significant risks.
• Many risks could be substantially lowered if Tribes had the capacity to manage
environmental problems.
• A serious need exists to prevent damage to Indian reservation environments in
order to (a) protect cultural and religious values towards the environment, and
(b) maintain subsistence resources for future generations. For Native
Americans, there are no substitute lands for the reservations or their resources.
• Tribes need knowledge and resources to manage and protect the reservation
environment, and to influence policy decisions made off the reservation that
influence their health and their environment. •"•".•
The project demonstrated that risks on Native American reservations are
different than in the Region or America generally. The project demonstrated the
use of a methodology that included factors that enhanced EPA's ability to depict
more accurately the risks in Indian country. ,
The use of this improved methodology for exposure assessment has significant
implications. Although the Wisconsin Tribes may differ from other Tribes in wild
food consumption, religious and cultural values, this project is valuable in
demonstrating how such adjustments can and should be made in the exposure
assessment process for the Native American lifestyle. In addition, the lack of an
environmental protection infrastructure was found to be a significant risk for
Wisconsin tribes. Because many tribes lack adequate environmental protection
infrastructure, most Native Americans also face this risk. This has implications for
carrying out environmental regulations and policies that should be considered
when making risk management decisions.
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5.0 RISK ASSESSMENT AND RISK
MANAGEMENT
The Risk Assessment Subgroup had the task of answering two questions: (A) Does
EPA's risk assessment process accurately depict the risks to low-income and racial
minority communities?; and (B) Are changes needed in EPA's risk assessment and
risk management processes in order to address equity considerations?
The Sub-group decided to focus on several aspects of equity—race, age, gender and
income. The first three aspects have links with traditional health effects
information. As income is a marker for some aspects of quality of life, it may also
be relatable to additional factors dealing with health status and thus susceptibility
to environmental exposures.
To make risk-based decisions, EPA has a formal risk analysis process which
consists of two inter-related, but separate, process—risk assessment and risk
management. In making risk-based decisions (i.e., risk management), EPA uses
information developed in the risk assessment process to guide the decision-maker
in determining the appropriate action to take given the situation. In making the
risk management decision, managers consider a number of factors along with
human health risk. This is the phase of the decision-making process where many.
of the hard-to-quantify factors are considered by the decision makers. The factors
considered in the risk management phase range from social concerns to economic
concerns, from acceptance by the communities affected to technical feasibility.
There is an opportunity to consider relevant environmental equity issues during the
risk management process.
Bisk assessment characterizes the likelihood of a chemical agent or mixture to
cause an adverse health effect for humans and on a case-by-case basis provides a
numerical way to gauge the possible impact on a population(s) if exposure were to
occur. It provides an estimate of the probability that human exposure to a chemical
agent will result in an adverse health effect to the exposed individual, or an
estimate of the incidence of the effect within an exposed population. The product
of risk assessment is usually a statement of probability of an effect given a certain
duration, frequency and magnitude of exposure to the environmental pollutant.
Risk assessment as conducted at EPA, conforms to the Agency's published
guidelines and is usually comprised of four distinct parts: Hazard Identification,
Dose-Response Analysis, Exposure Assessment, and Risk Characterization.
Risk management is the decision process whereby officials decide what actions
are appropriate given the risk and other important factors. The basic framework
for this decision-making process is similar across agency programs; however, each
program must include certain factors as dictated by the statutes under which
authority they are regulating.
In the risk management process, decisions are made regarding acceptable levels
of exposure and risk In the past more attention has been given to the scientific,
technical, and science policy features of risk assessment than the components of the
risk management process. In contrast to risk assessment, there are at present no
published, peer-reviewed Agency guidelines for risk management decision-making.
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5.1 PRINCIPAL FINDINGS
Both the risk assessment and the risk management processes can affect how the
Agency addresses equity concerns. Hazard identification, dose-response
assessment, exposure assessment, and risk characterization provide the analytic
tools for identifying disproportionately impacted populations in terms of health. In
the risk management process, criteria are identified to help guide the weighing of
information. The Agency's choices in specific risk decision-making situations
regarding disproportional impacts are made based on these criteria.
The four components of EPA's risk assessment process as defined in risk and
exposure assessment guidelines do not exclude the consideration of age, gender,
racial/ethnic groups. Age arid gender and some racial/ethnic elements are
i traditional health topics and so are explicitly discussed in risk assessments
conducted by the Agency as appropriate. Age and gender are familiar tppics in
exposure guidance; information concerning exposure traits of racial/ethnic groups
are more limited. While the guidelines discuss some of these issues, the availability
of data for use in risk assessment is problematic. As such, a case can be made for
improving the availability of data. However, the guidelines state that when these
data are available and adequate for analytical purposes, they should be used in the
risk assessment process. . .
The Agency's risk assessments can be enhanced by more frequent
considerations of human activity patterns that may be influenced by custom, social
class, ethnic and racial culture. These sociological aspects may predispose
populations to exposures to environmental toxicants. It may also be helpful in
certain cases to present exposure analysis as a range of potential exposures and to
take into consideration demographic characterizations of the exposed population,
such as: age, gender, ethnicity and race. Likewise, quantitative estimates of risk
probabilities should be displayed as distributions across the exposed population;
considering the sensitive population groups that may exist in the overall exposed
population. In consideration of environmental equity, it is important that the
population group residing within the "high-end" of exposures be demographically
characterized, where such information is relevant to the risk manager.
Furthermore, to ensure that equity is considered and integrated in the regulatory
decision, it is important that risk management guidelines be developed to promote
equity considerations when selecting among regulatory alternatives.
One way in which risk assessments can be improved in terms of environmental
equity is to determine the proportionality and distribution of environmental
exposures and risk. Basic statistical analysis showing the cumulative frequency
distribution of environmental exposures and risk would be useful for the purposes
of identifying people residing at the lower 5%, the mean, the median and the upper
95th percentile in the estimcited distribution of environmental exposures to the
chemical agent dispersed from a source spatially and temporally. Once this is
done, the U.S. Census could be applied to that particular geographical area to
identify the age, gender, levels of income, race and ethnicity of the potentially
exposed population according to the estimated cumulative frequency distribution of
environmental exposures. This could permit quantitative analysis of the
proportionality of exposures and risk according to demographic classifications of
race, ethnicity, gender, age and income.
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In addition, the exposure analysis can be improved through the further
research and incorporation of human activity patterns that may be influenced by
custom, social class, and ethnic and racial culture. Factors such as dietary food
preferences, percentage of time spent indoors versus outdoors, and proximity of
residence to sources of environmental pollution are examples of sociological
variables that may predispose populations to exposure to environmental toxicants.
In consideration of environmental equity, it is important to move away from
generic exposure analyses to more site specific analyses that take these sociological
aspects into account. Basic to the concept of environmental equity is thorough
analysis and demographic identification of people whose activity patterns place
them in the "high-end" of exposures.
5.2 EVIDENCE OF INCREASED RISK
There is health evidence suggesting that exposure and resulting health risk ,to
environmental contaminants can be specific with regard to age, gender, race and
ethnic groups. Economic factors, in so far as they serve as an identifier for a life
style which can result in increased or decreased risk factors, may be relevant as
well. To augment the health and exposifre analysis in section two, the Risk
Assessment Subgroup notes the following studies:
• The last complete NHANES survey showed that lead poisoning in children
is more prevalent among inner-city poor, and blood lead is significantly
higher in African-Americans and Hispanics when compared to U.S.
children as a whole (ATSDR, 1988).
• Estimated lung cancer deaths in the U.S. attributable to indoor radon
exposure is about 2-fold higher in males than in females, and remains
higher even when adjusted for smoking (Nazaroff and Teichman, 1990).
• Epidemiologic studies of U.S. steel workers most heavily exposed to
mixtures of organic pollutants in coke-oven emissions at by-product plants
(e.g. at the topside of the oven) indicates that 90% were nonwhite. This
group of workers had an 8-fold higher rate of respiratory cancer than in the
general U.S. population (EPA, 1984).
* Fish consumption surveys indicate an association between average daily
rates of freshwater fish consumption and race/ethnicity. For example, if
the fish caught in a certain area are contaminated with a bioaccumulative
pollutant (e.g., PCBs, dioxins, methyl mercury, DDT), then consumption of
these fish will lead to exposure to these pollutants. The more that these
fish are included in the diet, the higher the exposure to these pollutants
will be. EPA has found that, on average, Asians are the highest consumers
of fish, followed in order by Native Americans, African Americans, and
Whites (EPA, 1991a).
In addition, certain ethnic populations tend to consume fish with a
higher fat content. Fish with a high fat content bioaccumulate lipophilic
(fat-loving) pollutants to a higher degree, thus, causing a higher exposure
to these pollutants in the populations which prefer high-fat content fish.
There are not adequate studies of urban/rural poor that could elucidate
the relationship between fish consumption and poverty. However, it is
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'
likely that there are significant numbers of rural and urban poor people who are
supplementing their daily intake of animal protein by catching and consuming fish
caught locally. If these fish are contaminated by pollutants that bioaccumulate,
then the pollutant exposures via fish ingestion for these consumers could be much
greater than for the average recreational angler.
• Analysis indicates that pregnant women consuming fish contaminated by a
bioaccumulative and lipophilic pollutant (PCBs, dioxin, methyl mercury)
may accumulate these pollutants in their body fat and subsequently transfer
the pollutant to their mother's milk. Pollutant exposures to the nursing
infant may be up to 10-fold greater than the mother's exposure. (EPA,
- 1991b).
• Exposure of young children to environmental tobacco smoke from parental
smoking, particularly during infancy, is causally associated with increased
prevalence of acute lower-respiratory-tract infections, respiratory symptoms
of irritation, middle ear effusions, reduced lung function, and a small
reduction in the child's rate of pulmonary growth and development (EPA,
1990b).
No national baseline currently exists of population exposures and risk to
environmental contaminants that is evaluated by age, gender, ethnicity, and race
for all environmental media. Therefore it is not possible to statistically evaluate the
proportionate risk burden by age, gender, ethnicity and race on a national scale.
The situations discussed in this report suggest that environmental inequities could
exist, but a quantitative evaluation of the issue is not possible using existing data.
5.3 FINDINGS ON COMPONENTS OF THE RISK
ASSESSMENT PROCESS
The risk assessment process consists of four parts. The specificity of the data
available for assessing the hazard identification, dose-response analysis, exposure
assessment, and risk characterization affect the specificity with which the Agency
can determine the risks faced by particular population subgroups.
5.3.1 Hazard Identification And Dose-Response Analysis
Hazard identification is the first stage in the risk assessment process. EPA
evaluates available scientific evidence and decides whether an agent or mixture is
likely to cause a particular adverse health effect. Specific population subgroups can
become a focus if the available information is similarly related to a subgroup.
Gender and age are commonly studied factors.
Information from epidemiologic studies has largely involved studies on the
standing work force, i,e., exposures to healthy White male workers. Given this
limited study population, the extrapolated hazards to the general population may
not portray the range of consequences to children, the elderly, the sick and
infirmed, females, racial/ethnic groups, or low-income populations. Hazard
information from animal studies, however, has the potential to provide information
on effects specific to gender and age. Gender is frequently accounted for and lately
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more interest is being directed to age. These types of information are integrated
into the risk assessment for humans as warranted. The dose-response analysis step
in risk assessment is closely tied to the hazard identification information and so it
tracks the available data accordingly.
When the Agency does have information about the susceptibility of certain
subgroups in the population, this information is taken into account in the risk
assessment. For example, children have been specially singled out as being at risk
from exposure to lead. The elderly are sensitive to carbon monoxide, and
particulate matter exposure. Asthmatics are a sensitive subgroup for sulfur oxides.
There are other examples where health information for special population groups is
key to the risk assessment finding and examples where such focus is not
achievable.
5.3.2 Exposure Assessment
Exposure assessment, the third phase of risk assessment, evaluates the likely
pathways leading directly or indirectly to human exposure to an environmental
agent or mixture; estimates the magnitude, frequency, and the duration of
exposure; and estimates the size of the exposed population and as needed
documents other vital physiologic features that may be relevant.
In general, ethno-cultural and economic considerations are not incorporated in
exposure assessments. However, such demographic categories may be useful
markers for identifying population subgroups that have some likelihood of
experiencing exposures significantly different from the average exposure and,
thereby, possibly different health risks from the average population. Cultural
specific behaviors, activity patterns, and food preferences vary significantly by
ethnic and racial groups, and these patterns may define pathways of exposure to an
environmental pollutant. For example, the importance of fish in the diet of certain
Native American Tribes has a great impact on the exposure of these tribes to any
contaminants found in the fish. If the fish that a group of Native Americans eat are
contaminated, the Native American's environmental exposure to these contaminants
will be greater than for the average population. In addition, preference for high-fat
content and bottom-feeding fish (i.e., catfish, carp, crappy, and eel) by various
races, ethnic groups, and low-income people can increase the exposure, and thereby
the risk, for lipophilic contaminants. Further, cultural preferences for the
consumption of internal animal organs, such as liver, brain, kidney, heart, liver or
pancreas of crabs, lobsters, or the consumption of whole fish are important factors
to consider in conducting the exposure assessment.
Economic circumstances may predispose certain populations to increased risk
factors. For example, industrial activities often are located in parts of town
inhabited by individuals of lower socioeconomic status. Low-income or poverty
populations may lack the means to live outside the areas surrounding the polluting
facilities. Urban and rural poor may subsist on fish caught in contaminated waters,
or from home-grown vegetables, beef and dairy products that may be chemically
contaminated from local industrial activity.
Time-use studies can depict human activity patterns within the population and
are useful in estimating the duration of exposure to environmental contaminants in
a particular setting. Such studies may reveal over-representation of certain racial
groups in high-exposure occupations, e.gv Latinos as migrant farm workers
exposed to pesticides. Also, as mentioned above, certain ethnic and racial groups
may derive the bulk of their dietary animal'protein from the consumption of fish.
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Age may also predispose populations to different exposures and perhaps also
to increased/risk depending upon dose-response relationships. Nursing infants
may have higher exposures than adults to bioaccumulative pollutants (EPA, 1991b).
The susceptibility to the effects from exposure to a contaminant may increase in
certain segments of the population with immune systems that are not functioning
at their maximum (i.e., newborns and the elderly).
One- to six-year old children are more likely to ingest soil than any other age
groups. If the soil that these children ingest is contaminated, their exposures to
these contaminants via this romte of exposure will be higher than for other age
groups. Children also tend to have different diets than adults, i.e., children
generally consume greater quantities of fruit and milk than adults. This may
predispose children to certain exposures to substances that are found in these
foods. Further, children have different physiologic rates and capacities than adults,
which may affect the exposure and dose-response relationship to those substances .
to which they are exposed.
The influence of gender on, activity patterns may lead women or men to greater
exposures; Home workers are predominantly female; their exposures to indoor air
pollutants in home micro-environments will be of longer durations than for males.
Certain occupations are dominated by male workers, such as the chemical industry.
Income levels, may define a population of urban/inner city dwellers whose
residences are co-located with small businesses or large enterprises which emit
contaminants to the nearby local environment. As an example, undesirable
exposures to solvents or other vented emissions could be a problem.
EPA has developed an Exposure Factors Handbook (EPA, 1990d). A review of
the handbook indicates a paucity of reliable exposure factors relative to human
activity patterns and cultural-specific behaviors. The [available studies on human
activity patterns (percent time spent in various activities while at work, home, and
recreation) are skewed toward middle income individuals, but are generally not
delineated by race/ethnicity (EPA, 1990c). .
EPA has recently published Exposure Assessment Guidelines. The guidelines
address the topics of age, gender, patterns of activity and identify some special
exposure situations among ethnic/cultural and racial groups. The guidelines
emphasize the advantages and use of demographic information in planning and
conducting exposure assessments, and the identification of appropriate population
groups for study given the toxic endpoint of a particular chemical (neurotoxicity,
male/female reproductive toxicity; developmental effects, carcinogenicity,
immunotdxicity). There is no other compendium of exposure assessment guidance
or directive that emphasizes special demographic issues, other than in the pesticide
program. OPP routinely tracts age-specific diet consumption levels in conducting
their exposure assessments. .
Given the potential variation in susceptibility and exposure among certain
groups of individuals in the population, estimation of the distribution of population
by age, gender, race, and ethnicity may be necessary to protect each of these
populations adequately. However, without adequate information about the
variation in susceptibility and exposure relative to these subgroups, the
demographic data will be of little value in addressing the risk to the subgroups.
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5.3.3 Risk Characterization
Risk characterization is the final step in risk assessment where all factors are
integrated into a summary and concluding statement about the nature and extent of
possible health impact resulting from an exposure.
It is the practice that if the available data base (i.e., health and or exposure)
provides insight into such factors as age, gender, race/ethnic susceptibility that
these elements are considered. The risk assessment guidelines vary in degree about
explicitly making reference to special population issues. While certain health
endpoints or specific risk management decisions (i.e. site-specific Superfund cases)
may naturally focus on particular population groups, other risk assessments
supporting national regulatory initiatives focus on an average person who might be
expected to have an average susceptibility to exposure to toxic contaminants in the
environment. This is a consequence of not having data rather than a reluctance to
deal with the issues raised by incorporation of such data in the analysis. In many
cases, the Agency is unable to characterize the possible risk to a target population
in terms of vital demographic factors.
5.4 FINDINGS ON THE COMPONENTS OF THE
RISK MANAGEMENT PROCESS
As discussed earlier, the risk management/decision making process has certain
features that are common to all programs. However, each program has unique
features in their risk management decision-making process, depending on which
environmental statute is applicable. The practice of risk management varies
somewhat across the Agency.
While some equity considerations find their way to the risk management table
because they are definable in the risk assessment process, there are currently no
other mechanisms such as published guidelines or other institutional elements
which guide the decision logic of addressing equity or in choosing among equity
issues.
5.5 CONCLUSIONS
•• The risk assessment process is not exclusionary with respect to age, gender,
racial/ethnic groups or socioeconomic status because the process does allow for
these factors to be taken into account in the analysis. However, data on these
factors are not always available to be used in the analysis.
• There is evidence that certain population groups experience increased exposure
and risk due to different activity patterns, cultural behaviors, diets, and
physiological differences.
• While peer-reviewed, published guidelines exist for risk assessment, there are
no guidelines for the risk management process. Risk management decisions
can greatly influence how the Agency addresses environmental equity issues.
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6.0 RISK COMlNiUNICATION
The standard definition for risk communication is "any purposeful exchange of
scientific information between interested parties regarding health or environmental
risks" (Covello et al., 1988). Risk cornmunication is seen as a "tangled web," with
information flowing in many directions, between multiple sources and audiences,
through formal and informal channels, and without explicit goals or objectives
(Plough and Krimsky, 1987; Krimsky and Plough, 1988).
Inits efforts to alert the public to risks, the Agency has sought to move beyond
simply transferring technical information, recognizing the desirability of public
involvement in the decision nuiking process. The EPA risk communication manual
(EPA, 1989a) highlights this goal:
The Agency does not view risk communication as a one-way street. It
recognizes the need to impart information but also to involve the public in the
decision-making process. The purpose of risk communication is not to allay
the public or merely help them see [the Agency's] point of view.
Risk communication, by itself, cannot redress distributional inequities in risk
However, risk communication is an integral part of the risk management policies
and programs that are intended to redress such inequities. The Agency's risk
communication efforts have been criticized by environmental equity groups for
failing to address the concerns of racial minority and low-income communities
during the policy making and subsequent risk communication processes.
Equitable risk management efforts require equitable risk communication efforts.
Equitable risk communication means ensuring that the Agency engages all affected
parties at the beginning of and throughout the decision making process. Outreach
and consultation are at the heart of an equitable risk communication program.
Underlying the relationship between equity and risk communication is the
issue of empowerment. For the public, there is nothing more frustrating than to be
given information on risks about which it can do nothing, or after the substantive
decisions have beenjnade (Kasperson and Palmlund, 1987).
Racial minority and low-income groups may experience particular frustration.
Actual or perceived alienation from the political process—a process perhaps seen as
ineffective or outright discriminatory—may steer these communities away from
participating in the formal process of public hearings, often the extent of risk
communication efforts. The groups perhaps most at risk may be least likely or able
to participate in the decision making process.
6.1 THE RISK COMMUNICATION PROGRAM
Risk communication is primarily a responsibility of the program offices and
regional offices. However, the Risk Communication Program (RCP), within the
Office of Policy, Planning, and Evaluation, provides technical assistance to the
program and regional offices and therefore sets the tone for all EPA risk
communication activities. RCP engages in a variety of activities in four areas:
training, problem-specific consulting and analysis, methods development, and
coordination and outreach. R.CFs training activities include several completed,
ongoing, and proposed courses, workshops, and manuals for EPA and State
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employees. The center-piece of the RCFs training is a two-day workshop in risk
communication.
EPA has been responsible in large part for directly and indirectly generating
much of the research in risk communication. The RCP has collaborated with
program and regional offices, other agencies and organizations, and academics on
specific problems for risk communication, including radon, the
community-right-to-know program, hazardous waste siting and cleanup, and
chemical risks. Other collaborative efforts have focused on more generic issues of
risk communication methods. The RCP has engaged in a number of outreach
efforts aimed at the general public. None of these projects or activities explicitly
addresses environmental equity issues in risk communication. However, the
materials contain valuable ideas about the process and content of risk
communication that could be directed to address equity issues.
The subgroup's evaluation of EPA risk communication efforts consists of two
components. The first component examines the four seminal documents that form
the core and set the tone of EPA's risk communication efforts: The Seven Cardinal
Rules of Risk Communication (Covello and Allen, 1988), Explaining Environmental Risk
(Sandman, 1986), Improving Dialogue with Communities: A Short Guide for Government
Risk Communication (Chess et. al., 1988), and Improving Dialogue with Communities: A
Risk Communication Manual for Government (Hance et. al., 1988). The second
component of the subgroup's evaluation examines risk communication within the
context of regulatory programs. The reviews begin with the Radon and
Community-Right-To-Know programs, the two most prominent risk communication
efforts within the RCP. Because pesticides, air toxics, and lead potentially impose a
high risk burden on minorities, these programs are also examined.
6.2 GUIDANCE FROM SEMINAL RISK
COMMUNICATION DOCUMENTS
Of the four seminal risk communication documents, The Seven Cardinal Rules of
Risk Communication (Covello and Allen, 1988) has become the de facto guideline for
conducting risk communication at EPA. The seven cardinal rules, presented as
common-sense guidelines, are a distillation of much of what we know from
research and experience: "Accept and involve the public as a legitimate partner,
plan carefully and evaluate your efforts, listen to the public's specific concerns, be
honest, frank, and open, coordinate and collaborate with other credible sources,
meet the needs of the media, and speak clearly and with compassion." Explaining
Environmental Risk, (Sandman, 1986) is a more discursive treatment of these themes,
intended to help decision-makers understand why some strategies for dealing with
the media and the public succeed while others fail. Improving Dialogue with
Communities: A Short Guide for Government Risk Communication (Chess et al., 1988)
and Improving Dialogue with Communities: A Risk Communication Manual for
Government (Hance et al., 1988) give detailed practical guidance to Agency
personnel responsible for the development of risk communication programs.
Largely based on interviews with numerous practitioners from academia, industry
and government, the guidance manuals have been criticized as "etiquette books for
risk communicators" (Otway and Wynne, 1989). Despite the criticism, they
represent the state-of-the-art in risk communication.
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The four publications lack explicit discussion of equity issues, yet guidance for
more equitable risk communication efforts can be extracted. For example, the
admonition to "involve all parties that have an interest or stake in this issue"
(Covello and Allen, 1988) is important in making risk communication more
equitable to all involved parties.
Below are brief discussions of how the guidance documents shape the Agency's
risk communication goals, process, and content.
6.2.1 Goals
None of the four publications aims explicitly at race, ethnicity, and income status,
though each explicitly and 'implicitly recognizes that issues of control and equity
(or fairness) underlie most risk controversies. Sandman asserts that "it is hardly
coincidental that the risks the public tends to overestimate generally raise serious
issues of equity and control" (Sandman, 1986). For example, though EPA asserts
that state-of-the-art hazardous waste facilities are completely safe, the public often
sees them as very risky. On the other hand, it has been difficult for EPA to
generate concern and action about radon—one of EPA's highest ranked risks—
because it is dispersed and naturally occurring.
The public is particularly concerned about the "outrage factors" (Chess et al.,
1988)—factors beside the scientific data of hazard evaluations, monitoring, and risk
assessments. Covello and Men stress this point: "People in the community are
often more concerned about such issues as trust, credibility, competence, control,
voluntariness, fairness, caring, and compassion than about mortality statistics and
the details of quantitative risk assessments." These do not affect environmental
risk, per se, but are an intimate part of the risk communication process. In general,
"risks that seem fair are more acceptable than those that seem unfair" (Chess et al.,
1988; Hance et al., 1988). The EPA's risk communication workshop, which is based
on these publications, emphasizes that fairness is an underlying factor in the public
perception of risk Failure to account for fairness as an attribute of risk is one
reason why expert assessments of risk differ markedly from public assessments.
Inequitable distributions of risk, such as the imposition of disproportionate risk
burdens on racial minorities and the poor may be perceived by those communities
as greater risks than risks that have less obvious inequities (e.g., radon).
