ML11356A490

Hudson River Sloop Clearwater (Cle) Pre-Filed Evidentiary Hearing Exhibit CLE000027, Unequal Exposure to Ecological Hazards: Environmental Injustices in the Commonwealth of Massachusetts

ML11356A490
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Environmental Health Perspectives VOLUME 110 l SUPPLEMENT 2 l April 2002 277 We analyze whether environmentally haz-ardous industrial facilities, power plants, municipal solid waste combustors (incinera-tors), toxic waste sites, land"lls of all types, and trash transfer stations are unequally distributed regarding the income and/or racial composi-tion of communities in Massachusetts. We used demographic data from the 1990 U.S.

Census, as well as data collected in the spring and summer of 2000 from the Massachusetts Department of Environmental Protection (DEP), U.S. Environmental Protection Agency (U.S. EPA), and the Massachusetts Toxics Use Reduction Institute, to analyze the exposure rates of all 351 cities and towns (minor civil divisions, or MCDs) in the state to the environmentally hazardous industrial facilities and sites listed above. Although 2000 U.S. Census data would have been more appropriate for us to use, it was not available at the time. At least one study shows that biases to the distribution of ecological hazards worsen over time (1).

In addition to these 351 cities and towns in Massachusetts, we also included seven subtowns or neighborhoods within the larger town of Barnstable: Barnstable, Centerville, Cotuit, Hyannis, Marstons Mills, Osterville, and West Barnstable. We also include 12 subtowns or neighborhoods within the larger city of Boston: Allston/Brighton, Charlestown, Dorchester, East Boston, Hyde Park, Jamaica Plain, Mattapan, Roslindale, Roxbury, South Boston, West Roxbury, and Downtown Boston (for the purposes of the report, Downtown Boston encompasses Central Boston and Chinatown, Back Bay and Beacon Hill, the South End, and the Fenway/Kenmore neighborhoods). Because these more specifc neighborhoods making up all of Boston and Barnstable are included, summary data for all-Boston and all-Barnstable are excluded from the totals. As a result, a total of 368 communities are ana-lyzed in this report. Only in Tables 1 and 2 of this report, where the most overburdened communities in the state are ranked, are Boston and Barnstable as all neighborhoods combined reintroduced to create a total of 370 communities.)

Each of the 368 communities is classi"ed by class and racial composition. Median household income determines the class status of a community (1), low income,

$0-$29,999; (2) medium-low income,

$30,000-$39,999; (3) medium-high income,

$40,000-$49,999; and (4) high income,

$50,000 and above. These categories re"ect reasonable cutof points in the data because, frst, the data have no distinct gaps in the income distribution of towns, and second, the

$40,000 cutof point divides the lower-and higher-income communities into roughly equally sized halves (Table 3). The distribu-tion of incomes takes the shape of a relatively normal curve with a mean of $41,293 and a standard deviation of $11,742. We selected a

$10,000 decrease/increase from $40,000 on the basis of generating reasonably sized groups with easily recognizable boundaries. The lower-income groups are not intended to indicate poverty conditions.

The percentage of total population made up of people of color determines the racial composition of a community, which we coded as follows, (1) low minority, less than 5% people of color; (2) moderately low minority, 5-14.99%; (3) moderately high minority, 15-24.99%; and (4) high minor-ity, 25% and greater. The vast majority of towns in Massachusetts have very small minority populations of less than 5%.

However, when we analyzed the remaining towns (Table 4), 10% increases in population proportions seemed logical for generating rel-atively acceptable frequencies in each cate-gory. The distribution of non-White populations as percentage of total population is extremely positively skewed, with a mean of 4.5% and a standard deviation of 9.5.

Only nine communities in the state have between 15 and 24.99% people of color, and 11 communities have 25% or more.

We made comparisons of low-and high-income communities and of low-minority-and high-minority-status communities in terms of exposure rates to environmentally hazardous industrial facilities, waste sites, power plants, incinerators, trash transfer sta-tions, and land"lls of all types. As illustrated in Table 5, we assigned a point total to each facility or site based on our assessment of the relative risks it typically represents to the community. We then added these point totals for each community and divided by total area to arrive at a density fgure. The density fgure provides a more accurate assessment of the environmental hazards confronting a given community because it This article is part of the monograph Advancing Environmental Justice through Community-Based Participatory Research.

Address correspondence to E.J. Krieg, Dept. of Sociology, Bufalo State College, 1300 Elmwood Ave., Bufalo, NY 14222 USA. Telephone: (716) 878-6629. Fax: (716) 878-4009. E-mail: kriegej@

bufalostate.edu For their invaluable research assistance, we thank K. Fredricks, T. Zilliox, E. Bourgeois, A. Gross-man, H. Tenney, W. Hope, S. Peck, S. Weinstein, P. Bakely, P. Hunter, P. Loh, K. Smalls, V. Eady, and M. Wilson. The authors remain solely respon-sible for the content of this report.

Received 13 August 2001; accepted 23 November 2001.

Environmental Justice This study analyzes the social and geographic distribution of ecological hazards across 368 commu-nities in the Commonwealth of Massachusetts. Combining census data with a variety of environ-mental data, we tested for and identifed both income-based and racially based biases to the geographic distribution of 17 diferent types of environmentally hazardous sites and industrial facilities. We also developed a composite measure of cumulative exposure to compare the relative overall risks characteristic of each community. To the best of our knowledge, this point system makes this the frst environmental justice study to develop a means for measuring and ranking cumulative exposure for communities. The study also controls for the intensity of hazards in each community by accounting for the area across which hazards are distributed. The "ndings indicate that ecologically hazardous sites and facilities are disproportionately located and concentrated in communities of color and working-class communities. The implication of this research for policy-makers and citizen advocates is that cumulative exposure of residents to environmentally hazardous facilities and sites should receive greater consideration regarding community demographics and environmental health indicators. We conclude that the provision of additional resources for envi-ronmental monitoring and ranking, as well as yearly progress reports, is necessary for communities and state agencies to achieve equal access to clean and healthy environments for all residents.

Key words: environmental justice, environmental policy, exposure assessment, hazardous waste sites, public health, toxic release inventory. Environ Health Perspect 110(suppl 2):277-288 (2002).

http://ehpnet1.niehs.nih.gov/docs/2002/suppl-2/277-288faber/abstract.html Unequal Exposure to Ecological Hazards: Environmental Injustices in the Commonwealth of Massachusetts Daniel R. Faber 1 and Eric J. Krieg 2

1Department of Sociology and Anthropology, Northeastern University, Boston, Massachusetts, USA; 2Department of Sociology, Bufalo State College, Bufalo, New York, USA Exhibit CLE000027 Submitted 12/22/11

controls for the size the community and the severity of the facility/site. Among our "nd-ings: low-income communities face a cumu-lative exposure rate to environmentally hazardous facilities and sites that is 3.13-4.04 times greater than that for all other commu-nities (measured by median household income) in the state. In addition, high-minority communities face a cumulative exposure rate to environmentally hazardous facilities and sites that is nearly nine times greater than that for low-minority communi-ties. Clearly, not all communities in Massachusetts are polluted equallylower-income communities and communities of color are disproportionately impacted.

We define environmental injustice as unequal access to healthy and clean envi-ronments, including environmental ameni-ties. We can better understand this broad definition in light of the definition of envi-ronmental justice, which we borrow from Bryant (2). Although we do not limit our definitions of environmental racism and environmental classism to conditions charac-terized by an overburden of ecological haz-ards, we consider such overburdens to be indicators of both environmental racism and environmental classism. We also stress that this study makes no attempt to argue causal Environmental Justice

• Faber and Krieg 278 VOLUME 110 l SUPPLEMENT 2 l April 2002

• Environmental Health Perspectives Table 2. Most extensively overburdened communities in massachusetts (total points per town).

Points per Rank Town Total points square mile Class status of town Racial status of town 1

Boston (all) 3,972 84 Low income ($29,180)

High minority (37%)

2 Worcester 1,248 32.4 Low income ($28,955)

Moderate-low minority (12.7%)

3 Downtown Bostona 1,014 224.8 Low income ($29,468)

High minority (31.9%)

4 Spring"eld 999 30.1 Low income ($25,656)

High minority (31.2%)

5 Cambridge 820 115.0 Medium-low income ($33,140)

Moderate-high minority (24.9%)

6 New Bedford 619 25.8 Low income ($22,647)

Moderate-low minority (12.2%)

7 Waltham 611 44.9 Medium-low income ($38,514)

Moderate-low minority (8.7%)

8 Lowell 611 42.0 Low income ($29,351)

Moderate-high minority (18.8%)

9 East Boston 556 123.3 Low income ($22,925)

Moderate-high minority (23.6%)

10 Framingham 537 20.3 Medium-high income ($42,948)

Moderate-low minority (9.6%)

11 Brockton 502 23.2 Medium-low income ($31,712)

Moderate-high minority (19.6%)

12 Dorchester 490 81.3 Low income ($29,468)

High minority (50.7%)

13 Pitts"eld 490 11.6 Low income ($29,987)

Low minority (4.6%)

14 Lynn 488 36.2 Low income ($28,553)

Mod.-high minority (17.0%)

15 Fall River 477 12.5 Low income ($22,452)

Low minority (2.7%)

16 Newton 467 25.6 High income ($59,719)

Moderate-low minority (7.0%)

17 Woburn 461 35.7 Medium-high income ($42,679)

Low minority (3.0%)

18 Chicopee 451 18.9 Low income ($28,905)

Low minority (4.4%)

19 Natick 443 27.6 Medium-high income ($49,229)

Low minority (4.7%)

20 Somerville 442 104.7 Medium-low income ($32,455)

Moderate-low minority (11.3%)

Total 16 of 20 towns most extensively overburdened 9 of 20 towns most extensively overburdened towns are lower income status ($39,999 or less) are of higher minority status (15% or more) aFor the purposes of this report, downtown Boston encompasses Central Boston and Chinatown, Back Bay and Beacon Hill, the South End, and the Fenway/Kenmore neighborhoods.

Cumulative data on the median household income is not available, but appears to fall below the $29,179 "gure for Greater Boston as a whole (a low-income category).

Table 1. Most intensively overburdened communities in Massachusetts (total points per square mile).

