United States General Accounting Office 

# Report to Congressional Requesters 

# 1GAO

June 1995 

# HAZARDOUSAND

NONHAZARDOUS WASTE Demographics of People Living NearWBte Facilities

# GAO United States General Accounting Office Washington, D.C. 20548 Besources, Community, and Economic Development Division B-260941 June 13,1995 The Honorable John Glenn Ranking Minority Member Committee on Governmental Affairs United States Senate The Honorable John Lewis House of Representatives Asyou requested, this report provides information onthe race and income ofpeople living near nonhazardous municipal solid waste landfills. It also summarizes 10other studies onthe demographics near avariety of waste facilities, primarily onesfor hazardous waste. As arranged with your offices, unless you publicly announce its contents earlier, we will make no further distribution ofthis report until 30daysafter the date ofthis letter. At that time, we will send copies to other appropriate congressional committees; the Administrator, Environmental Protection Agency; the Director, Office of Management and Budget; and other interested parties. Wewih also make copies available to others on request. Pleasecall meat (202) 512-6111if you oryour staff haveany questions. Major contributors to this report are listed in appendix IX

Peter F.Guerrero Director, Environmental Protection Issues

# Executive Summary

Purpose commercial, and household waste and other pollutants that havethe potential to pose health threats to people exposed to them. Some researchers havestated that racial minorities and low-income people (1) are not adequately brought into the decision-making process for selecting the sites of waste facilities, (2) are disproportionately exposed to pollutants intheir communities, and (3) maysuffer disproportionate health effects asaresult of such exposure. The overall question of whether the burden ofwaste facilities and environmental pollutants-such aslead, selected air pollutants, and pesticides-is disproportionate among groups of people and should be alleviated is known as“environmental justice.” At the request ofthe Ranking Minority Member ofthe Senate Committee on Governmental Affairs and Representative John Lewis, GAOreviewed certain aspects of the environmental justice issue. Specifically, GA0was asked to (1) provide information onthe race and income of people living near asample of nonhazardous municipal landfills, atype of facility that had not received much attention in prior research; (2) summarize 10 studies done by others of the demographics ofpeople living near waste facilities, primarily onesfor hazardous waste; (3) provide information on the efforts by the Environmental Protection Agency (EPA) to address environmental justice in its regulations on selecting the sites ofwaste facilities and in requirements for public participation in decisions about such facilities; and (4) provide information onthe extent of the data that havebeen collected to measure the health effects of hazardous and nonhazardous facilities on minorities and low-income people. 

# Background Under the Resource Conservation and Recovery Act of 1976 (RCRA), as amended in 1984,EPAregulates the operation and to some degree the location ofthousands of nonhazardous municipal landffis and facilities where hazardous waste istreated, stored, and disposed of. EPAis authorized to require that such facilities operate safely and that the public hasan opportunity to participate in the process for granting operating permits to them. Stateand local governments also haveregulatory responsibilities, particularly in approving the sitesfor such facilities. In response to studies on the broad subject of environmental justice, EPA and the administration have begun to reexamine policies and practices with regard to their impact on minorities and low-income people. In 1994, the President issued anexecutive order requiring federal agencies to

Page 2 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesExecutive Summary

develop strategies to address environmental justice in administering their programs. GAOanalyzed nonhazardous municipal landfills by applying data from the 1990census to asample of 190metropolitan and 105nonmetropolitan facilities.i The results of GAO'Sanalyses only apply to nonhazardous municipal landfills and should not be extended to hazardous waste facilities. GAOalso summarized the findings and methodologies of 10 recent national or regional studies that focused primarily onthe demographics of people living near hazardous waste facilities. 

# Results in Brief over-represented near amajority of the nonhazardous municipal landfills. According to GAO'Snationwide sample of municipal landfills, lessthan half of such landfibs had apercentage of minorities or low-income people living within 1mile ofthe facility that was higher than the percentage in the rest ofthe county. The 10studies that GAOsummarized, which focused primarily on the demographics of people living near hazardous waste facilities, hadvaried conclusions. Someconcluded that minorities and low-income people were disproportionately found near waste facilities, while others did not. It is difficult to generalize about the conclusions reached by the studies because the authors examined different types of facilities and used different methodologies and definitions of ‘racial minority.”
EPA'Slimited requirements on where hazardous and nonhazardous waste facilities may belocated have not addressed environmental justice. EPA'S current requirements for public participation in decisions also have not addressed environmental justice, but the agency recently proposed regulations in which it requested public comment on how to address this issue.
GAOfound that few datawere available on the health effects of hazardous and nonhazardous waste sites on minorities or low-income people.

‘The landfills areclassified asmetropolitan or nonmetropolitan depending onhowthe U.S.Bureauof the Censusclassifies the counties inwhich the landfik arelocated. % GAO’sanalysis of race,‘nonminorities” includes all whites notofHispanic origin and “minorities.” includes sUothers. In GAO’sanalysisof income andpoverty status,“minorities” excludes whites of Hispanic origin. Thisapproach wasusedbecauseofthe way the U.S.Bureauofthe Censusprovides data to the public.

Page 3 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesExecutive Summary



# Principal Findings
Minorities and Minorities and low-income people living near nonhazardous municipal 

## Low-Income PeopleWere landfills were not generally overrepresented. Onthe basis of its 

## Not Overrepresented Near representative sample, GAOestimated that for 73percent of the 

## the Majority of metropolitan 1andfYlsand 63percent ofthe nonmetropolitan landfills, the 

## Nonhazardous Municipal percentage of minorities living within f mile was lower than the 

## Landfills percentage of minorities living inthe remainder ofthe county. GAOalso estimated that the people living within 1mile of 54percent ofthe metropolitan and 52percent of the nonmetropolitan landfills had median household incomes that were higher than the incomes of residents in the remainder ofthe county. 

## Demographic Studies on The 10studies on hazardous waste facilities yielded arange of results. 

## Hazardous WasteFacilities Three of the 10studies concluded that minorities were more likely to live 

## HaveEelded Varied near hazardous waste sites than nonminorities. Four studies showed either 

## Results that there was no significant association between the location of awaste site and minority populations or that minorities were lesslikely to live nearby. The three remaining studies each used more than one methodology, and eachyielded multiple conclusions asto whether a disproportionate percentage of minorities lived near the facilities, Sevenofthe 10studies also reviewed economic factors. Three ofthe seven concluded that the incomes of people living near hazardous waste facilities were lower than the incomes ofpeople living farther away. Two studies presented data showing that the incomes of people living near facilities were not significantly different from the incomes of people in the comparison area Thetwo remaining studies each reported multiple conclusions depending onthe methodology used. Thevaried results ofthe studies could have been influenced bythe fact that they examined avariety of types of facilities, were intended to answer different research questions, and used different sample sixesand methods. An important limitation of these studies, aswell aswith GAO'Sstudy of nonhazardous municipal landfills, isthe assumption that proximity to a facility correlates to potential health risks. This assumption may not always hold true atspecific locations.

Page 4 GAO/RCED-95-84 Demographics of People Near Waste Facilltke

## Federal Regulations Have Not Focusedon Environmental Justice

Few Data HaveBeen Collected onthe Health Impacts of Facilities on Minorities or Low-Income People Executive summary

Current federaI regulations require that hazardous and nonhazardous waste facilities be located in aprotective setting (e.g.,not in afloodplain or fault zone) but do not consider the demographics ofthe people living nearthe proposed facilities. Local government zoning laws are more likely to influence the proximity of pollution sources to people by regulating local land use. While the public may comment to EPA on environmental justice issues during the process for issuing operating permits for hazardous and nonhazardous facilities, EPA’S public participation requirements do not specify that environmental justice be addressed. EPA’S process for issuing permits generally begins after asite hasbeen approved by state or local governments. In 1994,EPA proposed new regulations that would require applicants for operating permits for hazardous waste facilities to notify the public before submitting the application to EPA andto conduct aninformal public meeting, The proposal also asksfor public comment on how EPA can address environmental justice in the context of public participation in decisions about hazardous waste facilities.

EPA estimates that many hundreds of nonhazardous municipal landfills and hazardous waste facilities havecontaminated the groundwater, soil, and air, thereby potentitiy exposing people to harmful chemicals. EPA’S risk models, however, project low rates of additional deaths from cancer asa result of exposure to these facilities. Few data exist to document harmful health effects of exposure to hazardous or nonhazardous waste facilities, andvirtually no work has been done to document disproportionate health effects on minorities or low-income people. The 1994executive order on environmental justice caUs for EPA and other federal agencies to ensure that all potentially affected segments of the population-including minorities and low-income people-are represented in research on health and the environment. EPA’S final strategy in response to the order was not available asof March 1995, 

# Recommendations Agency Comments GAO is making no recommendations in this report,

EPA provided comments on a draft of this report. EPA commented that the draft report left the impression that the location ofwaste facilities isthe primary focus of environmental justice and that the report should make

Page 6 GAO/RCED-96-94 Demographics of People Near Waste FacilitiesExecutive Summary

clear that environmental justice relates to abroader setof issues, GAO agrees that environmental justice involves broader issues and hasfurther clarified the report on this point. EPAsuggested that GAOclarify its discussion ofthe requirement in the 1994executive order that federal agencies collect demographic data for areas around certain facilities and sites. GAOhas made this clarification. EPAalso suggested that GAOclarify the federal, state, and local roles in the process for selecting sites and granting permits to RCRAfacilities. GAOhasemphasized the roles ofthe various government agencies in the report asappropriate. The full text of EPA'Scomments and GAO'Sresponses to them are provided in appendix VIII.

Page 6 GAOIRCED-95-84 Demographics of People Near %ate Faciliti~Page 7 GAO/RCED-95-84 Demographics oPPeople Near Waste Facilities

# Contents

Executive Sun-u-nary Chapter 1 Introduction

Chapter 2 Environmental Justice-An Evolving Issue



# Minorities and EPA’s Efforts to Address Environmental Justice Executive Order Directs Federal Agencies to Develop Environmental Justice Strategies Objectives, Scope, and Methodology Agency Comments
Populations Near Municipal Landfills Were More Likely to Havea Higher Percentage of Nonminorities Than Rest of County 21 

# Low-Income People Incomes Near Municipal Landfills Were Higher Than Incomes in 27 

# Were Not Restof County asOften asThey Were Lower 

# Disproportionately Represented Near the Majority of Nonhazardous Municipal Landfills Chapter 3 33 

# Past Environmental Studies of Hazardous WasteSitesHaveYielded Varied Results 34 Different Study Questions and Methodologies Used May Have 41 

# Justice Studies of Ledto Varied Results 

# WasteFacilities Have Direct Comparison 3etween Results of Our Study and Others Is 45 

# Yielded Varied Difficult Attempts to Examine Trends OverTime 46 

# Conclusions Observations 47

Page 8 GAO/RCED-95-84 Demographic8 of People Near Waste FacilitiwContents



# Chapter 4 49 

# EPAk Regulations for EPA’s Siting Standards for Hazardous and Nonhazardous Waste 49 Facilities 

# Site Selection and EPA’s Current Regulations on Public Participation 52 

# Public Participation Have Not Addressed Environmental Justice, but Changes Are Being Considered Chapter 5 Data on Health 56 Federal Efforts to Determine Health Effects of Waste Facilities on Minorities and Low-Income Peoule 56 

# Effects of Waste Facilities on Minorities and Low-Income People Demographic Conditions and Risk-Reiated Characteristics at Municipal Landfills in Our Survey EPA’sAttempts to Assess Health Risk of Nonhazardous and Hazardous Waste Facilities on General Population 58 59 

# Appendixes Appendix I: Methodology for Analysis of Municipal Landfills Appendix II: Overview of Municipal Solid Waste Landfills Surveyed Appendix III: People Living Near Municipal Landiills Were Likely to Have Poverty Rate Similar to or Lower Than Rate in Restof County Appendix TV:Relative Differences Between People Within 1Mile of Landffls and in Rest of County Appendix V:Cross-Tabulations of Income and Poverty Rate of People Within 1Mile of Landfills and in Rest of County, by Race Appendix VI: Results From GAO’s Survey on Public Participation at Municipal Landfills Appendix VII: Cross-Tabulations of Demographic Data and Landfill Characteristics Appendix VIII: Comments From the Environmental Protection Agency Appendix Ix: Major Contributors to This Report 62 70 72

78 88 103 106 116 120 

# Tables Table 3-l: Summary of Conclusions of Demographic Studies 34

Page 9 GAO/RCED-96-84 Demographics of People Near Waste FadlitiesContents

Table I.1:Response Rate for Survey of Municipal Landfills Table III. 1:Sampling Errors for Selected Percentages and Sample Sizesof Metropolitan Landfills 64 72 Table III.2: Sampling Errors for Selected Percentages and Sample Sizesof Nonmetropolitan Landfills 73 

# Figures Figure 2.1:Metropolitan LandfIlls Where Percentage of Minorities and Nonminorities Living Within 1Mile WasHigher Than Percentage in Rest of Host County or Nation Figure 2.2:NonmetropoIitan Landfills Where Percentage of Minorities and Nonminorities Living Within 1Mile WasHigher Than Percentage in Restof Host County or Nation Figure 2.3:Degree of Difference Between People Living Within 1 Mile of Metropolitan Landfills and in Restof Host County, by Race 22

23

25 Figure 2.4:Degree of Difference Between People Living Within 1 Mile of Nonmetropolitan Landfills and in Rest of Host County, by Itace Figure 2.5:Median Household Income Within 1Mile of Metropolitan Landfills Compared With Income in Restof Host County or Nation Figure 2.6:Median Household Income Within 1Mile of Nonmetropolitan Landfills Compared With Income in Restof Host County or Nation Figure 2.7:Degree of Difference Between Median Household Income Within 1Mile of Metropolitan Landfills and Income in Rest of Host County Figure 2.8:Degree of Difference Between Median Household Income Within 1Mile of Nonmetropolitan Landfills and Income in Rest of Host County Figure 3.1: Illustrative Example of Different Boundary Areas Used in Demographic Studies F’igure I.1:Illustration of aCounty Boundary With aMunicipal Landfill and l- and 3Mile Areas Figure III.1: Poverty Rate Within 1Mile of Metropolitan Landfiis Compared With Rate in Rest of Host County or Nation Figure III.2: Poverty RateWithin 1Mile of Nonmetropolitan Landlills Compared With Rate in Restof Host County or Nation F’igure III.3: Degree of Difference Between Poverty RateWithin 1 Mile of Metropolitan Landfills and Ratein Rest of Host County 26

28

29

30

31

43 66 74 75 76

Page 10 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesContents

Figure IIL4: Degree of Difference Between Poverty RateWithin 1 Mile of Nonmetropolitan Landfills and Rate in Restof Host County Figure IV.1:Degree of Difference Between People Within 1Mile of Metropolitan Landfills and in Restof Host County, by Race Figure lV.2: Race of People Within 1Mile of Metropolitan Landfills Relative to Restof Host County Figure IV.3: Race of People Within 1Mile of Metropolitan Landfills Relative to Restof Host County Figure IV.4 Raceof People Within 1Mile of Nonmetropolitan Landfills Relative to Restof Host County Figure IV.5 Median Household Income of People Within 1Mile of Metropolitan Landfii Relative to Restof Host County Figure IV.6 Median Household Income of People Within 1Mile of Nonmetropolitan Landfii Relative to Rest of Host County Figure lV.7: Poverty Rate of People Within 1Mile of Metropolitan Landfills Relative to Restof Host County F’igure IV.8: Poverty Rate of People Within 1Mile of Nonmetropolitan Landfills Relative to Restof Host County Figure V.1:Metropolitan Landfills Where Median Household Income of Minorities and Nonminorities Living Within 1Mile Was Higher Than in Rest of Host County or Nation Figure V.2:Absolute Difference Between Median Household Income of People Living Within 1Mile of Metropolitan Landfills and in Restof Host County, by Race Figure V.3:Relative Difference Between Median Household Income of People Living Within 1Mile of Metropolitan Landfills and in Restof Host County, by Race Figure V.4:Nonmetropolitan Landfills Where Median Household Income of Minorities and Nonminorities Living Within 1Mile Was Higher Than in Rest of Host County or Nation Figure V.5:Absolute Difference Between Median Household Income of People Living Within 1Mile of Nonmetropolitan Landfills and in Rest of Host County, by Race Figure V.6: Relative Difference Between Median Household Income of People Living Within 1Mile of Nonmetropolitan LandlYIs and in Rest of Host County, by Race Figure V.7:Metiopolitan Iandfills Where Poverty Rate of Minorities and Nonminorities Living Within 1Mile WasHigher Than in Restof Host County or Nation 77