6.2.2 Process
Covello and Allen (1988) emphasize that "[a] basic tenet of risk communication in a
democracy is that people and communities have a right to participate in decisions
that affect their lives." Racial; minorities and low income groups may feel wholly
excluded from the process, or the issues of greatest concern to them may be
dismissed peremptorily. The gravest problems of risk communication tend to arise
when "citizens determine that the issue is important, that the authorities cannot be
trusted, or that they themselves are powerless" (Sandman, 1986). A good
communication process should therefore build trust in the Agency, allow the public.
i to influence decisions, and convey the message that issues of concern to the
community will be taken seriously. Despite the Agency's 20 year focus on human
health, some believe the Agency is more concerned with White, middle classes
issues such as leisure and recreation, wildlife and wilderness preservation, and
resource conservation than with the problems faced by minorities and low-income
groups (Bullard, 1990).
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Involving the community early and substantively demonstrates the Agency's
confidence in the public and its willingness to share power and take public
concerns seriously. Placing notices in the Federal Register and holding large public
hearings may be broadly defined as risk communication efforts, but they are
generally inadequate for many communities. Evidence suggests that these
processes are inaccessible to low-income and racial minority groups (Mohai, 1991).
Therefore, the Agency has attempted in certain site-specific programs such as
Superfund, to design a process that is "citizen-focused," and to learn from the
community what type of involvement is preferred. These smaller, more informal
meetings of people with similar concerns are generally more constructive and
effective forums for the exchange of ideas.
Any effective risk communication process must involve all parties with an
interest or stake in the issue at hand. Ironically, the groups (such as the poor and
racial minorities) who may be at most risk may also be the most difficult to "reach."
It is important, therefore, to devote time and energy to the slow, hard work of
building bridges with other legitimate and representative groups. Chess et al. cite
this factor in their chapter on building trust and credibility: "Enlist the help of
organizations that have credibility with communities" (Chess et al., 1988). This
facilitates two way communication—crucial in any risk communication effort—but
particularly so with racial minority and low-income communities where people
may perceive that EPA (and the government in general) does not consider their
concerns. In a number of cases, the Agency has initiated dialogues with such
groups on specific issues. For example, the Agency has had discussions with
farmworkers on pesticide exposure issues that are particularly important to them.
A related issue is the use of community-appointed experts to assist in the
interpretation of technical materials. Because they are often unable to pay for it,
poor and racial minority communities have limited access to expert assistance on
environmental issues (Freudenberg, 1984). This limits the rate at which poor and
racial minority groups can "get up to speed" on the technical aspects of
environmental issues and reduces their effectiveness in adversarial proceedings in
which the technical issues play a central role. Recognizing the need to provide
communities with access to technical expertise, the Agency has begun to explore
ways, such as Technical Assistance Grants, that will provide this help to
communities.
6.2.3 Content
There has been much written about the most effective content of risk
communication materials, including how to present risk numbers and how to make
appropriate risk comparisons. The documents Improving Dialogue with Communities:
A Short Guide for Government Risk Communication and Improving Dialogue with
Communities: A Risk Communication Manual for Government, written to apply to all
communities, give extensive, practical advice on effective content. This advise can
be applied to low-income and racial minority groups, but it would be more easily
used if accompanied by information that discusses the particular needs and
preferences of low-income and racial minority communities.
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The documents emphasize the need to involve the community to find out what
information people want to know and in what form. This is especially important
with low-income and racial minority groups whose concerns and assumptions may
differ from those anticipated by EPA officials. The materials of the risk
communication materials effort should be in the appropriate languages to reach
affected racial minority and ethnic groups. The materials must be relevant,
understandable, and answer the questions of the intended audience.
6.2.4 Summary
The Agency's seminal risk communication documents provide sound advice that
can be applied to some of the equity issues facing EPA. However, more guidance
is needed that illustrates these general principles with explicit reference to the
needs and concerns of facial minority and low-income groups. The Agency may
need to develop new methods and recruit new message carriers to communicate
with these communities. Risk communication efforts in Regions I, m, and V will
contribute sound, practical advise and model approaches needed to advance the
Agency's risk communication efforts.
6.3 RISK COMMUNICATION IN REGULATORY
PROGRAMS
The following discussion offers snapshots of five regulatory programs within EPA.
6.3.1 Radon Risk Communication
EPA (1987g) estimates that between 5,000 and 20,000 lung cancer deaths per year
may be due to radon exposure in the home. The main thrust of the Radon Action
Plan has been risk communication to encourage the public to test their homes and
mitigate if they find elevated levels of radon. The Agency is and has been engaged
in a variety of risk communication activities at the national level and through state
agencies, including:
• The maintenance of a toll-free radon "hotline;"
• The wide dissemination of the Citizen's Guide to Radon (EPA, 1986b), which
has been the primary risk communication vehicle;
• The dissemination of more specific informational materials such as Removal
o/ Radon from Household Water (EPA, 1987h) and Radon Reduction Methods: A
Homeowner's Guide (EPA, 1989b);
• The development and dissemination of public service announcements
(PSAs) for broadcast and print media;
• The preparation and distribution of a pamphlet for journalists stressing the
newsworthiness of the radon issue (EPA, 1989c).
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lit addition, the Agency has collaborated with several states in media
campaigns to increase public awareness. In the fall of 1990, the Agency sponsored
a National Radon Action Week in collaboration with the American Lung
Association, the American Cancer Society, the American Medical Association, the
American Academy of Pediatrics, the National Congress of Parent Teachers
Associations, the National Education Association, and the Consumer Federation of
America. The Agency is presently working with the Advertising Council to explore
a range of public relations and direct marketing strategies (CRCPD, 1990).
Many states have initiated their own efforts in collaboration with EPA, using
funds from the State Indoor Radon Grant (SIRG) Program. Many of these efforts
involve surveys of residential or school radon levels, but some states are using the
funds to develop more imaginative risk communication programs. For example,
Kentucky is creating a community and regional radon information/education
outreach program. The program is intended to reach individuals in local Parent
Teachers Associations, the American Cancer Society, and the public health
community, as well as agricultural and home extension agents.
This is probably the most extensive risk communication effort of any EPA
program. Unfortunately, the communication of the risk from radon has not
resulted in action by many households. ^EPA estimates that only about 5% of
dwellings have been tested for radon, and only 8% of those for which mitigation is
necessary have actually mitigated (EPA, 1990b).
Equity Issues in Radon Risk Communication. As a natural hazard, it may seem
strange that equity should be a concern in dealing with radon, but there are
actually several problematic issues.
There has been a considerable amount of research on risk communication with
regard to radon, but all of this focuses on homeowners. As Sjoberg (1989)
concludes following a review of this research for EPA:
Virtually all research so far has been conducted with homeowners so the social
strata that have been represented have not been representative of the whole
population. We do not know how people who rent their homes respond to
radon risk, or how involved their landlords are in monitoring and mitigating
such houses.
j
As noted in Table 3 (Section 2.1.2), a significant percentage of racial minorities do
not live in homes they own.
The research literature does not contain an explicit analysis of equity with
respect to risk perception of radon, willingness to take remedial actions, and
effective risk communication. Empirical studies do suggest, however, that
low-income and poorly educated people are more likely to perceive radon risks as
less severe than the other risks they face, and are less likely to test for radon or
mitigate if they discover elevated levels (Doyle et al., 1989)! It is believed that the
lower rates of testing among low-income groups reflect concern over the potentially
high cost of mitigation if a problem is discovered, rather than the cost of
purchasing test kits, which are relatively inexpensive.
Most testing for radon is conducted during the purchase and sale of houses,
and EPA's risk communication efforts have focused almost exclusively on
homeowners as the target audience. One potentially large audience that has not
been targeted in these efforts are owners and managers of multi-family housing
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units such as apartments. While those living in units above the second story may
not face a radon problem, and therefore do not need the risk information, there are
a significant number of rental units at the basement and first floor levels. Those
individuals living in basement apartments, which are often the least expensive
units, may be especially at risk. Congress has asked Housing and Urban
Development (HUD) to develop a program oh testing and mitigation in public
housing, but there has been little activity as yet.
In terms of content and presentation, many of the risk communication materials
produced at both the state and federal levels are of extremely high quality.
Enormous effort has been put into the development of these materials to ensure
that they present the necessary information in an appealing and comprehensible
form for the general public. Experts in risk communication and reading
comprehension reviewed many of the materials. Focus groups with members of
the public were used both to develop and test the materials. Indeed, this is an
ongoing process, and a substantially revised Citizen's Guide is to be released this
fall. Unfortunately, the content is again geared towards homeowners. There are no
materials tailored to rental properties—either for the tenants or the landlords. The
risk communication materials offer no advice to renters about how to deal with
landlords who refuse to test, or what renters can do if they find their dwellings
have elevated levels of radon. Similarly, there is no information explaining the
incentives for landlords to test and mitigate.
Even if low-income homeowners do test for radon, the necessary mitigation
work may be prohibitively expensive. Some of the mitigation options
recommended by the EPA (e.g., in the Radon Reduction Methods: A Homeowner's
Guide) may have significant energy costs. For poor households, the energy costs of
opening windows and ventilating crawl spaces may outweigh gains in reduced
radon risk. Risk communication on mitigation should, therefore, include some
discussion of this trade-off, alternative measures that may be cheaper, and the
availability of any grants, subsidies, or tax incentives that might apply.
EPA's radon communications materials recommend that people contact their
state radon office for additional information on the risks of radon and how to test
and mitigate. Many states send out packets of information, including the list of
testing companies that meet EPA's Radon Measurement Proficiency (RMP) Program
quality controls. Unfortunately, many of these offices can only be reached by
calling a toll number during the most expensive calling period. This adds an
additional barrier to testing, and is a barrier for those who cannot afford such calls.
Furthermore, EPA's existing toll-free hotline, which provides only a prerecorded
message offering to send EPA's introductory brochure, might be enhanced.
Finally, smokers who are exposed to radon have an increased risk of lung
cancer over those who only smoke or are only exposed to radon. Since a higher
proportion of low-income and racial minority groups smoke, there would be an
increased overall risk to radon from these groups. EPA, however, is extremely
cautious about including a discussion of the relationship between radon and
smoking in the risk communication materials. This reluctance is based on the
assumption that both smokers and non- smokers may face unacceptable risks if
they live in a house with elevated levels of radon, and the fear that focusing on
smoking may lead non-smokers to believe they are not at risk. Emphasizing
smoking may also have an adverse effect by alienating smokers, who then also
refuse to test or mitigate. While the Citizen's Guide presents little information
about the relationship between smoking and radon, it does recommend that
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individuals can reduce their risks by stopping smoking themselves and
discouraging smoking in their home.
6.3.2 Community Right-To-Know
For the purposes of this paper, community right-to-know (CRTK) is defined
broadly, encompassing the Emergency Planning and Community Right-to-know
Act (EPCRA) of 1986 (also known as SARA (Superfund Amendments and
Reauthorization Act), and in addition, CERCLA (Comprehensive Environmental
Response, Compensation, and Liability Act), the Oil Pollution Act of 1990, the
Pollution Prevention Act, and the Clean Air Act of 1990. Two program offices, the
Chemical Emergency Preparedness and Prevention Office (CEPPO) (within the
Office of Solid Waste and Emergency Response (OSWER)), and the Office of
Pollution Prevention and Toxics (OPPT), have the main responsibility for
implementing EPCRA, but many other EPA offices, have been involved in
developing and implementing the CRTK program. In some important respects, the
CRTK program extends beyond EPA to many other federal agencies, to state and
local governments, and to non-governmental organizations. This section discusses
several aspects of CRTK that have implications for equity issues.
Availability of Information to Racial Minority and Low-Income Groups. Under
the CRTK program, most groups have equal potential to obtain the technical and
other risk information that accompanies or flows from regulation development if it
is requested. However, the existence of this source of information is not widely
known, except by interested industry representatives, environmental professionals,
and other researchers. Further, this information is, by its nature, often highly
technical and, therefore, not easily understood by the general public. Specifically,
three barriers to low-income and minority groups obtaining and using this
information have been identified:
Language barriers
Very little of the formal CRTK and EPA-wide public relations output is
presented in Spanish or other non-English languages. The technical and rule
making material is virtually all in English. It is rare to find heavy participation
by Hispanic or other linguistic minorities in EPA rule making hearings or other
large-scale public meetings.
Metropolitan Proximity
All EPA regional and headquarters offices are in major cities. Government
repository libraries (which contain some EPA materials and usually have
librarians capable of assisting interested patrons) tend to be in major cities and
within sizable universities. Thus, rural populations have relatively less access
to information or assistance available through these mechanisms.
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Education Level Bias
Environmental issues and information are inherently technical and are
sometimes complex. A person with some educational background in those or
related issues is in a better position to identify and to be able to make use of
much of the data that we have broadly included in CRTK information. Access
to facilities with computers are also required to make use of some of EPA s risk
data.
Tailoring Messages to Target Audiences. By and large, EPA's technical and
regulatory output comes in one style—technical-containing many legal and
scientific terms that appear to be jargon to other readers; it assumes a large
amount of background knowledge on the part of the readers. The process of
making this information available to a wide audience is a resource-intensive task.
So far/it currently has been undertaken for certain key areas, with plans to expand
it as resources are available. , „ , t ,'
In some cases, tailoring of EPA's message has been successfully accomplished.
The usual motivation has been to encourage compliance with some program among
the regulated community. As examples, the Underground Storage Tanks program
has produced very readable compliance guides for the proprietors of gas stations
and other businesses likely to have such tanks. The certified pesticide applicator
training program takes into account the educational levels and language skills of
those who are to be trained and certified. Some labeling and other aspects of
pesticide use explicitly deal with Spanish-speaking farm workers.
In those cases where EPA has expended efforts to communicate directly and
clearly, documents have been written in straightforward English, sometimes with
careful attention to graphical content, assuming moderate skills on the part of the
intended readers. The annual Toxic Release Inventory (TRI) national reports, some
of CEPPO's documents and other general EPCRA documents (eg. "Why Accidents
Happen," "Chemicals In Your Community," and a brochure explaining EPCRA
section 311/312 requirements to small businesses), and some materials from the
Superfund program are among the examples of successful efforts.
The Outreach Committee of the EPA Title m Implementation Work Group
occasionally turned its attention to special language needs. This resulted in the
translation into Spanish of ait least one short brochure explaining the use and access
of TRI data. CEPPO has recently made arrangements to have the "Chemicals In
Your Community" brochure translated into Spanish, and has received requests to
have other materials translated into Spanish and some Indian languages.
6.3.3 Air Toxics
Although the risks considered by the Community Right-to-Know (CRTK) program
and thrAir Toxics program are similar, there are enough differences in the sources
and nature of the risks that separate risk communication efforts are necessary for
these two programs. In particular, the CRTK programs deal mainly wi* releases of
pollutants to various environmental media (often episodic releases), while the air
toxics programs are concerned with ambient concentrations and human exposures
(via a single medium), often from multiple, chronic, and/or unknown release
sources. The Air Risk Information Center (Air RISC), located at EPA's Research
Triangle Park f acility, has produced one monograph and three pamphlets (EPA,
1991c,d,e,f) on communicating air toxics risk issues. Information was not available
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as to how widely these materials have been disseminated or whether they (or any
other written or oral risk communication activities emanating from EPA
headquarters) have enabled significant numbers of citizens to participate in
dialogue about air toxics problems.
Review of Air RISC Materials. Air RISC has produced several quality documents
that address equity concerns. The three pamphlets that Air RISC has produced are
readable, graphically attractive, understandable, and unusually complete in their
discussions of uncertainties, costs and benefits, risk comparisons, and the
importance and legitimacy of public perceptions about risk. However, these
pamphlets do not directly address racial and income factors as they affect exposure,
susceptibility, and, thereby, risk.
The monograph on "Air Pollution and the Public" is particularly praiseworthy.
It contains an extensive discussion of the variety of process and substantive goals of
a risk communication program, and of the variety of target audiences that should
be identified. However, the treatment of this latter issue is silent with respect to
racial and income equity. Nevertheless, the document does encourage the
environmental official to "consider groups based on common demographic,
educational, or vocational interests, which will not necessarily be within the
geographic or political boundaries (of the exposed community)," advice which
could be interpreted to apply to racial or income groups.'
Moreover, the section on haw to communicate to different audiences is very
sensitive to equity issues. The document advises the agency official to tailor the
message to the appropriate educational level (without being condescending), to
consider that cultural and sociological factors may influence both risk perception
(and benefits perception) and how people view authority figures (giving as an
example an allegedly successful "tailored" risk communication to
Portuguese-speaking fishermen in Massachusetts), and to pay careful attention to
both the questions people ask as well as the questions left unasked because of
possible confusion, incomprehension, or fear.
6.3.4 Pesticide Porgrams
Risk communication and equity are prominent problems for the Office of Pesticide
Programs (OPP) because so many of the migrant and seasonal farm workers who
are exposed to pesticides on the job are poor and racial minority groups. Risk
communication is especially difficult because of low literacy rates and the diversity
of languages. Moreover, the population is dispersed over a wide area and, in the
case of migrant workers, constantly on the move. Finally, as recent immigrants, or
illegal aliens, many workers are especially suspicious and distrustful of any
government authority.
Pesticide Labels and Risk Communication. The label of a registered pesticide is
required to convey information concerning its contents, potential hazards to human
health and the environment/and directions for use. Any regulation which applies
to the use or handling of a pesticide product must be included in the label.
Pesticides are placed in one of four toxicity categories. The least toxic are not
required to car# any particular hazard labeling. Those in the other three
categories must carry one the following signal words (in order of increasing
toxicity): "CAUTION", "WARNING", or "DANGER." The Federal Insecticide,
Fungicide, and Rodenticide Act (FIFRA) also requires that any pesticide containing
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a substance highly toxic to human health shall depict a skull and crossbones figure
on the label along with the word "POISON" in prominent, red letters. On some
agricultural pesticides, these words are written in Spanish as well as English. The
signal words are found near the top of the label, underneath the trade name and
chemical content information. Below the signal words are precautionary statements
advising users of the type of hazard and protective measures to take, for example,
whether gloves or goggles ought to be worn. Also included in the precautionary
statements is information on how to administer first-aid in case of poisoning, and
in some cases a note to the physician. Hazards to the environment and wildlife are
placed below the statements regarding human health. For the user, the label is,
therefore, the main source of information concerning the potential dangers and safe
use of a particular pesticide.
Under FIFRA section 2(q)(l)(E), a label is required to be written in a way
"likely to be read and understood by the ordinary individual under customary
conditions of purchase and use." The label language assumes literacy at the
secondary level of education. Those with low literacy skills or whose first language
is other than English may have trouble understanding the label warning. Many
agricultural pesticide labels contain a warning in Spanish not to use the pesticide
until the label has been fully explained. Some registrants have chosen to translate
the entire label for certain products into Spanish.
The high rates of illiteracy among minorities and low-income groups
compounds the communication problems with these groups. Finding a way to
communicate warnings to those with low literacy skills has been a particular ^
challenge. During the mid-1980s a label utility workgroup was established within
EPA to explore the use of pictograms or symbols, as well as other ways to make
the labels easier to Understand. A contractor was hired to interview consumers and
suggest ideas in a report, but no action has been taken since the report was issued.
At this time, another work group has been formed^ take a look at these and other
issues involving labels. Of particular concern is ti\e adequacy of labels on
household pesticide product's in communicating information about potential health
and environmental hazards, EPA plans to address this concern during the re-
registration process for household pesticides (EPA, 1991).
Farmworker Protection: The Worker Protection Program. Final regulations on
Worker Protection Standards are due out within the next year. They will apply to
workers on farms, and in forests, greenhouses and nurseries. The regulations are a
response to the inadequacies, of current standards in protecting the health of
agricultural workers, as presented in the background material for flie Worker
Protection Standards proposed in 1988 (Federal Register, July 8,1988). •
The new regulations will cover a variety of activities and topics, including:
increased training in pesticide application, use of protective gear, notification of
agricultural workers of what pesticides have been used and where they have been
applied, reentry intervals for more toxic pesticides, and the availability of soap and
water to wash off residues. The key to these efforts lies in education and training
for agricultural workers, including farm workers. Much written material is already
available in Spanish and English. This material describes safety practices,
appropriate types of protective gear, how to interpret label information, and what
to do in case of an accident. In addition, slides and video presentations are being
prepared in both Spanish and English.
The task of relaying this information, however, is enormous. The Federal
Register notice of the proposed Worker Protection Standards estimated that 2.3,
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million workers are exposed directly or indirectly to agricultural pesticides. A
large portion of this number includes migrant and seasonal farmworkers. In the
states of California, Oregon, and Washington it is estimated that 80% of the migrant
fan« force is Latino (Vaughan and Nordenstam, 1989). Many of them have limited
education and read at about a 5th grade level in their own language. Seasonal
farmworkers are of varied ethnic backgrounds. In some areas, Haitians and Asian
immigrants have also taken up farm work Outreach to farmworkers will therefore
require extensive efforts in cross-cultural communication.
While much of the safety training materials are well illustrated, it is recognized
within the Occupational Safety Branch that these materials alone will be of
marginal value in reaching farmworkers with little formal education. These
materials will be most useful in aiding those who will teach the farmworkers about
safety practices.
In preparing materials for farmworkers, the Occupational Safety Branch of OPP
intends to make them concise and understandable. One source of advice in
preparing the materials has been staff of Latino background with experience in the
Peace Corps and knowledge of farmworkers' conditions.
Grower organizations, the Cooperative Extension Service of USDA, and public
service organizations are important channels for reaching the growers with new
information on regulations as well as training materials on pesticide safety. To
reach the farmworkers, OPP plans to communicate through farmworker
organizations, which will do the necessary training. Two organizations which are
scheduled to receive funding include the National Migrant Resource Program
(NMRP) and the Association of Farmworkers Opportunity Programs (AFOP)
The NMRP is associated with the Migrant Health Project in Texas; the funding
is for migrant health, which includes health hazards from pesticides. AFOP is an
association of farmworker organizations that are primarily involved in employment
braining and upgrading job skills. Through an inter-agency agreement, funds have
been allocated to AFOP for safety training. The purpose of the funding is to train
those individuals chosen to be pesticide safety trainers by their respective
organizations. These trainers will go out into the fields to meet with farmworkers
in their camps after working hours. Farmworker organizations often use mobile
classrooms or provide transportation in order to get the worker to the classes
AFOP is convinced that only by training the farmworkers in small groups, where
the workers feel free to ask questions, will this training be effective. The need for
culturally-sensitive materials for other groups, such as Haitians and Laotians are
under consideration.
In addition to the Worker Protection Program, the Communications Branch of
OPP conveys information about risks associated with pesticides to labor and
farmworker groups. The Communications Branch regularly contacts farmworker
organizations when an announcement is considered relevant to farmworkers For
instance, the announcement of the agreement to restrict the use of the pesticide
parathion because of occupational safety concerns was communicated to the United
Farm Workers, Friends of the Farmworkers, and the National Association of
Community Health Centers.
6.3.5 Lead
The EPA lead programs are another example of an important and highly visible
risk for which relatively little formal risk communication materials exist. The
Office of Water has produced several pamphlets on lead in drinking water (dated
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April 1987, December 1988, January 1989, and April 1989). In addition, the Office
of Water (OW) is drafting a. document—A Primer: Developing a Community-Based
Public Education Program on Lead in Drinking Water, (October 6,1989) which grew
out of a pilot public education program that EPA conducted in Raleigh, North
Carolina. This document is designed largely for water suppliers. EPA's final
regulation for lead in drinking water requires public water suppliers to deliver
educational materials to consumers. EPA is developing general materials based on
the Raleigh experience and will be providing them to public water suppliers in
camera-ready form. OW will publish final guidance and encourage public water
suppliers to work with local public health agencies.
Review of Materials front the Office of Water. The various pamphlets are very
informative and comprehensible to a wide variety of audiences. Issues of special
concern to racial minorities and the poor are raised and generally dealt with
sensitively. For example, the pamphlets are not just aimed at homeowners, but at
renters in large apartment buildings (who may not be able to remove lead
effectively by flushing their taps each morning). The pamphlets recommend that
people test their household water for lead, yet they do not provide information as
to whether subsidized or inexpensive tests might be available (except in the case of
the pamphlet "Get the Lead Out"). OW has research underway to develop
inexpensive field kits. „,,,,,
A good example of how an issue is addressed in a way that will be helpful to
low-income families is the discussion on the routine flushing of household taps.
Although EPA notes that such a measure will only increase a house's water bill by
approximately 25 cents per month, the pamphlets take pains to suggest that
households can use the flushed water to wash floors or water house plants, or can
bottle the water coming from the tap after it has been flushed for later use-in both
cases, reducing the small but possibly significant cost of incremental water usage.
Although these suggestions may in fact have been motivated by water conservation
rather than cost-saving considerations, they will be appreciated by readers who
have serious financial concerns.
Broader Equity Issues in Lead Risk Communication. There appears to be some
There is a sentiment among some lead pollution activists that EPA and other
agencies only stepped up their efforts to abate lead exposure when lead was found
to be a serious problem for populations other than inner-city racial minorities. The
allegations that EPA's attention to lead pollution in general reflects a lack of
concern about the health problems of certain populations is unsubstantiated.
However, the fact that these sentiments exist should be borne in mind by EPA in
conducting future risk communication activities.