Points per Rank Town name square mile Class status of town Racial status of town 1

Downtown Bostona 224.8 Low income ($29,468)

High minority (31.9%)

2 Charlestown 134.3 Medium-low ($35,706)

Moderate-low minority (5.1%)

3 Chelsea 127.4 Low income ($24,144)

High minority (30.3%)

4 South Boston 126.2 Low income ($25,539)

Low minority population (4.2%)

5 East Boston 123.3 Low income ($22,925)

Moderate-high minority (23.6%)

6 Cambridge 115.0 Medium-low income ($33,140)

Moderate-high minority (24.9%)

7 Somerville 104.7 Medium-low income ($32,455)

Moderate-low minority (11.3%)

8 Roxbury 101.3 Low income ($20,518)

High minority (94.0%)

9 Allston/Brighton 100.0 Low income ($25,262)

High minority (26.9%)

10 Watertown 98.6 Medium-high income ($43,490)

Low minority (3.8%)

11 Everett 98.1 Medium-low income ($30,786)

Moderate-low minority (6.0%)

12 Boston (all neighborhoods) 84.0 Low income ($29,180)

High minority (37%)

13 Dorchester 81.3 Low income ($29,468)

High minority (50.7%)

14 Lawrence 59.3 Low income ($22,183)

High minority (34.9%)

15 Malden 57.8 Medium-low income ($34,244)

Moderate-low minority (10.1%)

Totals 15 towns 14 of the 15 most intensively overburdened towns 9 of the 15 most intensively overburdened towns are are of lower-income status (less than $40,000) of higher minority status (15% or more people of color) aDowntown Boston encompasses Central Boston and Chinatown, Back Bay and Beacon Hill, the South End, and the Fenway/Kenmore neighborhoods.

Table 3. Median household income.

Income bracket Frequency Valid %

Cumulative %

$0 to $29,999 50 13.6 13.6 13.6

$30,000 to $39,999 137 37.2 37.2 50.8

$40,000 to $49,999 114 31.0 31.0 81.8

$50,000 or more 67 18.2 18.2 100.0 Total 368 100.0 100.0 Table 4. Percentage of population that is non-White.

Income bracket Frequency Valid %

Cumulative %

Less than 5%

299 81.3 81.3 81.3 5-14.99%

49 13.3 13.3 94.6 15-24.99%

9 2.4 2.4 97.0 25% or more 11 3.0 3.0 100.0 Total 368 100.0 100.0

associations between social and environmen-tal conditions. It is descriptive in its orienta-tion alone, and neither the data nor the type of analysis allows for discussions of causality.

Unequal Exposure to Hazardous Waste Sites In thousands of communities across the United States, billions of pounds of highly toxic chemicals, including mercury, dioxin, polychlorinated biphenyls, arsenic, lead, and heavy metals such as chromium, have been dumped in the midst of unsuspecting neigh-borhoods. These sites poison the land, cont-aminate drinking water, and potentially cause cancer, birth defects, nerve and liver damage, and other illnesses. In a 1991 study, the National Research Council found that over 41 million people lived within 4 miles of at least one of the nations roughly 1,500 Superfund waste sites (3). Although these dumps are the worst of the worst, in 1993 the U.S. Office of Technology Assessment estimated that the United States has as many as 439,000 other hazardous waste sites (4).

In Massachusetts, 32 sites, located (totally or partially) in 42 towns, are on the U.S. EPA NPL, or Superfund, list. The Fort Devens site encompasses parts of the towns of Ayer, Shirley, Lancaster, and Harvard. The Ford Devens-Sudbury Training Annex site encom-passes parts of the towns of Sudbury, Maynard, Hudson, and Stow. The Hanscom Field/Hanscom Air Force Base site encom-passes parts of Bedford, Concord, Lexington, and Lincoln. The Otis Air National Guard/

Camp Edwards site encompasses parts of Falmouth, Bourne, Sandwich, and Mashpee.

The South Weymouth Naval Air Station site encompasses parts of Weymouth, Abington, and Rockland. The W.R. Grace & Company, Inc., site encompasses parts of Acton and Concord. The remaining 26 sites are located in single towns (5). These towns are home to more than 1,072,017 residents, including 70,491 people of color. Approximately 61,000 people live within a 3-mile radius of the Iron Horse Park Superfund site in North Billerica. In addition to these Superfund sites, Massachusetts has over 21,000 DEP haz-ardous waste sites. Together, 3,389 of these Superfund or DEP sites are considered to pre-sent health risks.

For residents living near Superfund and other major toxic waste sites, the National Research Council also found a disturbing pattern of elevated health problems, includ-ing heart disease, spontaneous abortions and genital malformations, and death rates; infants and children suffer a higher inci-dence of cardiac abnormalities, leukemia, kidney-urinary tract infections, seizures, learning disabilities, hyperactivity, skin dis-orders, reduced weight, central nervous sys-tem damage, and Hodgkins disease (6-8).

Scientists also believe that exposure to indus-trial chemicals contributed to the dramatic increases since the 1950s in cancer of the testis, prostate gland, kidney, breast, skin, and lung, as well as malignant myeloma, non-Hodgkins lymphoma, and numerous child-hood cancers (9-11)attributable to the death of half a million Americans each year.

In Massachusetts, elevated rates of leukemia (especially among children) have been linked to the industrial chemical trichloroethylene found in the town of Woburns drinking water, as well as tetrachloroethylene in drink-ing water on the Upper Cape (12-14).

Massachusetts now has one of the highest rates of breast cancer in the countrysome 4,400 women are diagnosed and 1,000 women die each year. Women living on Cape Cod are particularly vulnerable, with a 20%

higher rate of breast cancer than women liv-ing elsewhere in the state (15).

Many current policy initiatives may be intensifying problems they were designed to cure. Most environmental laws require busi-nesses to contain pollution sources for more proper treatment and disposal (in contrast to the previous practice of dumping on-site or into nearby commons). Once the pollution is trapped, the manufacturing industry pays the state or a private company for its treat-ment and disposal. The waste, now com-modified, becomes mobile, crossing local, state, and even national borders in search of ef"cient (i.e., low-cost and politically feasi-ble) areas for treatment, incineration, and/or disposal. More often than not, the waste sites and facilities are themselves hazardous and located in poor or working-class neighbor-hoods and communities of color (16-18). In this respect, an environmental issue affecting the general population has been addressed in a manner that displaces the problem in a new form onto more politically marginalized sec-tors of the population (19).

Hazardous waste sites nationwide are among the more concentrated environmen-tal hazards confronting low-income neigh-borhoods and communities of color.

According to a 1987 report by the United Church of Christs Commission on Racial Justice (20), three of every five African Americans and Latinos nationwide live in communities that have illegal or abandoned toxic dumps. Communities with one haz-ardous waste facility have twice the percent-age of people of color as those with none, and the percentage triples in communities with two or more waste sites. A subsequent follow-up study conducted in 1994 has now found the risks for people of color to be even greater than in 1987: they are 47% more likely than Whites to live near these poten-tially health-threatening facilities (21). In short, race and poverty are the two most crit-ical demographic factors for determining where commercial hazardous waste facilities are located in the United States (including hazardous waste generators of all sizes across Massachusetts) (22). Industry itself often blatantly states that the disempowered of American society should serve as the dump-ing ground for American business. A 1984 report by Cerrell Associates for the California Waste Management Board, for instance, openly recommended that pollut-ing industries and the state locate hazardous waste facilities in lower socio-economic neighborhoods because those communities had a much lower likelihood of offering political opposition (23).

Federal governmental enforcement actions also appear to be uneven regarding the class and racial composition of the impacted community. According to a 1992 nationwide study, Superfund toxic waste sites in communities of color are likely to be cleaned 12-42% later than are sites in White communities. Communities of color also witness average government penalties for violations of hazardous waste laws ($55,318) that are only one sixth the average penalty assessed in predominantly White communi-ties ($335,566). The study also concluded that the government takes an average of 20% longer to place toxic waste dumps in minority communities on the NPL, or Superfund, list for cleanup than it does in placing sites located in White areas (24).

Massachusetts currently has over 21,038 hazardous waste sites, including 3,389 more serious Tier I-II sites, according to March 2000 DEP data (25). As required under state law, hazardous waste sites must be ranked according to the severity of their risk to human health and the environment. The DEP has developed a tier classification sys-tem for determining the danger level of a hazardous waste site to the public health and Environmental Justice

• Unequal exposure to ecological hazards Environmental Health Perspectives

• VOLUME 110 l SUPPLEMENT 2 l April 2002 279 Table 5. Environmental hazard point system.

Points for rating severity of each Type of hazardous facility or site facility or site DEP hazardous waste site (general) 1 DEP hazardous waste site (Tier I-II) 5 U.S. EPA NPL (Superfund) waste site 25 Large power planttop "ve polluter 25 Small power plant 10 Proposed power plant 5

TURA industrial facility 5

Municipal incinerator 20 Resource recovery facility 10 Incinerator ash land"ll 5

Demolition land"ll 3

Illegal site 5

Sludge land"ll 5

Tire pile 5

Municipal solid waste land"ll 5

Trash transfer station 5

the environment. Sites can be classified as Tier IA, IB, IC, or II, with Tier IA sites requiring the most stringent oversight and Tier II the least. We used a numerical rank-ing sheet (NRS) to calculate the numerous ecological and public health factors that determine a sites classification. The NRS has "ve main sections (25):

1. The exposure pathways section evaluates the ways a person can be exposed to tox-ics, speci"cally the soil, groundwater, sur-face water, and air.

2. The disposal site characteristics section evaluates the toxicity of the released mate-rial(s).

3. The human population and land uses sec-tion evaluates the potential risks based on nearby population and land and water uses.

4. The ecological population section evaluates the potential risks posed to the environ-ment based on the sites proximity to sensitive areas such as wetlands and endangered species.

5. The mitigating disposal site speci"c condi-tions section takes into account conditions at the site not otherwise factored into the NRS.

DEP ranks a large number of the most serious Tier IA sites in suburban areas rather than in urban areas such as Boston, citing drinking water issues as one of the primary reasons. The presence of a hazardous waste site in a larger urban area where the drinking water is transported from a distant reservoir may not pose the same threat as it would in a suburban/rural community dependent on local groundwater sources.

As indicated in Table 6, a signi"cant con-centration of both Tier I-II and nontier sites appear to be concentrated in lower-income communities in Massachusetts. Communities where median household income is less than

$30,000 contain an average of 120.9 DEP hazardous waste sites, whereas communities where the median household income is

$30,000 or greater contain an average of 41.9-50.2 hazardous waste sites. As a result, low-income communities average roughly 2-3 times more DEP hazardous waste sites than higher-income communities.