79 81 82 83 84 85 86 87 90

91

92

93

94

95

97

Page 11 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesContents

Figure V.8:Absolute Difference Between Poverty Rate of People Living Within 1Mile of Nonmetropolitan LandfiIIs and in Restof Host County, by Race Figure V.9:Relative Difference Between Poverty Rate of People living Within 1Mile of Metropolitan LandflUs and in Rest of Host County, by Race Figure V.10:Nonmetropolitan Landfills Where Poverty Rate of Nonminorities and Minorities Living Within 1Mile WasHigher Than in Restof Host County or Nation Figure V.11:Absolute Difference Between Poverty Rate of People Living Within 1Mile of Nonmetropolitan Landfills and in Restof Host County, by Race Figure V.12:Relative Difference Between Poverty Rateof People Within 1Mile of NonmetropoIitan Landfills and in Rest of Host County, by Race Figure VII.1: Landfills Where Percentage of Minorities or Nonminorities Living Within 1Mile WasHigher Than Percentage in Rest of Host County, Stratified by Type of WasteAccepted Figure VIE?: LandfiIls Where Percentage of Minorities or Nonminorities Living Within 1Mile WasHigher Than Percentage in Rest of Host County, Stratified by Presence of Lined Waste Cells Figure VII.3: Landfills Where Percentage of Minorities or Nonminorities Living Within 1Mile WasHigher Than Percentage in Restof Host County, Stratified by Presence of Leachate Collection Systems Figure VII.4: LandfiIls Where Percentage of Minorities or Nonminorities Living Within 1Mile WasHigher Than Percentage in Rest of Host County, Stratified by Groundwater Contamination Figure VI1.S:LandfilLs Where Percentage of Minorities or Nor-minorities Living Within 1Mile WasHigher Than Percentage in Rest of Host County, Stratified by Presence of Groundwater Monitoring 98

99

loo

101

102

108
110

112

113

115

Page 12 GAO/RCED-96-84 Demographics of People Near Waste FacilitiesContents

Abbreviations

ATSDR Agency for Toxic Substances and Disease Registry CERCLA Comprehensive Environmental Response, Compensation,

EPA GAO NIEHS NPL RCRA USGS and Liability Act of 1980

Environmental Protection Agency General Accounting Office National Institute of Environmental Health Sciences National Priorities List Resource Conservation and Recovery Act of 1976 United StatesGeologkal Survey

Page 13 GAO/RCED-Bls-84 Demomphkaof People Near Waste FacllltlceChapter 1 

# Introduction

The issue of environmental justice-the question ofwhether minorities and low-income people bear adisproportionate burden of exposure to toxic pollutants and any resulting health effects-has beenthe subject of growing concern over the past decade. The issue hasbecome one ofthe top priorities ofthe Environmental Protection Agency (EPA), and following the issuance ofthe administration’s executive order on environmental justice in early 1994,many federal agencies are now required to consider environmental justice in administering their programs. 

# Environmental Justice-An Evolving Issue The environmental justice movement gained national prominence in 1982 when ademonstration took place against the location, or “siting,” of a hazardous waste landfill in Warren County, North Carolina, acounty with apopulation that ispredominately African American. In response to complaints, the then-chairman, Subcommittee on Commerce, Transportation, and Tourism, House Committee on Energy and Commerce, and then-Delegate Walter Fauntroy ofthe District of Columbia requested that we investigate the relationship between siting, race, and income for the four commercial hazardous waste landfills located in EPA'S Region IV in the southeastern United States.In June 1983,’we reported that for three of the four 1andfG surveyed, African Americans made up the majority ofthe population living nearby. In addition, at least 26percent of the population in all four communities was below the poverty level. In 198’7, the United Church of Christ published anationwide study ofthe association between hazardous waste facilities and the racial/socioeconomic composition ofthe communities hosting such facilities. The study, Toxic Wasteand Raceinthe United States,reported that race was the most significant factor among the variables tested in association with the location of commercial hazardous waste facilities regulated under the Resource Conservation and Recovery Act (RCRA).The study found that the communities with the greater number of commercial hazardous waste facilities had the highest percentages of racial and ethnic minorities asresidents. According to the study, while the economic status (measured by household income and housing values) of residents in the host communities appeared to play an important role in the Iocation of commercial hazardous waste facilities, the race of the residents proved to be more significant.

‘Siting ofHazardous

WasteLandfk andTheir Correlation WithRacial and Economic Statusof Surrounding Communities (GAO/‘RCED-83-1133, June 1,1983).
Page 14 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesChapter 1 Introduction



# EPA’sEfforts to In response to these growing concerns, in July 1990EPAestablished the 

# Address Environmental Equity Workgroup to review whether racial minorities and low-income people bear adisproportionate burden of environmental risk 

# Environmental Justice and to develop recommendations accordingly. InJune 1992,the Workgroup issued its final report: Environmental Equity: Reducing Risk for All Communities. The group concluded that racial minorities and low-income people were disproportionately exposed to lead, selected air pollutants, hazardous waste facilities, contaminated fish, and agricultural pesticides in the workplace. EPA'Sreport stated that the information available on the environmental risk was limited but outlined anagenda for EPAto help better define the problem. Among its recommendations, the report saidthat EPAshould establish mechanisms, along with the necessary staff and resources, to help ensure that concerns about environmental justice are incorporated into the agency’s long-term planning and operations. To this end,in November 1992EPAestablished anOffice of Environmental Equity, which was renamed the Office of Environmental Justice in 1994.The office servesasthe agency’s point of contact for outreach, technical assistance, and information on environmental pollution affecting racial minorities and low-income communities. Complementing the activities of the Office of Environmental Justice are (1) an Executive Steering Committee, (2) a Policy Working Group, and (3) acore of environmental justice coordinators in program offices in EPA'Sheadquarters and in all regional offices. The Executive Steering Committee, made up of deputy assistant administrators and deputy regional administrators, isto provide direction onstrategic planning to ensure that environmental justice isincorporated into the agency’s operations. The Policy Working Group’s objective isto ensure policy development and coordination of environmental justice projects across the agency’s program offices. Environmental justice coordinators are to provide education and information about environmental justice in their offices and regions. EPAhasalso established the National Environmental Justice Advisory Council, under the authority ofthe Federal Advisory Council Act, to advisethe Administrator of EPAon environmental justice issues. Many of EPA'Soffices and regions are developing action plans for environmental justice, conducting conferences and workshops, and undertaking research onthis issue. For example, in April 1994EPA'SOffice of Solid Waste and Emergency Response issued atask force report on environmental justice addressing how hazardous and solid waste

P4xge16 GAOIRCED-96-84 Demographics of People Near Waste FacilitiesChapter 1 Introduction

management programs in EPA could better address the concerns of minorities and/or low-income people. 

# Executive Order A On February 11,1994,the President issued Executive Order 12898,entitled 

# Directs Federal Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations. Among other things, the order requires 

# Agencies to Develop federal agencies to develop acomprehensive strategy for making 

# Environmental Justice environment+l justice apart oftheir decision-making and operations. 

# Strategies The order applies to specified federal agencies and others designated by the President that conduct any federal program or activity that substantially affects human health or the environment. Theseactivities are asdiverse asremoving lead from public housing, controlling pollution in urban rivers, licensing hazardous waste incinerators, and regulating farm workers’ exposure to pesticides. The order established an Interagency Working Group on Environmental Justice composed ofthe heads ofvarious federal agencies. The working group ischarged with, among other things, providing guidance to agencies on identifying environmental justice problems; worldng with agencies to develop strategies to ensure environmental justice; and coordinating health research, data collection, and analysis. Periodic reports to describe the implementation ofthe order are also required. To implement the order, task forces have been established on (1) research and health, (2) outreach, (3) data collection, (4) enforcement and compliance, (5) implementation, (6) Native Americans, (7) definitions and standards, and (8) interagency projects. 

# Objectives, Scope, and Methodology At the request ofthe Ranking Minority Member of the SenateCommittee on Governmental Affairs and Representative John Lewis, we agreed to obtain information onthe demographics of people living near waste facilities. In discussions with the requesters’ offices, we agreed to provide the following:

l information on the racial and income characteristics of people living near anationwide sample of nonhazardous municipal solid waste landfills;

l asummary of the results of other studies conducted by EPA, industry, and academia on the demographics of people living near waste facilities, primarily ones for hazardous waste;

Page 16 GAO/RCED-96-M Demographics of People Near Waste FacilMesChapter 1 Introduction

l information onthe extent to which WA addresses environmental justice in its requirements for selecting sitesand soliciting public participation in the process of building solid and hazardous waste facilities; and

l information onthe datathat have been collected on the potential health effects ofsolid and hazardous waste facilities on minorities and low-income people living nearby. To obtain general information about the nation’s municipal solid waste landfills and make national estimates about this information, we conducted asurvey of 500metropolitan and 500nonmetropolitan landfills. Wereceived 791responses, ofwhich 623were usable. Most of the responses we could not usewere from landfills that did not meet our criteria of being nonfederal municipal landfills that were open during 1992. Wereceived the majority ofthe responses in early 1994.More details on how we conducted this survey are included in appendix I,and details of some ofthe general information we collected are in appendix II. To specifically address the first objective onthe racial and income characteristics ofpeople living near nonhazardous municipal solid waste landfills, we added several questions to the original survey for asubsample of300metropolitan and 150nonmetropolitan landfills to determine their location. The subsample was taken to provide amanageable workload that, because of our sample design, would allow usto make national estimates about the characteristics of people living near metropolitan and nonmetropolitan landfills ascompared with those residing in the rest of the county. Wereceived responses from 259metropolitan and 124 nonmetropolitan landiills, ofwhich 190and 105were usable because they fit our criteria of being nonfederal facilities that had accepted municipal waste and were operating in 1992.Using ageographic information system computer program in conjunction with 1990data from the U.S.Bureau of the Census, we collected data onthe racial2and income characteristics of people living within 1and 3miles ofthe 295landfills and compared these with the characteristics of people living in the rest ofthe county asa whole.3 This comparison enabled usto determine whether minorities and/or poor people aremore or less likely than nonminorities and/or higher-income people to live near nonhazardous municipal landfills. A

%Iouranalysis ofrace,“nonminorities” includes aI whites notof Hispanic origin and“minorities” includes allothers. Inouranalysis ofincome andpoverty status, ‘minorities” excludes whites of Hispanic origin. Thisapproach wasusedbecauseof thewaythe U.S.Bureauofthe Censusprovides dak?tothe public. “Asweexplain inchapter 2,the results ofouranalysis ofpeople within 3miIesof landfills were comparable tothoseofour l-mile analysis andarenot included inthis report.

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Chapter 1 Introduction

more detailed summary of our approach and methodology for this objective iscontained in appendix I. To address the second objective of summarizing studies done by others, primarily onthe demographics ofpeople living near hazardous waste facilities, we undertook aliterature search to identify relevant studies on the extent to which racial minorities or poor people aremore likely than nonminorities or higher-income people to havewaste facilities in their communities. Welimited our search to studies of either anational or regional scope that had been conducted since 1986on nonhazardous and hazardous waste disposal, treatment, or storage facilities. Weidentified 10 studies of hazardous waste facilities that met our criteria Thesestudies had been conducted by EPA, academia, advocacy organizations, and industry. Only 2ofthe 10studies also addressed nonhazardous waste facilities. Wesummarized the results and conclusions that the authors presented and the methodologies and assumptions they usedto conduct their analyses. Asummary ofthe studies is contained in chapter 3.An expanded version of our summaries is contained in our report entitled 10 StudieS on Demographics Near WasteFacilities (GA@‘RcED-95158R, June 13, 1995). To address the third objective on the extent to which EPA addresses environmental justice in its siting and public participation requirements, we reviewed the relevant policies, regulations, and guidance for the RCRA program that outline the requirements with which owner/operators of municipal and hazardous waste facilities must comply in order to construct and operate their facilities. Wealso reviewed the requirements for public participation outlined inthe February 1994executive order on environmental justice and arule proposed by EPA in June 1994on public participation. In addition, we examined a 1994study conducted on behalf of EPA onthe states’ regulations for siting hazardous waste facilities. For the fourth objective concerning efforts to assessthe potential health effects of living near municipal and hazardous waste facilities, we reviewed relevant literature and interviewed officials at EPA andthe Department of Health and Human Services. Under the executive order on environmental justice, EPA andthe Department of Health and Human Services share alarge part ofthe responsibility for research onthe relationship between the environment and human health. Among other information, we reviewed the detailed data on health that EPA usesto support its current regulations for regulating municipal and hazardous waste facilities.

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IChapter 1 Introduction

Our survey of landfills also gathered information on design characteristics and other factors that could be indicators of potential risk to people living nearby. Wecross-tabulated the demographic data from the l-mile areas with several of these characteristics, including the useof protective liners, leachate (liquid that percolates through landfills) collection systems, and groundwater monitoring. The purpose was to determine whether or not minorities or low-income people were disadvantaged with respect to the presence ofthese characteristics. Wediscuss the results ofthis effort in appendix VII. Weconducted our review between February 1993and March 1995in accordance with generally accepted government auditing standards. 

# Agency Comments EPA provided written comments on adraft ofthis report. Thefull text of these comments, along with our responses, ispresented in appendix VIII. EPA commented that the draft gavethe impression that the issue of environmental justice islimited to the location of hazardous and nonhazardous waste facilities and that the report should make clear that environmental justice relates to abroader setof issues.Weagreethat the issue isbroader and have made changesto clarify that point.

EPA also commented on how we described the 1994executive order on environmental justice. In particular, EPA pointed out that the order addresses more than hazardous and nonhazardous waste facilities and suggested that we clarify our description ofthe order’s requirement that federal agencies collect and analyze demographic data around facilities and sites.Wehave made changes to reflect these comments.

EPA also saidthat the agency iscontinuing to develop analytical tools for addressing environmental justice and that it would bepremature to suggest that the methodology we usedto analyze the demographics of people living near nonhazardous waste facilities was an established methodology. Werecognize that there are limitations to our methodology and identify them throughout the report. Finally, EPA

suggested that we clarify the different roles that it and local governments have in regulating the selection of sites for RCRA facilities. The agency also pointed out that current regulations allow the public to comment on environmental justice and other issues related to proposed actions in granting permits for RCRA facilities. Wehavemade changes to the report to clarify these points.

