Introduction: Community Based Environmental Protection at the USEPA

"Participatory development" and "grassroots activism": these phrases evoke images of empowered citizens working together on issues of concern, building a bright future for their neighborhoods and communities. An appreciation for community-based initiatives are increasingly prevalent in the environmental movement, as large national environmental organizations struggle to reach out and engage participants from diverse backgrounds. Even federal agencies often accused of promoting top-down, monolithic solutions to local problems have jumped on the band-wagon of grassroots solutions. The United States Environmental Protection Agency represents one such federal agency as it promotes a new paradigm for protection of the environment and human health: community based environmental protection (CBEP).

Community based environmental protection at the EPA attempts to address environmental problems holistically by taking a "multimedia approach:" in other words, by viewing air, water, and land pollution as threats to a particular ecosystem. CBEP utilizes a geographic focus (regional, municipal, ecosystem, watershed, etc.,) and emphasizes the need to involve communities in identifying environmental issues, setting priorities, and creating solutions. In theory, CBEP "integrates environmental protection with human needs, considers long-term ecosystem health, and fosters linkages between economic prosperity and environmental well-being. It encourages communities to create their vision of environmental health and quality of life and to encourage human activity compatible with that vision" (USEPA 1997).

At a workshop held on June 25, 1997, entitled "Developing a CBEP Framework for EPA," Region V employees in Chicago had the opportunity to interact with Washington D.C. officials charged with developing the CBEP approach within the agency. Five CBEP environmental and programmatic goals were proposed at this meeting:

• Identify and reduce environmental stresses affecting human health and the quality of life.
• Prevent habitat fragmentation and degradation and restore habitat quality.
• Sustain biodiversity and healthy ecosystem processes at a regional scale.
• Sustain vibrant, livable, and economically diverse human communities.
• Incorporate distinct community and stakeholder goals and values, especially from low-income and/or minority populations, in the design and implementation of ecosystem management initiatives.
• Empower communities to address their environmental, economic, and social needs as a whole through effective partnerships, improved communication and greater access to high quality data, information, and tools.

Representatives from the various divisions within Region V were asked to voice their concerns and raise questions as to how the CBEP approach will impact their work within the agency. One of the recurring concerns voiced by participants is the difficulty in conceptualizing how the practice of CBEP interfaces with the EPA's enforcement and regulatory mandates. Much of the day-to-day work in the media divisions (i.e. air & radiation, water, Superfund, etc.) consists of permitting reviews, inspections, and developing risk and impact assessments. While specific forms of community involvement are mandated for the Superfund division, questions remain as to what a community based approach in other divisions might look like, how much time community based activities will take, and what kind of expertise will be required.

A second set of concerns revolves around the community development and quality of life goals stated explicitly in CBEP framework. Some employees wonder if CBEP will involve EPA staff in social and economic issues outside the scope of their work, such as economic development initiatives, community politics, and social service provision. Are they expected to take up the role of community organizers and advocates? Related to this issue is the perplexing one of how "community" ought to be defined. The environmental scientists at the meeting argued that political boundaries are insufficient for environmental protection work, since they don't conform to ecosystem realities. What should be done in instances where environmental problems cross political boundaries?

Perhaps most troubling to some employees is the sense that CBEP represents a politically generated, lay-person approach to environmental protection which may or may not be based on scientifically grounded assessments and priorities. To some, CBEP means placing non-expert residents and community based organizations in decision making positions about ecology and public health. Some worry that in the effort to be inclusive and participatory, citizens and advocacy groups will be increasingly involved in making decisions about environmental health best left up to experts.

Those with a more positive opinion of CBEP argue that citizen involvement could complement agency expertise in situations where the EPA does not have a regulatory or enforcement mandate, yet where environmental concerns persist. For example, non-point-source pollution in urban settings often fall outside the issues addressed in environmental legislation. A CBEP approach to these problems would consist of working through stakeholders like community organizations and municipal conferences to foster collaboration and creative approaches to address these issues (USEPA 1996).