However, if lower-income communities are typically larger in size, one would expect them to have a higher number of such sites.

To control for the size of the community, we calculated the number of sites per square mile to obtain a more accurate exposure rate. This revealed an even more pronounced class bias.

Low-income communities, where median household income is less than $30,000, aver-age nearly 14 DEP hazardous waste sites per square mile. In contrast, higher-income com-munities, where median household income is

$30,000 or more, average 3.1-4.1 hazardous waste sites per square mile. Thus, low-income communities have approximately 3.5-4 more hazardous waste sites per square mile than higher-income communities. These figures remain relatively consistent with comparisons of the more serious Tier I-II hazardous waste sites. In short, low-income communities in Massachusetts experience a far higher expo-sure rate to DEP hazardous waste sites than higher-income communities.

These disparities repeat for communities of color. In Massachusetts, communities where people of color compose less than 5%

of the population average 41.2 DEP haz-ardous waste sites, whereas communities where people of color compose 25% or more of the population average 162.5 sites.

Communities considered moderately high minority (where people of color compose 15-24.99% of the population) average nearly 190 sites. As a result, higher-minority com-munities, where people of color compose 15% or more of the population, average well over 4 times as many DEP hazardous waste sites as low-minority communities.

To control for the size of the community, we calculated the number of sites per square mile to obtain a more accurate exposure rate.

This revealed an even more pronounced racial bias. High-minority communities aver-age 27.2 DEP hazardous waste sites per square mile, whereas low-minority commu-nities average 2.9 hazardous waste sites per square mile. Thus, high-minority communi-ties have 9 times more hazardous waste sites per square mile than low-minority communi-ties. These figures remain consistent with comparisons of the more serious Tier I-II hazardous waste sites. In short, communities of color experience a far higher exposure rate to DEP hazardous waste sites than predomi-nantly White communities, indicating that race is strongly associated with the location of tier and nontier hazardous waste sites in Massachusetts (Table 7).

Only in the case of U.S. EPA Superfund sites do the class and racial biases associated with DEP hazardous waste sites disappear.

This trend could be accounted for by the high number of Superfund sites on military facilities often located in rural and suburban locales near more af"uent communities, par-ticularly on Cape Cod. At least 47 Tier IA sites are in Bourne because of contamination from the Massachusetts Military Reservation (Figure 1).

Environmental Justice

• Faber and Krieg 280 VOLUME 110 l SUPPLEMENT 2 l April 2002

• Environmental Health Perspectives Table 6. Class-based disparities in the location of hazardous waste sites.

DEP tier I-II Towns with Average number Average number Number DEP hazardous hazadous U.S. EPA of DEP hazardous of DEP hazardous Median household income of towns (%

waste sites waste sites Superfund sites waste sites waste sites (1990 U.S. Census category) of all towns)

Count

(%)

Mean Count

(%)

Mean Count

(%)

Mean per town per square mile

$0 to $29,999 (low) 50 (13.6) 6,044 (28.7) 120.9 987 (29.1) 19.7 5

(10.4) 0.10 120.9 13.9

$30,000 to $39,999 (medium-low) 137 (37.2) 6,863 (32.6) 50.1 1,101 (32.5) 8.0 14 (29.2) 0.10 50.1 4.1

$40,000 to $49,999 (medium-high) 114 (31.0) 4,771 (22.7) 41.9 742 (21.9) 6.5 17 (35.4) 0.15 41.9 3.1

$50,000 or more (high) 67 (18.2) 3,360 (16.0) 50.2 559 (16.5) 8.3 12 (25.0) 0.18 50.2 3.2 Totals 368 (100) 21,038 (100) 3,389 (100) 48 (100) 63.3 5.0 Information on all hazardous waste sites was provided by DEP and U.S. EPA databases in March 2000. All DEP waste site information provided above includes U.S. EPA Superfund sites as part of the count.

Table 7. Racially-based disparities in the location of hazardous waste sites.

DEP tier I-II Towns with Average number Average number Number DEP hazardous hazadous U.S. EPA of DEP hazardous of DEP hazardous Non-White population of towns (%

waste sites waste sites Superfund sites waste sites waste sites (1990 U.S. Census category) of all towns)

Count

(%)

Mean Count

(%)

Mean Count

(%)

Mean per town per square mile 5-14.99% (low-moderate) 49 (13.3) 5,219 (24.8) 106.5 849 (25.1) 17.3 16 (33.3) 0.33 106.5 9.0 15-24.99% (moderate-high) 9 (2.4) 1,708 (8.1) 189.8 257 (7.6) 28.6 3

(6.3) 0.33 189.8 23.4 25% or more (high) 11 (3.0) 1,787 (8.5) 162.5 314 (9.3) 28.6 0

(0.0) 0.00 162.5 27.2 Totals 368 (100) 21,038 (100) 3,389 (100) 48 (100) 63.0 Information on all hazardous waste sites was provided by DEP and U.S. EPA databases in March 2000. All DEP waste site information provided above includes U.S. EPA Superfund sites as part of the count.

Unequal Exposure to Land"lls and Transfer Stations Land"lls can also pose hazards to communi-ties. Seven former Massachusetts land"lls are now federal Superfund sites. Even newer land-

"lls, which are lined with plastic, can threaten underground water supplies. Tables 8 and 9 provide data on seven different types of land-

"lls and related facilities: incinerator ash land-

"lls, demolition land"lls, illegal sites, sludge land"lls, tire piles, municipal solid waste land-

"lls (garbage dumps), and trash transfer sta-tions. Of these sites, incinerator ash land"lls are typically most hazardous, because "y ash wastes produced by incinerators and power plants contain concentrated levels of heavy metals such as arsenic, lead, and cadmium; radioactive elements; cancer-causing organic compounds; and other contaminants.

Massachusetts has a total of 954 different landfill types, of which the majority (566) are garbage dumps. As outlined in the Tables 8 and 9, the states land"lls and trash transfer stations are concentrated in lower-income communities and communities of color. In communities where the median household income is less than $30,000, there are 0.18 of these landfill-types per square mile, a "gure slightly higher than the 0.13-0.15 rates for higher-income commu-nities. Municipal solid waste landfills make up 57.5% of all land"ll types and are found in 91.3% of all communities, making them relatively constant across all communities.

When municipal solid waste landfills are removed from the analysis, it is clear that lower-income communities (<$40,000 aver-age income) have a much greater proportion of every other type of landfill than higher-income communities ($40,000 or above).

For instance, whereas lower-income commu-nities make up 50.8% of all towns in the state, they are home to 58.9% of all inciner-ator ash landfills, 66.7% of all demolition land"lls, 71.4% of all illegal sites, 74.5% of all sludge landfills, 69.5% of all tire piles, and 58.9% of all transfer stations.

Racially based biases to the distribution of landfill types are prominent. Analyzing all land"ll types, communities where people of color compose less than 5% of the population average 0.13 of all landfill types per square mile, whereas communities where people of color compose 25% or more of the population average 0.36 land"ll types per square mile, a rate nearly 3 times higher. These data clearly reveal race biases and class biases to the loca-tion of all land"ll types, with the exception of municipal solid waste land"lls.

Unequal Exposure to Polluting Industrial Facilities American industry produces enormous quantities of pollution and toxic waste each year. According to the U.S. EPA Toxic Release Inventory (TRI) for 1998, some 23,000 facilities reported a total of 7.3 bil-lion pounds of chemical pollutants released into the nations air, water, land, and under-ground areas. The vast majority of these pollutants93.9% (or 6.9 billion pounds) were released into the environment directly on-site (26). Thus, citizens who work and reside in the communities in Environmental Justice

• Unequal exposure to ecological hazards Environmental Health Perspectives

• VOLUME 110 l SUPPLEMENT 2 l April 2002 281 Figure 1. Unequal exposure to hazardous waste sites, compared with an average of 4.94 sites per square mile for all 368 Massachusetts communities in 2000. (A) Exposure to hazardous waste sites by race. (B)

Exposure to hazardous waste sites by class.

30 20 10 0

Less than 5%

5 to 14.99%

15 to 24.99%

25% or more Mean number of sites per square mile Percentage of population that is non-White A

3 9

23 27 16 14 12 10 8

6 4

2 0

$0 to

$29,999

$30,000 to

$39,999

$50,000 or more

$40,000 to

$49,999 Mean number of sites per square mile Median household income B

14 4

3 3

Table 8. Class-based disparities in the location of all land"ll types.

Number Incinerator Municipal Average Average Median household of towns ash Demolition Illegal Sludge Tire solid waste Transfer number of all number of income (1990 U.S.

(% of all land"lls land"lls sites land"lls piles land"lls stations land"ll types all land"ll types Census category) towns)

Count (%)

Count (%)

Count (%)

Count (%)

Count (%)

Count (%)

Count (%)

per town per square mile

$0 to $29,999 (low) 50 (13.6) 2 (11.8) 8 (20.5) 7 (33.3) 12 (20.3) 5 (21.7) 69 (12.2) 33 (14.4) 2.9 0.18

$30,000 to $39,999 137 (37.2) 8 (47.1) 18 (46.2) 8 (38.1) 32 (54.2) 11 (47.8) 203 (35.9) 102 (44.5) 2.8 0.13 (med.-low)

$40,000 to $49,999 114 (31.0) 7 (41.2) 9 (23.1) 5 (23.8) 12 (20.3) 5 (21.7) 185 (32.7) 62 (27.1) 2.5 0.15 (med.-high)

$50,000 or more 67 (18.2) 0 (0.0) 4 (10.3) 1 (4.1) 3 (5.1) 2 (8.7) 109 (19.3) 32 (14.0) 2.3 0.14 (high)

Totals 368 (100) 17 (100) 39 (100) 21 (100) 59 (100) 23 (100) 566 (100) 229 (100) 2.6 0.15 Information on all land"lls was provided by DEP databases in April 2000.

Table 9. Racially based disparities in the location of all land"ll types.

Number Incinerator Municipal Average Average Non-White pop-of towns ash Demolition Illegal Sludge Tire solid waste Transfer number of all number of ulation (1990 U.S.