Page 19 GAOAZCED-95-84 Demographics of People Near Waste FacilitiesChapter 2 

# Minorities andLow-Income PeopleWere Not Disproportionately Represented Near the Majority of Nonhazardous Municipal Landfills Wefound that the percentage of minorities and low-income people living within 1mile of nonhazardous municipal landfills was more often lower than the percentage in the rest of the county. Whenthe datafrom our sample were used to make estimates about alI nonhazardous municipal landfills in the nation, neither minorities nor low-income people were overrepresented near lanrlt”llls in any consistent manner. Wecompared the percentage of minorities and nonminorities living within 1mile of municipal landfills with the percentage inthe rest ofthe county andthe nation. Wealso examined the difference between the median household incomes of the people within 1mile and the people inthe rest ofthe county and the nation.l If minorities or low-income people were subject to environmental inequity, the comparisons should show more municipal landfills with ahigher percentage of minorities or low-income people living nearby than were living in the rest ofthe county. Again, this was not the case. Weconducted similar analyses ofthe populations within 3miles of the landfills and arrived at results that were comparable to the results for the l-mile area Consequently, the data for people living within 3miles are not included in this report. The data presented in this chapter describe the populations within 1mile of one type of waste facility-nonhazardous waste municipal landfiis. These data provide information only about populations nearthat type of facility. Nonhazardous municipal landfills aretypically owned and operated by local governments, although asubstantial number are owned by private companies. The majority of the waste sent to these facilities is household and commercial garbage and nonhazardous industrial waste. Despite the useof the term Ynonhazardousnto describe these landl?lls, a small amount of hazardous waste from households and industry can be legally disposed of in them. (Seeapp. II for more detail on certain characteristics of municipal landfills.) Overthe years, the regulations on how landfills are designed and constructed have become more protective. EPA regulations promulgated in 1993require that newly built municipal landfills haveliners, leachate collection systems, and groundwater

‘In addition, weexamined (I) thepovetty ratesofpeople Iiving within 1mile of landfills, (2)the relative difference between the incomes andpoverty ratesof people living within 1mile ofthe landfills andinthe restofthe county, and(3)the waytheincome andpoverty ratesofpeople living near landfills broke out by race,Thesedata arepresented inappendixes III, IV,andV,respectively. %achate isliquid originating from precipitation, groundwater, orfrom the wasteitself that flows through alandfill. It may be released into gmundwater unlessit iscaptured byacollection system. It mayalsobecontaminated with hazardoussubstancesleached from the waste.
Page 20 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesChapter 2 Minorities and Low-Income People Were Not Disproportionately Represented Near the Msjority of Nonhazardous Municipal Landfilb

monitoring. When landfills arefilled they must be closed in amanner designed to minimize the release of leachate.

- 

# Populations Near Nonminorities made up 80and 84percent of the population within 1mile 

# Municipal Landfills WereMore Likely to Have aHigher Percentage of Nonrnino>ties Than Restof County of metropolitan and nonmetropolitan municipal landfills, compared with the 1990national averagesof 73and 85percent, respectively.3 The populations near landtIlls often hadahigher percentage of nonminorities than the rest ofthe county in which the landGIl is located (hereafter referred to asthe host county). Furthermore, we found very little difference between metropolitan and nonmetropolitan areas in terms of the racial composition ofthe people living near landfills relative to the people in the rest ofthe county. Figures 2.1and 2.2show how often the percentage of minorities and nonminorities living within 1mile ofthe metropolitan and nonmetropolitan landfills was higher than the percentage of minorities and nonminorities in the rest ofthe county and the nation. Asthese figures show, the percentage of nonminorities living near both metropolitan and nonmetropohtan land6Jls was generally higher than the percentage living in the rest ofthe county and the nation. Similady, the percentage of minorities was lower more often than not.

3Thepeople living withii 1mile of metropolitan andnonmetropolitan landfills were compared with those living inall metropolitan andnonmetropolitan counties inthe restof the nation, respectively.

Page 21 GAWRCED-96-84 Demographics of People Near Waste FacilitiesChapter 2 Minorities and Low-Income People Were Not Disproportionately Represented Near the Majority of Nonhazardous Municipal Landfills

Figure 2.1: Metropolitan Landfills Where Percentage of Minorities and Nonminorities Living Within 1Mile Was Higher Than Percentage in Rest of Host County or Nation 100 Percentrgo of Landfills 90 80
70 60
50 40
30 20 10 T: 3

ComparedWith HostCounty 

# 8 I 8 I 9 Compared With National Average.

Note: N = 190.
The national average for metropolitan areas is 73 percent nonminority. The data in figure 2.1and all ofthe figures that follow represent the findings from our sample of landfills. National estimates cannot be accurately madewithout applying amargin of error. The approximate sampling errors (which range from 3to 10percent) can befound in tables III. 1and III.2 in appendix III and should beapplied to the data in each figure. For example, in figure 2.1,27 percent of the landfills had a percentage of minorities within 1mile that was higher than the percentage in the rest ofthe county. Using 27percent and asample sizeof 190,the sampling error from table III.1for figure 2.1isapproximately 5percent. By applying this approximate sampling error, we can estimate that between 22and 32percent of metropolitan landfills nationwide had apercentage of minorities that was higher than the percentage in the rest ofthe county.

Page 22 GAO/RCED-96-M Demographics of People Near Waste FacilitiesChapter 2 Minorities and Low-Income People Were Not Disproportionately Represented Near the Majority of Nonhazard ous Municipal LandfUb

Asfigure 2.2shows, we estimate that 37percent of nonmetropolitan 1andIUs had apercentage of minoriti& living nearby that was higher than the percentage in the rest ofthe county. Weestimate that 32percent of nonmetropolitan landfills had apercentage of minorities living nearby that was higher than the percentage of minorities in nonmetropolitan areas nationwide.
Figure 2.2: Nonmetropolitan Landfills Where Percentage of Minorities and Nonminorities Living Within 1Mile Was Higher Than Percentage in Rest of Host County or Nation 100 Percentage of lmdfillr 90 80 70 60 50 40 36 20 IO 0

Compared With Host County

Note: N = 105. Compared With National Average*

*The national average for nonmetropolitan areas is 85.1 percent nonminority. Wealso found that in thevast majority of cases,the racial differences between those living near a1andf1U and those in the rest ofthe host county were not significant. That is,the percentage of minorities or nonrninorities

Page 23 GAO/RCED-95-84 Demographica of People Near Waste FacilitiesChapter 2 Minorities and Low-Income People Were Not Disproportionately Represented Near the Majority of Nonhazardous Municipal Landfllls

living within 1mile of the landfills was not significantly higher or significantly lower than it was inthe host county.4 Figures 2.3and 2.4show how much the percentage of minorities or nonminorities living near alandfill differed from the percentage ofthese groups in the host county. For example, figure 2.3shows that for 62percent of metropolitan landfills, the difference between both the minority and nonminority populations in the l-mile areaand the rest ofthe county was not significant (less than 10percent). Asthe figure alsoshows, there were few landfills-about 13percent-where the percentage of minorities living within 1mile was significantly higher than it was in the host county.

4Forpurposesoftheanalysis inthis report, weconsidered differences of 10percent or moreas significant.
Page 24 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesChapter 2 Minorities and Low-Income People Were Nat Disproportionately Represented Near the Majority of Nonhazardous Municipal Landfills

Figure 2.3: Degree of Difference Between People Living Within 1 Mile of Metropolitan Landfills and in Rest of Host County, by Race 100 Perwntags of Landfills 90 00 70 60 50 40 30 20 10 0

Comparison of Nonminorities Comparison of Minorities

Note: N = 190

aThe percentage in the 1-mile area is at least 10 percent less than the percentage in the rest of the host county. bThe percentage in the l-mile area is at least 10 percent more than the percentage in the rest of the host county. Asfigure 2.4shows, for nonmetropolitan landfills, anevenlarger percentage--over 70-showed adifference in racial makeup of lessthan 10percent when compared with the host county. And evenfewer ofthese nonmetropolitan land6Us-about 9percent-had asignificantly higher percentage of minorities living nearby than the rest of the county.

Page 26 GAO/RCED-96-84 Demographics of People Near Waste FacilitbChapter 2 Minorities and Low-Income People Were Not Disproportionately Represented Near the MJority of Nonhazardous Municipal Landfills

Figure 2.4: Degree of Difference Between People Living Within 1Mile of Nonmetropolitan Landfills and in Rest of Host County,byRace 100 Percentage of Lmdfitls 90 60 70 60 50 40 30 20

Comparison of Nonminorities Comparison of Minorities

Note: N = 105
“The percentage in the i-mile area is at least 10 percent less than the percentage in the rest of the host county. bThe percentage in the l-mile area is at least 10 percent more than the percentage in the rest of the host county Two examples of specific landfills help to illustrate the figures above. One landfill that fell in the middle category (where the percentage of nonminorities was not significantly different than the nonminority population in the rest ofthe county; in other words, within 10percent more or lessthan the rest ofthe county) isin ametropolitan area in a northeastern county with over 330,000people. Thepopulation in the l-mile area near the landfill was 97percent nonminority, while the population in the rest ofthe county was 96percent nonminority. Another urban landfll in asouthwestern county of almost 600,000people showed a significant racial difference. While the population in the l-mile area around

Page 26 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesChapter 2 Minorities and Low-Income People Were Not Disproportionately Represented Near the Majority of Nonhazardous Municipal Landfills

that landfill was 61percent nonminority and 39percent minority, the population in the rest ofthe county was 75percent nonminority and 25percent minority-a difference of 14percent. The people living near our sample of municipal landfills were more likely to be nonminorities than minorities relative to the rest ofthe host county in all regions ofthe country. Wedivided the country into four regions: Northeast, South/Southwest, Midwest, and West.Wedid not havealarge enough sample of landfills in each region to make regional estimates. Therefore, our conclusions about individual regions can only reflect conditions atour sample of landfills within those regions. In each region, a mqjority ofthe landfills had larger percentages of nonminorities Iiving within 1mile than lived in the rest ofthe county. However, the degree to which this was true differed from region to region. For example, in the Northeast, 81percent of metropoIitan and 53percent of nonmetropolitan landfills had higher percentages of nonminorities living within 1mile than lived in the rest ofthe county. In the South/Southwest, 60percent of metropolitan and 61percent of nonmetropolitan 1andfiIIshad higher percentages of nonminorities living within 1mile than lived in the rest of the c~unty.~ 

# Incomes Near Municipal Landfills WereHigher Than Incomes in Rest of County asOften as They WereLower Low-income people were not overrepresented near municipal landfills relative to people in the rest ofthe county. Thepeople living near metropolitan landfills were more likely to havehigher incomes relative to those in the nation than were the people living near nonmetropolitan landfills. Figures 2.5and 2.6compare the median household incomes of the people living within 1mile of metropolitan and nonmetropolitan landfills with those of the people in the rest of Ihe county and the nation. These figures show that in both metropolitan and nonmetropoIitan areas, the people near landfills had median household incomes that were higher than the incomes in the rest ofthe county asoften asthey had incomes that were lower. The people living near metropolitan landfills were about aslikely to have median household incomes higher than the national median for metropolitan areasasnot. However, the people living near nonmetropolitan landfills were more likely to haveincomes lower than the national median for nonmetropolitan areas.

5Wedefined the four regionsonthe basisof EPA’sregions.The Northeast included the statesin EPA’s Regions I,II, and III. The South/Southwest included thestatesin EPA’sRegions IVandVI.The Midwest included thestates in EPA’sRegionsV,VII, andVIII. TheWestincluded thest.atesin EPA’s RegionsIXandX The number of metropolitan andnonmetropolitan landfills in thefour regionswere asfollow: Northeast, 67metropolitan and 17nonmetropoktn landfills; SoutWSouthwest,60and36; Midwest, 29and23;West,34and29.
Page 27 GAO/RCED-95-84 Demographics of People Near Waste FacititiesChapter 2 Minorities and Low-Income People Were Not Disproportionately Represented Near the Majority of Nonhazardous Municipal Landfills

Figure 2.5: Median Household Income Within 1Mile of Metropolitan Landfills Compared With Income in Rest of Host County or Nation 100 Percentage of Landfills 9.

60 70 60 64 50 46 40 30 20 10 0 ElPercent Percent Percent Percent Where Where Where Where Income Income Income Income IS IS IS IS Higher Lower Higher Lower Compared With Compared With Host County National 54 46 

# la

Note- N = 190.

aThe national median for metropolitan areas is $32.086.

Page 28 GAO/RCED-9584 Demographics of People Near Waste FacilitlwChapter 2 Minorities and Low-Income People Were Not Disproportionately Represented Near the Majority of Nonhazardous Municipal tandfilts

Figum 2.6: Median Household Income Within 1 Mile of Nonmetropolitan Landfills Compared With Income in Rest of Host County or Nation 100 Percentage of Landfills 90 60 70 60 50 40 30 20 10 0 65
52 40
35

Kl II Percent Percent Where Where Income Income IS Is Higher Lower Compared With Host County Percent Percent Where WllSl-3 Income Income Is IS Higher Lower Compared With National Median.

Note: N = 105.
BThe national median for nonmetropolitan areas is $23,075. Figures 2.7and 2.8show the degree of difference between the median incomes of the people living within 1mile of landfills and the incomes of people in the rest ofthe county. The people near nonmetropolitan landfills were lesslikely to have median household incomes that differed significantly from incomes in the rest ofthe county than were those living near metropolitan landfills. As figure 2.7shows, the incomes of the people living near metropolitan landfills were significantly lower than those ofthe people in the rest of the county about 21percent ofthe time and significantly higher about 31percent ofthe timen Meanwhile, asfigure 2.8 shows, the incomes ofthe people living near nonmetropolitan landfills were significantly lower than those of the people in the rest of the county 9percent ofthe time and significantly higher 22percent ofthe time.

“For the purposes of this analysis, we define asignificant difference in median household income as one greater than $5,000. App. III contains figures showing the relative difference between income6 of people within Iiving within 1mile of landfills and people living in the rest of the county.

Page 29 GAO/RCED-96-84 Demographics of People Near Waste FacilitiesChapter 2 Minorities and Low-Income People Were Not Disproportionately Represented Near the Majority of Nonhazardous Municipal Landfills

Figure 2.7~Degree of Difference Between Median Household Income Within 1Mile of Metropolitan Landfills and Income in Rest of Host County 100 Percentage of Landfills 90 80 70 60 50 48 40 31 30 21 20 10 0 Loi

Note: N L 190

aThe median household income of the people in the l-mile area was at least $5,000 less than the median household income in the rest of the host county. bThe median household income of the people in the 1-mile area was at least $5,000 more than the median household income in the rest of the host county.

Page 30 GAO/RCED-96-84 Demographics of People Near Waste FacilitiesChapter 2 Minorities and Low-Income People Were Not Disproportionately Represented Near the Majority of Nonhazardous Municipal Landfills

Figure 2.8: Degree of Difference Between Median Household Income Within 1Mile of Nonmetropolitan Landfills and Income in Rest of Host County 100 Percentage of Landfills 90 80 70 60 50 40 30 20 -

Note 1: N = 105 Note 2: Percentages do not add to 100 percent because of rounding

aThe median household rncome of the people in the l-mile area was at least $5,000 less than the median household income in the rest of the host county. bThe median household tncome of the people in the i-mile area was at least $S,COOmore than the median household income in the rest of the host county. While median household income isone indicator of people’s economic status, poverty rates-whether aperson’s income is below the national definition of poverty7-is another indicator. In our survey, we found that the people living near municipal landfills were not likely to havehigher poverty rates than the people in the rest of the county. The datafrom this analysis are presented in appendix III.

7’Poverty” is defined by the U.S. Bureau of the Census as an individual or family income below a certain amount. In 1990,this amount, known as the poverty line, was $6,310 for an individual and $12,674 for a nonfarm family of four. In our analysis, we used the census data for individuals below the poverty line.

Page 31 GAO/&CED-96-84 Demographics of People Near Waste FacJUtJesChapter 2 Minorities and Low-Income People Were Not Disproportionately Represented Near the Majority of Nonhazardous Municipal Landfills

Wealso examined the median income and poverty status ofthe people living near landfills by race. Our data did not indicate that either low-income minorities or low-income nonminorities living near landfills were disadvantaged relative to minorities and nonminorities living in the rest ofthe county. These data are presented in appendix V.

Page 32 GAO/RCED-96-94 Demographics ofPeople Near Waste FacllltiesChapter 3 

# PastEnvironmental Justice Studies of Waste Facilities HaveYieldedVaried Conclusions

Wesummarized 10demographic studies that focused onthe populations around several types of waste facilities. These studies were conducted by EPA, academia, advocacy organizations, and industry.’ Thestudies varied in their conclusions regarding whether minorities or low-income people have adisproportionate number ofwaste facilities in their communities. For example, while several ofthe studies concluded that minorities or low-income people bear adisproportionate burden, others concluded that they do not. Somestudies, depending onthe type of analyses conducted, had mixed results regarding whether minorities or low-income people were disproportionately burdened by the presence ofwaste facilities in their communities, An expanded version of our summaries is contained in our report entitled 10Studies on Demographics Near WasteFacilities (GAOIRCED-95158R, June 13,19%). Thevariety of methodologies used in the studies appears to have influenced their results. The researchers focused on different types of facilities, including landfills, incinerators, storage, and treatment sites. In addition, the researchers applied different definitions of minorities and of the affected areaaround the facilities. None ofthe 10studies-nor our work with nonhazardous land-accounted for changes that may have occurred in the demographics around the facilities between the time the facilities were sited andthe period that the studies addressed. Specifically, they did not address whether the presence of the facility contributed to current residential patterns around it. While it is important to determine the current demographic condition around waste facilities, it isalso important, when addressing environmental justice issues,to know the conditions at the time the facilities were built and how they have changed over time. Generally, these studies, aswell asour own analysis of nonhazardous landfills, eachfocused on one category of facility and did not attempt to account for the cumulative effects of all types of pollution sources within particular communities. Such ananalysis could provide amore complete picture ofthe burden of pollution sources imposed onvarious demographic groups, including minorities or low-income people.