While these debates continue to ferment within the agency, the Office of Strategic Environmental Analysis in Region V is moving ahead to integrate a community based approach into the work of the Region V office. Toward this end, a CBEP coordinator has been hired, and a work group has been established to grapple with these issues as they apply to Region V. Some of the Region V teams are already experimenting with CBEP, including one team based in Chicago.

The Chicago Team and Its Mission

The Greater Chicago Initiative (GCI; better known as The Chicago Team) of Region V is a place-based initiative comprised of staff from various EPA divisions. In its mission statement, the Chicago Team acknowledges the interconnectedness of environmental problems in the greater Chicago region and the need to address a wide range of issues. Some of these issues include urban sprawl; brownfields redevelopment and remediation; illegal dumping; odor reduction; groundwater and soil contamination; restoring and protecting biodiversity; and public health problems such as PCB contamination, asthma, and lead poisoning. The team focuses its attention on the southeast and west sides of Chicago due to the particularly intense environmental and public health problems faced by these communities. On the southeast side of Chicago, the Chicago team sees its role as 1) helping to develop consensus and a coordinated approach to environmental protection and conservation; 2) supporting development of remediation technologies which are cost effective; 3) promoting pollution prevention and waste reduction; and 4) encouraging job training of residents in environmental remediation. On the west side of Chicago, environmental health is the GCI's greatest concern, especially lead poisoning and asthma.

As mentioned above, the GCI is working to integrate a community-based approach into its work. Toward this end, the Chicago Team is developing a steering committee of key stakeholders in the Greater Chicago area. This steering committee will help to set priorities for the Chicago Team grant program, evaluate project proposals, and help to coordinate and foster collaboration between various environmental activists and organizations. As a means furthering community awareness of the Chicago Team, and increasing the effectiveness of its own work, the Greater Chicago Initiative conducted community outreach interviews with environmental and public health organizations in Chicago in the spring and summer of 1997.

I was invited to participate in this outreach effort as an SfAA/EPA Fellow during the summer of 1997. The objectives of my internship with the Greater Chicago Initiative were to:

• Conduct informational interviews with community based and city-wide environmental and public health organizations, informing them of the work of the GCI and assist them in making appropriate contacts within the U.S. EPA.
• Obtain data about the types of environmental information used by these organizations, and solicit feedback about their format preferences for such information.
• Facilitate increased programmatic awareness and collaboration among environmental, public health, and community based organizations in Chicago.
• Analyze the interaction of the Chicago Team and local environmental organizations, and provide suggestions as to how the Chicago Team might enhance its community based approach .

Methods

After compiling a city-wide list of over 200 environmental, community based and public health organizations, I developed a classification scheme after consulting with members of the Chicago Team. One organization from each category was chosen for an interview using the following criteria: high visibility in the environmental community, lack of Chicago Team knowledge about its activities, an advocacy/political focus as opposed to a social service focus, location on the southeast or west side of Chicago, potential for providing additional contacts in the environmental community, personal interest on the part of the intern and/or Chicago Team members. Interviews were scheduled with the director of each organization. 45 organizations were interviewed, 17 of which dealt exclusively with the southeast or west side of Chicago. Interviews with these 17 organizations were conducted along with site visits to the organizations.

During the interviews, the informant was provided with a copy of the Greater Chicago Team Performance Agreement for 1998 and was invited to review the plan and offer suggestions for prioritizing the items listed. Organizations were also asked to distribute the work plan to other environmental organizations and to their constituents for their input. Using a semi-structured interview format, informants were then asked to provide information in the following areas:

• a brief history of the organization and funding sources
• current areas of programming and activities
• identification and analysis of the most pressing environmental and/or public health issues in Chicago, and in the local neighborhood in which the organization works
• a local definition and description of their community
• a list of other environmental, public health organizations, or community based organization with which the organization works
• sources of environmental data used in strategic planning or programming
• areas of convergence/divergence between USEPA and the mission of the organization
• previous involvement with the USEPA.