In fact, EPA has already taken action to reduce the amount of lead in gasoline,
which contributed to a reduction in average blood lead levels over the past 10 to 20
years from 15 micrograms per deciliter (ng/dl) to 5 ng/dl. However, since the
Agency's action to reduce lead in gasoline, new scientific, research demonstrated
that harmful effects occur at blood lead levels previously considered safe. Based on
this new information, the threshold level for lead toxicity concern has declined
steadily. In response to this new scientific information on lead, EPA developed a
strategy to reduce lead exposures to the fullest extent practicable, with particular
emphasis on reducing the risk to children—the population at greatest overall risk.
Implementation of this strategy is intended to reduce elevated blood-lead levels in
the nation's children and, gpLven that a disproportionately large percentage of
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children from minority and low-income families have elevated blood lead levels,
will have a greater impact on children in these high-risk groups.
Critics of EPA's lead programs have indicated that EPA's emphasis on
particular exposure pathways reflects a biased avoidance of the exposures of
greatest concern to poor and racial minority citizens. According to the Alienee to
End Childhood Lead Poisoning (AECLP), exposure to lead via drinking water
contributes only 1 to 2 ug/dl or less to the background blood lead concentration
(which may exceed 10-20 ug/dl in high-risk cases). EPA has stated that the three
major sources of lead contributing to blood-lead levels above 10 ug/dl appear to
be: (1) lead-based paint, (2) urban soil and dust, and (3) drinking water. The
Agency is directing its risk communication efforts to provide information on
exposure from these pathways for all groups that may be affected by these
exposure pathways.
Further, EPA is currently working on the development of model course
curricula for inspectors, supervisors, workers, and designers to address the
problems associated with the removal of leaded paint. In addition, a brochure for
parents and day-care providers that will provide information on the hazards of
lead exposure and how to reduce these hazards is under development.
6.4 CONCLUSIONS
Neither the Risk Communication Program in general, nor the specific efforts in risk
communication, have explicit equity goals. Indeed, they seldom mention race,
income, or other characteristics that might influence the distribution of risks and
benefits, or the effectiveness of risk communication. The risk communication
efforts have not been aimed at addressing disproportionate distributions in risk, nor
are there explicit guidelines to ensure that the risk communication process itself is
as effective as it could be at reaching all affected populations.
While risk communication guidance contains valuable advice, much of it is
general; it does not explicitly address the issue of equity. One can extract ideas for
more equitable risk communication from the guidance, but both the Agency and
affected communities would benefit from risk communication guidance that
explicitly addresses equity issues.
Unfortunately, the real practice of risk communication is seldom able to live up
to the aspirations of those who craft written guidelines. Even in those instances
where members of the community have been actively engaged in the
decision-making process, these tend to be the members of society more likely to
participate even without encouragement from EPA. Racial minority and
low-income groups often feel excluded. While EPA believes that risk
communication is a two-way process, many of the activities tend to be
unidirectional, aimed at "educating" the public. Providing information in this
manner without assuring forums for substantial input into the decision-making
process can lead to frustration and anger on the part of the public.
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7.0 OUTREACH EFFORTS
Administrator Reilly's fourth and final charge to the workgroup was to review
institutional relationships, including outreach to and consultation with racial
minority and low-income organizations, to assure that EPA is fulfilling its mission
with respect to these populations. ,
7.1 NATIONAL ENVIRONMENTAL EQUITY
NETWORK
Local grassroots organizations play a key role in the environmental equity
movement. These groups often are comprised of individuals who historically may
not have been part of a large membership environmental organization. In many
cases, individuals in these groups live in racial minority or low-income
communities and have mobilized around a threat to their immediate community,
such as a landfill or incinerator. It is of critical importance that the Agency make a
special effort to contact these groups both through EPA headquarters initiatives
and, more importantly, the Regional Offices. Traditional community
organizations such as religious organizations also offer a unique opportunity to
reach individuals whose lives are directly affected by environmental equity issues.
An excellent example is the United Church of Christ (author of Toxic Waste and
Race, 1987). The United Methodists, National Council of Churches, and the
Presbyterian Church have all been actively involved in the environmental equity
movement. Clearly, part of EPA's responsibility to achieve effective outreach is to
identify community orgaiuzations with the credibility and means to reach
individuals who otherwise may not be reached. ,
Effective use of the media is an essential component in reaching population
groups with a direct stake in environmental equity issues. The Subgroup compiled
information on a range of racial minority and ethnic newspapers and newsletters
published nationally as well as locally. These publications provide a valuable
conduit for disseminating information. EPA is also exploring increased use of
radio public service announcements in languages other than English.
The headquarters outreach committee has begun to contact hundreds of
organizations and individuals nationwide to build a national environmental equity
network. The outreach effort includes organizations such as universities, minority
rights membership organizations, community-based grass-roots groups, religious
organizations and local extension services. Groups and individuals are also
included from the Agency's traditional constituencies such as environmental
groups, civic, and consumer groups, labor organizations, business and trade groups,
congressional representatives, and state and local organizations. This network will
become a cornerstone for hearing concerns, sharing information, and exchanging
success stories. The list will be made available to the Risk Communication
Program, Regional offices, and program offices for use in risk communication and
outreach on specific rules zirid Agency initiatives. .
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7.2 COOPERATION WITH OTHER FEDERAL
AGENCIES
Although EPA has several on-going efforts with the U.S. Department of Agriculture
(USDA), the US. Department of Health and Human Services, the Appalachian
Regional Commission, and the US. Census Bureau, there is significant room for
increased cooperation. Work with Health and Human Services has focused on
developing a proposed Memorandum of Understanding between EPA and the
Agency for Toxic Substances and Disease Registry-(ATSDR). The memorandum
contains a section under which the agencies agree to exchange information related
to health and risk assessments. Also, ATSDR has a minority health initiative that
should be coordinated with EPA's environmental equity initiatives.
EPA's work with USDA has centered on establishing links with the
Cooperative Extension Service—a Federal/State partnership where agents
disseminate information to local communities. A pilot project is being developed
by the Extension Service in which a training manual is being written to incorporate
environmental concerns—including environmental equity issues. If successful, the
project will be used as a model for training manuals used by other local extension
services in other parts of the country. EPA is supporting the project by providing
information on environmental equity concerns. The Agency also is discussing
strategies for tapping into the existing network of hundreds of local extension
services nationwide to spread the word about its environmental equity work and
gain valuable feedback.
The Appalachian Regional Commission (ARC) is a Federal-State agency
concerned with economic, physical, and social development in Appalachia. EPA's
work with ARC has focused on developing a Memorandum-of-Understanding
(MOU) between ARC and EPA's Public-Private-Partnerships (P3) Program. The
MOU seeks to promote public-private partnerships and other financing alternatives
in solving environmental problems facing small, economically disadvantaged
communities in this region.
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8.0 EQUITY EFFORTS AND
PERSPECTIVES AT THE REGIONAL
LEVEL
Many environmental equity issues will best be addressed by regional offices
because environmental problems and local populations differ widely across the
United States. Regional staff, closer to the problems and the communities at risk,
will be better suited to identify and solve equity issues. The role of the
headquarters office should be to identify broad national environmental equity
issues, develop policies with strong regional representation and provide technical
assistance to the regional offices.
'r A Regional Perspectives Subgroup was formed to detail perspectives from
regional staff on^equity issues and to collect information on regional environmental
equity activities. Regional staff were surveyed by telephone. They were asked to
comment on where inequities might exist Regional contacts were also asked about
projects underway that targeted equity issues or strongly impacted specific
population groups.
8.1 REGIONAL STAFF PERSPECTIVES
Through many discussions with regional staff, the most important discovery to
emerge Was that many were unaware of equity issues. When pressed staff
members could cite anecdotal evidence that environmental risks impact certain
communities disproportionately. However, many believe that the Agency's
activities are generally equitable, because its mission statement is focused on the
environment, not on particular groups. This perception—founded on the
assumption that national standards and a focus on resources protect all
communities equally—is, in part, what has allowed instances of disproportionate
distribution of pollutants to continue unaddressed.
Awareness of equity issues varied considerably by region. Most frequently,
staff members cited the following as areas of concern: The existence of large
numbers of hazardous waste sites in low-income communities, EPA's lack of
control over the siting process, and disproportionate distribution of National
Priorities List sites. Regional staff also consistently pointed to issues surrounding
siting of publicly owned treatment works (POTWs) and construction grants under
the dean Water Act. It should be noted, however, that the siting of POTWs is a
local decision and not within EPA's jurisdiction.
Most of the Regional staff members interviewed identified outreach as a key
method for addressing environmental equity issues. There are examples of EPA
targeting information to specific, high risk populations. Among the examples of
this are Region DCs translation of Worker protection standards into Hmong; the
translation of Superfund Factsheets into Portuguese for use in New Bedford, MA
(Region I); and Region ITs production of the Spanish publication "Mercuric y el
Ambiente" ("Mercury and the Environment").
Outreach on environmental equity issues can be conducted in two ways. It can
be unidirectional, with the Agency communicating its message to the communities
of concern, or bidirectional, with the Agency engaging in a dialogue with these ^
communities, both communicating its message and listening to the communities'
concerns. Regional staff members support a bi-directional approach, believing that
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the Agency needs to exhibit a willingness to address community concerns as well
as^the Agency's own agenda. Examples of a bi-directional approach are Region
DCs underwriting of Spanish-language radio call-in programs in the Fresno,
California area that deal with issues of pesticide use and worker safety, and Region
VIII's model risk communication program.
Given the general lack of awareness demonstrated by many regional staff, the
importance of the individuals addressing equity concerns increases. Regional staff
familiar with environmental equity issues demonstrated the ability to address the
issue through existing programs. In many cases, equity issues can be addressed
without major shifts in staff responsibilities or programmatic changes. However,
awareness of equity issues by individual regional staff is not sufficient. Equity
considerations must be incorporated systematically into all aspects of the Agency's
field work. '
Despite the general lack of awareness, there are on-going regional activities that
address environmental equity issues. Many of these activities began before the
Workgroup was formed. Through the efforts of a relatively small number of staff,
several regional offices have managed to conduct research, outreach, and risk
communication efforts targeted to racial minority and low-income communities.
However, the efforts are not comprehensive, and should be viewed as
demonstrations of what regions can do to address equity issues.
8.2 REGIONAL EQUITY PROJECTS
EPA's regional offices are leading the way in on-the-ground, practical programs to
reduce perceived and actual environmental inequities. Regional offices are engaged
in a variety of environmental equity projects including risk assessment, risk
communication, and programmatic efforts targeted to reduce disproportionate risk.
The following list of projects includes regional and Headquarters programs that
address risks in racial minority and low-income communities. This list expands
upon and adds new information to that information included in the Summarv
Report. ' .'
Project Name: Urban Environmental Initiative
Region: I (Boston)
Contact: James Younger
Phone*: 617-565-3427
Project Summary:
The Urban Environmental Initiative is an attempt to develop a bi-directional
communication strategy. The ultimate goal of the Initiative is to develop a listing
of environmental issues to be addressed—an environmental agenda—for the Boston
area which includes the concerns of racial minqrity communities.
Currently underway in Boston, the project focuses on community awareness,
empowerment and involvement in environmental issues. The program is exploring
the impact of environmental problems on the urban community with particular
emphasis on environmental problems other than lead, such as air pollution, PCBs
and radon.
Region 1 is employing a broad-based meeting approach. Groups of community
leaders, black college student government presidents, local urban media outlets and
EPA officials have been convened. Nine meetings will be held over the course of
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two years and will culminate in a major conference in the spring of 1993. This
outreach will not only address critical issued but also convey to the community a
description of the Agency's mission statement, mandate, and authorities.
Project Name: Strategic Planning Initiative
Region:! (Boston)
Contact:
Phone #:
James Younger
617-565-3427
Project Summary:
In 1990, Region I refined its strategic planning process to serve as a tool for
managing human health and ecological risks. The region articulated four strategies
in this ongoing process: Changing organizational culture, pollution prevention,
resource protection, and relationships with government agencies. Recognizing the
importance of environmental equity, the region incorporated the issue under
changing organizational culture. A component of the region's articulated vision
emphasizes this commitment: "A New England where rich and poor alike share in
the benefits of a healthy environment."
Key to the strategic planning process is the undertaking of strategic analysis to
assess the Region's internal strengths and weaknesses. The region determined that
it is not addressing the problem of environmental equity, since low income groups
may be facing higher risks and disproportionate costs for environmental protection.
The present organizational culture does not support the skills and approaches
necessary to advance environmental equity. The region also identified as a critical
issue the need to focus its outreach efforts to address environmental equity. Part of
the region's integrated action plan provides for equity awareness training.
Project Name: Supeifund Enforcement Investigation
Region: II (New York)
Contact: Dana Williams
Phone #: 212-264-1709
Project Summary:
In 1990, Region 2's Equal Employment Office (EEO) proposed examining the
hypothesis that more affluent communities were receiving more favorable cleanup
through the Superfund program. The study will document if there are more
Superfund/CERCLIS sites located in racial minority and/or poor communities.
Using census data recently loaded into a Graphics Information System (GIS), a map
will be developed that includes the location of CERCLIS and Superfund sites and
pertinent demographic data. Demographic data will include per capita income and
percentage of population in racial minority groups.
In addition to this site location/demographic analysis, the study will examine
cumulative individual risk at sites, using standard risk assessment methodology to
quantify the risk to public health in reasonably foreseeable exposure scenarios.
Are more affluent communities able to speed up the Superfund process? This
study will identify the key factors in determining the speed of activity of
remediation at Superfund sites. Do racial minority and poor communities receive
proper attention in the earlier stages of the Superfund process? To measure the
efficiency of the Superfund process, time frames in the earlier stages of the process
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will be investigated. An evaluation of the amount of time spent performing these
tasks may reflect environmental inequities stemming from higher prioritization
given to more politically charged sites.
Are more sites making the National Priority List (NPL) in affluent communities
than in poorer communities? CERCLIS sites with severe enough environmental
conditions are placed on the NPL and are therefore eligible for a federally funded
cleanup. This study will evaluate the type and degree of political pressure
exercised by communities in influencing whether sites are placed on the NPL.
The following elements of the Superfund process will be investigated:
• " Do biases exist within the Hazard Ranking System that would favor
affluent communities and allow them to receive higher scores and be
placed on the NPL?
• Is public involvement more visible in more affluent communities?
The methodology will be dependent upon the data available. The first level of
analysis involves anecdotal evidence found through interviews with the Superfund
st^? m Region 2. The second level will involve quantitative measures, focusing on
the statistical significance of the data. If the data are available and adequate, a
third level of study will be performed involving multiple regression analysis.
^-°Fe*ations ^^ be developed between demographics and the various elements of
the Superfund process.
Project Name: Baltimor^Washington, D.C. Urban Environmental Risk Initiative
Region: HI (Philadelphia)
Contact: Dominique Luckenhoff
Phone*: 215-597-6529
Project Summary:
Multi-media environmental risk profiles for socioeconomic subgroups within the
study area will be developed and displayed on Geographic Information System
(GIS) maps. GIS will serve not only to assist with the analytical work, but also to
present the results in a format understandable to the general public. These risk
profiles will also be compared to background or reference conditions in order to
determine whether environmental risks within the defined study areas are
disproportionately distributed by socioeconomic class. Community outreach to
organizations and individuals representing the affected populations in the study
areas will be conducted with the assistance of state and local officials and Morgan
State University. In addition to communicating EPA's risk assessment findings,
these community outreach forums will also be used to reach consensus on the
environmental problems of greatest concern and how best to address them based
upon community needs and available resources.
Project Name: Radon and Asbestos Awareness Program (RAAP)
Region: HI (Philadelphia)
Contact; Aquanetta Dickens
Phone #: 215-597-4553
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Project Summary:
The Radon and Asbestos Awareness Program (RAAP) targets racial minority
communities for effective communication of health risks associated with radon and
asbestos. The program is now being piloted in the Philadelphia area, with the
intention of being transferred to other major metropolitan areas within the region.
The program involves regular radio forums consisting of professionals from EPA,
other federal agencies, universities/colleges and private industry to communicate
the health threats of radon and asbestos and to obtain direct feedback from
members of ethnic communities on their experiences and perceptions of the
problems.
Project Name: Multi-Cultural Participation in the Chesapeake Bay Program
Region: HI (Philadelphia)
Contact: Dominique Lueckenhoff
Phone #: a5-597-6529 "
Project Summary:
The Chesapeake Bay Program is developing a multi-cultural participation program
to broaden public participation and involvement in the restoration of the Bay. The
target groups for greater involvement are citizens of African, Latino and Asian
descent, -as well as rural poor and others with a direct economic link to the
productivity of the Bay.
The focus of the program is on structuring public information materials and
educational programs to have broad appeal and encourage increased participation.
This includes surveying multi-cultural interests to evaluate the impact of the
Chesapeake Bay Program on racial minority and low-income communities. For
example, the Anacostia Public Education arid Participation Program of the
Interstate Commission has reached over 40,000 people since 1988. The program has
a quarterly newsletter, 9 sub-basin coordinators and educational activities and
outreach. A prime goal of this program is to get every foot of every stream within
the Anacostia watershed "adopted" by local residents and businesses.
Project Name: Lead Education and Abatement Program (Project LEAP)
Region: V (Chicago)
Contact: William H. Sanders HI, Project Director
Phone *': 312-3S3-3808
Project Summary:
INTRODUCTION
The Region 5 comparative risk study was completed in the summer of 1990. The
study identified lead as one of the multi-program pollutants of concern. The region
thus selected lead as a priority area, and tasked the medium programs, and a
project director, with development of a comprehensive strategy/implementation
plan to address and remediate lead contamination in the six state region.
The group recognized that lead poisoning in children is now considered to be a
national epidemic. Lead exposures from exterior and interior residential paint, as
well as exposures from contaminated soils and dust in and around structures
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present in most urban areas, drinking water, air emissions, food, occupational
settings, and hobby activities, result in multiple pathways of exposure. These
exposures are responsible for a number of adverse health effects in humans,
especially in children. Because children are at elevated risk, a targeted population
has been chosen to be children under seven years of age, and women of child'
bearing age as a surrogate for the fetus. Within this population group, African and
Latino-Americans are particularly targeted in recognition of an increased body
burden susceptibmty/vulnerability to the uptake and effects of lead exposure.
Within the region, 68 Metropolitan Statistical Areas (MSAs)—essentially all the
inner-city locations—are being studied.
Project LEAP is a multi-media and multi-program approach having four basic
components: (1) data analysis and targeting; (2) pollution prevention; (3) education
and intervention activities; and (4) abatement activities. The project will be
implemented over a three year period, and is a component of the Agency Lead
Strategy. The project focuses upon data analysis, air modeling of major sources,
prioritization of sources and areas for targeting purposes, and selection of
geographic areas for attention during the second and third years of the Project.
The data analysis stage will be completed in the Spring of 1992.'
PROJECT STATUS
AJDRS-FS data (stationary source air emissions) have been obtained and organized in
a database for all Region 5 states except for Ohio (data is pending from the state
agency). Toxic Release Inventory (TRI) data are also being used in this project.
Between the two data bases, all reported significant sources of stationary source
exposure via the air pathway should be ascertained. Emission information for the
30 Municipal Waste Combusters located within the region, along with other facility
information, is also being incorporated. Significant sources within the 68 MSAs
will be selected for air concentration and deposition modeling
The national database for drinking water contains a very limited number of
public water supplies reporting exceedances of the then-existing 50 ppb drinking
water standard for lead (Le., there have been a relatively small number of
exceedances). Information is being provided by each of the six states on actual
measured values, as reported, for public water supplies serving residents in the 68
MSAs.
Although all Superfund sites in the region have been mapped in geographic
information systems (GIS) format, information has not been evaluated for lead.
Consequently, that information will have to be gleaned from individual hard copy
reports of the preliminary assessment/site investigations for each site in the areas
of interest. A similar approach will be started for RCRA facilities. LEAFs first
report, Spatial and Numerical Dimensions of Young Minority Children Exposed to Low-
Level Environmental Sources of Lead, is complete and available upon request.
Project Name: Geographic Enforcement Initiative
Region: V (Chicago)
Contact:
Phone #:
Bert Frey
312-886-6823/6771
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Project Summary:
The Region 5 Geographic Enforcement Initiative (GET) is a major part of an
ongoing, risk-based, multi-media effort focused on Southeast Chicago and
Northwestern Indiana. This heavily industrialized area is beset with a host of
environmental problems affecting air, water, soil and quality of life. The residents
olthis area include a high percentage of low-income and minority people.
Previous evaluations of this area have highlighted a variety of unacceptable human
health and ecological risks.
The goals of the GEI are:
• Reduce toxic loadings in the area by 50% by 1990.
• Restore Ecological Systems within the area.
• Achieve a high level of compliance with all Federal and State environmental
laws and regulations.
, • Achieve full compliance with Annex 2 of the Great Lakes Quality Agreement.
t '
• Develop and implement a pollution prevention program to complement Federal
and State Enforcement.
• Integrate an aggressive communications strategy into each aspect and phase of
the initiative.
Project Name: CIS/Comparative Risk Equity Analysis
Region: VI (Dallas)
Contact: Lynda Carroll,
Phone #: (214) 655-6570
Project Summary:
Region 6 has developed Geographic Information System (CIS) and Comparative
Risk capabilities to evaluate environmental equity concerns in the five states in the
area. Region 6's comparative risk methodology identifies susceptibility factors as
part of risk evaluations for human health. Factors such as age, pregnancy, genetics
(race), personal income, pre-existing disease and lifestyle are susceptibility
measures. Considerations of racial minority status are included in the genetics and
lifestyle factors. The other factors indirectly assess the socioeconomic status of
identified population groups.
Susceptibility factors have been analyzed for site specific studies (i.e., areas
around hazardous waste sites) and large geographic locations such as cities, states
or the region. Combined with chemical release data (i.e., the Toxic Release
Inventory or monitoring information), geographic and demographic data and state
health department vital statistics data, regional equity assessments can be
performed routinely.
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Project Name: Gulf Coast Toxics Initiative -
Region: VI (Dallas)
Contact: Lynda Carroll
Phone*: (214)655-6570
Project Summary:
The Gulf Coast Toxics Initiative is a major 1992 enforcement effort in Region 6.
The program will target facilities in the sensitive Gulf Coast ecoregion where most
of the toxic releases in the region occur. The region's inspectors will allocate 38
percent of their time to this initiative. Owing to the high human populations and
quantity of wetlands in the Gulf Coast of Louisiana and Texas, it was selected as
the most likely area to benefit from an intensive multi-media enforcement effort.
Project Name: Rio Grande Study
Region: VI (Dallas)
Contact: Lynda Carroll
Phone*: (214)655-6570
• " /
Project Summary:
The Agency is committing $352,000 over the next two years for a study that will
monitor and analyze the presence of toxic chemicals along the Rio Grande from El
Paso to the Gulf of Mexico. The study is designed to determine whether
environmental pollution is causing the high incidence of birth defects in the lower
Rip Grande Valley and whether the health of residents along the U.S.-Mexico
border is at risk. Water and sediment samples will be taken in the Rio Grande
above and below all major urban areas and industrial sites outside of urban areas.
The EPA will also sample each tributary as it enters the Rio Grande, as well as
sampling wastewater treatment discharges and untreated sewage at their points of
discharge. Furthermore, the study will include laboratory analysis of fish samples
taken from various points along the river.
Project Name: Region Vn Indian Strategy
Region: VH (Kansas City)
Contact: Dewane Knott
Phone*: 913-551-7000
Project Summary:
,' 'M| ,11 • , , , ^
The focus of EPA's Indian Strategy is to develop the capability within tribes to
manage their own tribal environments. Since tribal environments and the
corresponding environmental problems vary nationally, Region VH is implementing
the strategy by concentrating in the three areas identified as priorities by the tribes
in the region: solid waste, environmental education and groundwater protection.
A Native American Senior Employment Program person has been hired to work
exclusively with the tribes on solid waste issues by providing training
opportunities. In terms of environmental education, Region Vn is distributing an
environmental curriculum to the reservation schools accompanied by teacher
training, distributing training videos to the tribes, and coordinating with the local
Native American junior colleges. Groundwater contamination is being addressed
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with additional outreach and by including a groundwater component in all grants
awarded to tribes.
Project Name: Environmental Education Initiative
Region: VII (Kansas City)
Contact: Rowena Michaels
Phone #: 913-551-7000
Project Summary:
Region VH and the University of Kansas established a National Environmental
Education and Training Center to provide leadership in environmental education,
teacher training and professional development. The region funded a pilot teacher
training project to develop exemplary environmental education modules for use in
the four state area. The project focused on educating K-6 teachers at a two-week,
on-campus "Summer Institute" in July, 1991. Special emphasis was placed on
assuring that teachers selected for the "Summer Institute11 represented diverse
school districts from urban and rural areas in Region VH. The Center will continue
to assure that diversity is a special focus in future educational efforts.
The Region VH Strategic Plan covering fiscal years 1993 through 1996 includes
commitments to work extensively with educators throughout the region to assure
that young people receive adequate information, about environmental matters to
make sound environmental choices throughout their lives. The Plan also
recognizes environmental equity as an important issue which will be reflected in
communication and outreach.
Project Name: Equitable Enforcement Investigation
Region: Vin (Denver)
Contact: Elmer Chenattlt
Phone: #: 303-293-1622
Project Summary:
Region 8 has initiated an investigation of polluting facilities and enforcement
actions in the Denver-Boulder metropolitan area using Geographic Information
System (CIS) technology. The concern is that one or more localities may experience
a significant degree of inequity with regard to, the level of enforcement.