‘The studiesexamined avariety of locations where hazardousandnonhazardous waste isfound, including hazardousand nonhazardouswaste facilities regulated under RCRA; hazardouswastesites regulated underthe Comprehensive Environmental Response,Compensation, and Liability Act of 1980 (CERCLA),asamended; and cement plants. Inthis report, we refer totheselocations collectively as facilities orsites.

Page 33 GAO/EKED-96-84 Demographics of People Near Waste FacilitiwChapter 3 Past Environmental Justice Studies of Waste Facilities Have Yielded Varied Conclusions



# Studies of Hazardous WasteSites Have around facilities that handle hazardous waste, were regional or national in scope, and were conducted after 1986.Only two ofthe studies also 

# Yielded Varied Results examined facilities that handle nonhazardous waste. It isdifficult to generalize about the conclusions drawn bythe studies because the authors examined different universes and used different methodologies and definitions of “racial minority. “z. Table 3.1summarizes the main conclusions ofthese 10studies. In the caseofthe studies done for EPA on35commercial hazardous waste landfills and 41cement plants, we derived our own conclusions from the data gathered for the studies because the agency did not draw its own conclusions.

Table 3.1: Summary of Conclusions of Demographic Studies Number and type(s) of Study’s author and date facilities Sponsor United Church of Christ 415 RCRAa commercial United Church of Christ Commission for Racial hazardous waste Commission for Racial Justice and Public Data facilities and 18,164 Justice Access, Inc., CERCLAb “uncontrolled” 1987 toxic waste sites Main concl&ions Racetethnicity Income ZIP codes where ZIP codes where facilities were located facilities were located were more likely to have were more likely to have higher minority populations with lower populations”; incomes. race/ethnicity was a stronger indicator of proximity to waste facilities than income. Claritas, Inc. for Waste 132 RCRA hazardous Waste Management, Inc. Most ZIP codes where Not studied. Management, Inc., 1992 and nonhazardous waste facilities were located facilities operated by had a lower percentage Waste Management, Inc. of minoritiesC than the host state. E.B. Attah for EPA’s 4,855 CERCLA Region IV, 1992 hazardous waste sites EPA and Clark Atlanta University At the county level, the Not studied. study found no relationship between the number of sites and the percentage of minoritiesd At the census tracte level, the average number of CERCLA sites increased as the percentage of minorities increased. (continued)

‘In thesesummaries,we usethe terms usedbythestudies’ authors to identify population groups.
Page 34 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesChapter 3 Past Environmental Justice Studies of Waste Facilities Have Yielded Varied Conclusions

Number and type(s) of Main conclusions Studv’s author and date facilities Sponsor Racekthnicity Income ViGYAN, Inc., for EPA, 1992 35 RCRA commercial EPA In the majority of cases, Not studied hazardous waste landfills the percentages of blacks and Hispanics’ living near landfills were equal to or fess than the percentages of blacks and Hispanics living in the surrounding county. (GAO’s conclusjons based on EPA’s data.) John A. Hird, 1993 788 Superfund sites’ University of Counties with more No link was found Massachusetts-Amherst minoritiesd had more between poorer counties Superfund sites when and the number of other socioeconomic Superfund sites they factors were held contained. constant. Rae Zimmerman, 1993 814 Superfund sites EPA and New York When the author used When the author used University unweighted averages, unweighted averages, the percentages of the poverty rate in blacks and Hispanicsh in Superfund communities Superfund communities was comparable to that were lower than they in the nation. On a were in the nation. When weighted basis, the averages were weighted poverty rate in Superfund to take into account the communities was slightly communities’ population, higher but still blacks and Hispanics comparable to that in the were found to be more nation. The association of prevalent in Superfund poverty with location was communities than is less pronounced than typical of the nation. that of race/ethnicity. Center for PoLcy 530 RCRA commercial National Association for Minority populationsc in ZIP codes where Alternatives, hazardous waste facilities the Advancement of 1993 were more likely to facilities were located 1994 (update of United Colored People and live inZIP codes where Church of Christ study) were more likely to have United Church of Christ facilities are located than populations with lower Commission for Racial they were in 1980; incomes. Justice race/ethnicity was still a stronger indicator of proximity to a facility than income. Social and Demographic 454 RCRA commercial Waste Management, Research Institute, Using three different Using three different hazardous waste facilittes tnc., and the Institute for University of geographic study areas geographic study areas Chemical Waste Massachusetts-Amherst, in metropolitan areas, the in metropolitan areas, the Management authors concluded that authors concluded that 1994 there was no consistent there was no consistent national-level associatjon national-level association between the location of between the location of facilities and the facilities and the percentage of blacks percentage of and Hispanicsh living low-income people living nearby. nearby. (continued)
Page 36 GAOIRCED-96-84 Demographics of People Near Waste FacilitiesChapter 3 Past Environmental Justice Studies of Waste Facilities Have Yielded Varied Conclusions

Number and type(s) of Main conclusions Study’s author and date facilities Sponsor Race/ethnicity Income Rae Zimmerman, for EPA’s 210 Superfund sites EPA Within 1mile of the sites, Rents and housing Region II, 1994 the weighted and values were used as a unweighted mean and proxy for income. Values median percentages for within 1-mile area were minority populations’ lower than state were below or about the averages. same as the proportions in the state. ICF Inc., and ViGYAN Inc., 41 cement plants, EPA The percentage of The percentage of for EPA, 1994 including 29 that burned minoritiesC within 1and 5 people below the poverty hazardous waste as fuel miles of the plants was line within 1and 5 miles and 12 that did not. greater about as often as of the plants was greater it was less than the about as often as it was percentage of minorities less than the poverty rate in the host county. for the host county. (GAO’s conclusion (GAO’s conclusion based on EPA’s data.) based on EPA’s data.) *RCRA isthe Resource Conservation and Recovery Act of 1976,as amended, which regulates the generation. storage. treatment, disposal, and transportation of hazardous and, to some extent, nonhazardous solid waste. bCERCLAisthe Comprehensive Environmental Response, Compensation, and Liablllty Act of 1980, as amended, also known as Superfund. CERCLA “uncontrolled” hazardous waste sites refers to sites that have been listed by EPA as needing an assessment to determine whether they are serious enough to be placed on the National Priorities List for cleanup under CERCLA =ln this study, minority populations are defined as including persons of Hlspanic origin and blacks, American Indians, Asians and Pacific Islanders, Eskimos and Aleuts, and others that are nonwhite and not of Hispanic origin. No double counting of persons of Hispanic origin and racial minorities occurs. din this study, only race was analyzed. People of Hispanic origin were not analyzed. ‘The Department of Commerce’s Bureau of the Census defines census tracts as small, locally defined statistical areas in metropolitan areas and some counties. They generally have stable boundanes and an average population of 4,000. fln this study, people of Hispanic origin were analyzed independently of racial categories. Thus, Hispanics may be included Inthe data on racial minorities tosome extent. g”Superfund sites” refers to sites on the National Priorities List. They are sites that EPA has evaluated and determined should be cleaned up under CERCLA. As of December 1994, there were 1,288 sites on or proposed for the list. Yn this study. only people of Hispanic origin and blacks were analyzed. Also, because people of Hispanic origin were analyzed independently of blacks, Hispanics may be included in the data shown for blacks to some extent.

Page 36 GAOIRCED-95-84 Demographics of People Near Waste FacikfeaChapter 3 Past Environmental Justice Studies of Waste Facilities Have Yielded Varied Conclusions



## Studies ReachedVarious Conclusions About Whether Minorities Were Overrepresented Near WasteFacilities Three of the 10studies concluded that minorities were more likely to live near hazardous waste sites than nonminorities. These studies were done by the United Church of Christ/Public Data Access, Inc., the Center for Policy Alternatives, andJohn A. Hird. Two studies concluded that there was no significant association between the location of the sites and minority populations orthat minorities were lesslikely to live near sites. These studies were done for WasteManagement, Inc., and EPA'SRegion II. ViGYAN, Inc.‘s study for EPA of 35commercial hazardous landfills did not draw conclusions about the results. However, our interpretation ofthe study’s data isthat in the majority ofthe cases,the percentages of blacks and Hispanics living near the landfills were equalto or lessthan the percentage of blacks and Hispanics living in the host county. Similarly, the study done for EPAon 41cement plants did not draw conclusions about the results, but our interpretation ofthe data isthat the percentage of minorities living nearby was higher than it was in the host county about as often asit was lower. Three studies--EPA’s Region IV, RaeZimmerman, and the University of Massachusetts-Amherst-each were split asto whether minorities were disproportionately affected by the location of waste facilities. The 1987study by the United Church of Christ is credited with being the first national study of environmental justice. Part ofthe study examined RCRA commercial hazardous waste facilities across the country. It concluded that among the variables tested, race was the most significant factor related to the location of such sites;the other variables were related to income and housing values. In communities (defined asthe areawithin aresidential ZIPcode) where two or more facilities were located orwhere one ofthe nation’s largest landfills was located, the percentage of the population composed of minorities was, on average, more than three times that of communities without such facilities. In 1994,the Center for Policy Alternatives issued an update ofthe Church of Christ’s analysis of RCRA sitesthat basically confirmed the earlier findings. Onthe other hand, the 1994study by the

## group atthe University of Massachusetts-Amherst concluded that no consistent national-level association existed in metropolitan areas between the location of RCRA commercial hazardous waste facilities and the percenwe of blacks and Hispanics living nearby. The study found onevariable for which there was astrong, consistent, and often significant association with the location of a facility. This variable was the concentration of people who worked in manufacturing occupations in the census tract.

Page 37 GAO/RCED-96-84 Demographics of People Near Waste FacilitiesChapter 3 Past Environmentul Justice Studies of Waste Facilities Have Yielded Varied Conclusions

The University of Massachusetts-Amherst group examined race and ethnic@ near RCRAhazardous waste facilities in metropolitan areas.The study contained several analyses using geographic study areas ofvarying distances. The authors reported, for example, that the percentage of blacks in census tracts where facilities arelocated was about the same (14.5percent) asit was in the remaining censustracts with no facilities (15.2percent). The percentage of Hispanics in tracts with facilities was 9.4percent compared with 7.7percent for tracts without facilities; however, the difference was considered only marginaIIy significant. In contrast, when the tracts containing facilities were defined to include areas within 2.5miles ofthe sites and then compared with all the remaining tracts without facihties in metropolitan areas,the results changed dramatically. For the census tracts encompassed within 2.5miles ofthe facilities, the authors found the percentages of blacks (24.7percent) and Hispanics (10.7percent) were significantly higher than the 13.6percent for blacks and 7.3percent for Hispanics residing in the tracts without facilities. The authors concluded that their analyses showed no consistent national-level association between the location of commercial hazardous waste facilities andthe percentage of blacks and Hispanics residing nearby. Waste Management, Inc., and EPA also studied samples of RCEU commercial hazardous waste facilities. WasteManagement analyzed 132of its facilities, which included about 30commercial hazardous waste facilities. EPA commissioned astudy on the universe of35commercial hazardous waste landfills. WasteManagement concluded that the ZIP codes in which its facilities (for both hazardous and nonhazardous waste) are located had lower percentages of minorities than the host state about 75percent ofthe time, EPAdid not draw conclusions from the study conducted for the agency byViGYAN Inc., which compared populations within l/2 mile to 5 miles of the facilities with populations in the host county. Wereviewed EPA’S analyses ofthe study’s data and concluded that inthe majority ofthe cases,the data showed that the percentages of blacks and Hispanics living near the landfills were equal to or lessthan the percentages in the county. Oneof the three studies that examined sites onthe Super-fund National Priorities List concluded that minorities were more likely to live nearby. John Hird’s 1993study concluded that counties with higher concentrations of minorities had more Superfund sites when factors such asmedian housing value, poverty levels, and unemployment rates were held constant to remove them from the analysis, RaeZimmerman’s 1993study was

Page 38 GAOIRCED-95-84 Demographics of People Near Waste FacilitiesChapter 3 Past Environmental Justice Studies of Waste Facilities Have Yielded Varied Conclusions



## StudiesThat Examined Income LevelsShowed Varied Results divided onthe issue. Using asimple unweighted analysiq3 the author concluded that the percentages of blacks and Hispanics in Superfund communities were lower than those in the nation. However, Zimmerman reported that when weighted averageswere usedto take into account the communities’ population level, blacks and Hispanics were more prevalent in Superfund communities than they were in the nation. Thestudy conducted for EPA’S Region II in 1994found theweighted or unweighted mean and median percentages to be below or about the samefor minority populations living within 1mile of Superfund sites asthey were in the state(s). Several ofthe studies also covered CERCLA sites-those that EPA identified asneeding an evaluation to determine whether they should beplaced on the National Priorities List and cleaned up under the Superfund program. The United Church of Christ reported that blacks were heavily overrepresented inthe populations of the six metropolitan areaswith the most CERCLA sites. EPA’S Region lV reported that at the census-tract level, the average number of CERCLA sites increased asthe percentage of minorities increased but that atthe county level,there was no relationship between the number of sites and the percentage of minorities.
Sevenof the 10studies also examined variables related to income or poverty. Three of the sevenstudies concluded that the incomes of people living near hazardous waste facilities were lower than those ofthe chosen comparison group. These studies were by the United Church of Christ, the Center for Policy Alternatives, and EPA’S Region II. Onthe other hand, John Hird found no statistical link between poorer counties and the number of Superfund sitesthey contained. And, while EPA’S study of populations near cement plants did not draw conclusions, our interpretation ofthe study’s data isthat the poverty rates near the plants were greater than the rates for the host county about asoften asthey were lower. The Center for Policy Alternatives’ update ofthe 1987United Church of Christ study examined RCRA commercial hazardous waste facilities. The study accounted for changes in the facilities that had occurred since 1980, using 1990census data updated to 1993.With respect to poverty, the center reported that ZIP codes in which either three commercial facilities, an incinerator, or one of the nation’s largest landfills were located had poverty rates that were 35percent higher and income levels that were

3An unweighted analysis counts each community the same even though one community might have a population of 1,000andanother apopulation of 10,000. Aweighted anaIysiswould account forsuch population differences.
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19percent lower than the national average. However, the study reports that these differences were not statistically significant. The study done for EPA’S Region II analyzed Superfimd sites in New York and New Jersey and found that the characteristics of house value and rent (used asproxies for income) were lower within 1mile ofthe sites than these characteristics across the state. In contrast, other studies concluded that poverty levels were lower or not significantly different near facilities. For example, Hird examined Super-fundsites, using the host county asthe study area According to this study, no statistical link existed between poorer counties andthe number of Superfund sites they contained. The results indicated that more economically advantaged counties (in terms of both wealth andthe absence of poverty) were likely to have more Super-fundsites.A higher median value for housing in the county was strongly correlated with a larger number of Super-fundsites, while higher poverty levelswere signiticantly associated with fewer such sites. RaeZimmerman and the University of Massachusetts-Amherst study found mixed results in terms of economic factors. Zimmerman examined the locations of 814Superfund sites in 622communities across the country and concluded that the unweighted mean percentage of people below the poverty level was slightly lower than but comparable to that ofthe nation. In contrast, when weighted averageswere used,sheconcluded that 14percent ofthe people in all of the study areaswere living below the poverty level.This percentage was somewhat higher than the national average, which at that time was 12.4percent. However, Zimmerman did not consider these differences to be significant. The University of Massachusetts-Amherst group also examined poverty rates near RCEZAhazardous waste facilities in metropolitan areas.The study contained several analyses in which the authors used geographic study areas ofvarying distances. The authors reported, for example, that the mean percentage of families below the poverty level in censustracts with facilities was about the same (14.5percent) asit was in the remaining census tracts without facilities (13.9percent). In contrast, when the tracts containing facilities were defined to include areaswithin 2.5miles ofthe sites and then compared with all the remaining tracts without facilities, the results changed. For the census tracts falling within 2.5miles offacilities, the authors found that the percentage offamilies below the poverty level (19 percent) was significantly higher than the percentage offamilies below the poverty level residing in the census tracts without facilities

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(13.1percent). Therefore, the authors’ overall conclusion was that their analyses showed no consistent national-level association between the location of commercial hazardous waste facilities andthe perc&age of economically disadvantaged people. 