(% of all land"lls land"lls sites land"lls piles land"lls stations land"ll types all land"ll types Census category) towns)

Count (%)

Count (%)

Count (%)

Count (%)

Count (%)

Count (%)

Count (%)

per town per square mile Less than 5% (low) 299 (81.3) 11 (64.7) 30 (76.9) 14 (66.7) 50 (84.7) 21 (91.3) 445 (78.6) 180 (78.6) 2.5 0.13 5-14.99%

49 (13.3) 5 (29.4) 4 (10.3) 3 (14.3) 5 (8.5) 2 (8.7) 92 (16.3) 35 (15.3) 3.0 0.16 (low-moderate) 15-24.99%

9 (2.4) 0 (0.0) 3 (7.7) 0 (0.0) 4 (6.8) 0 (0.0) 17 (3.0) 8 (3.5) 3.6 0.30 (moderate-high) 25% or more (high) 11 (3.0) 1 (5.9) 2 (5.1) 4 (19.0) 0 (0.0) 0 (0.0) 12 (2.1) 6 (2.6) 3.1 0.36 Totals 368 (100) 17 (100) 39 (100) 21 (100) 59 (100) 23 (100) 566 (100) 229 (100) 2.6 0.15 Information on all land"lls was provided by DEP databases in April 2000.

which these facilities are located typically experience much greater exposure rates to industrial pollutants (27).

Exposure to industrial pollutionespe-cially air pollutionis proving deadly to tens of thousands of citizens. Human exposure to hazardous air pollutants (HAPs) can result in both acute and chronic health effects. Short-term, acute effects can include eye irritation, nausea, dif"culty breathing, asthma, or even death. Long-term, chronic effects include damage to the respiratory or nervous systems, birth defects and damage to reproductive sys-tems, neurological disorders, and cancer.

Aggravated by the exhaust from over 200 mil-lion motor vehicles (particularly in larger met-ropolitan areas), industrial air pollution kills over 60,000 Americans each year. Half a mil-lion people living in the most polluted areas in 151 cities across the country face a risk of death that is 15-17% higher than that for those living in the least polluted areas (28).

In Massachusetts, poor air quality poses a serious threat to public health. According to data provided by the U.S. EPA Cumulative Exposure Project (CEP), every county in Massachusetts has levels of key airborne toxic chemicals in the form of volatile organic com-pounds that exceed health-based state levels.

At least 16 toxic compounds exceed the acceptable levels of concentration set by both federal regulatory agencies and the Allowable Ambient Limits, a health-based risk standard of the DEP (29,30). For instance, concentra-tions of benzene, 1,3-butadiene, formalde-hyde, and acroleinchemicals that are known to cause numerous adverse health effects, including neurological disorders, birth defects, reproductive disorders, and respira-tory diseasesexceed Massachusetts allowable ambient limits in all counties by up to 80 times. Nearly 1,300 deaths are caused by par-ticulate air pollution in Massachusetts statisti-cal metropolitan areas each year (31).

In recent years, a number of studies have been conducted on the unequal exposure to air pollution and other environmental haz-ards. The "ndings of these studies point to a consistent pattern of environmental racism and class-based ecological injustices (32).

Within Americas urban areas, for instance, lower-income people (particularly those liv-ing below the poverty level) are found to be more exposed to combined concentrations of air pollutants than higher-income popula-tions. Similarly, people of color are consis-tently exposed to significantly more air pollution nationwide than are Whites, with a gap that is wider and more consistent than that for income bias (33,34). According to the U.S. EPA, 57% of all Whites nationwide live in areas with poor air quality, compared to 80% of all Latinos (35). In Los Angeles, 71% of the citys African Americans and 50% of the Latinos are estimated to live in what are categorized as the most polluted areas, compared to only 34% of Whites (36). Unequal exposure to air pollutants for lower-income families and people of color is further aggravated by substandard housing, inadequate healthcare, a lack of public parks and safe spaces, and a lack of social services.

In a previous study, Maxwell (37,38) explored whether polluting industrial land uses were differentially distributed regarding the racial (percentage of minority population) and class (median family income and percent-age living in poverty) compositions of 351 cities and towns in Massachusetts. Maxwell also examined whether higher intensities of polluting land uses were associated with increased incidence of certain cancers. The study used demographic and land use data from three time points spanning the 35-year period from 1950 to 1985, as well as historical data on industry. The study sought to answer two questions: a) Are there inequities in the social distribution of polluting land uses across Massachusetts communities? b) Are higher intensities of polluting land uses associated with increased cancer in Massachusetts com-munities? This study found that traditional manufacturing industries (associated with the old economy) inequitably burdened lower-income, higher-poverty, and higher-minority communities. The results of the regression analyses of land use and cancer also suggested that higher intensities of total manufacturing and industrial/commercial land uses were asso-ciated with a higher incidence of lung cancer (and probably also bladder cancer and non-Hodgkins lymphoma) (39).

A 1993 study of Essex, Hampden, Middlesex, Norfolk, Suffolk, and Worcester counties in Massachusetts between 1987 and 1992 with data collected by the U.S. EPA under the federal Resource Conservation and Recovery Act (RCRA) (40) found that the vast majority of people of color are concentrated in the counties where 82.7% of the states large quantity generators (LQG) of toxic materials and all commercial hazardous waste treatment, storage, and disposal (TSD) facilities are located. However, a closer analysis of Suffolk County found that 13.2% of LQG/TSD facil-ities were located in the mostly minority com-munities (census block groups) and that 26.4% of the facilities were located in the mostly White communities. Thus, it did not appear that in Suffolk County LQG and TSD facilities were concentrated in minority com-munities. Likewise, the study also found that 34% of these facilities were located in the poorest communities (measured by quartiling block groups)with a median income of

$21,615 or lesswhereas 22.6% of facilities were found in the wealthiest communities with a median income of $37,452 or more.

Here we summarize information from the states Large Quantity Toxics Users who reported to the Massachusetts Toxics Use Reduction Act (TURA) program from 1990 to 1998 (1998 is the most recent year that TURA data are available) (41). TURA began in 1989 with the goal of reducing toxic waste generation by 50% by 1997. The program includes a database of toxic waste use similar to that of the federal TRI but with more detailed information. As required under TURA, a company must report the quantity and types of toxic chemicals it uses if it annu-ally manufactures, processes, or uses 10,000 pounds of toxic chemicals or more. These toxic chemicals pose a threat to nearby resi-dents, workers, and the environment from potential accidents, emissions on-site into the immediate environment, worker handling, waste disposal, toxins in the product, and product disposal.

Between 1990 and 1998, 1,029 distinct TURA facilitiesranging from a high of 727 "rms in 1991 to a low of 520 in 1998used over 9.886 billion pounds of toxic chemicals in production (values do not include quanti-ties for chemicals considered trade secrets).

During this same time, these large industrial facilities produced 370,163,204 pounds of chemical waste byproduct that they reported as transferred off-site for recycling, recovery, treatment, and/or disposal. Another 164,385,598 pounds of toxic chemical waste byproduct they released on-site directly into the environment (discharged into the air, ground, underground areas, or adjacent bod-ies of water) of the communities in which they were locatedan amount equivalent to 2,055 tractor-trailer trucks each loaded with 80,000 pounds of toxic waste (42,43). The electric, gas, and sanitary services sector is the largest source of on-site releases to the envi-ronment under TURA. In 1998, the 28 "rms in this sector accounted for 39% of all on-site releases, 71% of which were hydrochloric acid. The chemical and allied products sector, which represents a little over half of total statewide use, accounted for 13% of total on-site releases and 31% of off-site transfers.

As shown in Table 10, communities with a median household income of less than

$30,000 or between $30,000 to $39,999 compose 50.8% of all communities in Massachusetts but are home to 66.2% of all TURA facilities and 85.6% of all chemicals used by TURA facilities between 1990 and 1998. More important, communities with these median household incomes received 78.7% of all chemical emissions into the local environment by TURA facilities during this time. Although communities with median household incomes of $40,000 or more represent nearly half of all communities in the state (49.2%), they house only 33.8%

Environmental Justice

• Faber and Krieg 282 VOLUME 110 l SUPPLEMENT 2 l April 2002

• Environmental Health Perspectives

of all TURA facilities, 21.3% of all chemical emissions, and 14.4% of all chemicals used by TURA facilities from 1990 to 1998.

In fact, as shown in Table 11, communi-ties with a median household income of less than $30,000 average 6.3 TURA facilities per town, 932,910 total pounds of chemical emis-sions released into the environment per town, and 73,061 total pounds of chemical emis-sions per square mile of town space for 1990-1998. This contrasts sharply with com-munities with median household incomes of 40,000-$49,999, which average 1.8 TURA facilities per town, 161,028 total pounds of chemical emissions per town, and 10,937 pounds of chemical emissions per square mile of town space. In comparison with upper-income communities (median household income $40,000 or more), low-income com-munities average over three times as many TURA industrial facilities, three times as many TURA industrial facilities per square mile, 3.75-5.79 times as many pounds of chemical emissions into the environment per town, and roughly seven times as many pounds of chemical emissions per square mile.

Thus, the data indicate that the class status of a community is a signi"cant predictor of the level of exposure to TURA industrial facilities and emissions. The data indicate that lower-income communities bear a greatly dispropor-tionate burden of the pollution emitted by these types of industrial facilities.

The data also show that communities of color are overburdened. Although communi-ties where people of color compose less than 15% of the population account for 86.2% of all chemical emissions and 84.1% of all TURA facilities, they also account for 94.6%

of all communities in the state. Although communities where people of color compose 15% or more of the population receive only 13.8% of all TURA emissions and house 15.9% of all TURA facilities, they compose only 5.4% of towns in the state (Table 12).

Table 13 shows that communities where peo-ple of color compose 25% or more of the population average 8.8 TURA facilities and 1.1 TURA facilities per square mile, com-pared to an average of just 2 facilities and 0.12 facilities per square mile for communi-ties where people of color compose less than 5% of the population. In short, high-minority communities average over 4 times as many TURA industrial facilities and over 9 times as many TURA industrial facilities per square mile as do low-minority communities in Massachusetts. Furthermore, higher-minority communities (where 15% or more of the population are people of color) average 1,061,041-1,216,360 total pounds of chemi-cal emissions from TURA industrial facilities and 110,718-123,770 pounds of chemical emissions from TURA facilities per square mile for 1990-1998, compared to just 342,579 pounds of total chemical emissions Environmental Justice

• Unequal exposure to ecological hazards Environmental Health Perspectives

• VOLUME 110 l SUPPLEMENT 2 l April 2002 283 Table 13. Racially based disparities in the exposure rate to TURA industrial facilities (1990-1998).