1980 demographic data has been assembled for the Denver-Boulder Metro area.
Census tract areas range from populations of 30 ta 8,000 (average 4,000). Income
data was projected onto the areas for both poverty and poverty threshold areas.
Poverty areas are made of tracts where greater than 25% of the persons live below
the poverty level. Poverty thresholds areas are defined as areas where greater than
12% of the population lives below the poverty level. Ethnic composition has also
been included in the GIS.
Environmental hazard data derived from the CERCLIS inventory and the Toxic
Release Inventory (TRI) was then projected on to the area maps. Of the universe of
315 sites, approximately 120 appear to present a potential health hazard. These
include 98 CERCLIS and 22 TRI sites.
Future project activities will entail collecting enforcement data and adding it to
the data base. Once this is completed, a review of the level of enforcement with
regard to ethnicity and income level can than be delineated. If inequities do exist,
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recommendations will be made to ensure equitable distribution of enforcement
activities.
':,' k » .
•Project Name: Outreach Program in Ethnic Communities
Region: Vm (Denver)
Contact: Elmer Chenault
Phone #: 303-293>1622
Project Summary:
Region 8 is currently developing and testing a model outreach program designed to
communicate environmental awareness to ethnic communities. The program
heavily emphasizes two-way communication and is being piloted in a low-income
neighborhood in Denver. Based on initial meetings with the community, the multi-
media approach is being designed to communicate, in simple common language:
• Risk Assessments: How are they done, what they mean, how they are
used, etc. (For example: What is a risk factor? How is it determined?
What risks are acceptable, why/why not?)
• Legal Rights: What peoples rights are and how they can be pursued.
* SARA Title m (Community-Right-To-Know): What is it? How does it
work? What is it for? Who can access what information? How?
• Technical Assistance Grants (Superfund): How can communities access
technical assistance grants or other types of grants? Technical Assistance
Grants can be used to do studies, hire technical experts, perform outreach
into communities, etc.
« Federal vs. State Responsibilities: Explains who has responsibility for
oversight, enforcement, and law suits relating to polluting industries.
• Hazardous and/or Toxic Materials: Why are materials defined as
hazardous and/or toxic?
Once the program has been implemented and modified in Region VIE, an
information packet will be distributed for national application. The kit will include:
• An EPA outreach model for low-income communities;
• Actions Plans for Workshops;
* Detailed Workshop Presentations; and
• Detailed schedule to implement community workshops.
Project Name: California Migrant Labor Drinking Water, Enforcement Program
Region: DC (San Francisco)
Contact: Mona Ellison
Phone*: 415^744-1846
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Project Summary:
METHODOLOGY
For years, small water system compliance with the National Primary Drinking
Water Regulations has been a focus of EPA Region 9^ public water supply
enforcement efforts. During the past year, Region 9 has worked to gather
information on a subset, of these systems — migrant labor camps in California.
Since migrant farm workers are known to be vulnerable to many environmental
hazards, the Region 9 Drinking Water Branch was concerned that labor camps
shared many, if not more, of the compliance problems common to small systems
throughout the state.
A listing of over one thousand labor camps was obtained from the California
Department of Housing and Community Development. This listing revealed over
300 camps, located throughout 41 of California's 58 counties, which might have
water systems meeting the Safe Drinking Water Act definition of a public water
system. , ,
In addition to the county environmental health agencies, several migrant
worker and rural community assistance agencies were contacted to discover any
camps unknown to both state and county agencies. Contact was made with the
Rural Community Assistance Corporation (RCAC), California Rural Legal
Assistance Foundation, California Institute for Rural Studies, and the Agricultural
Workers Health Center in Stockton.
FINDINGS
The survey revealed that labor camp water systems may have a higher
noncompliance rate than other categories of smaller systems. Most camps were not
inventoried or being monitored as public water systems by county environmental
health agencies, although they met the definition of public water systems. In
summary, we found 191 violating labor camp water systems (some camps have
more than one violation) serving over 8,500 people in 20 counties. Failure to
monitor (sample) and report is the most common violation category. Not all labor
camps house "migratory" people; many camps serve water to workers and then-
families in single family dwellings on a year-round, permanent basis. Some house
and serve water to people for at least six months or longer.
FOLLOW-UP
More than one county contact warned that strict enforcement of the drinking water
regulations may 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 country contacts, labor camp owners have often
chosen to close their camps rather than comply with regulations.
Counties were contacted to discuss the enforcement options available for
bringing violating camps into compliance. Options included the county assuming
full enforcement responsibility, EPA issuing the initial enforcement action (a Notice
of Violation) with county follow-up enforcement, if necessary, or EPA assuming
full enforcement responsibility.
In June 1991, a final report of Region 9*8 findings, including an appendix listing
the violating camps and related pertinent information was sent to the California
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Department of Health Services (DHS), the California Department of Housing and
Community Development (HCD), and all county environmental health agencies
involved in the survey. EPA Region 9 hopes to work in a close, collaborative effort
with bpth DHS and the county environmental health agencies, as well as HCD, to
bring as many violating labor camp water systems into compliance as possible.
As part of this effort, Region 9 staff plan to accompany county housing and/or
public water system inspectors on routine inspections of some labor camps.
Project Name: Hawaii Environmental Risk Ranking Project
Region: DC (San Francisco)
Contact: Gerald Hiatt
Phone*: 415-744-1022
Project Summary:
The state of Hawaii has undertaken a comparative risk project to identify and rank
environmental problems facing the state. Risk assessment information is being
used to rate Hawaii's environmental problems on the basis of threats to: human
health, environment, economic welfare and quality of life. One of the major quality
of life concerns is the effect of development and pollution on native Hawaiians,
including a number of subsistence-level communities. Native Hawaiian culture
and religion are closely tied to the environment and the sociological and
psychological impacts of environmental change extend beyond direct health and
ecosystem effects.
Two issues unique to native Hawaiians are being considered: 1) cultural and
religious impacts of loss or degradation of specific ecosystems or sites; and 2)
increased exposure to environmental pollution in subsistence-level Hawaiian
communities. Three professors at the University of Hawaii are assisting the project:
Drs. Luciano Minerbi, Davianna McGregor, and Jon Matsuoka.
Project Name: Pesticide Applicator Training
Region: X (Seattle)
Contact: Allan Welch
Phone*: 206-553-1980
Project Summary:
Region 10 has developed, in conjunction with the Washington Department of
Agriculture, a Pesticide Applicator Training course in Spanish. This training
module was developed for Hispanic farmworkers who find it easier to learn in
Spanish. During 1991, a total of 400 Hispanic farmworkers attended one of the six
session courses that were held at six different locations in Washington state. Many
of the participants took and passed the Washington private applicator exam. A
copy of the training program will be made available through the Washington
Department of Agriculture.
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Project Name: A Methodology for Estimating Population Exposure from the
Consumption of Chemically Contaminated Fish
Region: Headquarters/Region X (Seattle)
Contact: Craig McConnack
Phone*: 202-260-5873
Project Summary:
The purpose of the study is to develop a methodology to estimate populations that
may be at a greater than average risk from eating fish contaminated from industrial
point pollution. These populations eat fish at a greater than average rate and
include Native Americans; Asians, Blacks, and recreational and subsistence fishers.
The methodology developed provides an estimate of a geographical area of
potential exposure and an estimate of exposure and risk in consideration of age, sex
and race/ethnicity. The methodology will assist EPA regional offices and states in
issuing fish advisories.
To collect more data on the fish consumption patterns of Native Americans,
EPA is sponsoring the Columbia River Inter-Tribal Fish Commission Survey of Fish
Consumption and Related Issues. In this survey, four Pacific Northwest Indian
tribes are being surveyed about their fish consumption habits.
Project Name: Effectiveness of the SRF Program: Economically Disadvantaged
Communities -
Headquarters: Office of Policy Analysis
Contact: Bob Greene
Phone*: 202-260-7069
Project Summary: .
This study is testing whether the State Revolving Fund (SRF) Loan Program is
providing equitable funding to economically disadvantaged small communities and
the proportion of water qualify problems contributed by these communities. (SRF
is the funding mechanism under the Clean Water Act for publicly owned treatment
works). Data on communities receiving SRF loans and construction grants, amount
of loan/grant, purpose of the award, community size, and financial condition of the
community is being put on a data base. Data will be collected relating to the
effects of small, economically disadvantaged communities on water quality. The
study will also review alternative methods of creative financing for economically
disadvantaged communities. Project completion is being set for spring of 1992, and
will be relevant to the Clean Water Act reauthorization proceedings in Congress.
Project Name: Public-Private Partnerships (P3) Program
Headquarters: Office of Administration and Resources Management (OARM)
Contact: David Osterrcian
Phone*: 202-260-1020
Project Summary:
The P3 program works to leverage public and private resources for environmental
protection financing in small and/or economically disadvantaged communities. P3
is implementing demonstration projects in each of the EPA regions to serve as
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of practical solutions to local environmental financing problems. The
projects, designed to be replicated in communities across the nation, develop and
test new financing arrangements and encourage private participation in
environmental services. To date, twenty projects have been funded.
P3 also has a joint demonstration program with the Appalachian Regional
Commission, a Federal-State agency concerned with economic, physical, and social
development in Appalachia. The program promotes partnerships and other
financing alternatives to solve environmental problems facing the small and
economically disadvantaged communities of the Appalachian region.
The P3 program is evaluating the feasibility of establishing a development fund
that will serve as a permanent source of money for supporting innovative
demonstration projects. This fund would be a non-profit authority that makes
grants and low-interest loans to finance the development of public-private
partnerships. The initial feasibility study is being conducted in Puerto Rico.
Project Name: EPA Lead Reduction Strategy
Headquarters: Office of Pollution Prevention and Toxics
Contact: Joe Carra
Phone*: 202-260-1815
Project Summary:
EPA's comprehensive lead strategy, released last February, has a goal of reducing
lead exposures to the fullest extent practicable, with particular interest in reducing
the risk to children. One of the objectives EPA will use to set program priorities
and gauge program success is the significant reduction in the number of children
with blood lead levels greater than 10 ug/dl. EPA is currently evaluating the
feasibility of regulating the commercial use of lead solder for drinking water
plumbing, and a lead leaching standard for plumbing fittings. Last June, EPA
published a final rule reducing the amount of lead in drinking water. It ensures
tfiat homes with the highest risks are targeted for treatment. As a result,
approximately 600,000 children will have their blood lead levels reduced below 10
ug/dl. In addition, by next spring, EPA will propose lowering the National
Ambient Air Quality Standard for lead.
Project Name: Mexico-U.S. Integrated Border Environmental Plan
Region: Headquarters, VI (Dallas), and DC (San Francisco)
Contact: Richard Kiy
Phone*: 202-260-0791
Project Summary:
In response to a request by the Presidents of the Mexico and the U.S. in November,
1990, EPA and its Mexican counterpart have developed a bilateral plan to protect
the environment in the border area. Of particular concern are the inadequate waste
water treatment and drinking water facilities for the colonias (unincorporated
t^w*3 along the border.) The plan was released in mid-winter of 1992. The U.S.
National Enforcement Training Institute held training sessions for Mexican
inspectors of maquiladora industries on March 23-27,1992.
EPA, joining forces with the State of Texas and the U.S. Department of
Agriculture (USDA), has launched a major initiative to address the severe water
! .. ' '"' ' .66
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pollution and water supply problems faced by the colonias on the United States
side of the U.S.-Mexico border.
U.S. colonias are small, unincorporated, rural border communities which often
suffer from substandard housing, inadequate roads and drainage, and limited or no
water pr sewer treatment facilities. Lack of these basic sanitation facilities poses
serious public health risks, among them hepatitis and cholera, for the more than
200,000 residents of these predominantly Latino communities.
Colonias were largely bypassed by thie national water cleanup programs of the
last 20 years. Since 1972, EPA's multibillion dollar Construction Grants program
has been the major source of funds for municipal wastewater systems in the U.S.
By statute, grants could only be awarded to state or local governments. Most U.S.
colonias are in unincorporated areas and their environmental problems have been
largely unaddressed as a result.
Federal and state multimillion dollar efforts will result in measurable
improvements in coloraa environments* EPA has requested $50 million for 1993,for
the construction of wastewater systems in these disadvantaged communities in
Texas. The State of Texas is already administering an EPA-funded $15 million
special State Revolving Fund to. provide indoor plumbing in colonias.
EPA will also work in tandem with USDA's Rural Development Administration
to tackle the water problems of colonias. USDA requested $25 million for 1993
specifically for drinking water systems in colonias. The State of Texas is also
contributing sizable funding for water pollution control in Texas colonias.
Project Name: Environmental Health Equity Analysis: Evaluation of Potential
Human Exposure to Pollution Using the Toxics Release Inventory
Headquarters: Office of Health Research
Contact: Ken Sexton
Phone*: 202-260-5900
Project Summary:
The Office of Health Research (OHR) has initiated a project to evaluate the
relationship between levels of pollutant emissions and the extent of exposure to
racial minorities and/or people of lower socioeconomic status. The first step
involves an analysis of the location and magnitude of emissions (as identified by
the Toxics Release Inventory) and the demographic characteristics of the population
in the surrounding area. Demographic data will come from the U.S. Bureau of the
Census or the Donnelley Marketing data base. Additional data sets, such as the
attainment of the National Ambient Air Quality Standards, will be added as the
project develops. The analysis will be done by state, county and targeted
geographic areas. This is a long-term effort that began in February 1992.
The Office of Health Research (ORD) and the Office of Air Quality Planning
and Standards are developing a demographic study of toxic air emissions. A
massive GIS will be used to plot TRI air releases and Census Bureau demographic
data. This is a long-term, larg;e scale study that will begin in 1992.
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9.0 INSTITUTIONAL MODEL FOR
ADDRESSING ENVIRONMENTAL
EQUITY ISSUES
The Equity Analysis Subgroup reviewed definitions of environmental equity and
explored how to incorporate equity into Agency operations. As part of their
efforts, the Subgroup developed the following comprehensive model for addressing
environmental equity issues at EPA.
9.1 BACKGROUND AND RATIONALE
EPA should develop institutions and mechanisms to address environmental equity
issues as they arise. The institution should be accessible to affected communities
and capable of grappling with many different forms of equity (racial, socio-
economic, age, etc.) where equity issues are being addressed by others, such as
Congress, the states and other Agencies, EPA should attempt to appropriately
coordinate its efforts with these other institutions.
9.2 MISSION OF AN INSTITUTIONAL RESPONSE
To insure that equity plays a role in shaping national environmental policy, the
equity program at EPA should have a broad mission.
9.2.1 Goals
• Display the Agency's good faith and due process in decision making.
• Provide a procedural mechanism within the Agency to aid officials making
difficult equity decisions.
9.2.2 Functions
Education/Communication
• Stimulate the Agency to consider equity issues in the course of its decision-
making.
• .'.,, , ',.'.. . ....-'•
* Educate the Agency and facilitate communication about equity issues as they
arise, both internally and with other organizations. Support a similar
educational process at regional and state levels.
Policy Recommendations and Guidelines
• Develop and issue policy guidance. Develop a process for the consideration of
equity issues. Identify equity issues where programs or offices fail to do so.
Consultation
'• Consult with appropriate program offices to clarify equity issues inherent in
policies and decision processes. Determine whether all relevant information
has been collected. Help to resolve conflicts if they arise.
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Review
• Review the equity implications of previous decisions and policies. Perform
"audits" of the institution and its programs at regular intervals.
9.3 IMPLEMENTATION PLAN
The Agency should pursue a phased approach toward formally institutionalizing
an equity function into its structure and operations. This approach is outlined
below and illustrated in the following diagram.
9.3.1 Phase One: Short Term
1. Creation of an Internal Standing Equity Group -
EPA should establish an internal standing group to address equity concerns, and
should provide this group with adequate staff and financial resources to support its
functions. This group would normally meet quarterly but could be convened as
needed. The proposed equity group is shown in Figure 2 and includes the
following:
An Equity Committee which builds on the role of the current
Environmental Equity Workgroup. The Committee would be supported by
a Coordinator (1.0 FTE minimum) who would provide an institutional
focus for equity issues and act as a conduit to outside groups.
Figure 2:
Equity: Institutional Model (Internal)
EPA Equity Group
Representatives From All Program Offices
Office of
Water
Office of Solid Waste and
Emergency Response
I
EQUITY
COMMITTEE
STANDING GROUP
Committee
Coordinator
Representative from
Administrator's Office
Office for Communication
And Public Affairs "^
Points of Contact for All
External Groups
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Representatives from all EPA Program Offices. This function could be
filled by Special Assistants in each Assistant Administrator's Office. These
representatives would be responsible .for monitoring potential equity issues
in their respective offices and keeping AA's informed of program-relevant
equity concerns of external groups.
A Representative from the Administrator's Office (Special Assistant) who
would keep the Administrator informed of the Equity Group, its work, and
emerging issues.
A contact within the Office of Communications and Public Affairs to
facilitate public education and outreach activities.
The Equity Group would initially focus on the functions of education,
communication, and issue identification, and would:
*
• Maintain steady communications with outside groups; serve as a
clearinghouse for their concerns.
• Provide outreach to advocates for low-income groups and maintain
communications with "invisible minority" advocacy groups, e.g.
organizations focusing on hunger, homelessness, occupational safety.
"' ,li»f • , ' ' , ' ! ' ' I
• Identify environmental equity issues in Agency activities, such as proposed
rulemakings, issuance of guidelines, and grant allocation.
• Provide technical assistance to program offices in carrying out
Environmental Equity Workgroup recommendations and addressing equity
issues.
• Coordinate activities and policies with equity implications with other
Federal Agencies such as Health and Human Services.
• Educate the Agency about equity through holding internal symposia and
workshops.
• Sponsor a yearly conference which focuses on equity or equity-related
issues.
2. External Advisory Committee
In addition to an internal Equity Group, EPA should establish an advisory
board on environmental equity, referred to in Figure 3 as the "Equity
Analysis/Policy Advisory Subcommittee," in the style of the Science Advisory
Board. This external group would consist of highly credible and impartial experts
who could perform individual case reviews and offer policy recommendations to
the Agency on equity issues. This group would fulfill the functions of policy
review and consultation. The membership of the board should reflect the range of
intellectual perspectives on equity, including philosophers, economists, sociologists,
anthropologists and grassroots groups.
The subcommittee would be a group with standing membership and would be
responsible for developing positions on individual cases referred to it by the
internal mechanism within EPA. It would be responsible for selecting appropriate
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operational definitions for the term "equity" for application to given situations. The
internal EPA equity group would incorporate the advisory committee's
recommendations into Agency activities as it saw fit.
3. Identification of Research Needs
Both the Equity Group and the advisory committee would highlight areas in
which additional research and data collection where needed to understand the
distributional impacts of environmental policy. These needs could be addressed on
an ad-hoc basis or by formal inclusion in the research plans of the EPA Office of
Research and Development or Office of Policy, Planning and Evaluation.
9.3.2 Phase Two: Long Term
The long term objective is the internalization of skills for analyzing and considering
equity in EPA decisiorunaking. This can occur with the aid of experience gained
through interaction with the various resource groups and the advisory board
described above.
"Internalization" would be oriented towards affecting and building internal
processes which are equity sensitive and would take place in the following areas:
• Systematic planning and program review
The internal group would develop guidelines for program review which
become part of the Agency strategic planning and program evaluation
processes. This would begin with at least one regional and one program
pilot project to develop guidelines and methodologies and then become
mandatory for all regional arid Headquarters strategic plans, depending on
the outcome of the pilot projects. Equity sections of the strategic plans
would be reviewed by the Equity Group.,
• Periodic equity "audits"
The internal group could expand its activities to include periodic audits of .
the institution, its existing and emerging programs. Such audits would
focus on broad issues of environmental equity such as: the social and
geographic distribution of benefits and burdens, the allocation of scarce
resources for risk reduction/management, and of communities'
participation in risk allocation decisions which could affect the quality of
their lives.
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10.0 COMMENTS FROM EXTERNAL
REVIEWERS
10.1 SUMMARY OF COMMENTS
10.1.1 Major Points
• EPA should be commended for taking up the issue but has a considerable ways
to go to strengthen and implement its recommendations. No specific time
tables, actions or anticipated outcomes are given with the recommendations.
• The report overstates the lack of data on environmental risks to racial minority
and low-income communities. The report identifies lack of data as a major
finding, but EPA is not planning activities to remedy this gap. EPA should
request funding for data needs.
....... • '
• Some high-level officials view equity as a public relations issue. The
communications plan released by Rep. Henry Waxman is indicative of EPA's
lack of commitment to solve environmental inequities and the
dishonesty/disrespect with which EPA treats racial minority organizations.
EPA should not continue to attempt to co-opt legitimate leaders.
• EPA should appoint a special assistant to the Administrator for environmental
equity with decision-making authority, budget and staff.
•» ' ' ''"' ' ' '
• EPA has recognized the need for a new Farmworker Protection (FWP) Rule for
12 years but still none exists. 5 staff are devoted to the FWP. Rule, but 52 staff
work on radon gas protection which affects middle-class single-family homes.
EPA should immediately issue enforceability provisions of the FWP Rule to
make the existing regulations enforceable.
• EPA is one of the worst federal agencies in terms of integration of its
workforce. EPA should put people of color employees in substantive decision
making positions.
• EPA should integrate environmental equity into Operating Year Guidance,
strategic plans, and Agency themes.
• EPA should work with civil rights groups to equitably implement pollution
prevention.
* EPA should establish an Environmental Equity Advisory Board.
• After more than 2 decades of operation, why has EPA (and the report) failed to
address inequitable siting concerns? EPA's current position of delegating
authority over facility siting to private industry and states creates and
perpetuates environmental inequities. The report does not go far enough in
calling for mandated permitting requirements that would force states and
private industry to address siting equity. EPA should examine aggregate risks
in the permitting process.
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• A national health care.policy, national industrial policy and a national energy
policy are necessary to address environmental inequities. The Administrator ,
should tajce the lead in coordinating other federal agencies to develop these
policies. ,
10.1.2 Michigan CoaUdon
• EPA should be commended for taking up the issue but has a considerable ways
to go to strengthen and implement its recommendations. The
recommendations could produce some important results, but in their current
form they appear general and weak. No specific time tables, actions or
anticipated actions are given with the recommendations. When will the
Agency state that it will take action?
• Most important issue is the implementation of environmental equity policies.
• The report overstates the complexity of defining environmental equity. This
gives the impression that EPA is casting doubt on the existence of the problem.
• The report overstates the lack of data on environmental risks to racial minority
and low-income communities. There is also more information about the impacts
of environmental hazards on these communities. EPA's definition of risk is too
narrow and does not include anxiety, depression, sleep disturbances and others.
• The report almost totally ignores issues of cause and effect. No mention of
housing discrimination, poverty or imbalances in political access and power.
• There is no mention of industry's role in promoting environmental inequities.
Industry should be required to use nontoxic materials to eliminate hazardous
byproducts of manufacturing.
• There was no mention of intra- and inter-agency coordination.
• Three of the proposals contained in the March 1990 letter to the Administrator
were omitted from the report: 1) require, on a demonstration basis, that racial
and socioeconomic equity considerations be included in Regulatory Impact
Assessments; 2) enhance the ability of Historically Black Colleges and
Universities and other minority institutions to participate in and contribute to
the development of environmental equity; and 3) appoint special assistants for
environmental equity at decision-making levels within the Agency.
• The report would have been strengthened if more ongoing input had been
solicited from external groups and individuals.
; . *
• The report fails to acknowledge the expertise (experience and common sense)
of community groups in addressing environmental problems.
• There are high-level officials that view equity as a public relations issue. EPA
needs to publicly acknowledge that environmental equity issues are real and
serious problems.
• Authors were "encouraged" by the following:
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— Geographic targeting of high-risk populations;
— The Administrator's April 1991 policy statement: "The consequences of
environmental pollution should not be borne disproportionately by any
segment of the population."
— Recognition of the general lack of health effects by race and income.
— Recognition that EPA and other government agencies can improve
communication.
— Recognition of the need for environmental equity awareness training.
— Recognition of the need to ensure that EPA programs are equitable, that
enforcement actions reflect the degree of risk, and that access to decision-
making is available to all communities.
Report recommendation #1: EPA should not only increase the priority that it
gives to environmental equity issues, it should make environmental equity the
top priority.
Report recommendation #2: Race and income information should be routinely
included in risk assessments. Concern voiced over the statement that studies of
health effects and exposure should collect and disaggregate data by
race/income "to the degree feasible."
Report recommendation #3: Deep concern stated that the recommendation
calls for moving "toward" incorporating equity considerations in the risk
assessment process.
Report recommendation #4: A sound recommendation but it should have a
time table.
Report recommendation #5: Environmental equity impacts of proposed rules
should be done on a routine basis, not only "where appropriate."
Report recommendation #6: Although this recommendation has much
potential, specifics on how it will be implemented are lacking.
Report recommendation #7: EPA should do more than increase current outreach
and communication efforts. EPA should involve racial minority and low-
income people in environmental policy-making.
Report recommendation #8: Target dates should be set. EPA should appoint a
special assistant to the Administrator for environmental equity with decision-
making authority, budget and staff. The external advisory committee is
extremely important
A national health care policy (including a basic floor of health insurance),
national industrial policy and a national energy policy are necessary to address
environmental inequities. The Administrator should take the lead in
coordinating other federal agencies to develop these policies.