## StudiesContain Few Data on Raceby Income For the most part, the studies did not attempt to cross-tabulate race and income aswe did in our analysis of nonhazardous municipal landfills. Zimmerman did determine the number of Superfund sitesthat were located in communities that had relatively high levels of poverty and minorities. For example, her report noted that at93sites, more than 15percent ofthe population was black and more than 15percent was below the poverty line. Shealso reported that at 53ofthese sites, more than 15percent ofthe population was black and more than 20percent was below the poverty line. However, sheconcluded that the association of severepoverty with Superfund sites was lesspronounced than the association of race and ethnic&y with such sites. In its study, the United Church of Christ concluded that race was a stronger indicator than income ofthe location of waste facilities. However, the published report did not present detailed data to support this statement. Others, including Hird and the authors ofthe University of Massachusetts-Amherst study, performed analyses that accounted for race and income or economic variables but did not conduct cross-tabulations. 

# Different Study Questions and Methodologies Used May Have Ledto Varied Results The 10studies were intended to answer different research questions, and thus different results could be expected. All the studies examined avariety of samples offacilities that handled hazardous waste, andtwo also examined facilities that handled nonhazardous waste. They also analyzed different geographic areas around the facilities and compared the demographics inthose areaswith the demographics in avariety of larger areasto determine whether inequity existed. Furthermore, the studies chose different subsets ofthe minority population to examine. 

## Different Research Onereason for the different results ofthe 10studies could bethat the 

## Questions WereExamined authors asked different research questions. Thetwo most common types of questions can be summarized asfollows:

l In terms of all “areas” (whether defined ascounties, ZIPcodes, census tracts, block groups, or some other measure), are minorities or

Page 41 GAOIRCED-96-84 Demographics of People Near Waste FacilitiesChapter 3 Past Environmental Justice Studies of Waste Facilities Have Yielded Varied Conclusions

economically disadvantaged segments ofthe population disproportionately located in areasthat contain hazardous waste facilities compared with areas that do not contain such facilities?

. Given that afacility is located in anarea, arethere any differences between the racial or economic profile ofpeople near the facility (i.e., within 1mile) compared with the proftie of people further away? These two very different research questions can yield different results. In the first case,the focus is broad-national or regional, for example. In the second case,the focus is onthe local level-the level atwhich decisions are made on where facilities will belocated. 

## Sizeof SampleandQpe of The five studies that examined RCRA commercial hazardous waste facihties 

## Facility used sample sizesranging from 35to over 500.In the three studies that focused on Super-fundsites, one study had asample of 210Superfund sites in one region, while the other two analyzed about 800sites nationwide. The United Church of Christ and EPA’S Region IV analyzed the populations around more than 18,000and 4,800CERCLA sites4 respectively. The other two types offacilities included in the studies are nonhazardous waste facilities and cement plants. WasteManagement, Inc., examined the population near all of its disposal facilities-about 100nonhazardous waste landfills and about 30commercial hazardous was& facilities. EPA studied 29cement plants that burned hazardous waste asfuel and 12 plants that did not. 

## Area of Comparison The studies analyzed the populations of avariety of geographic areas around the waste facilities. Each of these areas is considered by the authors to bethe “communityn potentially affected by the facility. Because these communities canvary dramatically in size,their definition can have an impact onthe results. Thestudy areas included censustracts, ZIP codes, communities, counties, and zones with boundaries at aspecific distance from the facility, such as l/2 mile or 5miles. By comparison, our study addressed a l-mile areaaround afacility’s boundaries. Figure 3.1illustrates the relationship between the different boundaries that havebeen used in the studies. The boundaries do not have standard sizes;these are for illustrative purposes only. This example shows the

4Asof December 1994,about 3i’,O00 CERCJA sites had beenevaluated and 1,288had been placed onor proposed forthe National Priorities List.At thetime the United church of Christdid its study, the national inventory of CERCLA siteswasabout 18,000.

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potential differences between areas asdefined by acounty boundary, a ZIP code, acensus tract, or aspecified distance from afacility located in a metropolitan area.While all the people within a3-mile areaare closer, by definition, to the landfill than anyone outside of the area,that is not necessarily true for acensus tract or ZIPcode.Asfigure 3.1shows, a resident in acensus tract hosting afacility may live further from the facility than aresident in anadjacent censustract.

3.1: Illustrative Example of Different Boundary Areas Used in Demographic Studies

v County

boundary I_ Census

tractboundary ZIPcodeboundary

The studies also used different areasfor comparison, which may also have

influenced their findings. For example, the studies by the United Church of

Page 43 GAO/RCED-96-84 Demographics of People Near Waste FacilitiesChapter 3 Past Environmental Justice Studies of Waste Facilities Have Yielded Varied Conclusions

Christ and the Center for Policy Alternatives, which usedthe ZIPcodes of commercial hazardous waste facilities astheir study area,compared these areas with ail the residential ZIPcodes across the country where no facilities were located. The University of Massachusetts-Amherst study compared census tracts where commercial hazardous waste facilities were located with census tracts where there were no facilities. The authors of the first two studies concluded that minorities were over-represented near these facilities, while the University of Massachusetts-Amherst group reported that there was no consistent national association in metropolitan areas between the location of facilities and the percentage of blacks and Hispanics. A possible reason for this may bethe difference in sizebetween ZIPcodes and census tracts. As another example, while Hird compared counties where Superfund sites were located with ail counties without Superfimd sites,Zimmerman compared communities containing Superfund siteswith the geographic region (north, east,south, west) in which these communities were located and with the country asawhole. Hird concluded that there was no link between poverty levels in the counties and the number of Super-fundsites. Zimmerman’s study was divided in its findings, concluding that on an unweighted basis the poverty rate in Superfund communities was comparable to that in the nation but that when the analysis wasweighted to take into account the communities’ population level,the poverty rate was slightly higher. bike the United Church of Christ, WasteManagement usedZIPcodes in its study of its own facilities. However, its study compared populations living in ZIP code areas with the percentage ofthese populations in the host state. EPA’SRegion IV categorized census tracts and counties bythe percentages of minorities they contained and calculated the average number of CERCLAfacilities per census tract and county. Thestudy done for EPA of 35commercial hazardous waste landfills compared the racial demographics within various distances-for example, l/2 to 5miles-with the demographics in the host county, the host state, andthe nation. EPA’S study of cement plants also used l/2 to 5-mile distances, andcompared the people living near them with the people living in the host county and the nation. The study for EPA’SRegion II compared the demographics for distances ranging from within l/4 mile to 4miles of Super-fundsiteswith the demographics ofthe host state and the surrounding municipality. However, the primary focus ofthe analysis was for areas 1mile from sites,

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## Definition of Minority The studies examined different subsets of minority populations. One common limitation in the studies isthat data on Hispanics are not always broken out byrace. Because “Hispanic” isan ethnic rather than aracial distinction, it ispossible to either overcount or undercount the number of minorities in anarea. For example, white Hispanics may not be counted as minorities at all, while black Hispanics may be counted twice, asblacks and asHispanics. Severalstudies, including those ofthe United Church of Christ and the 1994update by the Center for Policy Alternatives, usedthe definition that we used in this report, counting everyone other than non-Hispanic whites asminorities. The University of Massachusetts-Amherst group studied only black and Hispanic minorities, excluding Asians, Native Americans, Pacific Islanders, and “others. nAlso, the authors ofthat study did not distinguish black Hispanics from black non-Hispanics. Similarly, Zimmerman did not break out the data on Hispanics by race.
EPA’S Region IV used the terms “white” and “minority.” Because this study defines “minority” asthe total population minus the white population, Hispanics may be undercounted. Although Hispanics represent only about 1percent ofthe region’s population, they may be asignificant factor in certain cities or regions. For example, in Florida, one of the states in Region Iv, Hispanics make up almost 9percent ofthe population. 

# Direct Comparison It would be difficult to compare the results of our analysis in chapter 2 

# Between Results of with those ofthe studies addressed in this chapter because ofthe many differences between them. Weexamined nonhazardous waste landfills, 

# Our Study and Others while the other studies focused primarily on several types of hazardous 

# Is Difficult waste facilities. Our methodology also differed from the methodology used by most ofthe studies. The only other study to examine alarge number of nonhazardous waste facilities was the study by WasteManagement, which examined the populations near 132facilities, including about 100nonhazardous waste landfills and treatment facilities. The company used amuch different methodology than we did, comparing racial demographics within ZIP codes with demographics statewide. While the difference in methodologies makes comparison inexact, the results ofthe two studies are somewhat consistent. WasteManagement found that about 75percent of its hazardous and nonhazardous facilities were located in ZIPcodes that had anequal or higher percentage ofwhites than the state did, Wefound

Page 46 GAOIRCED-96-84 Demographics of People Near Waste FacilitiesChapter 3 Past Environmental Justice Studies of Waste Facilities Have Yielded Varied Conclusions

that the percentages of nonminorities within 1and 3miles of amajority of the landfills nationwide were about the sameasor higher than they were in the surrounding county.5 Most ofthe other studies eachexamined avariety of hazardous waste facilities, including landfills and treatment and storage facilities. Several of the criteria usedto select sites might affect landfills differently than they do the other types of facilities. These criteria include the amount of acreage needed and the cost of available land. Landfills aretypically larger than the other types offacilities, which may meanthat suitable land is available only on the outskirts of developed areas. Other factors that may differ between landfills and other facilities, and thus affect their locations, include geological conditions, remoteness of location, accessto transportation, and proximity to related businesses and industries. Different locations within acounty-outskirts versus inner city, for example-may be populated by different racial or economic groups. If so, the type of facility studied mayhaveabearing onthe results of a demographic analysis. The other study among the 10we reviewed that examined only landfills was the study done for EPA ofthe nation’s 35hazardous commercial waste landf?lls. There may be more similarity between the nonhazardous waste landfills in our study andthe hazardous waste landfills in EPA’S study than there isbetween nonhazardous waste 1andfiUsand the other types of facilities studied. While EPA did not draw conclusions, our interpretation of the data in this study shows that it, too, found that, in the majority of cases the percentages of blacks and Hispanics living within a5-mile radius of the facilities were equal to or lessthan the percentages of blacks and Hispanics living in the surrounding county.

B 

# Attempts to Examine All ofthe studies that we reviewed examined a“snapshot” of population 

# Trends Over Time characteristics from around the time the study was done. The studies’ authors generally usedthe most recent data available-from either the 1980or 1990census.That approach does not address any changesthat haveoccurred in demographics around asite since it was first approved and built. Onehypothesis that hasbeen suggested isthat communities near awaste facility (or other locally undesirable land use) become more populated

‘As noted in ch.2,the results ofouranalysisofthe3-mileareaare not provided inthis report because they werecomparable to the results ofouranalysisofthe l-mile area

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with minorities or low-income people in the years or decades after the facility is built.” The proposed explanation isthat the presence of the facility may causethose who can afford to moveto become dissatisfied and leavethe neighborhood. Also, by making the neighborhood less desirable, the presence of afacility may decrease property values, making housing more affordable to low-income people. This “market dynamic” could lead to low-income people moving into the area And, to the extent that minorities havelower average incomes than nonminorities, it could result in adisproportionate share of minorities moving near the facility. Weattempted to examine changes in demographics subsequent to the siting of27municipal solid waste landfills but were unsuccessful7 The Census Bureau did not havethe necessary computerized geographic data that would have allowed usto compare the 1980census datafor populations within 1and3miles of the landfills with the data for these populations from the 1990census. 

# Observations Our findings of amix of conclusions and methodologies in the other studies can be usedto make several observations. Oneisthat standardized methods would be useful in determining whether specific communities are experiencing environmental inequity. To achieve such standardization, agencies would need methods that, at aminimum, (1) consistently define racial minorities; (2) identify astudy areathat is,in fact, affected by polluting facilities; and (3) compare the study areawith anappropriate larger area An important limitation of our study and the others we reviewed isthe assumption that proximity to afacility leads to risk. However, closeness to afacility isonly aproxy for risk. Living 1mile from onefacility may be much different than living 1mile from another facility, given differences in the types andvolumes of hazardous waste handled and in humans’ exposure to that waste. In fact, living 1mile from the samefacility but in different directions, could havedifferent effects, depending onthe flow of air and groundwater, for example. Future work that quantifies the actual

GVickiBeen, “Locally Undesirable LandUsesin Minority Neighborhoods: Disproportionate Siting or Market Dynamics?,” TheYale LawJournal, Vol. 103,No.6,Apr. 1994. Theauthorsofthe University ofMassachusetts-Amher study alsoreport thatthey areinvestigating trends indemographics overtime near hazardouswastesites. ?Fheselandfills were taken from our larger sampleof296facilities, andall beganoperations between 1977and 1981.
Page 47 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesChapter 3 Past Environmental Justice Studies of Waste Facilities Have Yieided Varied Conclusions

risk to people living near facilities would enhance understanding ofthis issue. In addition, studies done onthe cumulative effects of multiple pollution sources in residential communities could provide amore comprehensive look atthe total potential impact of environmental factors. Thestudies that we reviewed-as well asour own--examined the populations near a particular class of facilities, such asSuperfund sites; hazardous waste landfills; or facilities for the treatment, storage, and disposal of hazardous waste. The cumulative effects of other types of pollution sources could also bestudied, including hazardous waste generators, utihties, sewage treatment plants, and freeways. Conducting such studies using standard methodologies and factoring in geographic patterns specific to the localities will challenge researchers.

Page 48 GAO/RCED-96-94 Demographics of People Near Waste FacilitiesCha&er 4 

# EPA’sRegulations for SiteSelection and Public Participation HaveNot Addressed Environmental Justice, but ChangesAre Being Considered

- To date, EPAhasexerted limited control over where hazardous and nonhazardous waste facilities are located. Stateand local governments typically approve the decisions to place hazardous and nonhazardous waste facilities in specific locations. Current federal regulations do not specificalIy restrict facilities from being located in residential areasand do not consider environmental justice. EPArecently chose not to propose new standards that could haverestricted hazardous waste facilities in residential areasbecause it believed these standards would not be cost-effective.
EPA'SreguIations asof March 1995for providing the public with an opportunity to participate in decisions about hazardous and nonhazardous waste facilities have not specifically addressed environmental justice. The regulations that EPAdoes have on public participation typicaIly take effect when EPAor thestate’ is deciding whether anoperating permit will be granted, which normally occurs after the site hasbeen selected. Stateand local governments typically determine the opportunities for public involvement in decisions about the location of asite. In June 1994,EPA proposed new regulations that would require anorganization to notify the public that it intends to apply for an operating permit, although this would probably occur after the site has been selected. In proposing the regulations, EPAalso asked for public comment on how it canmodify its public participation regulations to better integrate minority and low-income communities into the decision-making process. In 1993,EPA issued guidance for its regions and the states on how to encourage public participation, including amongst minority and low-income communities, when they are considering permit applications for hazardous waste facilities. Our survey of landfiG included anumber of questions about the techniques usedat specific landfills to increase public participation. The results are discussed in appendix VI. 