Data and Observations

While the EPA employees at the CBEP workshop were primarily concerned with how to do their job within a CBEP framework, and how CBEP interfaces with the EPA's mission, interviews with community residents, activists, and organizations revealed another set of possible impediments to implementing CBEP in Chicago. These challenges fall roughly into five areas:

A High Degree of Organizational Diversity within the Environmental Community

Chicago area environmental organizations maintain diverse types of constituent bases, and address an extraordinarily wide range of environmental issues, though a relatively small number of organizations tend to be the conveners of large environmental projects and campaigns. Some organizations are national organizations with local chapters. For example, the IL chapter of the Sierra Club has a membership of individuals numbering in the thousands, but much of the advocacy work is done by volunteer experts and a 2 person paid staff. Other organizations, such as the Friends of the Chicago River, OpenLands, and the Westside Alliance for a Safe-Toxic Free Environment (WASTE) are Chicago-specific organizations that rely heavily on networking and coalition building for their base of support. WASTE, for example, has approximately 30 members, primarily community based organizations, churches and health organizations.

City wide volunteer organizations, perhaps more so than the neighborhood based organizations, compete for a limited base of volunteers. For example, on the southeast side of Chicago a few key individuals serve as officers in several of the environmental organizations. Most of the organizations interviewed expressed the need to get more people involved in their organization, but they face a shortage of staff, time, and money, and a lack of interest on the part of residents. One activist explained the dilemma: "We go for the light, the people who already have an interest. We haven't been as good about trying to involve people who don't come to us expressing interest." In effect, while the environmental community is diverse in terms of missions and structure, a relatively small subset of Chicago residents is involved.

Organizational diversity poses a challenge to the Chicago Team in that collaborative projects, educational materials and presentations, and areas of joint concern will have to be explored individually with and tailored to each organization. Because of the tendency of these organizations to attract a small subset of people with a predisposed interest in the environment, the EPA will not find these organizations to be effective conduits to the majority of Chicago citizens who are uninvolved in environmental issues, yet are affected. In addition, some of these organizations have a long history of working with the USEPA, sometimes as partners, and sometimes as opponents. These histories will continue to affect the perception of the EPA despite the introduction of a "new" CBEP approach.

Diverse conceptualizations of "the environment"

"The environment" and "environmental problems" are conceptualized differently in each Chicago neighborhood. "Environmental concerns" elicited from my interviews with community leaders and environmental activists extend far beyond the problems of pollution and conservation traditionally addressed by the EPA. A partial list of the issues generated from interviews illustrates the complex ways in which people conceptualize environmental problems:

personal safety, garbage pick up, graffiti, asthma, lead poisoning, toxins in schools, environmental risks stemming from imported food and goods, gangs, access to greenspace/openspace, illegal dumping, noxious odors, air pollution, brownfields redevelopment, communicable diseases, unsafe water, prostitution, drug dealing, handicap accessibility, fish contamination, food contamination, animal rights, soil contamination.

Some patterns emerge out of this complexity which may be useful to the Chicago Team as it attempts to devise outreach strategies. I found that community based organizations tend to conceptualize environmental issues as quality of life issues and/or environmental justice issues. One of the most visible environmental justice campaigns on the west side of Chicago was a three year long fight to shut down an incinerator accused of causing environmental illnesses. Leading the fight was a single-issue coalition organization comprised of 36 organizations, most of which were community based, though some like the Sierra Club and the American Lung Association were city-wide organizations. Once the battle to close the incinerator succeeded, this coalition went through a transitional period in which it considered whether or not to disband. Instead of disbanding, the members of the organization established a new, broader based mission, including the protection of the health of westside residents, promoting environmental issues (e.g. illegal dumping, brownfields redevelopment, toxic free schools), and seeking sustainable economic development.