Average number Average number Average total TURA Average total TURA Non-White population Number of town of TURA facilities of TURA facilities chemical emissions chemical emissions (1990 U.S. Census category)

(% of all towns) per town per square mile (lb) per town (lb) per square mile Less than 5% (low) 299 (81.3) 2.0 0.12 343,579 22,735 5-14.99% (low-moderate) 49 (13.3) 5.4 0.40 796,689 86,014 15-24.99% (moderate-high) 9 (2.4) 7.4 0.75 1,216,369 123,770 25% or more (high) 11 (3.0) 8.8 1.1 1,061,041 110,718 Table 10. Class-based disparities in the location and emission levels of TURA industrial facilities (1990-1998).

Median household Number of TURA total chemical TURA total chemical TURA total Number of distinct income (1990 U.S.

towns (% of emissions (lb) transfers (lb) chemical use (lb)

TURA facilities Census category) all towns)

Count

(%)

Mean Count

(%)

Mean Count

(%)

Mean Count (%) Mean

$0 to $29,999 (low) 50 (13.6) 46,645,477 (28.4) 932,910 101,318,279 (27.4) 2,026,366 4,476,070,293 (45.3) 89,521,406 317 (30.8) 6.3

$30,000 to $39,999 137 (37.2) 82,734,924 (50.3) 603,905 188,923,288 (51.0) 1,379,002 3,981,354,062 (40.3) 29,060,979 364 (35.4) 2.7 (med-low)

$40,000 to $49,999 114 (31.0) 18,357,199 (11.2) 161,028 53,110,764 (14.3) 465,884 734,856,631 (7.4) 6,446,111 201 (19.5) 1.8 (med-high)

$50,000 or more (high) 67 (18.2) 16,647,998 (10.1) 248,478 26,810,873 (7.2) 400,162 693,992,469 (7.0) 10,358,097 147 (14.3) 2.2 Totals 368 (100) 164,385,598 (100) 370,163,204 (100) 9,886,273,455 (100) 1,029 (100)

Table 11. Class-based disparities in the exposure rate to TURA industrial facilities (1990-1998).

Average number Average number of Average total TURA Average total TURA Median household income Number of towns of TURA facilities TURA facilities chemical emissions chemical emissions (lb)

(1990 U.S. Census category)

(% of all towns) per town per square mile (lb) per town per square mile

$0 to $29,999 (low) 50 (13.6) 6.3 0.49 932,910 73,061

$30,000 to $39,999 (med-low) 137 (37.2) 2.7 0.21 603,905 55,524

$40,000 to $49,999 (med-high) 114 (31.0) 1.8 0.13 161,028 10,937

$50,000 or more (high) 67 (18.2) 2.2 0.12 248,478 12,502 Table 12. Racially based disparities in the location and emission levels of TURA industrial facilities (1990-1998).

Non-White pop-Number of TURA total chemical TURA total chemical TURA total Number of distinct ulation (1990 U.S.

towns (% of emissions (lb) transfers (lb) chemical use (lb)

TURA facilities Census category) all towns)

Count

(%)

Mean Count

(%)

Mean Count

(%)

Mean Count

(%) Mean Less than 5% (low) 299 (81.3) 102,730,053 (62.5) 343,579 219,844,801 (59.4) 735,267 5,051,993,299 (51.1) 16,896,299 601 (58.4) 2.0 5-14.99%

49 (13.3) 39,036,778 (23.7) 796,669 114,887,155 (31.0) 2,344,636 1,885,264,731 (19.1) 38,474,790 264 (25.7) 5.4 (low-moderate) 15 to 24.99%

9 (2.4) 10,947,318 (6.7) 1,216,369 14,415,034 (3.9) 1,601,670 182,564,805 (1.8) 20,284,978 67 (6.5) 7.4 (moderate-high) 25% or more (high) 11 (3.0) 11,671,449 (7.1) 1,061,041 21,016,214 (5.7) 1,910,565 2,766,450,620 (28.0) 251,495,511 97 (9.4) 8.8 Totals 368 (100) 164,385,598 (100) 370,163,204 (100) 9,886,273,455 (100) 1,029 (100)

and 22,735 pounds of chemical emissions per square mile for low-minority communities.

Thus, in comparison with low-minority communities, high-minority communities average roughly 3-3.5 times as many pounds of chemical emissions into the environment from local TURA facilities and 4.86-5.44 times as many pounds of chemical emissions per square mile. Thus, the racial status of a community once again appears to be a major factor in the level of exposure to TURA indus-trial facilities and pollution. The data indicate that communities of color bear a greatly dis-proportionate burden of the pollution emitted by these types of facilities (Figure 2).

Unequal Exposure to Power Plants The electric power industry is one of the most polluting industries in New England and the entire country. In 1998, electric utilities gen-erated 1.1 billion pounds of toxic chemical emissions nationwide, according to U.S.

EPA-TRI data. In fact, electric utilities emis-sions of sulfuric acid and hydrochloric acid pushed them near the top of the toxic inven-tory in many states (44). Power plants are also major contributors to the formation of smog.

Smog, also called ground-level ozone, is formed when nitrogen oxides, emitted as a byproduct of burning fossil fuels at electric power plants and in automobiles, mix with volatile organic compounds in the presence of sunlight. Smog is a major trigger of asthma, increased lung in"ammation, coughing, and emergency hospitalization due to respiratory distress. The unhealthiest levels of smog are generally recorded during the summer (45).

Power plants are also major contributors of gases that cause global warming and toxic mercury emissions that seriously threaten public health and environmental quality.

In Massachusetts, nearly 1,300 residents of statistical metropolitan areas die each year from particulate air pollution (46). Air qual-ity continues to deteriorate. During the summer of 1999, Massachusetts recorded 21 unhealthy air days, where the ozone level of those days surpassed the allowable limit set by the U.S. EPA. The people currently most vulnerable to the effects of breathing smoggy air are children, the elderly, and people with asthma or other respiratory diseases (47).

Despite ongoing attempts to control smog and soot-forming pollutants, the risk of developing cancer or reproductive, develop-mental, or neurological disorders due to chemical exposures in the air necessitates fur-ther efforts in controlling air pollutants.

Coal and oil-burning power plants, speci"cally those plants built prior to 1977, are a major source of air pollution in the state. In fact, utilities in Massachusetts are responsible for over 60% of the states soot-forming sulfur dioxide emissions, 15% of the states smog-causing nitrogen oxide emissions, and 30% of the states heat-trap-ping carbon dioxide emissions. Sulfur diox-ide emissions are the main precursor to the creation of soottiny particles that pene-trate deep into the throat and lungs. Fossil-fuel power plants are also responsible for more than 800 pounds of airborne mercury emissions every year. Mercury causes severe damage the neurological system and has developmental effects on fetuses and small children (48). Mercury is so toxic that a mere one third of a teaspoon is enough to render the fish of a 25-acre lake unsuitable for children and pregnant women to eat. As a result of a loophole in clean air laws, 14 plants in New England are legally polluting at much higher levels than newer plants built since 1977. The oldest fossil-fuel power plantsthose built before 1977are not required to meet the same emissions stan-dards as newer, cleaner plants (49).

As indicated in Table 14, the states power plants are disproportionately located in communities of color and lower-income communities. Although just 5.4% of all communities in the state are communities where people of color compose 15% or more of the population, they are home to 18.2%

of all active power plants and 23.4% of all proposed power plants in the state. Likewise, although 50.8% of all towns in the state are communities where median household income is less than $40,000, they are home to 65.6% of all active power plants and 63%

of all proposed power plants.

Five of the dirtiest power plants in the statethe Canal, Brayton Point, Salem Harbor, Mount Tom, and Mystic plants are legally emitting at 2.9-4.0 times the emission rate of plants built after 1977. The "ve plants are responsible for 89% of sulfur dioxide emissions and 57% of nitrous oxide emissions from all stationary sources in Massachusetts (the Brayton Point plant is the largest, most polluting power plant in all of New England). In fact, these "ve plants are responsible for more than 50% of the power plant pollution in all of New England, pro-ducing more than 24 million tons of heat-trapping carbon dioxide emissions in 1998.

And pollution rates from these power plants have been increasing substantially since 1996 (50,51). As a result, these "ve power plants are the largest industrial sources of green-house gasses in the state (52).

As shown in Table 15, four of the five plants are located in low-income or moder-ately low-income communities. Clearly, lower-income communities are disproportion-ately burdened by the most polluting power plants. In terms of racial bias, only the Mount Tom power plant is located in a high-minority Environmental Justice

• Faber and Krieg 284 VOLUME 110 l SUPPLEMENT 2 l April 2002

• Environmental Health Perspectives Figure 2. Unequal exposure to industrial pollution, compared with an average of 36,262 pounds of chemical emissions per square mile during 1990-1998 for all 368 Massachusetts communi-ties. (A) Exposure to chemical emissions by race.

(B) Exposure to chemical emissions by class.

140,000 120,000 100,000 80,000 60,000 40,000 20,000 0

80,000 60,000 40,000 20,000 0

$0 to

$29,999

$30,000 to

$39,999

$50,000 or more

$40,000 to

$49,999 Less than 5%

5 to 14.99%

15 to 24.99%

25% or more Mean emissions (lb) per square mile Mean emissions (lb) per square mile Median household income Percentage of population that is non-White A

B 22,735 86,014 123,770 110,718 73,061 55,524 10,937 12,502 Table 14. Racial and class-based disparities in the location of power plants.

Number of DEP Number of DEP Number of active power proposed power towns (% of plants (June 2000) plants (June 2000) 1990 U.S. Census category all towns)

Count (%)

Count (%)

Non-White population Less than 5% (low) 299 (81.3) 38 (69.1) 10 (58.8) 5-14.99% (low-moderate) 49 (13.3) 7 (12.7) 3 (17.6) 15-24.99% (moderate-high) 9 (2.4) 7 (12.7) 3 (17.6) 25% or more (high) 11 (3.0) 3 (5.5) 1 (5.9)

Totals 368 (100) 55 (100) 17 (100)

Median household income

$0 to $29,999 (low) 50 (13.6) 14 (25.5) 2 (11.8)

$30,000 to $39,999 (medium-low) 137 (37.2) 22 (40.0) 7 (41.2)

$40,000 to $49,999 (medium-high) 114 (31.0) 16 (29.1) 7 (41.2)

$50,000 and greater (high) 67 (18.2) 3 (5.5) 1 (5.9)

Totals 368 (100) 55 (100) 17 (100)

community (Holyoke); the remaining four power plants are located in low-minority or moderately low-minority communities.