# EPA’sSiting Standards The restrictions that EPAplaces onwhere facilities can be located do not 

# for Hazardous and specifically limit their proximity to people, nor do they take into account 

# Nonhazardous Waste the demographics of residents. Because planning for land usetraditionally hasbeen alocal concern, state and local governments haveplayed amuch 

# Facilities larger role in determining the location ofwaste facilities and often have regulations regarding how close these facilities can beto populated areas. EPA'Sapproach hasbeen that if design and operating standards are met, it is not necessary for the protection of human health to limit the location of the facilities in relation to residences.
‘Many statesamauthorized by EPAto issuepermits for waste facilities.

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## EPA’sCurrent Restrictions For nonhazardous municipal landfills, the type offacility we surveyed, EPA 

## onthe Location of issued comprehensive regulations in 1991that began to take effect in 

## Facilities October 1993.These regulations apply to existing and new landfills, and address location, among other things. These more extensive regulations have caused many landftis to close andwilI haveasignificant impact on facilities built in the future. The restrictions on the location of nonhazardous landfills generahy concern specific geological characteristics. The regulations restrict landfills from being located in floodplains and geologically unstable areas or near airports.” In addition, they restrict new landfill units or lateral expansions of existing units in wetlands, seismic impact zones,andfault areas.The restrictions do not necessarily prohibit landfills from being located in any of these areas, but require that owners or operators applying for apermit demonstrate that they havetaken adequate precautionary measures. For hazardous waste facilities, only one RCRA requirement affects the proximity ofwaste treatment, storage, and disposal facilities to communities: Containers with ignitable or reactive waste must beatleast 50feet away from the facility’s property line. Current general standards for locating hazardous waste facilities, including hazardous landfills, are not quite ascomprehensive asthe 1991standards for nonhazardous landffls. The restrictions that apply to hazardous waste facilities concern seismic areas,floodplains, salt dome formations, and underground mines and caves.Wetlands are not specifically identified. Furthermore, the seismic considerations for hazardous facilities are not ascomprehensive asthose in the standards for the nonhazardous facilities. 

## EPAHasChosenNot to Propose New Location Standardsfor Hazardous Facilities RCRA called for EPAto adopt regulations establishing such performance standards for hazardous waste facilities “asmay be necessary to protect human health and the environment,” including requirements covering the location of the facilities. In 1992,EPAdrafted additional location standards for new and expanding hazardous waste facilities, The draft also asked for public comment on environmental justice issues. However, the Office of Management and Budget rejected the draft because it saidthe costs to implement such standards would exceed the potential benefits. In 1994,the agency formed awork group to examine additional standards and to consider environmental justice issues asthey relate to the siting of

*Landfills attract birds, which canposeathreat to aircraft.

Page SO GAOIRCED-95-84 Demographics of People Near Waste FacilitiesChapter 4 EPA’s Regulations for Site Selection and Public Participation Have Not Addressed Environmental Justice, but Changes Are Being Considered

facilities. According to the Chief ofthe Permits Branch in the Office of Solid Waste,the work group considered (1) more stringent technical location standards, (2) setback requirements to establish the distances required between facilities and nearby residents, (3) the impact of current state requirements, and (4) ways to address environmental justice issues. In March 1995,the official told usthat the agency had decided that the small number of new hazardous waste facilities being built did notjustify the effort to develop and propose new standards. He alsosaid that EPA decided that it could better address concerns about environmental justice through guidance onthe operation of existing facilities. Details onsuch guidance haveyet to bedeveloped. 

## StateStandardson Locating Facilities Near Land Usedfor Residences At aminimum, facilities must comply with the RCRAlocation standards for both hazardous and nonhazardous facilities described above.According to an EPAdocument, almost 40states haveadditional standards for locating hazardous facilities that are more stringent than EPA’S current standards.3 The EPA document indicated that states cangenerally promulgate regulations about sites more easily than the agency itself can because the states may be able to adopt asiting standard without first showing that it is necessary to protect human health and the environment. A 1994draft study conducted by an EPAcontractor identified the types of requirements that many states impose on hazardous facilities.4 According to the study, 23states consider or require setbacks that prohibit hazardous waste facilities from being within acertain distance of land usedfor churches, schools, or residences, for example. The distances range from 75feetto 8miles. According to the study, 16states also consider or require “buffer zones,” which prohibit or restrict the waste units from being close to afacility’s property line. The distance between the units and the properly line most commonly required is200feet but ranges from 50feet to l/2 mile. The 1994draft study also pointed out that most local governments have zoning and planning requirements that address suitable locations and control such items asproximity to populations. However, the draft study did not list those requirements because ofthe vast number of specific local laws.

“OSWEREnvironmental Justice Task Force Draft Final Report,Office ofSolidWasteandEmergency Response,EPA,Apr. 25, 1994. ‘State-byState Sumrxui esof Social Siting Criteria, working draft prepared forthe RCRA Siting Workgroup by ICF Incorporated, July 28, 1994.

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# EPA’sCurrent Regulations on Public environmental justice. They are intended, however, to allow citizens, including members of minority and low-income communities, the 

# Participation opportunity to influence the permits issued to waste facilities. EPAnoted in its response to our draft report that its current regulations allow members of the public to comment on environmental justice and other issues and that the agency considers all public comments before issuing apermit, particularly those concerning the protection of human health. 

## EPA’sCurrent Public Participation Regulations for Nonhazardous Facilities EPA'Scurrent regulations for soliciting public participation in the process for issuing permits to nonhazardous waste facilities do not specifically address environmental justice. However, they do require the agency issuing the permit, generally the state,to hold apublic hearing before approving apermit ifthe agency determines there is asignificant degree of public interest in the proposed permit. To meet this requirement, the agency must

. make pertinent documents, such aspermit applications and draft permits, available to the public in convenient locations;

. maintain lists of interested people and notify them when important information isavailable;

. publicize notices of public hearings and mail notices to the interested parties onthe list at least 30days before the hearing; and s hold hearings attimes and places that facilitate public attendance and make available apublic record. Our survey of municipal landfills included questions onpublic participation directed to the landfills in our samplethat began operation after January 1,1988. (Forty-five ofthe 622respondents fit that criterion.) The questions were designed to learn the steps that landfill owners and operators had taken to provide opportunities for the public to participate in the process of selecting asite and issuing anoperating permit. Over two-thirds ofthe respondents saidthat they held public hearings to discuss both the location and the operation ofthe facility. About one-quarter did not hold hearings. In anumber of instances in which hearings were held, the respondents indicated that the public had influenced either the location or operation of the facility. More detail on the responses isfound in appendix VI.

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## EPA’sCurrent Public Participation Regulations for Hazardous Facilities EPA’S current regulations for granting operating permits to hazardous waste facilities likewise call for public participation but do not specifically address environmental justice. When EPA or an authorized state receives a permit application for afacility, it must begin compiling amailing list of interested community members in order to communicate important information about the permit process to them. After the agency has reviewed the application and made apreliminary decision, it must notify the public of its decision and make either the draft permit or the notice of intent to deny the permit available for public comment. The agency must mail notices to the citizens onthe list and issue notices in amajor local newspaper and over local radio stations. Members ofthe public may request ahearing on the draft permit or the notice of intent to deny apermit. Hearings must be held attimes and places that facilitate public attendance. Final decisions on the permit must include awritten response to both the written comments and those made atthe public hearing. 

## EPA’sProposal for Earlier Public Notice and Attention to Environmental Justice EPA proposed regulations inthe Federal Register onJune 2,1994, that would require earlier public notification and input inthe process of issuing permits for hazardous waste facilities. The agency hasreceived public comments onthe proposal and expects to issuethe final rule atthe end of the summer in 1995.Specifically, the proposal calls on applicants for permits to operate hazardous waste facilities to hold at least one public meeting to discuss the proposed facility before submitting the application. The public would be notified ofthe meeting at least 30days in advance and in amanner (newspaper, radio, signs, etc.) that is likely to reach ail affected members ofthe community, including minorities and low-income people. Under the proposed approach, EPA or the state would be required to notify the public when it received anapplication for apermit. The notice must include specific information about the application and the responsible contact person in the EPA or state office that grants permits. Furthermore, EPA or the state would beauthorized to require that the applicant establish and maintain arepository of information about the application. In addition to the specific proposals, EPA solicited comments from the public on anumber of environmental justice issues. EPA asked for comments onways to incorporate concerns about environmental justice into the public participation process under RCFCA. The agency also asked

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for comments onthe needfor additional rulemaking or policy guidance for incorporating environmental justice into certain aspects ufthe RCRA program for issuing permits, such ascorrective action5 EPA was interested in receiving comments on suggested methodologies and procedures for analyzing the “cumulative risk” and “cumulative effects” associated with human exposure to multiple sources ofpollution. EPAalso asked for comments on recommendations developed by the Office of Solid Waste and Emergency Response Environmental Justice task force, such as compiling anational summary of existing state, tribal, and local government requirements with regard to environmental justice for selecting sites for facilities. 

## EPA’sGuidanceto Regions In September 1993,EPA’S Office of Solid Waste issued the RCRA Public 

## andStatesto Improve Involvement Manual. The purpose ofthe manual isto help EPA’S regional 

## Public Participation offices and RcR&au%horizedstate regulatory agencies achieve effective public participation concerning permits and corrective actions at hazardous waste facilities. Asection ofthe manual is devoted to promoting environmental justice through public participation. While this guidance may improve public participation in EPA’S permit process, according to EPA the guidance was not necessarily intended to affect public participation in state and local governments’ decisions about where facilities are located. The manual describes over 25activities that EPAand state staff should consider implementing in order to involve all segments ofthe community in the process for granting permits to hazardous waste facilities under RCRA. Someofthe activities are designed to gaugethe community’s reaction to and concerns about afacility. EPA recommends that staff conduct interviews with local residents, elected officials, or community groups to obtain this information.

EPA also recommends that staff prepare apublic involvement plan; that is, aspecific plan for interacting with the community when apermit is being considered. The plan is supposed to assessthe level of community interest and recommend activities for involving the community in the process. EPA makes specific recommendations for addressing environmental justice in public involvement programs. Staffare advised to adapt to the special needs of the community and to identify internal channels of

5Cmrective action isaterm usedinthe RCRA program to refer to the investigation andcleanup of contamination athazardous wastefacilities.
Page 54 GAOIRCED-95-84 Demographics of People Near Waste FacilitiesChapter 4 EPA’s Regulations for Site Selection and Public Participation Have Not Addressed Environmental Justice, but Changes Are Being Considered

communication that the community relies on for its information, These channels could include foreign language newspapers or radio stations, or influential religious leaders. Interpreters areto be provided if needed for public meetings. Similarly, multilingual fact sheets andother information areto be prepared if necessary. EPA also encourages the formation of a community advisory panel to serveasthevoice ofthe community. 

## Executive Order’s Requirements onPublic Participation The President’s February 1994executive order on environmental justice calls for federal agencies to, among other things, translate crucial public documents, notices, and hearings related to human health or the environment for populations whose English islimited. It also calls for each federal agency affected by the order to ensure that public documents, notices, and hearings on human health or the environment are concise, understandable, and readily accessible to the public. The order also requires federal agencies, whenever practicable and appropriate, to collect and analyze information onthe race, ethnicity, and income for aseassurrounding facilities or sites expected to havea substantial local environmental, human health, or economic effect onthe surrounding populations when such facilities or sitesbecome the subject ofasubstantial federal environmental, administrative, orjudicial action. The information isto bepublicized unless prohibited by law. Agencies could usethis information to help design appropriate public participation efforts.

Page 66 GAO/RCED-95-84 Demographics of People Near Waste FacilltlesChapter 5 

# Data onHealth Effects of WasteFacilities on Minorities andLow-Income People

EPAand others have reported that few data are available on the health effects of hazardous and nonhazardous waste sites on minorities and people with low incomes. Executive Order 12898requires EPAto account for different socioeconomic and minority populations when collecting environmental human health data.’ In our survey of municipal k&fills, we found little association between the race, income, or poverty status of residents near landftis and certain 1andfiIl characteristics that could be used asindicators of risk, such as groundwater contamination, types of waste, or the useofprotective liners. Over the years, evidence hasbeen gathered of contamination being released into the environment by municipal waste landfills and hazardous waste facilities. However, the health effects risk models that EPAhas developed and used in support of its rulemakings predict that the number of additional cancer-related deaths resulting from exposure to materials released from landfills and hazardous waste facilities would be relatively low. Wedid not evaluate thevalidity of these risk models. 

# Federal Efforts to Determine Health Effects of Waste Facilities on Minorities and In recent years, EPAhasformed aWorkgroup and cosponsored a conference to examine the health effects of pollution sources, including nonhazardous and hazardous waste facilities, but the results havebeen inconclusive because of alack of sufficient data An interagency task force established in 1994responding to the executive order on environmental justice intends to assist in coordinating the collection of such data and to provide guidance to federal agencies intheir strategies for considering 

# Low-Income People environmental justice in their actions. 

## EPA’sWorkgroup and Conference In 1991,EPA’SAdministrator formed an Environmental Equity Workgroup and asked it, among other things, to “review and evaluate the evidence that racial minority and low-income people bear adisproportionate risk burden.” The EPAWorkgroup collected data on awide range of sources of environmental pollution. In 1992,the Workgroup issued areport entitled Environmental Equity: Reducing Risk For Ail Communities. While the report concluded that minorities may have agreater potential for exposure to hazardous and nonhazardous waste facilities, it did not provide any evidence of harmful health effects. In general, EPAconcluded that “there is

.+
.asurprising lack

‘Other agencies,suchasthe Department of Health andHumanServices,arealso required todasoby the executive order. Their efforts were not within thescopeofour review.
Page 66 GAOIRCED-96-84 Demographics of People Near Waste FacilitiesChapter 5 Data on Health Effects of Waste Facilities on Minorities and Low-Income People

of data on human exposures to environmental pollutants for Whites as well asfor ethnic and racial minorities.” EPA,the National Institute of Environmental Health Sciences (NIEHS), and the Agency for Toxic Substances and Disease Registry (ATSDR) sponsored a conference in 1992on environmental health issues called “Equity in Environmental Health: Research Issues and Needs.” The goal ofthe workshop was to examine the available scientific evidence on disparities in overall environmental health by ethnicity and socioeconomic status, to identify research needs and opportunities, and to recommend future directions. Papers onthe available evidence were prepared for the conference andwere published in aspecial issue of thejournal Toxicology and Industrial Health in the fall of 1993.Several ofthe papers addressed the health effects of hazardous waste facilities on people in general and minorities in particular. Oneof those papers, written bythe Director of NIEHS, the Director of EPA’S Office of Health Research, and anAssistant Administrator of ATSDR, contained amessagesimilar to EPA’S.While the authors said that evidence suggeststhat poor communities havehigher exposures to polhrtants, the scientific data are not sufficient to establish unequivocally the link between environmental health risks and income or minority status. In asecond paper, entitled “Hazardous Wastes, Hazardous Materials and Environmental Health Inequity, “’ the authors reported substantial disparities between the health ofAfrican Americans and that of other Americans. They also reported that establishing the causesofthese disparities was difficult because of alack of data They called for “extensive epidemiological studies to evaluate the full extent ofthe impact of hazardous materials onvarious minority communities.” 