City-wide environmental organizations were more likely to talk about air, water, and soil contamination, or species and habitat preservation as key issues. The exception to this pattern appears in the community based umbrella or coalition organizations which maintain a geographic focus that spans several communities. The Calumet Ecological Park Association (CEPA) in southeast Chicago provides a good example. The southeast side of Chicago was once a vast series of interconnected wetlands, which over the decades have been filled and converted to hazardous and non-hazardous waste landfills and steel factories. CEPA, comprised of an exceptional group of environmental activists, has been involved in cleanup initiatives, siting protests, wetland mitigations, watchdog activities, and most recently, securing a National Park Service study and subsequent recommendation that the Lake Calumet area receive official designation as a national heritage area. This designation may serve as a means of halting further environmental degradation, and securing funds to continue with cleanup efforts. This effort united residents of a number of southeast communities in advocacy for an improved quality of life on several levels.

Distrust of Government and Outside Experts

Interviews revealed that many environmental organizations and community residents view the EPA as a regulatory watchdog, interested primarily in cleanup of contaminated sites and monitoring point source pollution, with very little interest in community dynamics or grassroots concerns. Many also expressed skepticism at the idea of a "community based approach" emanating from a federal agency, in part due to the distrust and resentment many residents have for government and outside experts. They doubt that EPA's new approach is really community driven, since in their definition, a community based approach must emerge from the community. As one west side activist explained: "Decisions [on the west side] are made by people who don't live in the community.... [We know that] no one [who lives here] would treat their community this badly, with such a fundamental disrespect to property and land. Those who do live here don't think they can do anything about it." To many Chicago residents, the EPA is a faceless bureaucracy with which they are unfamiliar. Several people remarked to me over the course of the interviews that they were surprised that the EPA would send an "actual live person" to talk to them in their neighborhood. In minority communities, this distrust of outsiders is intensified by the perception that the environmental movement is comprised of white, anti-development activists who give primacy to the environment over desperately needed jobs.

Complex Community Dynamics

Chicago is a city of well-defined neighborhoods with distinct identities and histories. The "southeast" side of Chicago, which the EPA considers to be an undifferentiated "region" of Chicago, is in fact comprised of a number of insular and well-defined neighborhoods, each with their own identity and history. In fact, community organizers use "pride in place" as a necessary component of environmental improvement and community development. A large number of community based and city-wide organizations have established community garden programs in vacant lots as a means of beautifying the neighborhood, promoting environmental education, discouraging crime, and instilling a sense of ownership and pride in the community. Community organizing tactics depend on reconnecting people to a sense of place, helping them to feel invested in a locality.

This is not to say that individual residents remain in one community for their entire life. Environmental organizations often forget that intra-city movement is an important aspect of community dynamics with environmental consequences. Movement of people from one neighborhood to the other is fueled by a number of factors, including education concerns, safety concerns, socioeconomic changes, neighborhood desirability, and environmental concerns and the desire to reduce risk.

Insularity and intra-community movement pose a challenge to the Chicago Team's concept of a "west side" and "southeast side" of the City. While the EPA is correct in stating that many of the environmental problems facing these regions of the city are in fact regional, and pertain to all of the communities, residents are not necessarily concerned about pollution in neighborhoods other than their own.

 Difficulties Accessing Environmental Data

The Chicago Team was interested in the kind of data environmental organizations use to formulate policy, assess risk, and prioritize issues. The type of environmental data used by the groups interviewed varies widely according to the purpose of the organization, the technology available, staff size and expertise, and the availability of data pertinent to their mission. Groups like the Environmental Law and Policy Center use EPA data on utility pollution. Other groups like Friends of the Parks use city ordinances and city openspace plans as leverage for their own objectives. Some organizations rely on university based research programs to conduct policy-oriented research for them. Most community based organizations use little or no data sources other than residents' perceptions and experiences. However, I did find a commonly expressed desire for environmental and public health data that can be correlated to neighborhood level populations.

Recommendations for Improving the Community Based Approach and Discussion

Given these concerns and community dynamics, how can a large, bureaucratic agency like the EPA practice community based environmental protection?