According to a 2000 report by the Harvard School of Public Health (53), cur-rent emissions from the 805 megawatt Salem Harbor (Salem) and 1,611 megawatt Brayton Point (Somerset) coal-fired power plants alone can be linked to 43,300 asthma attacks and nearly 300,000 daily incidents of upper respiratory symptoms per year among the 32 million people residing in New England, eastern New York, and New Jersey. An addi-tional 159 premature deaths can be attrib-uted to this pollution each year. However, the health risks are greatest for those living in communities adjacent to these plants.

Twenty percent of the total health impact occurs in the 8% of the population that lives within 30 miles of the facilities. The four worst of these polluting power plants are all located in communities where the median household income is less than $40,000.

Thus, working-class communities once again appear to be unequally exposed to environ-mental hazards in Massachusetts.

Unequal Exposure to Incinerators Municipal solid waste combustors are facili-ties that combust solid waste derived in large part from household wastes. In 1999-2000, Massachusetts had nine municipal solid waste combustors in operation, which burned approximately 3.3 million tons of trash each year. These incinerators contribute to massive water and air pollution and related public health problems. For instance, garbage incin-erators emit more mercury than any other source in the state (54). Mercury, which is especially toxic to children and pregnant women, has been linked to kidney and ner-vous system damage and developmental defects. The U.S. EPA has identified these facilities as being a major source of mercury emissions to the environment, and DEP esti-mates that these facilities emit approximately 6,040 pounds of mercury into the air each year. DEP testing of in-stack concentrations for mercury emissions from these facilities in 1994 detected averages twice the new U.S.

EPA limits (55). In addition to air emissions, mercury may also exit these facilities in the form of ash, especially fly ash. As much as another 6,000 pounds of mercury is captured by the air pollution control devices installed at these facilities.

As shown in Table 16, six of these nine incinerators are located in communities where median household income is less than

$40,000. Only one of the nine incinerators is located in a community where the average median household income is $50,000 or more. Lower-income communities (less than

$40,000) have twice the number of incinera-tors as do higher-income communities

($40,000 or more). Although class consider-ations seem to be of some importance in the siting of these facilities, only one of the nine incinerators is located in a community where people of color compose 15% or more of the population. In fact, this is one of the few types of environmentally hazardous facilities in Massachusetts for which there does not appear to be a racial bias.

Unequal Community Exposure to Cumulative Environmental Hazards Many past studies on the disproportionate exposure of low-income communities and communities of color have focused on single indicators of environmental hazards. This study provides a composite measure to assess community exposure rates that includes all hazardous facilities and sites. We have devel-oped a point system that weighs the average risks of each type of hazardous facility/site to arrive at a cumulative measure of commu-nity exposure to all potential hazards, shown in Table 17.

We recognize the potential threats to the validity of such a point system. One threat lies in variations in the severity of similar hazard types. For example, we assigned each Superfund site 25 points, yet the risks posed by these sites are likely to vary depending on types of materials they contain, environmen-tal medium through which exposure occurs, size and proximity of nearby populations, and so forth. Second, the relative weights we assigned to different types of hazards may be problematic. For example, one Superfund site may not be equivalent to 25 DEP sites. To assess how well our point system represents current opionion in the "eld, we distributed the point system to a number of authorities including scholars and professionals at the Massachusetts DEP, who responded that the point system seemed valid to them.

To determine the cumulative exposure to environmentally hazardous facilities and sites, Environmental Justice

• Unequal exposure to ecological hazards Environmental Health Perspectives

• VOLUME 110 l SUPPLEMENT 2 l April 2002 285 Table 15. Unequal exposure to the top "ve power plant (fossil fuel) polluters in Massachusetts.

Income status Racial status SO2 rate in Jan-June Power plant Town of town of town 1999 (lb/mmBTU)

Salem Harbor Salem Medium-low Moderately low minority 1.20 Mount Tom Holyoke Low High minority 1.20 Brayton Point Somerset Medium-low Low minority 1.10 Mystic Charlestown Medium-low Moderately low minority 1.03 Canal Sandwich Medium-high Low minority 0.87 Table 16. Unequal exposure to municipal solid waste combustors (MSWCs).

Mercury in-stack Average annual Income status Racial status U.S. EPA limit 80 amount of mercury Town of town of town

(µg) (dscm) emitted (tons/year)

N. Andover High Low minority 297.0 1.11 Lawrence Low High minority 276.0 0.41 Millbury Medium low Low minority 183.0 0.52 Haverhill Medium low Moderate-163.0 0.35 low minority Agawam Medium low Low-minority 153.1 0.08 Pitts"eld Low Low minority 61.4 0.01 Rochester Medium high Low minority 61.0 0.11 Fall River Low income Low minority 25.6 N/A Saugus Medium high Low minority 17.0 0.4 Total 6 of 9 towns 1 of 9 towns is 160.0 3.02 (6,040 lb) are lower income higher minority dscm, dry standard cubic meter. Some 117 medical waste incinerators are also listed in the DEP Division of Air Quality Control Stationary Source Enforcement Inventory System (56).

Table 17. Unequal exposure to all types of hazardous facilities/sites combined.

Number of towns Average number of 1990 U.S. Census category

(% of all towns) points per square mile Non-White population Less than 5% (low) 299 (81.3) 6.4 5-14.99% (low-moderate) 49 (13.3) 18.7 15-24.99% (moderate-high) 9 (2.4) 42.7 25% or more (high) 11 (3.0) 57.0 Totals 368 (100)

Median household income

$0 to $29,999 (low) 50 (13.6) 27.9

$30,000 to $39,999 (medium-low) 137 (37.2) 8.9

$40,000 to $49,999 (medium-high) 114 (31.0) 7.0

$50,000 or more (high) 67 (18.2) 6.9 Totals 368 (100)

we totaled the points for each hazardous facil-ity and site in each community. Because geo-graphically larger communities could have more facilities and sites, we controlled for the geographic size of each community by calcu-lating the average number of hazard points per square mile, a more valid measure of exposure rate. We found gross imbalances in average point totals for lower-income com-munities and communities of color based on points per square mile. As shown in Table 17, communities where people of color compose less than 5% of the population average only 6.4 points per square mile, compared to 57 points per square mile for communities where people of color compose 25% of the popula-tion or more. In other words, high-minority communities face a cumulative exposure rate to environmentally hazardous facilities and sites that is nearly nine times greater than that for low-minority communities. In fact, there is a consistently sharp increase in the cumula-tive exposure rates to these hazardous facili-ties/sites that directly corresponds to increases in the size of the minority population in all communities. Without question, communi-ties of color appear to be greatly overbur-dened in comparison with low-minority communities and are unequally exposed to environmental hazards of almost every kind.

Likewise, communities where median household income is less than $30,000 average an exposure rate of 27.9 points per square mile, which dramatically contrasts with the exposure rates for communities where median household income is $30,000 or greater, which ranges from 6.9 to 8.9 points per square mile. As a result, low-income communities face a cumulative exposure rate to environ-mentally hazardous facilities and sites that is 3.13-4.04 times greater than that for all other communities in the state. As is the case with communities of color, low-income communi-ties are disproportionately exposed to environ-mental hazards of all kinds. Ecological racism and class-based environmental injustices appear to be widespread in Massachusetts.

Table 1 con"rms this claim, showing the communities that have the greatest densities of environmentally hazardous industrial facilities and sites. We have constructed an exposure rate using the method described above (whereby the point totals for all hazards pre-sent in the community are added together and then divided by the total area). As shown in Table 1, 14 of the 15 most intensively over-burdened towns in Massachusetts have median household incomes of less than

$40,000. In fact, 9 of the 15 towns have median household incomes less than $30,000.

Likewise, 9 of the 15 most environmentally overburdened towns in the state have popula-tions comprising 15% or more people of color. And 6 of the 15 towns have populations comprising 25% or more people of color. This is signi"cant in light of the fact that only 20 communities in the entire state have popula-tions comprising 15% or more people of colorand nearly half are among the 15 most intensively overburdened communities.

In Table 2, we analyze the 20 communi-ties with the greatest number of environmen-tally hazardous industrial facilities and sites.

Using the same method described for Table 1(except that we do not control for size of the community or density of hazardous facili-ties/sites), Table 2 reveals that 16 of the 20 most extensively overburdened towns in Massachusetts have median household incomes of less than $40,000. In fact, 11 of the worst 15 towns have median household incomes less than $30,000. In terms of race, we similarly "nd that 9 of the 15 most exten-sively overburdened towns in the state are of higher-minority status, where people of color compose 15% or more of the population.

Again, this is significant in light of the fact that only 20 communities in the entire state have 15% or more racial minorities. In fact, when we combine Tables 1 and 2 and elimi-nate overlapping towns, we find that 13 of the 25 most environmentally overburdened towns in the state are communities of color (where people of color compose 15% or more of population). As a result, two of every three communities of color in the state are among the 25 most environmentally over-burdened towns. In fact, citizens residing in a community of color in Massachusetts are 19 times more likely to live in one of these 25 most overburdened communities.

The conclusion to be drawn from this preliminary analysis is that the communities most heavily burdened with environmentally hazardous industrial facilities and sites are overwhelmingly low-income towns and/or communities of color. Clearly, not all Massachusetts residents are polluted equally working class and people of color popula-tions are disproportionately impacted (Figure 3).

What Can Be Done?

Addressing Problems of Environmental Injustice in Massachusetts Massachusetts should be accountable to all of its residents and strive for equal protection from pollution and other environmental threats. When any citizen is unwillingly harmed by exposure to industrial toxic pollu-tants found in the environment, an injustice is being perpetrated. So that no citizen of any community be put at risk, government agen-cies on all levels must deepen efforts to reduce the overall level of dangerous pollutants cur-rently found in the environment, as well as in our schools, homes, and workplaces. In this regard, TURA is a model program that should be expanded. Likewise, DEP should take additional steps to reduce the overall waste stream, increase recycling, and continue a moratorium on new land"lls and incinera-tors. Similarly, capping the cumulative emis-sions of power plants will reduce emissions in Massachusetts by tens of thousands of tons. It would also ensure that newer, cleaner plants bene"t from a level playing "eld by removing the pollution subsidy old plants currently enjoy. Major cleanups of these plants can take place without major implications for jobs or energy reliability.