## Interagency TaskForce on In the executive order on environmental justice, the administration 

## ResearchandHealth directed federal agencies to incorporate environmental justice into their 

## Established Under overall mission by identifying and addressing disproportionately high and 

## Executive Order adverse human health and environmental effects oftheir programs, policies, and activities on minority and low-income populations. It required eachfederal agency to develop, by March 1995,astrategy for addressing environmental justice issueswithin their operations. The order also tasks the agencies with, among other things, improving research and data collection and ensuring that alIpotentially affected segments of the

ZM.R.I.Soliman,C.T.LleRosa, H.W.Mielke,and K Bota

Page 67 GAO/RCED-96-M Demographics of People Near Waste FacilitiesChapter 5 Data on Health Effects of Waste Facllitiea on Minorities and Low-Income People

population-such asminorities and low-income people-are represented in research on health and the environment whenever possible. An interagency working group was formed to advise the agencies on preparing their strategies. A number oftask forces havebeen created to assistthe working group in carrying out its functions. Oneisthe task force on health and research, which iscochaired by representatives from the Department of Health and Human Services and the Department of Labor. The responsibilities of this task force areto (1) identify research on health issues conducted by other agencies, (2) interact with other agenciesthat are conducting studies on multiple exposures or that may have collected data,and (3) compile information on human exposure to chemicals and toxic substances and get abetter understanding of how agencies are using this information to estimate health effects. Like the other federal agencies, EPA isrequired to prepare astrategy for addressing environmental justice. A draft of EPA’S strategy was available for review asofJanuary 1995.With respect to health issues, one of EPA’S objectives isto ensure that the agency’s environmental policies are based on sound science and significantIy address and incorporate environmental justice and socioeconomic concerns into research. Another objective isto expand EPA’S capability to conduct research in areaswhere the agency can make the greatest contribution to environmental justice, including human exposure, cumulative risk, risk reduction, and pollution prevention. The &a.ft strategy c&Us for EPA to assessand compare the environmental and human health risks borne by populations identified by race, national origin, or income. The broad objectives spelled out in the draft strategy do not specifically address hazardous and nonhazardous waste facilities. 

# Demographic Conditions and Risk-Related Characteristics at In our analysis ofsurvey results and demographic data,we found little association between the race, income, or poverty status of people living near the landfills and landfill characteristics related to potential risk. The characteristics that we analyzed include the types ofwaste received and the presence of features designed to protect against potential releases of 

# Municipal Landfills in contamination. For example, we did not fmd that adisproportionate percentage of minorities or low-income people within 1mile of landfills 

# Our Survey that lack protective Liners.Theresults of our analyses are presented in appendix VII3

“Our information onthe relationship between landfill characteristics andpopulation demographics cannot always be usedto make national estimatesbecausethere were not always enough cases in the categories that we reviewed.

Page 68 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesChapter 6 Data on Health Effects of Waste Facilities on Minorities and Low-Income People

Our reason for examining these relationships was to determine whether minority or low-income populations were more prevalent near landfills that might be perceived asrisky. While it is difficult to generalize about the risks posed byalandfill, our analysis assumesthat risk could increase with the acceptance of hazardous waste andthe absence of protective design features. None ofthese conditions necessarily meansthat aspecific landfill poses arisk to people living nearby, but the public may perceive such characteristics to be reIated to risk. 

# EPA’sAttempts to AssessHealth Risk of Nonhazardous and Hazardous Waste Facilities on General Population While there is little evidence concerning the health effects of waste facilities on minorities or low-income people, EPA hasattempted to assess the risks of these facilities to the general population. Inthe course of developing regulatory requirements for municipal landfills and hazardous waste facilities, EPAhas developed models that predict potential human exposures to hazardous releases and the potential health effects. According to EPA'Sanalysis, the potential deaths resulting from exposure are low for both types of facilities. Wedid not evaluate thevalidity of either of these risk models because doing sowas beyond the scope of our work. 

## EPA’sRiskAssessmentsfor Nonhazardous Waste Landfills In its 1988proposed regulation for municipal landfills, EPAnoted that “existing data are not sufficient to conclusively demonstrate that [municipal landtills] currently are harming human health.

...However, the Agency’s recently completed risk assessments indicate that [municipal landfills] present future potential risks to human health.” In 1988,using these risk assessment models, EPAestimated that 17percent of municipal landfills posed risks greater than 1in lo6(i.e.,an exposed individual would haveagreater than 1in 1million chance of contracting cancer in that individual’s lifetime asaresult ofthe exposure. The exposure isassumed to havelasted over the ‘IO-yearlifespan ofthe individual). The assessment considered only groundwater contamination and used data onthe distance of landfills to drinking-water wells. EPAdid not estimate the risks from contamination ofsurface water, soil, or air. In October 1991,EPAissued its final rule for the location and operating standards for these landfills. In that rulemaking, EPAcited arisk assessment ofthe landfiils in operation before the new regulations went into effect that projected 5.7additional cancer deaths acrossthe country over a300-year period. EPAestimated that the new regulations will reduce

Page 69 GAO/RCED-95-84 Demogxaphics of People Near Waste FacilitiesChapter 5 Data on Health Effects of Waste Facilitb on Minorities and Low-Income People

the number of additional cancer deaths to 3.3asold landfills are replaced with new ones, 

## EPA’sRiskAssessmentsfor EPAhasalso projected the potential adverse health effects of contaminated 

## Hazardous WasteFacilities hazardous waste facilities. EPAestimated that 1,200 cancer caseswould result over the 12ELyearmodeling period if the contaminated facilities are not cleaned up. If these facilities are cleaned up, EPAestimated that there would still beabout 800cancer cases.Theprojections accompanied EPA'S 1993regulations for cleaning up contaminated hazardous waste treatment, storage, and disposal facilities.
EPAestimated that unless corrective action (the cleanup of the facilities) is conducted, 920to 1,700hazardous waste facilities could cause either cancer or noncancer health risks to people. EPA also estimated that if faciIities are converted to residential usein the future, approximately 1,800 sites could cause cancer and noncancer health effects.

Page 60 GACURCED-96-84 Demographics of People Near Waste FacilitiesPage 61 GAO/WED-95-84 Demographics of People Near Waste hci.UtiesAppendix I 

# Methodology for Analysis of Municipal Landfills

This appendix describes our methodology for surveying and analyzing municipal solid waste landfills. Our mail survey allowed usto (I) examine selected characteristics of such landfills and develop information ontheir location and (2) describe the demographic characteristics of people living nearby. Our approach in conducting the survey allowed usto make national estimates about the characteristics of such landftis and the demographics ofthose living nearby for both metropolitan and nonmetropolitan areas. Our universe ofpotential landfills was derived from alist maintained by the Solid WasteAssociation of North America. The association provided uswith acomputerized list of4,321federal and nonfederal landfills that were thought to meet two criteria (1) they were municipal solid waste landfills and (2) they were operating at some time in 1992.The association’s list did not include landfills in Montana Wereceived alist of 87municipal solid waste landfills in operation in that state in 1992from Montana’s State Office of Solid Wasteand added them to our list of landfills. Weidentified 78landfills that were federal facilities and removed them from the list. Therefore, the total number of landfills in our universe was 4,330. Wethen determined if each landfill was in ametropolitan or nonmetropolitan county, asdefined by the U.S.Bureau of the Census, based on whether the ZIP code of’the landfill was within ametropolitan or nonmetropolitan county. This classification resulted in auniverse of 1,498 metropolitan landfills and 2,832nonmetropolitan landfills. Wethen sampled 500metropolitan and 500nonmetropolitan landfills with equal probability. Wedesigned aquestionnaire that requested several pieces of information about each landfill. This information included, but was not limited to, the location; ownership and sizeofthe landfill; types ofwaste accepted; presence ofprotective liners, groundwater monitoring, or contamination atthe landf-ill; and opportunities for the community surrounding the landlill tovoice its opinions about the location and construction ofthe landfill. Wealso subsampled 300ofthe 500metropolitan and 150ofthe 500 nonmetropolitan landfills. Wedid this to determine the exact geographic location of each landfill sothat we could compare the demographics ofthe people living nearthe landfill with those residing in the rest ofthe county. For this subsample, we asked additional questions about location onthe

Page 62 GAOIRCED-95-84 Demographics of People Near Waste FacilitiesAppendix I Methodology for Analysis of Municipal Landfllls

questionnaire and included one or more United States Geological Survey (USGS) 1:24,000scale maps ofthe surrounding areasthat we determined would contain the landa. The landfill owner/operators were askedto return the USGS

maps with their landfill’s boundaries outlined onthe basis of roads and other natural features displayed onthe USGS map.Wechose to work with asubsample of the 1,000randomly selected landfills that was manageable in sizebut would allow usto make national estimates. Wesolicited expert review of apreliminary version of the questionnaire from the Environmental Protection Agency’s (EPA) Office of Solid Waste. Wethen determined the validity ofthe instrument by pretesting a preliminary version on selected individuals who represented the owner/operators of landfills ofvarying sizeand in different parts ofthe United States.Wepretested first in six locations: Warrenton, Va; York, Penn.; Dover, Del.; Baltimore, Md; Hedgesville, W.Va; and Richmond, Va Based onthe comments and reactions from these pretests, we revised the questionnaire sothat the questions would be uniformly interpreted and understood. Next, we pretested the revised version of the questionnaire at four additional locations (Jonesboro, Ga.;Dallas, Tex.; SanDiego, Calif. and Brooklyn, Ohio) and incorporated the comments and suggestions from these pretests. Wealso received written comments on aversion of the questionnaire from afirm that owns and operates many landfills across the country. Wemailed 1,000questionnaires to the owner/operators identified on our mailing list. The owner/operators were askedto complete and return the questionnaires within 10days.Wekept alogto track which questionnaires had and had not been returned. Wesent another questionnaire to nonrespondents, and after 3to 4weeks, we mailed postcards to nonrespondents. These postcards alerted the owner/operators to the second mailing ofthe questionnaire and asked for their quick response. If we still did not receive aresponse, we telephoned the owner/operators to determine whether they had received the questionnaire and intended to return it. In some cases,the owner/operator agreed to return the survey but did not do soexpeditiously. In those instances, we mailed another postcard to encourage aresponse. In afew cases,we encouraged owner/operators who were reluctant to complete the questionnaire to at least return the USGS mapwith their landfill’s boundaries drawn in.

Page63 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesAppendix I Methodology for Analysis of Municipal LandfilLs

About 79percent (791) ofthe 1,000initial questionnaires were returned, and about 85percent (383) of the 450in the subsample were returned. As illustrated in table I.1,for the subsample, 59ofthe responses from 259 metropolitan landfills and 18of the responses from 124nonmetropolitan landfills were not usable in our analysis becausethey did not meet our criteria of being nonfederal facilities that had accepted municipal solid waste and were operating during 1992.Wehadto exclude responses from 10metropolitan and 1nonmetropolitan landfills for other reasons that are explained in the table. To determine our response rate, we took the number of usable responses (190 metropolitan and 105nonmetropolitan landfills) and divided that figure by the original sample sizeminus the returns that did not meet the criteria for inclusion in our universe (300 minus 59for metropolitan landfills, and 150minus 18for nonmetropolitan landfills). Our response rates for the subsample were about 79percent for the metropolitan landfills and about 80percent for the nonmetropolitan landfills.

Table 1.1:Response Ratefor Survey of Municipal Landfills Surveys from overall sample for analysis of landfill

characteristics Metropolitan Nonmetropolitan Universe i ,498 2,832 Sample size 500 500 USGS maps from subsample for demographic analysis of landfills Metropolitan Nonmetropolitan I ,498 2,832 300 150 Returned (usable) 302 321 190 105 Returned (not usable) Closed before 1992 48 39 29 14 Not a municipal landfill Federal facility Returned after cut-off date Facility never opened OtheP 39 23 28 4
3 0 1 0 3 1 1 0
1 1 1 0
9 1 9 1 Not returned 95 114 41 26 Return rate Response rate ai .o% 77.2% 66.3% 73.8% 73.4% 78.8% Ten landfills were misclassified interms oftheir metropoliian and nonmetropditan status. Because they were misclassified, we did not include them in the analysis. 82.6% 79.5%

Page 64 GAOIRCED-95-84 Demographics of People Near Wnstt FacilitiesAppendix I Methodology for Analysis of MunicipaJ Landfllla

The impact ofthe nonrespondents may be investigated by conducting a follow-up study that compares nonrespondents to respondents to determine whether the nonrespondents are different from the respondents. Given time and resource restraints, we did not conduct this follow-up survey. Weedited the completed questionnaires to ensure that they had been completed correctly. If responses to the questions appeared to be contradictory, we made additional telephone callsto verify or correct the data Weperformed several different types of analysis using various data from our different samples. To describe the general characteristics of landfills presented in appendix II,we usedthe samples under the columns headed “Surveys from overah sample for analysis of landfill characteristics” in table I.1.When comparing the demographics of people living near the landfill areawith those in the rest ofthe county, presented in chapter 2, we usedthe samples under the columns headed YJSGS maps from subsample for demographic analysis of landfills.” Wealso cross-tabulated several of the landfill characteristics and the demographic data for the information in chapter 5and appendix VII. We used data for this analysis only from those landfills that returned both a usable survey and ausable USGS map. Our cross-tabulation analysis included 187metropolitan and 103nonmetropolitan municipal landfills. These landfills are asubset of the 190metropolitan and 105 nonmetropolitan 1andfiIlsidentified in table I.1. For our demographic analysis of the landfills that returned maps,we digitized (traced) the boundary of each 1andflIl using special software from the USGS that allowed usto determine the latitude and longitude deiining a landfill’s boundary. Using ageographic information system computer program, we developed two areasthat separated the landfill from the rest ofthe county. These areaswere 1and 3miles from the boundary ofthe landfill. (Seefig. 1.1.)Wewere ableto digitize atotal of 190metropolitan landfills and 105nonmetropolitan landfills.

Page 66 GAO/RCED-96-84 Demographics of People Near Waste FacilitiesAppendix I Methodology for Analysis of Municipal Landfills

Figure 1.1:Illustration of aCounty Boundary With a Municipal Landfill and l- and 3-Mile Areas

To determine the demographics ofthe people living near the landtills, we usedthe finest level of aggregation possible, the census block group. We did not usethe census block because the U.S.Bureau of the Census did not report data on income atthis level. For each landfill, we determined which block groups were either partially or completely within the landfill’s l- and 3-mile areas. If the block group was completely within the area,we used its complete demographic information (e.g.,number of minorities and nonminorities). If the block group was partially within the area, its demographic information was proportioned onthe basis ofthe amount ofthe block group area falling

Page 66 GAOIRCED-95-84 Demographics of People Near Waste FacilitimAppendix I Methodology for Analysis of Municipal Landfills

within the l- or 3-mile area The number of minorities and nonminorities residing in complete and partial block groups was then summed to determine the total number living inthe 1-or 3-mile area. In effect, we counted sJlthe people in some block groups and aportion ofthe people in other block groups’when we totaled the number of people within the area To determine the demographic characteristics of those living outside the area,we subtracted the number of people living in the areafrom the number living in the county. Wemade all our comparisons between the people living in the areaand the people living in the rest ofthe county. Within the l- and 3-mile areas,we counted only those people in the county, not those in anadjacent county. Wechose to compare the population within the l- and 3-mile areaswith the population in the rest ofthe county rather than to some other geographic area such asthe city or state.This decision was acompromise that we made for the following reasons. According to our survey, most municipal solid waste landfills are owned and operated by local or county governments. Our survey results also indicated that local or county governments had approved the locations for most landfills. Furthermore, the average landfill @ublic or private) typically received most of its waste from within the county. Ideally, we would haveclassified the landfills according to which government jurisdiction (city or county) had approved the location. If the city made the decision, we would have compared the population within the l- and 3-mile areaswith the population in the rest ofthe city. If the county madethe decision, we would have compared the populations within the l- and 3-mile areaswith the population in the rest ofthe county. To doso, however, would haverequired alarger sample to allow for sufficient samples in both categories. Wedid not have adequate resources to increase the sample size.Comparing the populations in the l- and 3-mile areaswith the population in the rest of the city would also havepresented aproblem in casesin which the l- or 3-mile area occupied nearly all ofthe area ofthe city, leaving little to compare. This situation would have occurred more often in rural areas. Furthermore, in some instances, city governments had decided to locate acity-operated facility on unincorporated land outside the city limits. This circumstance would have confused our analysis. Wetherefore decided to compare the populations within the l- and 3-mile areaswith those inthe rest of the county.