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10.1.3 Southwest Network For Environmental And
Economic Justice
• The communications plan released by Rep. Henry Waxman is indicative of
EPA's lack of commitment to solve environmental inequities and the dishonesty
and disrespect with which EPA treats people of color organizations.
• The Southwest Network sent a letter to the Administrator in July 1991, and
EPA has still not responded (as of 3/18).
• EPA treats the issue as recent in origin, but grassroots groups have been
dealing with environmental problems for decades.
• The report avoids acknowledging environmental inequities.
• There is no analysis of causes of environmental inequities. EPA policies,
including delegation of programs to state/local governments, voluntary
agreements with industry, and market incentives, disproportionately impact
racial minority and low-income communities.,
• The report fails to mention the farmworker protection (FWP) rule. EPA has
recognized the need for a new rule for 12 years, but still none exists. Five staff
are devoted to the FWP Rule, but 52 staff work on, radon gas protection for
middle-class single-family homes. It took EPA 3 weeks to cancel Alar (after
Meryl Streep testified before Congress about risks to white, middle-class
babies). In contrast, EPA reached the conclusion that it should cancel use of
Parathion in 1987 but withheld action until staff leaked word of the coverup in
1991.
• EPA has been dragging its feet continually since, 1980 on dealing with lead
poisoning. EPA shredded information indicating that inner-city children were
exposed at higher than reported levels. In the Dallas lead smelter case, EPA is
proposing lead cleanup in a racial minority neighborhood which is 50 times
less protective than exposure for the population in non-contaminated areas
(white neighborhoods). , ,
• EPA's "objective" risk assessment/risk management process has been
continually subject to political manipulation. EPA routinely factors politics and
power into its major risk management decisions. An excellent example is
EPA's decision to ban Alar and its inaction on banning Parathion.
Furthermore, EPA aggregates exposure in ways that dilute the vulnerability of
racial minority populations.
• While the report identifies lack of data as a major finding, EPA is not planning
any major effort to remedy this data gap. EPA has never asked Congress for a
major appropriation for research on farmworker risks or other environmental
equity issues.
• Exposure to pesticides, lead, air pollution, toxic dumps and incinerators are all
results of EPA policy implementation. For example, EPA's policy of promoting
incineration as an acceptable waste disposal method impacts primarily racial
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minority communities because they are being targeted as sites for the incinerators.
* EPA does not have a policy or standard practice of translating relevant
materials into non-English languages. Authors claim that EPA has translated
more of its materials into Polish than it has into Spanish.
• EPA is one of the worst federal agencies in terms of integration of its
workforce, which is especially true of racial minorities in substantive decision-
making positions.
• EPA has given the equitable implementation of its programs and statutory
responsibilities a low priority. The FY93 Operating Year Guidance has been
finalized for each office but environmental equity priorities are not included
anywhere. No EPA official with ranking as high as L. Crampton or E. Hartley
has disavowed either of their memos released in February.
• EPA's policy with respect to Native American tribes is premised on treating
tribes as states but not delegating power to tribes until each has developed an
"adequate" environmental infrastructure. An example is EPA's denial of
standing for the Yakima Tribe to be a party to the Hanford, WA federal facility
compliance agreement
• The priority that EPA gives Third-world issues and programs compared to the
priority of Eastern European countries is baffling in terms of EPA's "scientific"
risk-based approach to priorities.
• Regional implementation of the report's recommendations will require national
policy leadership and oversight
• Individual pollution prevention projects could have a good effect on ecology
but a new and greater risk to people of color maintenance workers without
EPA consideration of the tradeoffs.
* How does EPA plan to include grassroots organizations in regulatory
negotiations.
1], ' „ , I ;.i " ' , ! "
1. Recommendations from the Authors
1. EPA should accept the probability that people of color are at greater risk
because of the location of their homes and call for widespread pollution
prevention.
2. The Agency should develop a major EPA policy which creates a "presumption
of equity11 in EPA actions and requires an equity impact analysis for major
rules, programs, actions, reviews, etc.
3. EPA should integrate environmental equity policy into Operating Year
Guidance, strategic plans, and Agency themes.
4. EPA should work with civil rights groups to implement pollution prevention in
an equitable manner.
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5. Outreach and communication: Do not continue to attempt to co-opt legitimate
leaders. Work with us in mutual respect.
6. EPA should develop formal Federal Register requirements for all state and local
grant, permit, delegation and enforcement policies.
7. the Agency shotdd implement oversight of state and local grant, permit,
delegation, and enforcement for equitable implementation.
8. The EPA should establish an Advisory Board with representatives from
community-based and labor organizations.
9. EPA should request funding for data needs.
10. EPA should support a General Accounting Office investigation into whether
state programs are in fart equitable.
11. Legislation: EPA should support the Conyers bill, Waxman bill (lead), Chavis
bill (RCRA Reauthorization) and others.
12. EPA should put people of color employees in substantive decision making
positions and listen to input. The Agency should open dialogue and encourage
participation of employee organizations in developing overall EPA policy.
13. The Environmental Equity Workgroup should be assured of its independence.
Unions and employee organizations must be involved.
14. The EPA should work with the VS. Department of Agriculture and
environmental groups to include equitable considerations and civil rights and
labor groups in "power brokered" decisions.
15. EPA should develop an ongoing relationship with the Congressional Black,
Caucus and other groups.
16. EPA should reopen and reject the 1977 decision withholding application of
Civil Rights laws to environmental laws and programs.
17. EPA should immediately issue the enforceability provisions of the Farmworker
Protection Regulations to make the existing regulations enforceable.
18. EPA should apply the findings of the National Academy of Sciences Report on
Pesticides and Children to children exposed in farmworker situations. EPA
currently pretends either that children do not work in the fields or that children
are no more vulnerable than adults.
10.1.4 Dr. Robert Bullard
• During the September 1990 meeting between the Administrator and the outside
organizations, three major programmatic thrusts were explored: 1) an EPA
policy (within 1 year) to address environmental inequities and disproportionate
health risks borne by high-risk populations; 2) an EPA science panel (within 1
year) to advise the Agency on environmental equity issues; and 3) budget
resources to address equity problems, ie., a "targeted approach to impact those
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most at risk. The report does not indicate that any of these actions have been
initiated.
• The report contains a selective, biased and superficial review of the literature
on *? Ita^Ie ^d severity of environmental problems faced by low-income and
racial minority communities.
* The report did not produce one piece of original research or new information.
The Environmental Equity Workgroup failed to grasp the interrelationship
between race, class and environmental decision-making. A more in-depth and
comprehensive report and action plan could and should have been produced.
• The report omits the rich and voluminous literature on environmental politics
which challenges the notion of a "value-free" science and application of
technology.
• The report attributes class factors as the reason for the elevated risks borne by
people of color. In addition to racial barriers (i.e., segregation), environmental
inequities result from a host of factors including the distribution of wealth,
housing and real estate practices, land-use planning, redlining, and differential
enforcement of environmental laws.
report failed to make the link between domestic and global ecological
inequities.
'''• ' ' ! M „ • ,, , , ! ,' ' . „' , ' ' ' ' i ' ' "' '
The report failed to acknowledge the existence of the Cerrell Report (prepared
for Chemical Waste Management; stated that the best place to site facilities was
in politically disadvantaged communities.) The question of "Who gets what,
where and why?" is often a political decision and may have little or nothing to
do with science and objective criteria.
Nowhere in the report is the issue of institutional racial discrimination
addressed.
After more than 2 decades of operation, why has EPA (and the report) failed to
address inequitable siting concerns? The report failed to mention that the siting
inequities uncovered by the GAO in 1983 are worse in 1992. Siting inequities
have increased as a direct result of more stringent federal environmental
regulations and the difficulty (public opposition) in siting new facilities. EPA's
current position of delegating facility siting to private industry and states
creates and perpetuates environmental inequities. The Agency has done little
to encourage local and state governments to adopt equitable facility siting
plans.
The report does not go far enough in calling for mandated permitting
requirements that would force states and private industry to address siting
equity. EPA should examine aggregate risks in the permitting process. The
Agency can develop methodologies to address multiple exposures in
"saturated" communities.
EPA should require translations in predominantly non-English speaking (i.e.,
Spanish) areas where waste facilities are proposed.
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The report states that there are numerous examples of poor communities
l facilit but does not cite an of these ca
cases.
seeking a waste site or industrial facility but does not cite any
• The report offers no insights as to why EPA has done so little to protect those
who are most vulnerable. For example, the Agency has consistently delayed
and dragged its feet on the lead-based paint, soil and drinking water problem.
The report also failed to mention the West Dallas lead smelter case.
• The report glosses over the pesticide problem faced by workers and those who
live in nearby migrant labor camps. The report emphasizes the Agency's risk-
based decision-making but does not explain the difference in actions taken
against Alar (3 weeks) and Parathion (5 years).
• EPA will not be able to build an effective outreach program in racial minority
communities without addressing the question of environmental justice and
trust. Residents in these communities perceive the EPA as protecting industry
not the citizens.
• The report demonstrates the unevenness and lack Of awareness of equity
among EPA's regional offices and did not explain regional disparities.
10.1.5 Human Environment Center
• The report makes no distinction between adults and children in the area of risk
assessment.
• Far too little attention was paid to the special needs of urban communities.
• EPA could do a much better job of addressing inequitable environmental
problems by using data bases which analyze neighborhood composition by race
and income level.
• The Community-Right-To-Know Program (TRI) is underfunded by the federal
government. ;
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10.2 COMMENTS FROM EXTERNAL REVIEWERS
THE UNIVERSITY OF MICHIGAN
School of Natural Resources
April 1,1992
Post-It7" brand fax transmitted memo 7671 * °f p»s«
Dapt
Ms. RcinaMilligan
Office of Policy & Planning Evaluation
Water & Agriculture Policy Division
401M Street, S.W.
U.S. Environmental Protection Agency
Washington, D.C. 20460
Dear Ms, Milligan:
Please find enclosed a copy of the Review of the EPA Environmental Equity Workgroup
Report. We are truly sorry for the delayed response. But, we look forward to a provocative and
meaningful discussion, we also are sending a copy of the critique to other people who will be at
thp meeting. We also encourage you to send them a copy of the Review of the EPA
Environmental Equity Workgroup Report
If you have any questions regarding what is written herein, then please do not hesitate to
get in touch (313) 763-2470.
Sincerely,
xLu/v***^ uA*Afl*j("~
Bjunyan Bryant '
Associate Professor
BBdceh
Paul Mohai
Assistant Professor
P*B* duiWing 430 E. Univenity
Aon Axbor. Mkbigaa 48109*1115
Priwedoc
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HVERSITY OF MICHIGAN
loof of Natural Resources
Review of the EPA Environmental Equity Workgroup Report
April 1,1992
Bunyan Bryant, Paul Mohai, Benjamin Chavis,
Michel Gelobter, David Hahn-Baker, Charles Lee, Beverly Wright
la ibis report we want to be critical in ways that are helpful in order to move the agency forward in addressing this
important issue. We know that agency staff have pat in countless number of hours and are personally attached to the
outcome of this Report, Although critiques are often times hard to near because of our personal involvement we none-
theless ask you to read our comments with openness and fey to hear what we are saying. Even though we have tried to
be detailed and objective, our pain and our anguish may be reflected throughout some portions of this document; try not
to let the pain stand between you and your understanding of our concerns. Because the cold war is over and the world is
at peace for the most part, we should be able to turn our attention to pressing social and environmental problems here at
home. If we have the political will, there is nothing that we cannot do, and we firmly believe this. We start with micro
policy issues reflected in the Report The last section of our critique comes from a more macro analytical framework; we
want to nudge you to take the necessary steps to observe and implement environmental equity within a much larger
context Without environmental equity firmly seated within the context of much larger policies, then we will continue
to fight a rear guard action.
While the Environmental Protection agency (EPA) has been given a challenging and historic mission of including
environmental equity as a part of its policy decision making we feel that the most important issues are not so much what
has been committed to paper but the implementation of environmental equity policies so that people no matter where
they live or what color they are can live with confidence that their biophysical environment is safe and nurturing.
Although historically the effects of multiple pollutants in non-attainment areas have disproportionately impacted people
of color and low income groups, it is only recently thai scholar activists, primarily people of color, were able to bring
currency to environmental equity issues by both their activism and their scholarly •?&&. Although long overdue, the
EPA should be commended for at least taking up this charge, but the agency still has a considerable ways to go to
strengthen and implement its recommendations.
While the report conta**1? *««™« mendations that if implemented could produce some important results, in Iu current form
the recommendations appear general and weak. They lack force and conviction on the part of the agency. Every
recommendation begins with "EPA could" or "EPA should." At what point is EPA reaco to state that iisdE take
action? In some cases, recommendations ate further weakened by indicating that they will be carried out "where
appropriate." This is a significant loophole. What are the criteria for "appropriate" and who will decide when the criteria
are met?
Contributing to the lack of force of these recommendations is the absence of specifics and time tables as to how and
when recommendations are to be carried out (if to feet they will be carried out). Also, descriptions of the anticipated
outcomes of carrying out these recommendations are lacking.
Troubling also is the Report's casting of the background information on the problem of environmental injustice. The
Report appears to go out of its way to make the concept of "environmental equity" a complex one. The impression left
isthat the EPA is intentionally casting doubt on the existence of this problem (since we can't be sure of what it really is,
can wfrbe sure mat me problem is real?). EPA also appeals to be casting doubt by overstating the scarcity of evidence.
Although more information is definitely needed in order to fully understand all the ramifications of environmental
injustice, the evidence is considerably more than ample that the problem exits.
The following are more detailed comments about our reactions:
The Report needs to acknowledge the existence of other data regarding the distribution of environmental hazards
by income and race such as those included in Moftai and Bryant (1993). The EPA Report includes only 3 of the
16 studies discussed by Mohai and Bryant Also, considerably more information about the impacts of
environmental hazards exists than the EPA Report acknowledges when one begins to look beyond the incidence
of lead and the incidence of cancer and disease. These include psychological impacts (anxiety, depression, sleep
disturbances, impairment of cognitive functioning, and others) resulting from noise, odor, perceived risks, loss
1)
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3)
4)
7)
8)
»prcs>e«y values, aitf the diniiiu^ The issue of environmental eauitv
cannot be fully addressed with the narrow definition of risk put forth in this document Although there is a clear
need for mow data regarding the disiribution and impacts of environmental hazards by income and race the
Reports emphasis on lack of existing data gives the appearance of a strategy of denying that the problems
In the section entitled "Defying the Issues" (pages 7 to 10), the Report also appears to overeats the complexity
oftheconceptofequity. This overstatement once again takes on the appearance of denying the problem. We
can t be certain about what environmental equity is; so how do we know, that a problem exists.
issues of cause andeffect. The.most detailed statement of cause and effect is
"
, , a an use ecso
"P otw socipeconoinic factors that affect where people live and work," This same explanation is repeated on
page 13. The term "historical patterns" appears to imply "accident" or coincident" Nowhere does the report
mention the factors of housing discrimination, poverty (and the job and educational discrimination which leads
to disproportionate poverty among minorities), or imbalances in political access and power.
The EPA should not just recognize the need to increase the priority U gives to environmental equity but it
shouM make it the top priority. By making it the top priority, we all will undoubtedly benefit from cleaner and
safer biophysical environments. As state in the Report, "everyone has a stake in environmental equity because
it is also an argument for better environmental protection generally" (page 2, paragraph 4),
Given the disproportionate impact of environmental insults on communities of color and low-income people,
there is nothing more fundamental than getting industries to change their production strategies, particularly as
more and more waste is generated in an ever growing market. We were alarmed that none of the
recommendations dealt specifically with industry and the role U plays in promoting environmental injustice.
Industry should be required to use nontoxic materials in its manufacturing to eliminate hazardous waste as an
outcome of production. Communities of color will more often than not be the brunt of multiple environmental
insults and ar| expected to subsidize the overall growth of the economy with their health and their lives-
There is also a need to cojnmunicate not only with communities of color, but EPA needs to communicate
across its own units as well as with other governmental regulator agencies in order to formulate consistent and
noa-ointtadic tory policies. While there was no mention of intra- and inter-agency coordination, we feel that this
is defirately important. A policy of sound, productive inter- and intra-agency coordination, we feel, will help
solve equity problems in the long run. Environmental inequities will not go away unless we address
fundamental issues that are responsible for so much suffering and pain.
The Report highlights on page 6 only 4 of the 7 proposals put to EPA by the Michigan letter of March 1990
Three very important proposals contained in this letter are omitted; These include the following:
- require, on a demonstration basis, that racial and socioeconomic equity considerations be included in
Regulatory Impact Assessment;
- enhance tjie ability of Historically Black Colleges and Universities and other minority institutions to
participate in and contribute to the development of environmental equity;
, I.}; , ,, ,i '; "''",„' ' ', " ' " • ''!•'' ;"''' • ', : • , T! '''•'' ;','•'' ,,' ' , ' ' • • '' „• " • i|
- appoint special assistants for environmental equity at decision-making levels within the agency.
We feel that die Report could have been strengthens if the methodological approach had solicited ongoing input
from those who have spent years working on this issue. For example, if our ongoing support had been
solicited, then three proposals listed above may not have been left out of the Report and fewer issues would be
raised about its final outcome.
The report lafls to acknowledge the expertise of community groups in addressing environmental problems. EPA
has the science, community groups have the experience, but no one has a monopoly on common sense.
Community groups have expertise equally important to that of the EPA in addressing these issues.
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10) WeiecognizetJwharawojtcthathasbeendQne^
high reaches of the agency that view equity issues as public relations issues. EPA needs to pubhcally
acknowledge that environmental equity issues are not public relations issues but real and serious problems on
which the agency needs to take decisive action.
, - *.-• --Pf- -'- - .
U) RtsV a«re«""«t is a process in making decisions and has flaws. Risk assessment alone is not enough to solve
the problem
Although mote work needs to be done we felt encouraged by the following:
1) Geographic targeting
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"EPA should establish a research and data collection plan and maintain information which provides an objective basis for
assessment of risks by income and race."
We believe that this is an important step and commend the EPA for recognizing its important m achieving the goal of
environmental equity. However, we are quite concerned about the qualification that the agency makes when it states on
p. 31 that it wfll do so "to me degree feasible." How is "feasible" to be determined and who will mate that
determination? We are concerned that this qualification may come to be a significant loop hole and will effectively
eluniiiateunportaiuassessmeritsofriskbyinwweandiace. We believe thatrace and income information should be
routinely included in risk assessment. Furthermore, we strongly urge EPA to involve scholars of color from universities
around the country to be involved in this data collection.
Recommendations
"TJ1* EPA should rm?ye toward incorporating consideration of environmental equity into the risk assessment process. In
calculating population risk, distribution of environmental exposures and risks across the population should be estimated
where relevant. In some cases it may be important to know whether there are any particular Donnlation erouos at
disproportionately high risk." .
White this is an important goal, we are deeply concerned about the word "toward" in the first sentence. While the word
impUes goal directedness," since we do not have a time line, it is difficult to monitor progress. Twenty years from now
WI S°fo*4 1» still t» Raving toward considerations of environmental equity into the risk assessment process and we may
nqt 0$ any closer than we are today. Again this is an important goal, but we are concerned about the qualification
Where relevant." It is stated in the discussion of this Recommendation on page 32 that "Information on race and
income will not be necessary or appropriate for all risk assessments, and EPA should devote time to deciding what cases
demographic information should Ibe included in risk assessment" Our concerns are similar to that of Recommendation 2
Bow ;are "relevant" and "appropriate" cases to be determiiiedaiid who is to rnake that determination? We believe that race'
and ww^einformatioji should be gathered on a routine basis in meeting this objective. We feel that people of color
Recommendation 4
EPA should identify and target opportunities to reduce high concentrations of risk to different population CTOUDS
employfcg approaches developed for geographic targeting. *~*«—« & v,
W,e think that targeting various communities to reduce high concentrations of risk is a sound idea. We also hasten to add
that jnere might be some rural communities where people of color are differentially exposed to environmental insults.
We feel that specific starting and ending dates would be most helpful in evaluating both the process and the outcome
Al^o people of color should be included in the targeting as well as included in workshops in order to learn GK skills.
Recommendations
"E?Ashpuld, whew appropriate, selectively assess and «>rwit«sidt»movenw«ttowardei^^ It is ironic that one of the
roost important sections is also the the shortest. We hope that this in no way reflects the importance the agency is
placing upon this section. And just as important, we feel that people of color should be intricately involved in
rulemakmg and agency initiatives.
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Recommendation 6
"EPA should review and selectively revise its permit, grant, monitoring and enforcement procedures to address high
concennations of risk in racial minority and low-income communities. Since state and local governments nave primary
authority for many environmental programs, EPA should emphasize its concerns about environmental equity to them.
There appears to be much potential in this recommendatioru However, lacking are specifics. How are these P«*edBfe$ *>
be revised? And how will the risks in racial minority and low-income communities be addressed? What would be the
outcomes* me examples listed on page 35 of the ways in which EPA could implement this recommendation likewise
appear promising but they lack specifics of how these would be accomplished. Thus it is difficult to determine what the
results of implementing these proposals would be. We feel that people of color should be involved in penmt. grant,
monitoring and enforcement at all levels of the agency.
Recommendation 7
"EPA should expand and improve the level and forms with which it communicates with racial minority and lew-income
communities and should increase efforts to involve «hem in environniental policy-making."
As in other of the recommendations, this represents an important objective but specifics of how it will be accomplished
axe not weU defined. Although it is important mat minority and low income communities be adequately informed by
EPA of matters affecting them, how will information and the concerns of these affected communities be incorporated into
EPA policy making? People of color should be intricately involved in planning and implementing such communication
strategies. Such strategies should include a multi-media approach including the use of TV series show at prime time,
comic books, people of color newspapers and information dissemination through the churches.
Recommendation 8
"EPA should establish mechanisms to ensure that environmental equity concerns are incorporated in its long-term
planning and operation."
This is an exnsmely important step. We wonder why the sub-rewniinendations are stated so tentatively. "EPA could"
should be change to "EPA will" in each case. Target dates for achieving each of these sub-recommendations should be
established. In addition, EPA should appoint a spec!ialassistimt:(a person of color) for environmental equity with .
decision-making authority, budget, and staff. We recommend that this person of color report directly to the Administrator.
The external Environmental Equity Advisory Committee is an extremely important component We too feel that people
of color should not only make up two third of the committee, but people of color from the Michigan Croup, the United
Church of Christ Commission for Racial Justice, the Gulf Coasts Tenants Organisation, the Southwest Organizing
Network on Environmental and Economic Justice, and the PANOS Institute win be consulted on the criteria, the process
by which members are selected and rotated.
Environmental Equity and a Health-Care Policy
In this section we want to push you to your outer limits. Again we hope that you are open and are willing to hear us and
the pain that we have experienced from talking with people from around the country. We basically feel that
environmental equity cannot be obtained unless there is a national industrial policy, a national energy policy, and a
national health-care policy. To be serious about environmental equity, we have to place it within a broader context for
substantive discourse. Because the environment is aU inclusive, and overlaps with other areas of concern, this necessitates
expanding our horizons to meet contemporary challenges. We feel it can be done.
While much of the Report is involved in showing how complex environmental equity issues really are, we find that the
Report may provide the rationale for inaction. We eouldrevistethis same Report two decades from now and we may not
be closer to answers to complex questions raised in the Repeat than we are now and hundreds of thousands may have
suffered. To focus our attention on these complexities without providing bold relief to people in need fe to be less than
responsible. For example on page 13 it is stated that a person's activity pattern is the single most important
determinant of environmental exposures for most pollutants. To us this simply means that some peopte wiflun the same
neighborhood may subsidize production or growth and development more than others with their discomfort, their pain ana
large sums of money paid in medical health care bills. The true cost of producing goods and services incur society is
not calculated.
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Because of the thousands of new chemicals coming on the market and eventually released into the air, water and son,
those who are already differentially impacted by noxious pollutants can expect to be impacted even more. The number of
people experiencing sickness and pain may increase in the years to come. Yet it is ironic that 38 million people are not
fullyproiected by medical health care insurance. We hypothesize that a considerable number of them live in non-
attainment areas and most are vulnerable to a variety of toxic waste. We feel that the society as a whole should subsidize
growth and development, rather than relegating the burden to people of color the poor or those unable to to buy their
way into cleaner and more pristine environments. And white cancer rates between blacks and whites may be explained by
poverty, these differences may not be explained when we control for social class; when poor blacks are compared to poor
whites a larger percentage of the the former may be less healthy than their white counterparts.
The impression we get from the Report is that the issue is too complex and therefore it has to be researched more. This
reminds us of a statement that Martin Luther King made about the paralysis of analysis. We want to become empowered
from analysis-not paralyzed by it. We may be called to act in the face of inconclusive data. Are not there some times
w,hen we should make policy based upon significant associations rather than cause and effect? Yet even in the face of
conclusive data we feel the agency has been less than helpful. In ameliorating the impacts of lead on black children
(eight million of them exposed yearly in our inner cities and for every 10 to IS microliters of lead in the blood stream
there is a toss of 41.Q. points) we feel that the agency has not be able to respond in any meaningful way. We feel the
decisions for less than adequate action may be related to political and economic decisions. Meanwhile millions of black
and inner city children will pay for the price of production for the rest of their lives and there will be millions more
joining the ranks. Environmental equity means providing a basic floor of health insurance for those in society that are
most vulnerable to aggravated or toxic induced disease.