In addition to working for an overall reduction in the amount of pollution, Massachusetts needs to undertake a series of special initiatives to address the environ-mental injustices that exist in the state. As suggested by the evidence presented in this report, all people are not polluted equally in Massachusetts. Ecologically hazardous industrial facilities and waste sites are instead disproportionately located in communities of color and lower-income communities. As a result, citizens do not share the same access to a healthy environment. Massachusetts needs to develop and implement a plan to reduce these disparities for ecologically overburdened communities, beginning with public hearings on environmental injustices so that those who Environmental Justice

• Faber and Krieg 286 VOLUME 110 l SUPPLEMENT 2 l April 2002

• Environmental Health Perspectives Figure 3. Unequal exposure to all hazardous facili-ties and sites combined, compared with an aver-age of 10.4 points per square mile cumulative exposure rate for all 368 Massachusetts communi-ties. (A) Exposure to cumulative hazards by race.

(B) Exposure to cumulative hazards by class.

30 20 10 0

60 50 40 30 20 10 0

$0 to

$29,999

$30,000 to

$39,999

$50,000 or more

$40,000 to

$49,999 Less than 5%

5 to 14.99%

15 to 24.99%

25% or more Mean total points per square mile Mean total points per square mile Median household income Percentage of population that is non-White A

B 27 9

7 7

6 19 43 55

are affected can voice their concerns. As part of these efforts, the state must also begin to more systematically address the environmental injus-tices documented in this report. This includes the establishment of local, state, and federal government programs and policies that ensure environmental equity; avoid the siting of future hazardous facilities/sites in already over-burdened lower-income communities and communities of color; provide resources to these overburdened communities to create environmental amenities that can partly offset other environmental risks; and promote greater citizen participation in the problem-solving and decision-making processes that affect those communities. Elected officials, policymakers, government agency staff, com-munity activists, and ordinary citizens must work together to overcome the environmental injustices that exist in Massachusetts.

Furthermore, it is important that any strategies simultaneously address environmental injus-tices in both the racial and class contexts.

Otherwise, efforts to redress one type of inequity over others could serve to foster con-tinued inequity in other groups.

Additional recommendations that the state could adopt for ensuring environmental jus-tice in Massachusetts include the following:

a) Massachusetts should pass an environ-mental justice law that will ensure equal pro-tection and additional resources for overburdened areas. Such a new environ-mental justice law, currently under consider-ation by the Massachusetts legislature, should do the following:

• Make environmental protection a civil right protected under law.

• Create regulations for Areas of Critical Environmental Justice Concern (ACEJC) that would qualify areas overburdened by pollution, hazardous facilities, and sites and/or suffering from poor health for higher scrutiny in environmental permit-ting and greater levels of resources for cleanup and remediation. Such an act could amend the duties and responsibilities of the Executive Of"ce of Environmental Affairs (chapter 21A, section 2) and call for the development of statewide policies regarding the protection and use of areas of critical environmental concern to Massachusetts.

• Establish toxic-free buffer zones around sensitive receptors such as schools and day-care and healthcare facilities.

b) Massachusetts should increase the level of resources for the DEP and the Executive Office of Environmental Affairs (EOEA).

The capacity of the DEP and EOEA to suc-cessfully address issues of environmental injustice would require the provision of addi-tional funding, staff, and other resources to adequate levels. Additional responsibilities should not placed on already overburdened state agencies without the necessary funding to successfully perform the work.

c) DEP should also maintain its morato-rium on new landfills and incinerators.

Incinerators and many land"lls pose unaccept-able health risks to local residents and nearby communities and should be eliminated. The state should furthermore incorporate environ-mental justice into all existing regulations, which need to be enforced everywhere, espe-cially in lower-income communities and com-munities of color. In particular, the following policies and regulations need to integrate an environmental justice orientation:

• Environmental reviews under the Massachusetts Environmental Policy Act (MEPA) should include explicit considera-tion of disproportionate impact on low-income communities and communities of color.

• There should be strong oversight and enforcement of regulations for hazardous waste site cleanup (Massachusetts Contingency Plan 21E). More resources should be granted to the DEP to ensure rapid and thorough cleanups, especially in overburdened areas.

d) Massachusetts should review and, when necessary, halt the provision of eco-nomic development incentives for projects that will contribute more pollution to already overburdened areas. Development incentives such as tax credits and low-cost loans should not be offered to projects that increase pollution in areas already overbur-dened with pollution sources. To assist in this process, the state should track and mon-itor environmental disparities:

• A number of factors, such as housing dis-crimination, bank lending policies, local planning and zoning practices, licensing and permitting processes, and the geo-graphic distribution of public services, transportation networks, industries, and so forth, play some role in creating envi-ronmental injustices. The state should undertake and/or sponsor additional investigations to better understand the sources of environmental injustice.

• DEP does an excellent job of making its databases available to the public. These efforts can be further enhanced by keeping track of its progress on reducing environ-mental disparities. This information should be accessible to the public over the internet.

Additionally, more health and environmen-tal monitoring needs to be implemented in areas of high concerns. The state should ensure that the DEP receives adequate resources to perform these functions.

e) Finally, Massachusetts should adopt the precautionary principle over standard risk-assessment procedures when addressing environmental issues in overburdened communities. The precautionary principle says that if there is a strong possibility of harm (instead of a scienti"cally proven cer-tainty of harm) to human health or the envi-ronment from a substance or activity, precautionary measures should be taken.

Under current approaches to risk assessment in the state, environmental policy is oriented to promoting the dispersion of pollution to what are considered safe levels of public exposure. However, if pollution is instead highly concentrated in certain communities, as we have shown, then this approach is inad-equate. Overburdened communities must be granted additional protections as offered by the precautionary principle, which includes promoting additional study of activities of concern, shifting the burden of proof so that a chemical/activity is proven safe, and provid-ing incentives for preventive behavior, and/or measures such as bans or phase-outs of sub-stances suspected of causing harm. The time has come for the legislature and state of"cials to work hand in hand with the environmen-tal justice movement and community repre-sentatives to end environmental racism and promote new models of clean production and sustainable economic development.

REFERENCES AND NOTES 1.

Goldman B, Fitton L. Toxic Wastes and Race Revisited Washington, DC:United Church of Christ Commission for Racial Justice, 1994.

2.

The following de"nition of environmental justice is taken from Bryant B (ed). Environmental Justice: Issues, Policies, and Solutions Washington, DC:Island Press, 1995;6.

Environmental Justice: Environmental justice (EJ) is broader in scope that environmental equity. It refers to those cultural norms and values, rules, regulations, behaviors, policies, and decisions to support sustainable communities, where people can interact with con"dence that their environment is safe, nurturing, and productive.

Environmental justice is served when people can realize their highest potential, without experiencing the isms.

Environmental justice is supported by decent paying and safe jobs; quality schools and recreation; decent housing and adequate health care; democratic decision-making and personal empowerment; and communities of vio-lence, drugs, and poverty. These are communities where both cultural and biological diversity and respected and highly revered and where distributed justice prevails.

3.

National Research Council, Environmental Epidemiology:

Public Health and Hazardous Wastes. Washington, DC:

National Academy Press, 1991.

4.

Environmental Research Foundation. Rachels Hazardous Waste News, No. 332. 8 April 1993;1-2.

5.

U.S. EPA. Superfund Remedial Sites, National Priorities List. Washington, DC:U.S. Environmental Protection Agency, 11 April 2000.

6.

Numerous other studies have documented similar health impacts as the NRC report. [For example, see Goldberg S. An association of human congenital cardiac malfor-mations and drinking water contaminants. J Am Coll Cardiol 16(1):155-164 (1990).]

7.

Hoover R, Fraumeni R. Cancer mortality in U.S. counties with chemical industries. Environ Res 9:196-207 (1975).

8.

Andelman J, Underhill D, eds. Health Effects from Hazardous Waste Sites. Chelsea, MI:Lewis, 1987.

9.

For a discussion of the environmental impacts on cancer rates, see Krieg, E. Toxic Wastes, Race, and Class: A Historical Interpretation of Greater Boston [PhD Thesis].

Boston:Northeastern University, 1995.

10. Steingraber S. Living Downstream: An Ecologist Looks at Cancer and the Environment. New York:Addison-Wesley, 1997.

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• VOLUME 110 l SUPPLEMENT 2 l April 2002 287

11. Clapp R. The decline in U.S. cancer mortality from 1991-1995: whats behind the numbers? New Solutions: Am J Environ Occup Health Policy 7 (4):30-34 (1997).

12. Cutler J, Parker G, Rosen S, Prenney B, Healey R, Caldwell G. Childhood leukemia in Woburn, Massachusetts. Public Health Rep 101(2):201-205 (1986).

13. Lagakos S, Wessen B, Zelen M. An analysis of contami-nated well water and health effects in Woburn, Massachussets. J Am Stat Assoc 81:583-614 (1986).

14. Aschengrau A, Ozonoff D, Paulu C, Coogan P, Vezina R, Heeren T, Zhang Y. Cancer risk and tetrachloroethylene-contaminated drinking water in Massachusetts. Arch Environ Health 48(5):284-292 (1993).

15. The Silent Spring Institute is conducting an extensive investigation of the possible environmental causes of the breast cancer epidemic on Cape Cod. See Silent Spring Institute. The Cape Code Breast Cancer and Environment Study: Results of the First Three Years of Study. Newton, MA:Silent Spring Institute, 1998.

16. For studies that examine the inequitable distribution of hazardous waste facilities in specific regions of the country, see Bullard R. Dumping in Dixie: Race, Class, and Environmental Quality. Boulder, CO:Westview, 1990.

17. Bullard R, ed. Unequal Protection: Environmental Justice and Communities of Color. San Francisco:Sierra Club, 1994.

18. Bryant B, Mohai P, eds. Race and the Incidence of Environmental Hazards: A Time for Discourse. Boulder, CO:Westview, 1992.

19. Faber D, ed. The Struggle for Ecological Democracy:

Environmental Justice Movements in the United States.

New York:Guilford, 1998.

20. Chavis B, Lee C. Toxic Wastes and Race in the United States: A National Report on the Racial and Socioeconomic Characteristics of Communities Surrounding Hazardous Waste Sites. New York:United Church of Christ Commission for Racial Justice, 1987. This study analyzed data on the number and type of hazardous waste facilities in the approximately 35,5000 residential zip codes of the United States, along with data on percent minority population, mean household income, mean home value, number of uncontrolled toxic waste sites per 1,000 persons, and pounds of hazardous waste generated per person.