One of the primary barriers to implementing a community based approach at the EPA is the lack of knowledge and preconceptions that the general public has about the agency. The EPA has spent much time and energy on internal discussions of the pros and cons of a community based approach, yet very little on the ground, explaining how CBEP will change the character and/or work of the agency. None of the environmental organizations interviewed in this study with whom the EPA interacts regularly was aware that the agency had adopted a CBEP approach. In truth, the organizations interviewed are more interested in what, if any, concrete benefits CBEP might bring to them as opposed to expositions on the theory of a community based approach. These organizations are interested in grant programs, or truly collaborative action projects that will bring about desired results.

To some degree, the Chicago Team has avoided the difficult issues raised at the CBEP workshop by assuming the role of information-broker in the name of CBEP. Team members have participated in outreach interviews in which they inform organizations (primarily environmental groups) about grant programs and of the Chicago Team work plan and priorities. The team leader spends much of her time fielding calls about specific programs, grants, and EPA involvement in Chicago-area envioronmental problems. The Team works hard to increase information sharing between itself and environmental organizations, and has set forth an ambitious agenda which covers an exceptionally wide range of enviornmental and quality of life issues. However, the question remains as to whether or not this information-brokering role constitutes a truly community based approach to environmental protection. It is unlikely that this approach will succeed in educating the Chicago Team on an ongoing basis about the environmental concerns and quality of life issues of Chicago residents. Information-brokering, while important, will not ensure that community input is integrated into the priorities of the Chicago Team. And it is doubtful that this role will promote increased collaboration among agencies, organizations, and residents, though it might increase the information available about other groups' programs.

While there are limits to the types of activist roles allowed to the EPA, and while a great deal of skepticism exists within and outside of the agency about the legitimacy, advisability, and feasibility of a community based approach, I would like to suggest that there are specific actions which the Chicago Team could undertake which may improve its own efforts, and those of community and environmental organizations more generally:

• Host an informational workshop for Chicago environmental groups and the public on EPA processes and procedures (including CBEP), key environmental laws, and grants programs.
• Prepare materials and/or presentations on CBEP for local CBOs and city-wide environmental organizations. Involve these organizations in the CBEP workgroup which makes recommendations about integrating the approach into the work of the agency. These presentations and materials should be prepared in languages other than English where appropriate.
• Create a centralized list of Environmental Justice, Environmental Education, Chicago Team, and other grants that have been awarded to Chicago area organizations. Many organizations are not familiar with the grants available from the EPA. This list could be used by environmental and community based organization to research the types of grants available and to explore opportunities for collaborative project development and grant applications.
• Develop a mechanism to regularly obtain copies of the numerous reports that nongovernmental organization publish on environmental issues in the Chicago area.
• Network with city-wide coalitions of community based organizations dealing with quality of life and community development issues.
• Contact ethnic organizations not normally considered to be part of the environmental network. These organizations operate small environmental-related programs that go unnoticed and provide an important channel into environmental and public health issues faced by minority and immigrant populations.
• Contact churches in target areas. Many local churches sponsor community based organizations that have environmental concerns and/or programs. Churches also build environmental coalitions.
• Use health promoter organizations as sources of information and as a means of distributing information.
• Involve community development corporations (CDCs) in discussions about sustainable development and environmentally-friendly development practices.
• Follow through with the plan to develop a GCI steering committee. Build into the structure of this committee decision-making power for a wide range of community based organizations and environmental organizations, not simply the largest and most powerful of these groups.

Certainly, no one approach to community based environmental protection will work in all locales. Community dynamics and differing perceptions of environmental problems, the history of interaction between local communities and outside experts, and internal EPA concerns about "doing community work" dictate a long process of experimentation. It remains to be seen whether or not CBEP will continue as an "approach," or a "strategy," or whether it will be internally accepted and integrated into the day-today activities of the EPA. Ultimately, environmental activists and community residents will be the judge of this attempt to "reinventing" the USEPA.

Sources Cited

1996. United States Environmental Protection Agency. Introducing CBEP. CBEP Fact Sheet Series, May 1996. Washington D.C..

1997 United States Environmental Protection Agency. Proposed Outline for a Community- Based Environmental Protection Framework for EPA. Presented at the CBEP Workshop at Region V, Chicago offices of the USEPA, June 25, 1997.

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