Environmental Equity and a National Industrial Policy
The United States is probably die only industrialized country in the world without an industrial policy. To date, the
effects of not having such a policy has been devastating to the millions of people who have lost their jobs due to plant
closings and layoffs. Here recently workers in Ypsilanti, Michigan lost out to the workers in Arlington Texas because
the Arlington workers were willing to make more concessions. States are placed in the position by powerful industries
td compete with one another by marketing anti-labor or anti-environmental packages in order to attract them.
Unemployment brings with it the whole alphabet soup of attendant problems such as a lowered self-esteem, drug and
alcohol dependency, wife and child abuse. Since people of color are often the "last hired and the first fired," we are deeply
concerned about the disproportionate number of mem who have joined the ranks of the unemployed. We were also
alarmed that this Report failed to address the negative environmental consequences of industry and what could be done
about them.
We need an industrial policy to help us shift from a war-time to a peace-time economy with as little disruptions as
possible. We need an industrial policy that retrains workers for new jobs and one thai supports them during this
transitional period* We need an industrial policy that will put people to work to produce socially useful goods and
serVkra,aiid one that wiUrebd!4 and red vigour cities Weneedan
industrial policy that provides incentives for industry to invest in America and one that supports the sound stewardship of
oor land, our natural resources and the air we breathe. We need an industrial policy that requires non-toxic materials to be
used in the production process in order to curtail pollutants at the end of the production cycle. We need an industrial
policy that supports full employment arid one that is benign to the environment. I f other democratic and industrialized
countries in the world can have such a policy, then why can't we?
Environmental Equity and Energy and a National Energy Policy.
Environmental equity cannot be justly served unless we have a national energy policy. The amount of energy we waste
in this society is staggering. And as long as we are energy dependent on sources of energy from other nations, this
places us in a position to use military might to defend international corridors for the transport of energy supplies. We
must become much less dependent on foreign sources of energy by conserving our own. In 1976 Dennis Hayes stated that
"We annually consume more than twice as much fuel as we need to maintain our standard of living. We could lead lives
rich, healthy, and fulfilling-with much comfort and with more employment-using less than half the energy now used,"
Through energy conservation we not only become less dependent on international energy supplies but we can create more
jobs. In fact there is evidence to suggest that a sustainable energy economy would produce more jobs than one based on
fossil fuels, Havia and Lessen (1990:41) report that a study in Alaska found that "weatherization created more jobs and
personal income per dollar than any other investment, including the construction of hospitals, highways, or hydroelectric
86
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iiowtts " ?iom vreatoerizatMMisikme there ate a number of different jobs that can be created for home insulation workers,
arpenters, sheet metal workers and others. From the solar industry there is a need for photovoltaic engineers, solar
architects. Too there are a vast number of jobs that wffl come from recycling, recovering, reusing and reducing our waste
stream. Although the jobs may be numerous, we need to make sure that they are decent paying ones.
Although little noticed by the general public, protection of the environment and abatement and control of pollution have
grown to be a major sales-generating profit making, job creating industry. While some continue to argue that
environmental regulations destroy jobs, throwing millions out of work the fact of the matter is that most industries
close, not solely because of strict environmental regulations, but because of obsolete equipment, stiff competitum,
declinging sales lack of efficient production, and problems with raw materials (Kazis and Grossman 1982). In fact
pollution abatement control within the next decade will likely equal or exceed the U.S. Department of Defense Budget,
creating numerous jobs.(BeoJek, 1992). Therefore we not only need a national energy policy to reduce our dependency on
foreign energy sources, but we need an energy policy to stimulate enough jobs, where people of color wdl no longer be
diswooortionately unemployed. A sound energy policy and environmental equity can go hand in hand. The question is
whether we have the political will to make this happen. Therefore we challenge the Administrator to take on the task of
intra- and inter-agency coordination for a sound national health, industrial, and energy policy so that people can Jive and
work without fear in a sustainable, healthy, and productive environment. Only when this happens can we say that
environmental equity has been served.
Bezdek,R.H. 1992. Employment and ft
in the Environmental Protection Area Poring the 1990s
,.. .
Washington, D.C.: Management Information Services, Inc. An Interactive Symposium for Labour, Business,
and Environmentalists, Ottawa, Canada.
Bryant, B, and Mohai, P. 1992. flare aitf fte incidence of Environmental Hazards; A Timg for Discourse. Westview
Press, Boulder, CO. Inpress.
BuDarAR. 1990. PimmiriFin Pi™- Race. CiasE «.nri BnviTonmantel Quality. Westview Press. Boulder, CO.
BuBard, R. and Wright, B, 1987. Blacks and toe Environment. w»mhnMt Journal ^f Social Relations Vol 14. Pp 165-
184.
Flavin, C. and Lensseni-N. 1990. W»«-iHWarrh papy 1M: ftevond me Petroleum Age: Pestgning Solar Economy.
Washington, D.C.: WorldWatch Institute.
Hayes, D. 1°76- Worl4w^tch Paper 4: Enerpv: The Case for Conservation. Washington. D.C.: WorldWatch Institute.
Kazis, R. Grossman, Rl. i Q V^Oataia. Labor *"d the Environment. New YortePilgrim Press.
Mohai P and Bryant, B, 1992. "Environmental Racism: Reviewing the Evidence.* In B. Bryant and P. Mohai,
' editors, Raca and Ae ft^flWfr f BnvteymtftBlri Ha^r/j^r A Tima for Discourse. Westview Press, Boulder,
CO.
Taylor, D.E. 1989. Bkcks and the Environment Toward an Explanation of the Concern and Action Gap Between
Blacks and Whites. Environment and Behavior. Vol 21. Pp. 175-205.
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Southwest Network for Environmental and Economic Justice
211 10th St. S.W., Albuquerque, New Mexico. 87102 ,• (505)247-8832 • FAX (505)247-9972
Ramirez
Ouuoo
Richard Moore
Mtmktn
Arizona:
Rose Marie Augustine
Tucson
MikeFlorw
Sell*
RottZubU
Surprise
RoUnd Matukaja
Havuupai Nation
California:
Lucille Allen
Richmond
Jos£ Bravo
StnDisjo
Robin Cannon
Los Angeles
P*m Tiu Lee
Sin Francisco
Lori Salinas
Fresno
Colorado:
Mike Maes
Denver
N*» Mexico:
Antonio Lujifl
LasCruces
Joe Motif e
SinuTecesa
Johnny Russell, Jr.
Bloomficld
Donalyn Tones
Mescalero
Nevada;
Odessa Ramirez
Canon City
WilliamRaise, St.
Western Shcehone
Nation
Tests:
Susaaa Almanza
Austin
Antonio Dfiz
Austia
iPaisyOtiver
Texarkana
RubeaSoUs
San Antoaio
Lead Organisation:
SouthWest
Organizing Project
Richard Moore
Albuquerque
March 18, 1992
William K. Reilly, Administrator
United states Environmental Protection Agency
Washington, D.c. 20460
Dear Mr. Reilly:
On behalf of the Southwest Network for Environmental
and Economic Justice (The Network), we are submitting these
comments to the Environmental Protection Agency's
Environmental Ecruity Report.
It must be noted that we were never offered the
opportunity to comment on this report and we strongly
object to the fact that EPA has attempted to publish the
report without input from communities of color and
indigenous peoples. it is our communities and
organizations which are the focus of this study, so we have
a direct interest in its content.
We must also note with considerable alarm that the
most. recent draft of the Equity Report was released
publicly amidst serious controversy. At the press
conference in Washington D.C. staff members for Congressman
Henry A. Waxman of California released a "Communication
Plan" prepared by EPA's chief communication official.
According to Congressman Waxman, this plan is designed to
"co-opt the mainstream (civil rights) groups" to prevent
the issue from reaching a "flashpoint".
Congressman Waxman commented that "the agency views
th|^environmental equity initiative as a public relations
matter, not an opportunity to understand and respond to the
very real health problems faced by people of color...The
communication plan is a cynical 'divide and conquer'
strategy. it seeks to drive a wedge between activist
groups and traditional civil rights organizations. It
shows no appreciation of the serious environmental threats
faced by minority communities."
. Based on our experiences thus far with the present
administration of the Environmental Protection Agency, we
would have to agree with Congressman Waxman's assessment of
the EPA, and assume that we can expect nothing more than
business as usual from the Agency.
We would also like to state our support of the
dissenting opinion submitted by the National Federation of
Federal Employees, Local 2050, and the concerned members of
the Environmental Equity Workgroup and EPA staff. The
concern expressed by these employees offers true hope for
J f
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On July 31 1991, the Soxvthwest Network for Environmental and
Economic Justice sent a letter to EPA Administrator William Reilly.
The letter cited examples of the disproportionate impact of
pollution and contamination on communities of people of color
throughout the Southwest United States. The letter also provided
clear examples of policies pursued by the EPA that have been
detrimental to our communities.
We would like to ask that the July 31 letter be included as
part of the Environmental Equity Report.
The Network made a number of requests t;o the Agency asking for
information about EPA policies in communities of color, and asking
for a meeting with the Administrator.
To this day, eight »oniih!s later, the Southwest Network has not
received a response from the Aduinistrator to the requests made in
the July 31, 1991 letter.
The experiences and concerns outlined above raise for us a
very grave question: "How can we honestly believe that the current
Administration is willing to engage us in an open dialogue and
commit to working together with us to address the very real and
serious problem of environmental racism?" These are the most
recent examples of the disrespect and arrogance of the Agency which
we have experienced throughout its history, and which has led to
the need for developing an "Environmental Equity Report".
We continue to stand committed to working with the
Environmental Protection Agency to assure that it fulfills its
mandate for a safe environment in all communities, however we must
make clear that we will no longer tolerate the policy of disrespect
and dishonesty which continues to plague the EPA at the highest
levels. .
With these concerns in mind, we are submitting our comments to
the Environmental Equity Report. Our comments are general and
specific. Please feel free to contact us if you have any
questions.
Sincerel
Richard Moore
Co-Chair
Robin Cannon
Co-Chair
Odessa Ramirez
Co-Chair
Ruben Soils
Co-Chair
89
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SOUTHWEST NETWORK FOR ENVIRONMENTAL AND ECONOMIC JUSTICE
COMMENTS TO THE ENVIRONMENTAL PROTECTION AGENCY
ENVIRONMENTAL EQUITY REPORT
INTRODUCTION
The Report is more significant for what has been omitted than
what has been included. The Report treats the environmental
^quity issue as an academic debate rather than an EPA policy,
political, and civil rights issue. Similarly/In its twenty-one
years of existence, EPA has never acknowledged that many
environmental problems adversely affect people of color groups.
Ironically EPA treats the issue of environmental justice as a
concept of "recent11 genesis. In a recent cover article in a new
EPA publication, Administrator William Reilly "met with key
participants and received information on environmental equity that
he found'especially disturbing."1 This perspective is
fundamentally incorrect.
In Maxell, 1990, Administrator Reilly met with the so-called
''Michigan Coalition" (a predominantly African-American ad-hoc
^roup) and suddenly discovered "environmental equity." As a result
of this meeting, Reilly agreed to commission a workgroup study with
input from people of color organizations. We sincerely applaud
EPA's historic effort, but, as you may see from our comments, the
import is clearly limited and behind.
Grassroots people of color organizations have been dealing with
"environmental" problems for decades before the term "environmental
equity" was coined. ;
"'!'',.|i' • • ,/ ' ' " :>.W '- " ~ • ~ '^T ,:•": '"'" • '!• ".'"„ • ' ' 'i • r: r, 'i ••:",-,,.•%. .„, , •-" • • ,„ ,..••• ' ' ! ,. • •, '" „
Grassroots people of color organizations have been dealing
with "environmental" problems for decades before the term
"environmental equity" was coined. "Civil rights" issues, such as
decent housing and decent working conditions constituted
fnvirpnmental equity in action long before mainstream environmental
fr'oups discovered these problems. EPA staff have consistently
faised .these same concerns to the level of the Administrator since
It least 1984, with no success.
The Report findings miss the reason that EPA actions have such an
adverse impact on people of color. EPA cannot begin to address
equity problems until it acknowledges their existence, and this
document studiously avoids any such acknowledgement.
EPA cannot begin to address equity problems until it acknowledges
their existence, and this document studiously avoids any such
acknowledgement. ' .
Because there is no acknowledgement of the problem, there is
lio analysis of what is causing the problem, and an inadequate
analysis of how to address the problem. For example, several of
EPA's major policy thrusts work to reinforce environmental neglect.
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The Agency is irreversibly cominittejd to certain policy initiatives,
regardless of whether they create unfair burdens of environmental
exposure. Several policies such as delegation of powers to State
and local governments, voluntary deals with industry, and market
incentives all have direct and indirect inequitable features.
These policies all involve EPA-brokered negotiation of the power to
distribute environmental risks and these negotiations consistently
exclude people of color groups. In short, EPA is consciously
distributing environmental control to the same groups which people
of color for years have found to be the chief source of racial
inequity. Although most environmental statutes provide EPA the
authority to delegate programs, none of these statutes provides EPA
with the authority to administer its programs inequitably.
The report, incredibly, fails to even mention the farmworker
protection regulations. _ .
The Report, incredibly, fails to even mention the farmworker
protection regulations. The Agency's response to the risks of
migrant farm workers (over 90% African-American, Asian, and Latino)
is particularly disturbing. Although the average lifespan of these
farmworkers is barely fifty years, these people are not entitled to
the same protections as some "endangered species." Instead species
such as the blunt nosed leopard lizard are afforded more protection
from deadly pesticides than people of color farmworkers.
In 1979, EPA recognized that regulations to protect
farmworkers and their families from exposure to agricultural
pesticides were totally inadequate: EPA started revising its
regulations. currently, the Agency has still not developed new
farmworker protection regulations and has not seriously enforced
the existing obsolete regulations for years. Given the lifespan of
people of color migrant farmworkers, the twelve-year-delayed
regulations, such as they are, will be far too late for too many
laborers.
The Agency's priorities are clear: twelve years of inaction on
farmworker protection, with a skeleton staff of five. Contrast
this with the 52 employees EPA has working on radon gas protection
for middle-class single-family homes. Or the ability of EPA to
cancel the use of the chemical Alar on apples some three weeks
after actress Meryl Streep testified before Congress about white,
middle-class babies consuming minute residues on some apple
products. In contrast, EPA reached the conclusion that it should
cancel the use of the pesticide Parathion in 1987 because of the
health threat to farmworkers, but withheld action until a
staff member leaked word of the coverup last year.
91 .
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NETWORK.COMMENTS TO ENVIRONMENTAI, EQUITY REPORT. 3/18/92. PC.
I. FINDINGS
Given the evidence of specific events, specific policy decisions,
and data th'* actions in the 1980 's to eliminate nearly all
the lead in gasoline were a major step in the direction of
fnvironmental equity": This statement is either unbelievably naive
or an incredible attempt to rewrite history. It is unsupported bv
the facts.
has been dragging its feet continually si
1980
* -The Report correctly identified lead exposure of African-
American kids as a major environmental problem affecting health and
education of our inner city kids. However the Report failed to
??J« •1^S? EPA it^self &as been dragging its feet continually since
1222;-. ^ Aj^cy's record was so poor that the administration was
admonished by a Federal District Court action involving the way
that lead refiners and EPA conspired to ignore the racial
implications of their jointlydeveloped lead exposure policy.
v ^ During this period EPA was shredding information indicating
that inner-city children were exposed at even higher levels [EPA
shredded staff reports that showed that lead monitors which
recorded airborne lead levels of fumes actually breathed by inner
city residents correlated better with lead blood levels than lead
monitors which were remote]. EPA restricted enforcement of the
lead rules to such an extent that EPA attorneys had to file Freedom
of information Act Requests to find out what was going on in their
qwn cases. EPA developed a "methodology" for "rounding-off" lead
pollution figures which was unheard of in the history of
mathematics in order to give an extra break tjo small refiners.
The agency's record continues today. In the infamous Dallas
lead smelter case [highly contaminated communities of color
adjacent to lead smelters — the cases, beginning in the 1970's,
2£?«2 ti- ISEft01^3 ^??A i® Pr°P°sin9 lead cleanup in people of
color neighborhoods which is fifty times less protective than
for the population in non-contaminated areas (white
• The. Agency attempted to delay for twenty years
for drinking water, at the same time Vice President
having lead contamination removed from his vice
mansion, with EPA assistance. Why can't African-
Vice
92
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SW NETWORK COMMENT* T°
EQUITY REPORT. 3/18/92
B. EPA Has Delayed the Farmworker Protection Regulations for
Twelve Years Because it Knows that the African-American, Latino,
Native- American, and Asian-American Workers Do Not Have the
Political Power of the Agribusiness and Chemical Interests.
[see comments in introduction]
C . EPA' s Dependency on "Objective" Risk Assessment/Risk Management
Has Been Continually Subject to Political Manipulation.
Management Bias
p. 20 , NO. 3, "Risk assessment and risk management are not in
themselves biased...": This is not true. EPA routinely makes both
risk assessment and risk management decisions based on pure
politics and power of constituencies. Because EPA's priorities are
always subject to interference from political power, EPA's reliance
on its slogan that "risk based priority" setting will automatically
result in equitable treatment for people of color, is misplaced.
In addition, EPA's risk assessment efforts are only as good as
the data plugged in and is constantly subject to data gaps,
methodological challenges, and delays. If EPA intends to study
environmental equity until it has good data, the agency will never
act. The data on exposure of people of color will always be
subject to aggregation problems, just as this report is. If you
aggregate all exposure to people of color, rather than the
particular population exposed, the relationship may be hidden
[e.g., if you aggregate people of color eating eaters in Georgetown
S.C. with people of color fish eaters in Georgetown, D.C., you
conclude that there is no exposure problem related to fish
consumption in communities of color].
EPA routinely factors politics and power into its major risk
Management decisions. -- ._ - - -
EPA routinely factors politics and power into its major risk
management decisions. An excellent example of this is the
comparison between its decision to ban alar and its decision to ban
parathion. EPA moved to cancel the use of the chemical Alar on
apples some three weeks after actress Meryl Streep testified before
Congress about white, middle-class babies consuming minute residues
on some apple products. In contrast, EPA reached the conclusion
that it should cancel the use of the pesticide Parathion in 1987
because of the health threat to farmworkers, but withheld action
until a staff member leaked word of the coverup last year.
These considerations run throughout EPA decision-making.
Another good example is dioxin. The Report touches on contaminated
fish consumed by Latino, Asian, Indian, and African American
subsistence communities such as Georgetown, S.C. and Columbia River
in Washington. However, EPA has cut a deal with industry to ignore
93
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SW NETWORK COMMENTS TO EMVIRONMENTAL EQUITY REPORT. 3/18/92. PG. 5
the factthat people of color subsistence populations are eating
toxic chemicals thousands of times more concentrated than the same
toxic chemicals found at Times Beach and Love Canal, where EPA
spent hundreds of millions cleaning up soil that white families
were walking on. EPA's own internal risk numbers showed 10-6 for
Times Beach and 2 in 10 for dioxin in fish consumed by people of
color. , ',
I'.'i! , , • i , . , • .• ',i . ''••'''. ' ' '' ' ' ' "'V "
,i • ' . . ' ,1 ' . • , ' ; " . ', '• ' i,1 ' / _ ' ' v ' i ' , , ' , ,''"'. C i, :: •
Lack of Data
.. .EPA has never asked Congress for a major appropriation for
research. , ^_ I _
p. 11: EPA complains that data is incomplete, a major
problem, if true. However, EPA is not planning any major effort to
remedy this data gap. Environmental equity does not show up on EPA
internal ORD long term planning priorities. All agree that data on
farmworker risk is inadequate, yet EPA has never asked congress for
a major appropriation for research. In addition, EPA never seems
to find a problem regulating risk with "insufficient data" where
the politics are on the other foot (Alar?). If the Agency says it
lacks adequate statistics, why hasn't EPA done what Benjamin
Goldman, Dr. Robert Bullard, or the United Church of Christ have
done in their studies?
There is no reason why EPA could not have done a decent job of
correlating some existing data by now. Even without Toxic Release
inventory data and expensive mainframe computers, EPA has not even
approached Benjamin Goldman's the Truth about Where You Live or
Robert Builard'sDumping in Dixie. EPA implies that it just
discovered environmental equity two years ago. What was the
Agency's response to people of color employees' letter to the
Administrator six years ago (published in the EPA Journal) asking
EPA to tajce action?
: ... . , ;,| '. : ' , .'.'.•';. , ;. , :, : ' . , :*• '.;•?;;',:; v ,' - f, V '' •', | " ' , '• _' , '; • i V • •' : '". ,/^ ^vl,
D. EPA Policies work directly and indirectly to deny adequate
environmental conditions for people of color populations.
Policies such as ignoring inequitable state and local
programs,aggregating risk, cost-benefit analysis are continually
used against the interests of exposed communities of color (see
Analysis section). Exposure to pesticides, lead, air pollution,
toxic dumps and incinerators are all results of EPA policy
implementation. For example, EPA's policy of promoting
incineration as an acceptable waste disposal method impacts
primarily on communities of color who are being targetted as sites
for the construction of incinerators.
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SH METMORK CQMMEHTS TO EMVTRQNMENTAI. EQUITY REPORT.
3/18/92,
PG.
Translation of Materials
p. 25, translation: EPA does NOT have a policy or at least a
practice of translating relevant materials. In Kettlemen, EPA is
siding with Chemical Waste Management in preventing local residents
from receiving materials in Spanish. In the important farmworker
protection area, EPA declined to translate many of the materials
suggested by UCC and UFW. EPA has; translated more of its materials
into Polish than it has into Spanish.
E. Segregation of the workforce and continuing lack of cultural
diversity has resulted in biased input in policy decisions.
Segregation of Workforce
p. 8, "Defining the Issues": The Report mentions EPA's
"cultural diversity" effort but fails to note that EPA is one of
the worst agencies in the federal government in terms of
integration of its work force. This is especially true with
respect to segregation of people of color in substantive decision
making
EPA is one of the worst agencies in the federal government in
terms of integration of its workforce. ; __
positions involving mission of the agency. African American and
Latino employees are typically assigned to civil rights, personnel,
administration, .and other areas which will not affect overall EPA
policy. In the recent EPA awards ceremony, honoring those projects
the Agency finds most important, people of color professionals
accounted for less than two per cent of the award winners. EPA has
demoted, harassed, fired, and driven out of the agency as many
people of color as it has promoted. EPA refused to pay the
conference fee for people of color employees to attend the People
of Color Summit and has harassed employees who have had any contact
with Summit organizations. The EPA management has declined to
involve EPA people of color employee organizations in the
environmental equity issue (Blacks in Government, Minority Bar
Association, National Federation of Federal Employees, Hispanic
Advisory Council, etc.).
F. EPA has awarded a low priority to the equitable implementation
if its programs and statutory responsibilities.
The Report implies that EPA "discovered" the concept of
environmental equity. Both people of color employees, Office of
Civil Rights Staffers, and outside organizations such as the United
Church of Christ have been raising the issue to EPA management for
at least six years. The Southwest Network for Environmental and
Economic Justice sent a letter detailing the inequitable
enforcement policies of the Agency. What has been the Agency's
response?
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'"fii':•
SW NETWORK COMMEMTS TO ENVIRONMENTAL EQUITY REPORT. 3/18/92. PG. 7
p. 4, Summary of Recommendations, #1, "EPA should increase the
priority it gives to issues of environmental equity": The Report
never really explains, in terms of EPA operating procedures, how
EPA will accomplish this. For example, the FY 1993 individual
• office Operating Year Guidance has now been finalized for each
office, yet environmental equity priorities are nowhere to be
found. As far as the actual operating units of EPA are concerned,
environmental equity is not on the radar screen.
Nor is environmental equity found in long term FY 1992-1996
Strategic Plans for individual offices. This means that not only
does EPA not intend to address environmental equity issues now, it
will not even begin to address these issues until 1996. When the
Michigan coalition met with Mr. Reilly over a year ago, the
expectation was that EPA would be taking action on these issues .
It is also important to note that EPA staff had raised these same
issues to the Administrator,, as far back as 1985. In contrast to
the lack of real action correcting the problem, EPA's public
relations of f ice has whipped into action immediately, with stories
in the Post and the Times, and a strategy to co-opt civil rights,
church and academic groups.
. . .not only does EPA not intend to address environmental equity
issue now, it will not even begin to address these issues until
" ' • •
p. 9, bullet "reflect risk-based priorities...": No
environmental equity issues are identified in the FY 1993 budget or
FY 1993 b"f<3. See comment # 4, above. Both the Lew Crampton and
Edward Hanley memoranda support this finding. No EPA with ranking
as high as Crampton or Hanley has disavowed either of these memos,
arid EPA declined, (in the waxman hearing to officially disavow the
aeraos. , , : ' ...... ; , , ,„ • , ," .' ' , .... „ ' \,
p. 31: The verbs used in this section evidence EPA's lack of
commitment to any real policy change on this issue. Making, "clear
statements" and giving "signals" will not address twenty years of
Agency policy of inequity. "Indicating" our interest to States
will not change existing inequitable practices. The same remedies
were ineffective 30 years ago. If the Agency is serious about
change, it will implement the recommendations listed below.