21. Goldman B, Fitton L. Toxic Waste and Race Revisited: An Update of the 1987 Report on the Racial and Socioeconomic Characteristics of Communities with Hazardous Waste Sites. Washington, DC:Center for Alternatives, the National Association for the Advancement of Colored People, and the United Church of Christ Commission for Racial Justice, 1994.

22. Spence L. Race, Class, and Environmental Hazards: A Study of Socio-economic Association with Hazardous Waste Generators and Treatment/Storage/Disposal Facilities in Massachusetts [Masters Thesis]. Medford, MA:Tufts University, 1995.

23. Roque J. Review of EPA report: environmental equity:

reducing risk for all communities. Environment 35(5):25-28 (1993).

24. Lavelle M, Coyle M. Unequal protection: the racial divide in environmental law. Natl Law J (September):2-12 (1992).

25. For current data and definitions, see Massachusetts Department of Environmental Protection website.

Available: http://www.state.ma.us/dep/bwsc/sites/report

26. Of these on-site releases, 62.8% were to land, 29.9% were to air, 3.9% were to underground injection, and 3.4% were to surface water. There are now nearly 650 toxic chemi-cals and chemical compounds on the list of chemicals that must be reported to the U.S. EPA and the states under the Emergency Planning and Community Right-to-Know Act of 1986, which established the TRI program.

27. The 1998 TRI data and background information on the TRI program are available at http://www.epa.gov/tiinter/

tridata/index.htm [accessed 15 March 2000].

28. A study conducted by researchers at the Harvard School of Public Health, Brigham Young University, and the American Cancer Society, which was released on 10 March 1995 and appeared in the American Journal of Respiratory and Critical Care Medicine, estimated some 60,000 annual air pollution deaths [Pope CA III, Thun MJ, Namboodiri MM, Dockery DW, Evans JS, Speizer FE, Heath CW Jr. Particulate air pollution as a predictor of mortality in ta prospective study of U.S. adults. Am J Respir Crit Care Med151:(3):669-674 (1995)].

29. In Massachusetts, mobile sources (primarily motor vehi-cles) are responsible for 42% of the total HAP emissions in the state. Area sources, which are smaller air sources that release less than 10 tons per year of any individual HAP and less than 24 tons per year of combined HAPs, emit 51% of all HAPs in the state. Examples include gas stations, dry cleaners, and small print shops. Point sources are stationary facilities that emit (or have the potential to emit) 10 tons or more per year of any one of the listed HAPs, or 25 tons or more per year of combined HAPs. Point sources emit 7% of the total HAPs in the state. Examples of point sources include chemical plants, paper mills, power plants, and waste incinera-tors. Available: http://www.state.ma.us/dep/bwp/daqc/

"les/airtox.htm [accessed 15 March 2001].

30. Toering M, Sargent R. Every Breath We Take: How Motor Vehicles Contribute to High Levels of Toxic Air Pollution in Massachusetts. Boston:MASSPIRG Education Fund, 8 July 1999;1-32.

31. Wiles R, Savitz J, Cohen B. Particulate Air Pollution in Boston: Human Mortality, Pollution Sources and the Case for Tougher Clean Air Standards. Washington, DC:Environmental Working Group, 1997.

32. For a concise summary of these studies, see Mohai P, Bryant B. Demographic studies reveal a pattern of envi-ronmental injustice. In: Environmental Justice (Petrikin J, ed). San Diego, CA:Greenhaven, 1995;10-24.

33. Gelobter M. Toward a model of environmental discrimi-nation. In: Race and the Incidence of Environmental Hazards: A Time for Discourse (Mohai P, Bryant B, eds).

Boulder, CO:Westview, 1992;64-81.

34. Gianessi L, Peskin H, Wolff E. The distributional effects of uniform air pollution policy in the U.S. Q J Econom (May):281-301 (1979).

35. Wernete D, Nieves L. Breathing polluted air: minorities are disproportionately exposed. EPA J(March/April):16 (1992).

36. Mann E. L.A.s Lethal Air: New Strategies for Policy, Organizing, and Action. Los Angeles:Labor/Community Strategy Center, 1991.

37. Demographic data came from the U.S. Census; land use data are from a series of statewide aerial surveys, sup-plemented by U.S. and Massachusetts Census of Manufactures data on manufacturing industry. Cancer incidence data from 1982-1990 came from the Massachusetts Cancer Registry. The cancers of con-cern, selected on the basis of confirmed or tentative links to agricultural or industrial chemicals, are non-Hodgkins lymphoma, leukemia, multiple myeloma, soft tissue sarcoma, and cancers of the brain, stomach, prostate, bladder, kidney, lung, and breast.

38. Maxwell N. Land Use, Demographics, and Cancer Incidence in Massachusetts Communities [PhD Thesis].

Boston:Boston University, 1996.

39. The incidence of lung cancer was associated with industrial/commercial land use but only in speci"c years, which suggests that the high-tech industries dispropor-tionately hosted by well-to-do suburbs do not cause the same increase in lung cancer risk as does traditional, high-air-pollution manufacturing.

40. One can argue that towns are too large for detailed stud-ies of environmental injustice. The size of a town can potentially mask racial or economic heterogeneity within the town area. For instance, a town may have a 10%

minority population concentrated in a particular portion of the townpossibly the same section of town where polluting industries and facilities are concentrated.

Analysis at the town level could mask the concentration of hazards in minority neighborhoods.

41. Some 520 large quantity toxics users reported to TURA dur-ing the 1998 calendar year (the latest year such data is cur-rently available). These companies reported using over 1.184 billion pounds of chemicals (not including trade secret chemicals), of which over 132.6 million pounds were gener-ated as waste by-product. Of this by-product, some 50.5 mil-lion pounds of toxic chemicals were transferred off-site (for recycling, recovery, treatment, or disposal), while another 12 million pounds were released on-site directly into the environment (discharged into the air, ground, underground areas, or adjacent bodies of water). When we incorporate trade secret data into the 1998 TURA aggregate quantities, we "nd that 1.380 billion pounds of chemicals were used by state industry, 137 million pounds were generated as by-product; and 64 million pounds of this by-product was either released on-site into the environment or transferred off-site.

42. TURA was enacted in 1989 and had a stated 10-year goal of reducing the generation of toxic waste by 50% from the base year of 1987 to 1997. From 1990, the first reporting year, to 1998, adjusted by-product production dropped 48%. Using the same adjustment method, TURA filers have been equally successful in reducing their releases of TRI reported on-site chemicals by 83% since 1990.

43. Massachusetts Department of Environmental Protection.

1998 Toxics Use Reduction Information Release. Lowell, MA: A Report Developed in Conjunction with the Office of Technical Assistance for Toxics Use Reduction, the Toxics Use Reduction Institute, and the Executive Of"ce of Environmental Affair. Boston:Massachusetts Department of Environmental Protection, Spring 2000.

44. For the first time, electric utilities and mining facilities were included in the Environmental Protection Agencys annual toxic inventory 2000 report, which reviewed seven industrial sectors.

45. Natural Resources Defense Council. Breathtaking:

Premature Mortality Due to Particulate Air Pollution in 239 American Cities. Washington, DC:Natural Resources Defense Council, May 1996.

46. Wiles R, Savitz J, Cohen BA. Particulate Air Pollution in Boston: Human Mortality, Pollution Sources and the Case for Tougher Clean Air Standards. Washington, DC:Environmental Working Group.

47. Stanfield B, Farleigh A, Porreco G. Danger in the Air:

Unhealthy Smog Days in 1999. Washington, DC:Clean Air Network and U.S. Public Interest Research Group Education Fund, January 2000;2.

48. Sargent R, Toering M. Dirty Power in the Northeast: A Report on the 1998 Emissions of the Northeasts Dirtiest Power Plants. Boston:Campaign to Clean Up Polluting Power Plants, 1999.

49. Older fossil-fuel power plants built during the 1940s through the 1960s create the vast majority of power plant air pollution. In rewriting the 1970 Clean Air Act, amended in 1977 and 1990, electric industry lobbyists successfully persuaded Congress that older plants would soon be retired and therefore should be exempt from strict, new emission standards. Instead, this loop-hole has allowed owners of older, more polluting plants exempted from the modern standards to make bigger profits and stay in operation longer compared with the more expensive, cleaner, and newer power plants.

50. Data for the "rst half of 1999 show signi"cant increases in nitrogen oxide and carbon dioxide and slight decreases for sulfur dioxide (with the exception of the Brayton Point and Canal plants, which showed considerable gains). However, it should be noted that the overall reductions in sulfur diox-ide recorded during that time frame stemmed from the fact that many units were shut down for repairs or mainte-nanceand not from improvement in air pollution control technologies. Reports show that the Salem Harbor Plant in Salem was in fact shut down for good amount of time due to a "re at the plant, thus resulting in lower emission out-puts. Even taking this into account, the emission rate of sul-fur dioxide at Salem was still 4 times the emission rate of new coal-"re plants. The average emission rate of sulfur dioxide for all of Massachusetts was 1.04 lb/mmBTU, 3.46 times the 0.3 lb/mmBTU rate for newer, cleaner coal plants.

51. Toering M, Sargent R, Luppi C. Pollution Rising: New England Power Plants Emissions Trends 1st Half 1998 vs.

1st Half 1999. Boston:A Report for the Campaign to Clean Up Polluting Power Plants. Massachusetts Public Interest Research Group, 1999.

52. Although they do not typically produce dangerous air pollution, the states nuclear power plants continue to pose a threat of accidental radiation releases and are responsible for 99% of the high-level radioactive waste.

53. Levy J, Spengler J, Hlinka D, Sullivan D. Estimated Public Health Impacts of Criteria Pollutant Air Emissions from the Salem Harbor and Brayton Point Power Plants.

Cambridge, MA:Harvard School of Public Health and Sullivant Environmental Consulting, May 2000.

54. MASSPIRG urges cut in solid waste. MASSPIRG 17 (4):1-3 (Winter 2000).

55. The DEP estimate is based on 1991-1994 stack test data.

Available: http://www.state.ma.us/dep/files/mercury/

hgch3b.htm#table3x7 [accessed 15 March 2000].

56. For additional mercury data, see Massachusetts Department of Environmental Protection. Mercury in Massachusetts: An Evaluation of Sources, Emissions, Impacts and Controls. Boston, MA, June 1996. Available:

http://www.state.ma.us/dep/files/mercury/

hgch3b.htm#table3x8 [accessed 15 March 2000].

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• Environmental Health Perspectives