6. EPA and other federal agencies have established a patronistic
catch-22 policy with respect to Native American tribes. This two
pronged policy is premised on treating tribal governments as
"States" but not delegating power to the tribes until each has
developed an "adequate" "environmental infrastructure".
96
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sii mgraoBK COMMENT^ TO ENVTROHMEMTAL EQUITY REPORT. 3/18/92, pg. g
With respect to Native American issues, EPA describes pilot
programs which are the exceptioh to the rule: the environment in
which Native Americans are forced to live has been raped beyond
recognition. Major Native American issues include the basic
rights to natural resources and issues such as drinking water,
groundwater, Federal facility cleanup, OMB cuts, to Bureau of
Indian Affairs and other infrastructure resources, specific
problems in a number of Native American lands, Uranium and other
mining, Nuclear testing and contamination of Pacific islanders New
Mexico and other areas.
One example of the failure and inconsistency of EPA's
"infrastructure" approach is EPA's denial of standing for the
Yakima Tribe to be a party to the Hanford, Washington, federal
facility compliance agreement. Although EPA policies state that
Tribes should be treated like States, the Agency has consistently
excluded the Yakimas from negotiations on the extremely
contaminated Hanford site, even though the site is on land ceded by
the Yakimas, the Yakima's still retain rights on the site, and the
Yakima reservation is adjacent to the site.
H. EPA needs to reopen and examine the 1977 decision withholding
application of civil rights laws to environmental laws and
.'. programs. ' • •
II. GENERAL COMMENT
PUtrHr Relations -Spin Control
p. 4, Finding #4, This finding appears to express EPA's basic
approach to environmental equity — "if they would just listen to
us, environmental racism would disappear, we just have a failure to
communicate." Although not stated outright in the report, internal
EPA meraos detail the Agency's intent to treat environmental equity
as a "spin-control" PR exercise with no substantive policy changes
reflected anywhere in the Agency's operating guidance. ,
...EPA nemos detail the Agency's intent to treat environmental
equity as a "spin-control" PR exercise with no substantive policy
changes reflected anywhere in the Agency's operating guidance,
p. 4, Finding #5; We note that EPA removed the statement
"there is a strong commitment on the part of EPA managers and staff
to address the environmental equity issues." Deleting this
comment could apply to much of the Report. This is a significant
change in the direction of the Report in that it is the first
acknowledgement that EPA management does NOT view environmental
equity as a priority. There is a very strong question as to
whether EPA has any commitment to this issue, as can be seen in
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SW NETJfflRf OMfMEHTS TO ENVIRONMENTAL EQUITY REPORT. 3/18/92. PC. j
many EPA actions: co-opting interested organizations; Vic Kimm as
a witness; Cabinet Status bill support; the EE Report; Agency
Priorities; etc.
Exposure
p. 13, the "potential" for exposure...": People of color
don't just have the "potential" for exposure, people of color are
exposed. Yes, the "differences in exposure rates are complex and
deeply rooted in many aspects of society..." These "aspects of
society" are known to people of color as "racism" and the issue is
whether EPA policies are reinforcing environmental racism. Since
EPA does not acknowledge a problem, it never addresses this issue.
p. 17, 18, studies of "licensed anglers" may misrepresent the
number of Native Americans consuming fish, as noted on p. 18. We
suggest you consult the work and input of Dr. Jeffrey Foran of
George Washington University, and others familiar with this
research area..,....".
A study of fish consumption in people of color populations
generally does not reflect the fish consumption by "subsistence
populations", which, by definition, implies consumption dependence.
We are not necessarily interested in how many African Americans eat
broiled snapper in restaurants in Georgetown, DC, we are interested
in who eats hqw many catfish in Georgetown, SC.
r ^ r j>A Projects
p. 23, The Reports cites the Office of Pesticide Programs as
an example of EPA's equitable programs. This is the same office
which has been sitting on the farmworker protection regulations for
12 years and delayed the ban on parathion for five years. We note
that the latest draft deleted the example of the Office of Water's
fish survey. We would hope you have some better examples.
...''" ... , , ' ;ji'i , , :, , ' ',,',,,'.'„ I,, ' , : .„ i , ,:' , 'i : ' " „ '? .,':,'.",''' i ' , • • • • ;,
p. 41, EPA projects: The projects mentioned in this appendix
are important first steps taken by independent midlevel managers
and concerned EPA staff. However, many of the projects listed
consist of studies, surveys, outreach projects, communications
strategies and other actions which do not involve a basic policy
change or high level high priority policy commitment. These good
deed projects would disappear immediately with the slightest
objection from local aayors, state officials, politicians, or
special interests.
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S« MEPKOBK GOMMEMTS TO EMVTRQMMEMTAI. EQUITY REPORT. 3/18/92. PS. 10
III. ANALYSIS
Universal Stan.flaT>dg "Do Not: Raise All Boats"
p. 1, under "Environmental Equity": Although the "standards"
are universal, they are not uniformly applied or enforced and
therefore exposure is not "the same" for all sources. Although
some statutes and regulations provide for the "most vulnerable",
EPA aggregates exposure in ways that dilute the vulnerability of
people of color populations. Likewise, in risk assessment and risk
management EPA disaggregates exposed populations to increase the
cost benefit balance against people of color. For example, if
there is a 10-6 cancer risk and 10 2. population exposed to the
risk, then EPA can ignore the risk. In this way, EPA can always
ignore exposed populations of people of color one at a time because
for each pollutant and each source exposure there will be
insufficient exposed population to produce the one theoretical
cancer or other risk sufficient to overcome the cost benefit
equation.
Federalism and Cost Benefit Policy
There is a more invidious aspect to EPA's use of two major
policy thrusts, cost benefit analysis and the "presumption against
federal standards" (the Federalism Executive Order). By delegating
the power to assess risks to the State and local levels, and then
applying cost benefit analysis, EPA can effectively "value" the
life of a Mississippi African American baby at less than half of
the "value" of a middle class white Connecticut baby without a
trace of overt discrimination because the policies applied are
"neutral" on face.
International Issues
p. 8, international issues: The discussion on "international
equity" raises some additional issues. It is difficult to
understand how the Administrator is going to have any credibility
with Third-world countries given EPA's record and credibility with
Third-world populations in this country. In addition, the priority
that EPA gives Third-world issues and programs compared to the
priority of Eastern European countries is baffling in terms of
EPA's. "scientific" risk based approach to priorities. The cultural
diversity issue also continues to appear: EPA has consistently
recruited Polish and Eastern European employees for Eastern
European projects while ignoring Latino employees in developing its
Mexican program.
A good example of EPA's neglect of such problems is the
manifestation of anencephaly along the Mexican border, where the
U.S. trade agreement is subsidizing pollution along the Rio Grande.
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NETWORK COMMENTS TO ENvTRONMENTAI. EQUITY REPORT. 3/18/92. PG. 11
Process and
p. 9, 10, "While EPA can ensure that its processes...11: This
is an inadequate response, in that EPA could easily find that
delegation to State and local government is a neutral process,
therefore this policy carries no environmental equity
responsibilities for EPA. It is difficult to find evidence of
C>yert r§ci§m in EPA's past "process11 yet this process has resulted
in widespread environmental racism. What does EPA propose
Changing? EPA, like all other federal agencies with delegable
|>6wers, is ultimately responsible for ensuring that the statutes
that it administers are equitably implemented.
Farmworker Data
p. 19, Farmworker section. This section is apparently
attempting to make the absurd point that, "since we are poisoning
a few white farmworkers along with Latino, African-American, Native
American, and Asian workers, we should all be satisfied". Does EPA
think that civil rights groups would be happier if only more white
workers were poisoned? Is it not racism because growers don't
bother to selectively spray their workers? If there is some
worthwhile point in this section, we fail to see it. The section
is more significant for what it omits than what it says: no mention
of the long delayed farmworker protection regulations. This
section alleges that there is insufficient data on health impacts
of farmworker exposure. Yet EPA must have developed some measure
of the health benefits of regulating farmworker exposure for the
cost benefit analysis for the farmworker rule. The Agency,
however, has consistently failed to ask Congress for more studies.
glean, Air Act
PP« 25-26, CAA: EPA could utilize provisions of the Clean Air
Act and other statuses to address environmental equity questions.
However, in the past, the Agency has used CAA and other provisions
to support discriminatory environmental impacts against people of
color. There is nothing in this Report which suggests anything
other than business as usual. We note that you have deleted the
paragraph on CAA offsets - why? with respect to equitable
Compensation, congress and EPA appear to be moving in the opposite
direction. The new Clean Air Act Amendments, and EPA proposals,
provide for aggregating or averaging pollution sources by putting
th^ ^ ^irtiest jsource in more depressed economic areas. Other market
based approaches that EPA is pushing also favor pollution in one
place, capital returns in another.
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SW NETWORK COMMENTS TO ENVIRONMENTAL EQUITY REPORT. 3/18/92. PG. 12
Consents about Current Recoraeridations
p. 5, #6, This is a good suggestion but does not go far
enough. If EPA is really siarious about addressing environmental
inequity, it should implement the recommendations above.
i , . • j '
p. 16, "more study of this issue is required...": This issue
has been studied to death.; Study is not required, analysis and
action are required. EPA should accept the probability that people
of color are at greater risk because of the location of their homes
and call for widespread pollution prevention.
p. 24, siting and permitting of waste facilities: Typically,
EPA delegates siting and permitting decisions to State and local
governments, with an automatic EPA rubber stamp approval. For
example, the New York RCRA approval process includes state and
county officials and nearby landOWNERS. The EPA process is
systematically designed to exclude those with the least power and
most exposure.
p. 26, #3: The Report states here that equity issues are best
addressed at the regional level. Yet the Report also states that
there is great regional and State variation and that the most
significant finding about the regional offices was the ignorance of
the environmental equity issue. This recommendation (regional
lead) fails to recognize that these problems require national
policy leadership and oversight.
Cover memo. The cover memo from Mr. Wolcott suggests that
some of the most obvious remedies, oversight of the equity of State
delegated programs,,are limited by statute. Is EPA trying to argue
that civil rights statutes do not apply to environmental statutes?
We can find no such statutory provisions. Is the Agency saying
that congress intended these statutes to be administered, delegated
and implemented in an arbitrary and inequitable manner? . We can
find no such legislative history.
p. 21, communication: EPA's fundamental approach appears to
be a communication strategy, as noted in numerous internal memos.
"Outreach" and "communications Strategy" will not work if, it
appears, EPA views this as a mission to convince people of color
that they shouldn't worry so much about inequitable exposure. This
smacks of the approach that EPA attempted to apply in the Dallas
case: "they don't need a clean up, we'll just teach them how to
grow grass on their yards and then they wont notice the lead so
much"... ,
EPA expansion of outreach and participation:
How will EPA expand its outreach, with its current lack of
credibility? It would seem that the first step in outreach would
be to take credible action, build up your credibility before you go
"out to reach" people. An outreach program built on co-opting
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COMMENTS TO ENVIRONIiElTOAI. EQUITY REPORT. 3/18/92. PC
civil rights, church, and education organizations is
counterproductive and lowers the Agency's credibility. In
addition, EPA has very few people of color in substantive decision-
raaking positions who know anything about communicating with grass-
roots organizations. Using only a regional approach will not
address problems which are national in origin and which EPA refuses
•;1-.":to recognize. • i ' „ , ' '
p. 36: EPA does not need to "tell" people of color what it is
doing with respect to people of color studies and pilot projects:
E|>A needs £0 listen to people of color and take decisive action.
To the extent that EPA is developing an "incinerators are your
friends" c,pmmunicatipns strategy/ we do not regard this as a
dialogue among equals.
. i ' ,„" " , ' , "!ni,|ll!|, , | „ • '"' "I,, M , . ' , ., ,, , ' • , ,: i, ,!'" 'J,:'!•.,_,' !,„,! , ' '•' ,, ' • • ",: ,,:•;' ,' ,' ,',,:', '!"''! i" 'I ,' '• ,I>W
p. 25, pollution prevention: pollution prevention may have
mixed results for people of color workers or residents. We support
strongly EPA's efforts at pollution prevention if the Agency
actively initiates environmental equity review of its pollution
prevention actions as we are suggesting for other actions.
Currently,individual pollution prevention projects could have a
good effect on ecology but a new and greater risk to people of
color maintenance workers without EPA consideration of the
tradeoffs.
We are interested in joining the Agency in promoting this effort in
a manner beneficial to all.
'". '" ; ' ' ' ." i, ti ."' " •. , ' ' . "' i ' " ;" ,. ' . • "i ' ,i ';; ... ,' , „ , > , \ in, ., . „ /, r* ,, , . . , , ', , 1 • ., y, , ,,',,',, " ' , • UHJ!,::1 ;
p. —: The Report recognizes the interdependence of agencies
and organizations in addressing environmental equity issues. There
are seyeraj. good examples of this. EPA, the Natural Resources
Defense Council, and the Paper industry teamed up to exclude
cpmmuni.ties of cplpr who relied on fishing from a court settlement
involving dioxin in paper mills
EPA, the Department of
Agriculture, OMB, and the National Agriculture Chemical Association
teamed up to exclude farmworker input in the farmworker protection
regulations. EPA and Housing and Urban Development teamed up to
exclude apartment renters from getting adequate protection from
radon. We would like to know EPA's pans to start including
grassroots organizations in these coalitions.
p. 31 Better data and better priority setting based on
relative risk will ultimately make EPA's programs and policies
fairer. However, as we mentioned earlier, there are policy changes
which EPA could institute now. If EPA had been so concerned about
the lac,k of data, why hasn't it asked congress for more money for
spch data needs? Why doesn't EPA support Representative Conyers
bill on environmental equity? Why can't EPA perform analyses such
";i as Goldman's?
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s« KgrwxsRK COMMENTS TO ENVTRONMEN^AL EQUITY REPORT. 3/18/92. PS. 14
IV. RECOMMENDATIONS
a. The Agency should develop a Major EPA Policy which creates a
"presumption of equity" in EPA actions and requires an equity
impact analysis for major rules, programs, actions, reviews, etc.
b. EPA should integrate Environmental Equity policy into Operating
Year Guidance, strategic plans, amd Agency Themes.
c. Pollution Prevention: EPA should work with civil rights groups
to implement Pollution Prevention in an equitable way.
c. Outreach and communication: do not continue attempt to co-opt
legitimate leaders, work with us: in mutual respect.
d. EPA should develop formal Federal Register requirements for all
State & local grant, permit, delegation, and enforcement policy.
e. The Agency should implement oversight of State & local grant/
permit, delegation, enforcement, for equitable implementation.
f. The EPA should establish an Advisory Board with representatives
from community-based and labor organizations.
g. The EPA should request funding for data needs.
h. EPA should support a General Accounting Office investigation
into whether State programs are in fact equitable.
i. Legislation - EPA should support the Conyers bill, tiaxman bill,
Chavis bill, and others.
j. Cultural diversity and the integration of the workforce - EPA
should put people of color employees in substantive decision making
positions and listen to input. The Agency should open dialogue and
encourage participation of employee organizations in developing
overall EPA policy.
k. structure of Environmental Equity Workgroup - The Workgroup
should be assured of its independence. Unions & employee
organizations must be involved.
1. Relations with other agencies and organizations: The EPA
should work with the US Department of Agriculture, DA, and
environmental groups to include equitable considerations and civil
rights and labor groups in "power brokered" decisions.
m. EPA should develop an ongoing relationship with the
Congressional Black Caucus and other groups.
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iiiiiiil iiiiiili
NETWORK C
PC. is
n. EPA should reopen and reject the 1977 decision withholding
application of civil Rights lavs to environmental laws and
programs. .
o> EPA should immediately issue enforceability provisions of the
Farmworker Protection Regulations to make the existing regulations
enforceable.
p. EPA should apply the findings of the National Academy of
Sciences Report on Pesticides and Children to children exposed in
farmworker situations. EPA currently pretends either that children
do not work in the fields or that children are no more vulnerable
than adults.
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UNIVERSITY OF CALIFORNIA, RIVERSIDE
BERKELEY • DAVIS • IRVINE • LOS ANGELES • RIVERSIDE • SAN DIEGO • SAN FRANCISCO
SANTA BARBARA • SANTA CRUZ
DEPARTMENT OF SOCIOLOGY
RIVERSIDE, CALIFORNIA- 92521-0419
PHONE: (714) 787-5444 FAX: (714) 787-3330
March 19, 1992
Mr-. Robert Wolcott, Chairman
Environmental Equity Workgroup
Office of Policy, Planning and Evaluation
U.S. Environmental Protection Agency
Washington, DC
Dear Mr. Wolcott:
Enclosed please find a copy of my written comments to the Draft
EPA Environmental Report dated January 17, 1991.
Sincerely,
V
—*
Robert D. Bullard )
Professor
Enclosure
105
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f:J
; COMMENTS ON THE DRAFT EPA ENVIRONMENTAL EQUITY REPORT
! . Jl"*'' ;" -. Rpt>ert P. Buliard^ ,- '".. . ' ' ,, .".'•'."".'.'
Department Of Sociology
'University of California
Riverside, California 92521
Introduction
\ " ' ..'...;.; , . . - . „,
, . > . . '
The following comments are made in response to the EPA's draft
report entitled "Environmental Equity: Reducing Risk for All
Communities" datedJanuary 17, 1992.
The following comments are the views of the author and do not
in any way purport to represent the University of California. I
was one of the persons (i.e., Michigan Coalition) who .drafted .the
March, 1990 letter to EPA Administrator William Reilly and a member
of the group that met with the administrator and his staff in
September, 1990. However, I offer these comments as my own
critique of the Equity Report..
Programmatic Initiatives
" ' '.! f ! ! '. ,!'„'" ":' " ': •.•.''' . •. •' - : • ; '' ' :'. ' "• ' ' ' '. • ' " •''' ' • • ' • •'.'.• ' pi'.'.>'V 'i1
During the September, 1990 meeting with Mr. Reilly, three
major programmatic thrusts were explored: (1) an EPA mandated
policy (within one year) to address environmental inequities and
disproportionate health risks borne high-risk populations, (2) set
up a science panel (within one year) to advise the agency on
environmental equity issues, and (3) budget resources to address
equity problems, i.e., a "targeted" approach to impact those most
at risk. After more than eighteen months., there is no indication
in the Equity Report that any of these actions have been initiated
by the agency. ,
Selective Literature Review
After more than eighteen months of "study, " the EPA Workgroup
on Environmental Equity has failed to grasp the interrelationship
between race, class, and environmental decision making. First, the
report contains a selective, biased, and superficial review of the
literature on the nature and severity of environmental problems
faced by low-income and communities of color in the United States.
1 . - .',T! , .'' • .1 - ,. ''.'•. '', '.: ;;' i" '.. • ,Y i '• • ,;:;',:;" -,. l •' '... ""i ./ •/::."•.. '.'• ; y
Thesystematic omission of the published works that document
the impact of discriminatory land use planning, differential
enforcement of environmental regulations and laws, inequitable
facility siting on communities of color is telling. The report
makes only a p'assing reference to a handful of studies that have
documented a relationship between sociodemographic characteristics
of communities and environmental quality. However, numerous books
have been written on this subject dating back to the early 1970s.
Some of these works. include Allen V. Kneese and Blair .T. Bower,
Environme'ntal Quality Analysis (1972), D. K. Newman and D. Day, The
American Energy Consumer .(1975), Michael Greenberg and Richard
Anderson, Hazardous Waste Sites: The Credibility Gap (1984), Louis
..;' '•' • > • ••'*':• " ••,-' ': • ice ' . ' '" ' ' ' . ' "
-------
Blumberg and Robert Gottlieb, War on Waste (1989), Robert D.
Bullard, Dumping in Dixie: Race, Class, and Environmental Quality
(1990), and Benjamin Goldman, The Truth about Where You Live
(1991). The research findings in these books show clear patterns
where racial and ethnic minorities bear greater health and
environmental risks' than the larger society. These books were not
cited in the Equity Report.
The EPA Equity Report has not produced one piece of original
research or new information. More importantly, it has done a less
than adequate job in synthesizing the state of the knowledge in the
field of environmental equity. The report appears to reflect a
half-hearted and less than serious treatment of the subject matter.
Given the nature and importance of environmental and health
problems facing low-income, working class, and communities of color
in the United States, a more in-clepth and comprehensive report and
action plan could and should have been produced.
The omission of the rich and voluminous literature on
environmental politics further weaken the credibility of the report
findings. A growing body of multi-disciplinary environmental
research (sociology, political science, economics, planning, law,
ethics, engineering, natural resources, human ecology,, etc.) is
beginning to address equity concerns. Many of these disciplines
are now challenging the notion of a "value-free" science, science
policy/ and application of technology. Is the reader to assume
that the EPA has made and continues to make all of its decisions
based on "value-free risk-based priorities?" We know better. The
not so distant past is a-reminder that the "politics of pollution"
is alive and well in the USA. We offer the example of the agency's
own Ann Gorsuch Burford, Rita Lavelle, and John Hernandez scandal
in the 1980s. These were all advocates of "good science."
Environmental Racism, Fact or Fiction
Does racism exist in the United States? Environmental racism
does not exist if we are to believe the EPA Equity Report. The
.report attributes class factors as the reason' for the elevated
risks borne by people of color. However, the report offers very
little substantive and empirical evidence supporting its own
contention. ^ -
On the other hand, there is overwhelming evidence documenting
that, the roots of institutional racism are deep and have been
difficult to eliminate in-the American society. Discrimination is
a manifestation of institutional racism. Even in today's society,
racism influences where an individual lives, works, and plays.
Racism also influences the likelihood of exposure to environmental
toxins and the accessibility to health care.
Environmental racism defends, protects, and enhances quality
of life choices available to whites at the expense of people of
color. Environmental racism is reinforced by governmental, legal,
educational, economic, political, military/ and religious
institutions through policies and practices that have the
, 107
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consequence (whether intended or untended) of differentially
impacting people of color. For example, there is a direct
cprrelatfon,''between.^the exploitation of land and the exploitation
of people. To deny this fact is to .deny an important (though
painful) piece of this nation's history. The .nation was built on
free land (stolen from Native Americans), free labor (African
slaves), and free men (only white men with property held the
franchise).
There is substantial evidence indicating that the nation's
industrial and environmental policies have not impacted all
communities equally. The systematic targeting of people of color
Cpiranunities'1 for "noxious " facilities ,; such _ asn sewer treatment plants,
garbage dumps, lanclfiiis, incinerators, hazardous waste disposal
sites, lead smelters, and other risky technologies is environmental
racism. Excluding people of color from policy and decision-making
boards, commissions, and staffs of governmental and nongovernmental
organizations influencesenvironmental policy outcomes.
:• ••" : •,: i"!i;•'..; •,--."• vyi •.•;•'•<'^.-i.\ •••• •;.'•• ^ivi•'.•'< m ::«• ••::'••n>\./:•.•,••'.••':'•. :>-:^
Relaying remedial cleanup actions or bans on dangerous health-
threatening chemicals, pesticides, and other toxins solely because
the victims are mostly persons of color is environmental racism.
Allowing and encouraging dangerous chemicals,, pesticides, and
toxic wastes to be exported abroad to Third World nations is a form
of environmental racism and ecological imperialism. However, the
practice of targeting of people of color nation's for the export of
toxins is an extension this nation's domestic toxic dumping
policies. The Equity Report failed to make the link between
domestic and global ecological inequities.
The Web of Institutionalized Barriers .
African Americans are especially hard hit by environmental
racism. No matter what their educational or occupational
achievement or income level, African Americans are exposed ;tp
higher crime rates, less effective educational systems, high
mortality risks, more dilapidated surroundings, and greater
environmental threats because of their race.
Institutional barriers such as housing discrimination,
redlining, and residential segregation make it difficult for
African Americans and Latinos to buy their way out of health-
threatening physical environments. For example, in the heavily
populated South Coast air basin of the Los Angeles, over 71 percent
of African American^ and 5.0 percent of Latinos reside in areas with
the most polluted air, while only 34 percent of whites live in
highly polluted areas.
Thedevelopment of spatially differentiated communities where
people ofcolor are segregated from other Americans have resulted
from governmental, policies and marketing practices of the housing
|l| ' • ' ,', "i -I1', ''••'',": ,"' ,'",''• s i ., •• ' ' ', ' , 111'. •" •• I,,,,,, •'i ,",""'", ,,. "' i;i!i;\ I',,,1, ' • " , , ;,, , • • ,
' , • ••/ ..; ' •' ;,: • ., . ',: . • , . "108
:i j"
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"• . '' J. " • •
industry and lending institutions?. Housing segregation follows a
color continuum with African Americans being the most .racially
segregated minority group. Millions of African Americans are
geographically isolated in polluted urban neighborhoods away from
the expanding suburban job centers.
Some communities are spatially located on the "wrong side of
the tracks" and subsequently receive different treatment when it
comes to the delivery of public services including environmental
protection. In addition to racial barriers, environmental
inequities result from a host of factors including the distribution
of wealth, housing and real estate practices, land-use planning,
redlining, and differential enforcement of environmental
regulations.
Selective Targeting and the "Smoking Gun"
Are some communities more suitable, than others for .locating
waste disposal facilities? Very seldom is there a "smoking gun"
found detailing the thinking behind facility siting. The EPA
Equity Report failed to cite a single study challenging the notion
that waste facility siting is based on objective criteria.
The 1984 report Political difficulties Facing Waste-to-Enercrv
Conversion Plant Siting written by Cerrell Associates of Los
Angeles was a smoking gun. The government-sponsored study
confirmed what many people had suspected all along. Cerrell
Associates (a private consulting firm) advised the California Waste
Management Board to place waste-to-energy facilities (incinerators)
in areas least likely to express opposition, older neighborhoods,
and low socioeconomic neighborhoods.
The city of Los Angeles took the advise of the Cerrell
Associates report and proceeded to plan the city's first modern
municipal solid waste incinerator (LANCER 1) in the mostly African
American and Latino South Central Los Angeles. In addition,
private disposal companies and the state of California selected the
mostly Latino communities of East Los Angeles and Kettleman City
(located in the agriculural-rich Central Valley) for hazardous
waste incinerators. Both hazardous waste incinerators were
approved by the federal EPA,
The EPA Equity Report failed to acknowledge the existence of
the Cerrell Report. By doing so, it also failed to acknowledge the
role of government (i.e., California Waste Management Board) in
systematically "targetin" some communities for locally unwanted
land uses (LULUs) such as landfills, incinerators, .and other
noxious facilities. The question of "who gets what, where, and
why" is often a political decision and may have little or nothing
to do with science and some objective criteria.
Nowhere in the report is the issue of institutionalized racial
discrimination addressed. There is a large body of sociological
109
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1 "ft!11: ,?Wll;!VvWlf
I1 1111 111 111
studies that explain racial disparities in education, employment,
housing, law enforcement, and other areas. Why is it that the
report failed to consider racial discrimination as a factor that
contributes to siting disparities between people of color
communities and white communities as it relates to exposure to
industrial toxins, dirty air and drinking water, and the location
of noxious facilities such as municipal landfills, incinerators,
lead smelters, and hazardous waste treatment, storage, and disposal
facilities!
After more than two decades of operation, why has the EPA (and
its EquityReport) failed to address inequitable siting concerns?
The EPA has undertaken few .initiatives on its own to address this
problem. The Equity Report was correct in citing the 1983 General
Accounting Office study Siting of Hazardous Waste Landfills and
Their Correlation with Racial and .Economic Status of Surrounding
Cdmmunities. It is also worth noting that the GAO study was
initiatedonly after mass protests in predominately black Warren
County and District of Columbia Delegate Walter Fauntroy (who was
then chaired the Congressional' Black Caucus) requested a study.
The GAO discovered that 75 , percent of the off site commercial
hazardous waste landfills in EPA's Region IV were located in mostly
black communities. African Americans make up about one fifth of
the population in Region IV. The EPA did not fpllowup this federal
study in 1983.
The EPA Equity Report failed to mention the fact that the,
siting inequities uncovered by the GAO in 1983 are worse in 1992.
For example, the two operating offslte commercial hazardous waste
landfills in Region IV (Emelle, Alabama and Pinewood, South.
Carolina) are both located in Zip Code areas where African
Americans make up the majority of residents. African Americans
still make up only about one fifth of the region's total population
in 1992.
Siting inequities have increased as a direct result of more
stringent federal environmental regulations and the difficulty
(public opposition) in siting new facilities. No new sites,have
gone in the region. The legacy of past discriminatory waste
facility siting places African American residents in Region IV at
greater health risks than. other residents in the region. The
Equity Report failed to acknowledge "past in present
discrimination" (i.e., residuals of an earlier era and practices)
and the effect on quality of life~of communities of color.
It isnot an accident that the first national study on toxic
waste and race was conducted by a civil rights organization, not
the federal EPA—-the agency charged with environmental protection.
The gqmmission for facial Justice's Toxic Wastes and Race study was
released at the National Press Club in 1987. The EPA did not take
any action to fpllowup this study in 1987. On the other hand, the
Centers for Disease Control (CDC) and the Agency for Toxic
' , • ' "': , • , :. :,„ •' ' ' ., •..' HO. , , ' ' ".
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Substances Disease Registry (ATSDR) developed and or expanded
several minority environmental health initiatives, including a
•study and a national conference.'
Waiting for EPA to Act Can Be Hazardous to'Your Health
The EPA only took action on environmental equity concerns in
1990, after a letter was written to the administrator by a group of
social scientists who participated in a conference at _ the.
.University of Michigan. The Equity Report is in part a direct
'result of this "outside" prodding.
Unlike the EPA, communities .. of color did not discover
environmental inequity in 1990. They have been living" (and many
dying) with inequitable environmental quality for decades—-most
without the assistance of the BPA, The Equity Report correctly
cites the 1988 ATSDR The Nature and Extent of lead Poisoning in
Children in the United States: A Report, to Congress study and
points out the glaring racial and class dimensions of the lead
problem. For' example, lead affects between -3 to 4 million
children, most of whom are African Americans and Latinos who live
in urban areas.. Among urban children 5 years older and younger,
the percentage of African Americans who have excessive' levels of
lead in their -blood far exceeds the percentage of whites at all
income levels. •
The ATSDR- study found that for families earning less than
$6,000, 68 percent of African American children have lead
ppisoning, compared with 36 percent for white children. In
families with incomes exceeding $15,000, more than 38 percent of
African American children suffer from lead poisoning compared with
12 percent of whites. Lead- is a complex problem in that it
touches a number of program areas and require cooperative working
arrangements with multiple federal agencies, including
environmental, public health, hoiising problem, and education.
The ATSDR study deemed lead as the "number one environmental
health problems facing children." The Equity Report concurs that
"sufficient" scientific evidence, is available on lead and human
health risks. However, the report does not provide any insights as
to why'the EPA has done so little to protect those who are "most
vulnerable." The agency has consistently delayed and .dragged it
feet on the lead-based paint, soil, and drinking water problem. It
is important to note that having sufficient facts and documented
"proof" is not a strong predictor of the agency's action on
environmental and health ..problems that disproportionately urban
minority children. For millions of inner-city children, the
'agency's delaying tactic is tantamount to a life sentence in lead-
contaminated environments. .
The Equity Report also failed to mention some of the
questionable decisions the agency has made regarding communities of
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color and lead. A case in point is the EPA's mishandling of the
lead problem in the West Dallas, Texas neighborhood. West Dallas
residents still do not understand why the agency scrapped a 1983
voluntary cleanup plan proposed by the local lead smelter company.
The EPA demanded another study.
• , i1'
On December 31, 1991, the EPA began a comprehensive cleanup of
the lead-contaminated soil in West Dallas after more than a decade
Of delays, scandals, and excuses. An, estimated 30,000 to 4-0,000
gubic yardsof lead-tainted soil will be removed from the several
ffest pallas site,s, including school property, the West Dallas Boys
Club, and yardsof 140 private homes. The West Dallas soil is
scheduled to be dumped at a landfill in Monroe, Louisiana a
community that is 60 percent African American.
Moreover, the Equity Report failed to. uncover the fact that
§.11 three .of Dallas' s lead smelters happened to be located in
African American and Latinp neighborhoods. It is for certain that
the people in the Dallas neighborhoods were there long before the
smelter. Moreover, West Dallas residents did not invite the
polluting Industries into their neighborhoods. Moreover, few
residents actually worked in the plants that polluted their
neighborhood, homes, and children.
Some Workers are More Equal than Others
All communities, neighborhoods, residents, and workers are not
created equal. All environmental policies and protection measures
are not applied uniformly across class and racial groups. People
of color have had to wait longer than the general population for
the same protection others take for granted. The case of
farmworkers is a classic example of the double standards in
environmental and health protection.
The protection (or lack of) accorded farmworkers who handle
dangerous pesticides—is a classic example, of this problem. These
workers have been waiting since 1979 for treatment as "first-class"
workers. The ethnic composition of this segment of the workforce
represents a classic case of occupational segregation. More than
90 percent of farmworkers are persons of color (African American,
Afro-Caribbean, Latino, and Asian).
, !!„ , , «', :„:', ' , , ' , ' , • ' i ', , ''.
The Equity Report glosses over the pesticide problem faced by
workers and those who live in nearby migrant labor camps.
The report emphasizes the agency's "risk-based" decision making.
However, the report fails to explain (using its own "science") its
actions on the chemical Alar "scare" and its action on the
pesticide _Parathion. Action on Alar came in about three week,
while action on Parathion was delayed for five years after the
agency reached the conclusion that it should cancel its use.
! The literature cited in the farmworker section is grossly
<•' , • ' ,• ' -! • • ' " •• ' •• .V ' ' '••••'. • i"" • '112 " ' ' ' ' • " ' :"
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' - • • 8 • - '•
inadequate. For example, not a single piece of research by Dr.
Marion Moses (who head the Pesticide Project and has written
extensively on pesticides and farmworkers) is cited in the report.
The Equity Report falsely assumes that environmental equity means
that it is "acceptable" for the majority of farmworkers (people of
color) to be poisoned as long as ,a. few white farmworkers are
poisoned along with them. Environmental justice advocates are not
calling for white farmworkers to be have equal opportunity to be
poisoned. That is not equity. However, equity demands that the EPA
begin to address the differential value assigned to the health of
farmworkers and those act equitably toward farmworkers who may be
exposed to pesticides in the field and white-collar office workers
who may be at risk from chemicals in a "sick" building.
It is unfortunate that the Equity Report uses "intuition,"
(rather than a systematic review of the literature) to assess the
state of the pesticide exposure problem. For example, the report
states: "Intuitively, one would expect that ethnic minorities who
make up a large part of the documented and undocumented, farm
workforce might experience higher pesticide exposures" (page 19).
It should not take an eighteen-month study to figure out that the
general population runs fewer risks than farmworkers and their
families from being exposed - to malathion spraying and other
dangerous pesticides.
The Sacredness of Local Land 'Use Planning .
EPA's current position of relegating facility siting to
private industry and states creates and perpetuates, environmental
inequities. The Equity Report failed to -address inequitable and
discriminatory state and local government institutions. Some of
the siting inequities result from past "discriminatory practices of
local governments and private industry.
- The EPA sanctions many of . these discriminatory local
government and private industry decisions by granting operating
permits. The agency has done little to encourage local and state
governments to adopt equitable facility siting plans. Defining the
problem as a "local" land-use issue will not make it disappear.
The use of risk assessment/management procedures in siting and
permitting incinerator plants justify and favor projects being
pushed by both industry and policy-makers. Even William
Ruckelshaus (a two-time chief of the EPA and current. CEO of
Browning-Ferris Industries) described risk analysis as "a kind of
pretense." >
The Equity Report failed to recognize the importance of siting
and permitting decisions on equity. All communities are . not
treated the same when it come to facility siting. For example,
Houston from the early 1920s to the late 1970s located 100 percent
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of its city-owned municipal landfills and six out of eight of the
garbage incinerators in black neighborhoods. From 1970-1978, three
but of four of the privately-owned landfills 'were located in black
!Neighborhoods.
i,,; ':•• . "• ' • 'it'll .„•• . ' " v '•'•. '.*>. ; , ;iji' i : . • :. i :','.'• ••!', i'l;,:/."!'. " "i ' . .. "• : • '...•. i.. t '...'::.• , :.ti.
Althqugh African Americans made up only one-fourth of
Houston's population, 82 percent of the municipal landfill sites
(public and private) were located in black neighborhoods. White
Houstpnians used t:heir "NIlffiY" (not in my back yard) institutions
to keep waste facilities out of their neighborhoods. Conversely,
public officials and private industry responded by employing the
"PIBBY" principle "Place in Blacks Back Yard."
The decision to target black communities was made by an all-
white Houston City Council. No black .was .elected . tp. that office
until 1972. Nevertheless, Black Houstonians had been fighting
since the mid-sixties to keep garbage dumps put of their
neighborhoods. The Kerner Commission reported that a riot took
place on the "predominately black Texas Southern.University in 1967
after an eight year old black girl drowned at a garbage dump in the
inpstly black Sunnyside neighborhood.
Black and white communities are still^separate and unequal.
Some city councils, county.board of supervisors, and federal judges
still see black Communities (but not their white counterparts) as
, compatible land use with garbage dumps, landfills, and
'Incinerators. The Equity Report failed to cite a single case study
documenting the targeting of African American communities for
jnunicipal landfills. However, numerous cases exist.
. ill•:
•ft; ..'..;• As,( regpnt; .asr .June, 1991, the Board of Supervisors in King and
Queen County, Virginia selected a 420-acre site in a mostly black
community for a regional solid waste landfill. The supervisors
from 1969 to 1991 located all three of., the ...county-owned solid waste
landfills in black communities in the county. It seems that county
leaders rate black communities as more compatible than their white
counterparts for facilities where household garbage is dumped.
County leaders see nothing inequitable or unjust about siting all
of its landfills in black communities.
The EPA has taken the position of not involving itself in
local land use and siting decisions. By backing away from federal
equity requirements, the agency seems perfectly willing to allow
the Houston's and the King and Queen County's of the nation to
selectively dump on communities of color. These decisions mirror
those made by local and state government under "Jim Crow:"
everybody gets their garbage picked up, but only black communities
get the landfills and incinerators.
EPA's regulations impact and influence local land use and
facility siting in its power to grant permits. However, the EPA
has "yet to meet a .hazardous waste facility it didn't like." The
, • . , ,: ,' ' ' ' '" : ; .114 " ' ' •
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10 ,
Equity Report does not go far enough in calling for mandated
permitting requirements that would force, states and ,private
industry to address siting equity.
In addition, the EPA should examine aggregate risks in the
.permitting process. For example, a neighborhood like Chicago's
Southeast side is "saturated" with abandoned toxic waste dumps,
steel mills, municipal landfills, hazardous waste incinerators,'
salvage yards, grain elevators, and oil refineries. The EPA should
have responsibility for protecting the Southeast side Chicago
community from further risks that would result from siting another
waste facility in the area? Current EPA policies do not calculate
aggregate, cumulative, and synergistic risks posed by the various
polluting industries in a specific neighborhood. The end result is
a "sacrifice zone."
Here is where the agency might, expand its use of "social
impacts" in making permitting decisions. Surely, the agency can
begin developing - methodologies to address multiple exposure in
"saturated" communities.
States Rights as Civil Rights •'-...
States are now talking about "fair share" plans for the
interstate transport of municipal and hazardous wastes. No state
wants to become the dumping grounds for another state's garbage or
hazardous waste. Some states have resorted to outright, bans
(though illegal) and restrictions on out-of-state waste. Many
states are now borrowing the jargon of the civil rights movement in
defining fairness, ,equity, and justice in the interstate waste
crisis. However, few states have begun,to seriously address the
problem of intrastate equity, especially as it pertains to waste
facility siting and low-income and communities of color.
The federal government needs to take the leadership role in
assuring that both interstate and intrastate equity plans are given
equal consideration. Many local and state governments are the
chief culprits in disenfranchising low-income, working-class, and
minority communities and should not be given the chief
responsibility for assuring that environmental equity (facility
siting) is achieved.
Equal Opportunity Polluters
African Americans are hot the only group hit by environmental
injustice. 'Latinos and Native Americans are also affected. For
example, the small, rural town of Kettleman City, California has
drawn national attention. Chemical Waste Management, Inc., the
world largest waste disposal company, selected this small
farmworker community of 1,100 residents as a site for a proposed
hazardous waste, incinerator. The company already operates a
hazardous waste landfill in Kettleman City.
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j,i, i Jin i ", .' '
.A1]- of, the public hearing and written material in Kings County
was in English, although 40 percent of Kettleman City residents
speak^only English. In 1991, local residents filed a class action
lawsHit El Pueblo Para el Aire v Acrua Limoio (People for Clean air
and Water) v. County of Kings" The lawsuit challenged the impact
report, the use of English-only to communicate risks to local
residents, and operating hazardous waste incinerators in mostlv
minority communities.
i'ii". , " V :- • \Li <•''•'•• •': ;!:',i,;: '"'V'" ",::•". ,',' '.'• • '• ''. , '•• '•-,'.. :t, "•,, '•• •;* ; , •,:••'", ••' ' !:;; .. , (' ..,.,; ''•;,..« i ,''!;i
In January, 1992, a Superior Court judge overturned the Kings
County Board of Supervisor's approval of the incinerator, citing
.Lijs, impact on air quality in the agriculture-rich Central Valley
The judge ruled that the county's environmental impact report was
inadequate and that the county failed to involve local residents in
the decision by not providing Spanish translations of material
about the project. EPA should require translations in heavy non-
English speaking (i.e., Spanish) areas where waste facilities are
proposed.
This _is an important point given the location of hazardous
waste incinerators. For example, the nation's largest waste
disposal company, Chemical Waste Management, operates or has under
development five hazardous waste incinerators. All of the
company's incinerators are located in communities which have high
concentrations of minorities. The company operates an incinerator
in Chicago's. Southeast side (72 percent black and 11 percent
,,Jjata.no),. Sauget, Illinois (73 percent black), and Port Arthtir,
Texas (40 percent black and 6 percent Latino).. The company has
incinerators under development in Emelle, Alabama (90 percent
black) and Kettleman City, California (95 percent Latino).
Targeting Native Lands
Thei EPA Equity report gives the impression that communities
are actively recruiting noxious facilities. For example, the
report states: "[TJhere are numerous examples of poor communities
seeking a waste site. or industrial facility to increase the tax
Pase and create jobs" (page 24). The report fails to cite any of
these "numerous examples" and does not differentiate who is
actually doing the inviting. More often than not, it is the
business and political "elites" (not the ordinary residents of the
community) who have sought waste facilities as economic
development.
Native American lands pose a special case for environmental
protection. As environmental regulations have become more
stringent in recent years, Native American reservations have become
prime targets of waste disposal firms. Because of the special
quasi-sovereign status of Indian nations, disposal companies have
attempted to skirt state regulations which are tougher than the
federal regulations. The threat to Native lands exists from New
York to California. .
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More than three dozen reservations have been targeted for
landfills and incinerators. Nearly all of the proposals have been
defeated. In 1991, the Choctaws in Philadelphia, Mississippi
defeated a plan to locate a 466-eicre 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. The giant landfill was proposed by a firm that had
never operated a municipal landfill. The project was later dubbed
"Dances with Garbage." The Good Road Coalition, a grassroots
groups, using a recall election of the Tribal Council government,
blocked the proposal to build the giant municipal landfill on Sioux
lands.
Outreach vs Spin Control
The Equity -Report's "outreach" strategy to more akin to
a public relations campaign or "spin control" rather than any
substantive efforts to address environmental problems that
disproportionately impact people of color and . low-income
communities.
It is unlikely that the EPA can build an effective outreach
program in communities of color without addressing the question of
environmental justice and trust. For example, it is not uncommon
for residents in communities such as Northeast Houston, West
Dallas, Texarkana, Kettleman City, East Los Angeles, and Chicago's
southeast side-to view the EPA (and waste disposal companies) as
the "enemy." -Quite often residents-in these communities perceive
the" EPA as protecting industry not local citizens.
People of color groups have begun to build a national movement
against environmental injustice. In October 1991, the First
National People of Color Environmental Leadership Summit was held
in Washington, DC. This Summit demonstrated that white middle
class suburbanites do not have a monopoly on environmental concern.
Environmental activism was shown to be alive and well in African
American, Latino, Asian, and Native American communities-
The four-day Summit was attended by 650 grassroots and
national environmental leaders (representing over 300 people of
color environmental groups). Delegates came from all fifty states
including Hawaii and Alaska, Puerto Rico> Chile, Mexico, and the
Marshall Islands to share their action strategies, redefine, the
environmental movement, and develop common plans for addressing
environmental problems affecting people of color in the United
States and aro'und the world.
The Equity Report demonstrates the unevenness and lack of
awareness of equity among EPA's Regional offices. The report does
not list "equity initiatives" from all ten of EPA's regions., Is
this indicative of the lack of equity problems, in the regions not
reporting or the lack of initiatives? The report failed to explain
117
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';;,;; •;. . , ,, , / • ' : , ; ". , , ', ,.: 13 ,. ' ' ,;,,; ' , ..' . ,; . ! ,, ,' ,
these regional disparities. Will the'agency's environmental equity
thrust rely solely on voluntary actions of regional staff or will
it be mandated across regions? Environmental equity is too imporant
an issues to be left for voluntary action within the EPA. Equity
goals must be integrated throughout the agency's programs.
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ENVIRONMENT CENTER
February 13,1992
Memo To: Doretta Mitchum, EPA
From: Sharon Benjamin, Executive Director, Human Environment Center
RE: Comments on the draft report on "environmental equity"
First let me commend EPA on its efforts in beginning the hard work of dealin j
with "environmental equity" issues. As you may know, the Human Environment Cen
(HEC) has been active on these issues for well over 15 years and we know, from
experience, that there no easy answers to these issues.
EPA's report to the Administrator, Environmental Equity; Reducing Risk Fo
states that "environmental equity is important to the goal of achieving
more just society." We think that this is the only possible premise and we share this
commitment, as HEC was founded in the belief that "sustained resource conservatio
simply cannot be achieved amid intolerable flagrant social and economic inequities."
In light of the Center's particular" interests, I would like to comment on a nun ber
of topics related to the report.
Adults, Children and Environmental Equity:
As the report states, "Environmental equity is important to those who might ttear
disproportionately high risks" Unfortunately, the population that we believe to be n ost
at risk is not even explicitly considered in the report.
.The report makes no distinction between adults and children in the area of ri gk.
assessment. Although the report refers to the special needs of children relative to i
risk of lead poisoning, you make no systemic statements regarding the disproportion ite
risks that children bear. There are at least four good reasons for developing better
mechanisms for dealing with this:
* Children are more sensitive to toxins as they eat, breathe, and drink
more per unit of person than adults or the "average" person used in EPA's
current risk models;
* Very few federal laws specifically protect children, yet we know that in
light of the above, children need more protection not less. EPA must
v remedy this situation;
119
er
All
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By protecting children from undue risk we will be raising the threshold
• a# exposure rates, thus reducing the risks faced by whole communities,
arid JH"M"
* As a moral society we have a responsibffily to protect our children.
Geographic Breakout:
r? we were disappointed that the report apparently didn't break inform* tioit
Plf on a geographic basis. While it addressed the problems of inequitable risks cum ntJy
being borne by low-income and minority communities, far too little attention, in the < raft,
was paid to the special needs of urban communities. In 1972, HEC published Inner 2tv
Cancer Rates, which along with Ben Goldman's recent book, The Truth About Whet i
• . i i T — T — -- --» •-*»** ^-*» ^_ w*v*uAMu 0 J.WWWAII. 1/WW&9 AXit> 4.1UIII fYLAJUi WIIC: 3
, clearfy demonstrates that urban dwellers bear disproportionate shares of tl e
environmental burden and have fewer resources for dealing with these problems.
Although Goldman's work has just been released, it should serve to inform E! A's
wqjrking group on many of the issues raised in the report. One additional considerat an:
'
.
, work fereafcs data out on a county level bv states. EPA could do a much
be^er job of addressing inequitable environmental problems by using newly develope I
d£$* bases which analyze neighborhood composition by race and income level and th i»
allows for more informed decisipns. r
jit';'1'" • 'i ' "' 'i1 •' in - "''• !i , 1,:,.1'11 ••! , •'''
Right-To-Rnow:
Another area that wasn't touched on in your report (in the Public Communica ion
_ »#"- *J -v« •*» ^ *»*!•• *,*rjH*«^Av ^*A* •»AA*^ A U.h^A4V ^g^V^llllIflVlllVfl AW*
of Risk Section) is the information EPA collects through the Community-Right-to-Kn iw
Act ~ the Toxic Release Inventory, This is an incredible wealth of information. Yet, in
talking with local activists, it is clear that this effort is under-funded at the federal lev &
It |s faster by eight to nine months to get this information from states. K EPA is sen ms
about cornmunica|ing risk, you must put more resources into this effort. Democracy
buSt on the premise that citizens can make informed judgements when given good
im?rmation' E^A must make a bigger commitment to getting Toxic Release Inventoiy
information into f|e hands of the public.
NASA's Mission To Planet Earth:
Finally, no mention is made of NASA's Mission to Planet Earth or Landsat, y it
the information being developed by the program has been used to:
* prove that a large pulp and paper company in the United States was
responsible for the toxic sludge deposited at the bottom of Lake
Champlaii). Landsat "photographed" the exact location of the source of the
sludge, and tracked its movement through the large lake to its point of rest
on the other side. The company had denied responsibility, asserting that
no one could prove the company was the source of the pollution.
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* prove that asbestos-related tailings (tremolite and actinolite)
released into Lake Superior from an iron recycling facility on the shore
moved across the lake into the drinking water intake pipes on the lake at
Duluth, Minnesota. Landsat imagery & aerial photographs played a vital
role in confirming the flow of Lake currents, which carried the pollutants
across the lake.
* prove that a plume of pollution drifted hundreds of miles through
Lake Michigan into the drinking water supplies of Chicago. The plume
contained phenols, ammonia and other dangerous substances, requiring
frequent shut-off of Chicago's water intake valves. As a result, the proper
steel plant was blamed for creating the plume and forced to correct its
behavior. Skylab and aerial photography tracked the heated water in which
the pollution was carried.
Cleariy this diagnostic tool will be of great use to EPA staff in identifying
environmental inequities. ' - . •
We recognize that frameworks and paradigms for allocating scarce environmental
resources must be developed. Risk assessment is one way of dealing with these diffic
trade-offs. It is, however, an imperfect tool at best, and EPA must continue the process
of improving both the science of risk assessment and the process of discussing the val IBS
inherent in implementing any science. As you know, these are life and death issues for
many.
We look forward to working with you in the future.
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,,ii * * f -
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