Page 67 GAO/RCED-96-84 Demographics of People Near Waste FacilitiesAppendix I Methodology for Analysis of Municipal Landfills

In this process, we excluded block groups within the l- and 3-mile areas that fell outside the county inwhich the facility was located (host county). In 35 of the 295 landfills we analyzed, the l-mile area extended into atleast one other county. In 101instances, the 3-mile area extended into at least one other county. Wechose not to include the people in the other counties in our analysis because we did not believe it was appropriate to compare the demographics of people in the host county with the demographics of people from both that county and the adjacent counties. Our reasoning was that people in the adjacent counties were unlikely to havehad an opportunity to influence the decision about where the facility was located. Not including the people in the adjacent counties doespresent alimitation in our analysis, however, because these people could beaffected by the facility in the samemanner aspeople in the host county. For each I- and3-mile area andthe corresponding rest ofthe county, we developed demographic information on five areas:race/ethnicity (we included whites of Hispanic origin with the minority population), poverty status, median household income, poverty status by race/ethnicity, and median household income by race/ethnicity. All of the demographic data camefrom either the U.S.Bureau of Census Summary Tape File 1Aor the Summary Tape File 3A. For the data on income @overty and median income), the census data included whites of Hispanic origin with the white, or nonminority, population. Weusedthe data that described the rest ofthe county to establish what would be expected in the l- or 3-mile area if the groups were not disproportionate. For example, if non-Hispanic whites (termed in this study “nonminorities”) composed 50percent of the county’s population outside a l-mile area, we would expect that approximately 50percent of the population within the l-mile area would be nonminorities. If nonminorities made up only 30percent ofthe population inthe l-mile area, nonminorities would appear to be overrepresented. Thus, every metropolitan and nonmetropolitan landfill in our samplewas treated equally and categorized ashaving more orfewer minorities than expected, In the above case,the landfill would be classified ashaving fewer nonminorities than expected. Wealso classified metropolitan and nonmetropolitan landfills ashaving significantly more nonminorities than expected, about what was expected, or significantly fewer than expected. Thus, in the example above,we would haveclassified the landfill ashaving significantly fewer nonminorities than expected. Weperformed this type of analysis for all of the demographic data,

Page 68 GAO/RCED-96-84 Demographics of People Near Waste FacilitiesAppendix 1 Methodology for Analysh ofMunicipal Landfilis

Wealso compared the data from the l-mile areaswith data onthe nation asawhole. Weused national datafor the samevariables: race, median household income, and poverty status. Weanalyzed eachvariable interms of metropolitan and nonmetropolitan areas.While most ofthese data were readily avaiIable from the 1990census, some extrapolation was necessary to arrive at national data on median household income andpoverty status by race. Finally, we cross-tabulated the demographic data from the L-mileareas with several landfill characteristics selected aspossible indicators of risk. Thesecharacteristics included the use ofprotective liners, leachate collection systems, and groundwater monitoring. Thepurpose was to determine whether minorities or low-income people were underrepresented with respect to the presence ofthese characteristics. Because we used asample (called aprobability sample) to develop our estimates, each estimate hasameasurable precision, or sampling error, that may be expressed asaplu&ninus figure. A sampling error indicates how closely we can reproduce from asample the results that we would obtain if we were to take acomplete count of the universe using the same measurement methods. By adding the sampling error to and subtracting it from the estimate, upper and lower bounds for each estimate were developed. This range is called aconfidence interval. Sampling errors and confidence intervals are stated atacertain confidence level-in this case 95percent. For example, aconfidence interval, atthe 95-percent confidence level, means that in 95out of 100instances, the sampling procedure we used would produce aconfidence interval containing the universe value we are estimating. The sampling errors for our analysis are found in tables III. 1and III.2 of appendix III.

Page 69 GAWIKED-95-64 Demographics of People Near Waste Facilities

# Overview of Municipal SolidWasteLandfills Surveyed

Wesurveyed 500metropolitan and 500nonmetropolitan municipal 1andlUs about avariety of solid waste issues. The responses to aselect number of those questions aresummarized below for metropolitan and nonmetropolitan landfills. All ofthe percentages reflect only those landfills that responded to the questions.

. On the basis of usable’ survey responses we received from 301 metropolitan and 322nonmetropolitan landfills in operation atsometime in 1992,we estimate that 69percent (+/- 5percent?) of metropolitan landfills and 79percent (+I’-5percent) of nonmetropolitan landfills were owned by counties and municipal governments. About 24percent (+/- 5percent) of metropolitan and 13percent (+/-4percent) of nonmetropolitan landfills were privately owned. 9 The average metropolitan landfill was about 191acres in size,but the range was from 1acre to 2,000acres.The average nonmetropolitan landfill was about 98acres, while the range was from 1acre to 1,200acres.

l The averagemetropolitan landfill received about 50percent (+I-5 percent) of its waste from the communiw where it was located and 36percent (+/- 4percent) from the remainder of the county. Only about 7percent (+/- 3percent) of the metropolitan landfills accepted out-of-state waste. Nonmetropolitan landfills received about 61percent (+/- 7percent) of their waste from the local community and about 34percent (+/- 4percent) from the remainder of the county. About 3percent (+/-2 percent) received waste from out of stie. Out-of-state waste averaged lessthan 1percent (+/- 1percent) ofthe waste received by each metropolitan and nonmetropolitan municipal landfill.

l Typically, the waste sentto the landfills was household waste, industrial nonhazardous waste, and construction-related debris. Weestimate that only about 7percent (+/- 3percent) ofthe metropolitan landfills had received hazardous waste from sources that generate small quantities of waste and lessthan 3percent (+/-2percent} had received hazardous waste from sources that generate large quantities of waste.3Among nonmetropolitan landfills, 8and 1percent (+/- 3and 1percent) had received hazardous waste from small- and largequantity generators, respectively. + About 51percent (+/- 6percent) ofthe metropolitan landfiis had received asbestos, about 49percent (+/- 6percent) had received sewage sludge, and

‘Seetable I.1inapp. I,which givesthedataonthe number of usable andunusable responses. “Sampling errors havebeen rounded tothe nearestwhole number. “EPAprohibited municipal landfills from accepting hazardouswaste from largequantity generators starting in 1980.Municipal landfills areallowed toaccept hazardous wastefrom smallquantity generators.

Page 70 GAOACED-95-84 Demographics of People Near Waste FacilitiesAppendix II Overview of Municipal Solid Waste Landfills Surveyed

about 13percent (+/- 4percent) had received ashfrom municipal incinerators. For nonmetropolitan landfills the percentages were 43,36, and 5percent (+I- 6,5,and 2percent), respectively. 9 About 73percent (+/- 5percent) ofthe metropolitan landfills began receiving waste before 1980,and lessthan 3percent (+/-2 percent) began after 1990.Twenty-three percent (+/- 5percent) of the metropolitan landfills had closed by the time they received the questionnaire. Ofthose that planned to close and could estimate their closing date, 25percent (+/- 6percent) saidthey would close bythe end of 1995.Ofthe landfills planning to continue their operations beyond 1995,64 percent (+/- 8percent) planned to operate beyond the year 2000.

l Among nonmetropolitan landfills, 69percent (-+I-5percent) began receiving waste before 1980,and 1percent (+/- 1percent) began after 1990.Twenty-seven percent (+/- 5percent) ofthe nonmetropolitan landfills had closed bythe time they received the questionnaire. Ofthose that planned to close and could estimate their closing date,49percent (+/- 7percent) saidthey would close by the end of 1995.Ofthe landfills planning to continue their operations beyond 1995,64 percent (+/- 6percent) planned to operate beyond the year 2000.

l Forty-seven percent (+/- 6percent) of metropolitan landfills did not have protective liners beneath any oftheir waste units. Fifty-five percent (+/- 6percent) of the metropolitan landfills did not haveleachate collection systems in place at any oftheir waste units. Over90percent (+/- 3percent) said that they had groundwater monitoring. About 16percent (+/- 4percent) saidthat the landfill had caused groundwater contamination at sometime.

l Sixty-six percent (+/- 5percent) of nonmetropolitan landfills did not have protective liners beneath any oftheir waste units. Eighty percent (+/- 5percent) ofthe nonmetropolitan landfills did not haveleachate collection systems in place at any oftheir waste units. About 67percent (+/- 5percent) said that they had groundwater monitoring, About 7percent (+/- 3percent) said that the landfill had caused groundwater contamination at sometime.

Page 71 GAO/RCED-96-84 Demographics of People Near Waste FacilitiesAppendix III 

# People Living Near Municipal Landfills Were Likely to Have Poverty RateSimilar to or Lower Than Ratein Restof County

While median household income is one indicator ofpeople’s economic status, the poverty rate-whether aperson’s income isbelow the national definition of poverty’- isanother indicator. Onthe basisof our survey, we found that the people living near municipal landfills were not likely to haveahigher poverty rate than the people in the rest ofthe county. Data from this analysis are presented below. The data in figures III,1 through III.4 represent the findings from our sample of landfills. National estimates cannot be accurately madewithout applying amargin of error. The approximate sampling errors for the data on metropolitan and nonmetropolitan landfills can befound in tables III. 1 and III.2 and should beapplied to the data in each appropriate figure.
Table III.1: Sampling Errors for Selected Percentages and Sample Sizes of Metropolitan Landfills Sample size (N)and related sampling error atthe 9bpercent Percentage of confidence level landfills 160 165 170 175 180 185 190 5 3 3 3 3 3 3 3 10 4 4 4 4 4 4 4 15 5 5 5 5 5 5 4 20 6 5 5 5 5 5 5 25 6 6 6 6 6 5 5 30 6 6 6 6 6 6 6 35 7 7 6 6 6 6 6 40 7 7 7 6 6 6 6 45 7 7 7 7 6 6 6 50 7 7 7 7 6 6 6 Note: Sampling errors have been rounded to the nearest whole number.
For example, in figure 111.1, the people living within 1mile of31percent of the metropolitan landfills had ahigher poverty rate than the rate in the rest of the county. Using 31percent and asample sizeof 190,the sampling error atthe 95-percent confidence level for the information in figure III. 1is approximately 6percent. By applying this approximate sampling error, we can estimate that the people living within 1mile of between 25and 37percent of metropolitan landfills had apoverty rate higher than the rate in the rest ofthe county.

L’Poverty” isdefined bythe U.S.Bureauofthe Censusasanindividual or family incomebelow a certain amount. In 1990,this amount, known asthepoverty line, was$6,310 for anindividual and 812,674 for anonfarm family of four. Inour analysis,we usedthe censusdatafor individuals below the poverty line.
Page 72 GAOiRCED-96~84 Demographks of People Near Waste FacilitiesAppendix III People Llviug Near Municipal Landfllls Were Likely to Have Poverty Rate SMlar to or Lower Than Rate ln Rest of County

Table 111.2:

Sampling Errors for Selected Percentages and Sample Sizes of Nonmetropolitan Landfills Percentage of landfills 5 Sample size (N) and related sampling error at the 95percent confidence level 90 95 100 105 4 4 4 4 10 6 6 6 6 15 7 7 7 7 20 8 a a 7 2.5 9 a 8 a 30 9 9 9 a 35 10 9 9 9 40 10 10 9 9 45 10 10 9 9 50 10 10 9 9 Note: Sampling errors have been rounded to the nearest whole number. Figures III. 1and III.2 compare the poverty rate of individuals living within 1mile of metropolitan and nonmetropolitan landfills with the rate for individuals in the rest ofthe county and the nation. The poverty rate for the people living near metropolitan landfills was higher than the rate for people in the surrounding county 31percent of the time. Thepoverty rate for these people was also higher than the national average for metropolitan areas about 23percent ofthe time. The people Iiving near nonmetropolitan landfills had apoverty rate higher than the rate in the host county and the national averagefor nonmetropolitan areasabout 45 and 59percent of the time, respectively.

Page 73 GAO/RCED-96-34 Demographics of People Near Waste FacllltleaAppendix III People Livlng Near Municipal Landfills Were Likely to Have Poverty Rate Similar to or Lower Than Rate ln Rest of County

Figure 111.1:

Poverty Rate Within 1Mile of Metropolitan Landfills Compared With Rate in Rest of l-lost County or Nation 100 Percentage of Landfills 90 80 70 69
60 50 40 30 20

0 Percent Percent Percent Percent Where Where Where Where Poverty Poverty Poverty Poverty Rate Is Rate Is Rate lo Rate Is Higher Lqwer Higher Lower Compared With Host County Compared With National Average’

Note: N = 190.

aThe national average for metropolitan areas IS 12.1 percent

Page 74 GAO/RCED-96-84 Demographics of People Near Waste FacilitiesAppendix III People Living Near Municipal Landfills Were Likely to Have Poverty Rate Similar to or Lower Than Rate in Rest of County

of Nonmetropolitan Landfills Compared With Rate in Rest of Host County or Nation 100 Percentage of Landfills 90 80 70 60 55 5o 45

40 30 20

0 ll Percent Percent Where Where Poverty Poverty Rate lo Rate Is Higher Lower 10 59 

# 41 h

Percent Percent Where Where Poverty Poverty Rate Is Rate Is Higher Lower Compared With Host County Compared With National Average0

Note: N = 105.

aThe national average for nonmetropolitan areas is lE.8 percent. Figures III.3 and III.4 show how much the poverty rate ofthe people living within 1mile of the landfills differed from the rate ofthe people in the rest of the county. The poverty rate for individuals living near metropolitan landfills was not often significantly higher than the rate in the rest of the county.2 The rate was about the same or significantly lower most ofthe time. The sameheld true for people living near nonmetropolitan landfills.

2For the purposes ofthis analysis, asignificant difference inthe poverty rate isdefined as morethan 2.5percent. Inapp. IV,weshowthe relative difference between the poverty rates ofpeople living within 1mile ofthe landfills and inthe restofthecounty

Page 75 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesAppendix III People Living Near Municipal Landfllls Were Likely to Have Poverty Rate Similar to or Lower Than Rate ln Rest of County

Figure 111.3:

Degree of Difference Between Poverty Rate Within 1Mite of Metropolitan Landfills and Rate in Rest of Host County 100 Percentage of Landfills 90 60 70 60 50 47 40 35 30 20

cllr 19 10 0

Note 1: N = 190. Note 2: Percentages do not add to 100 percent because of rounding
“The poverty rate of the people in the l-mile area was at least 2.5 percent less than the rate in the rest of the hostcounty. bThe poverty rate of the people in the l-mile area was at least 2.5 percent more than the rate in the rest of the host county.

Page 76 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesAppendix III People Living Near Municipal LandfilLs Were Likely to Have Poverty Rate Similar to or Lower Than Rate in Rest of County

Figure 111.4:

Degree of Difference Between Poverty Rate Within 1Mile of Nonmetropolitan Landfills and Rate in Rest of Host County 100 Percentage of Landfills 90 60 70 60 50
4o 35 34 30 30 20 10 0 m

Noie 1, N = 105 Note 2: Percentages do not add to 100 percent because of rounding.

BThe poverty rate of the people in the l-mile area was at least 2.5 percent less than the rate in the rest of the host county. bThe poverty rate of the people in the l-mile area was at least 2.5 percent more than the rate in the rest of the host county.

Page 77 GAO/RCED-95-84 Demographics of People Near Waste FacUitieaAppendix IV 

# Relative Differences Between PeopleWithin 1Mile of Landfills andin Restof County

This appendix and appendix Vexpand on the data presented in chapter 2 and appendix III, inwhich we showed the absolute differences between the people living within 1mile of landfills and the people in the rest ofthe host county with respect to race, income, and poverty. The analyses in this appendix address the relative differences in race, income, and poverty status between people living within 1mile ofthe landfills and the rest of the host county. Calculations of both absolute and relative differences are equally valid but canproduce widely different results for particular situations, asdemonstrated below. In the interest of thoroughness, we conducted both analyses. However, the overall results were the same.We found that neither minorities nor low-income people were disproportionately represented near landfills in any consistent manner. While we also analyzed populations within 3miles ofthe landfills for this review, we did not include those results because oftheir close similarity to the results for populations within 1mile. The examples that follow illustrate the difference between our analysis of absolute differences and relative differences between populations. For these examples, we chose to look atthe differences between the racial composition of people living within 1mile of metropolitan landfills and in the rest ofthe host county. In our analysis ofthe absolute differences, we havedefined adifference of at least 10percent assignificant. If the percentage of nonminorities living within 1mile was at least 10percent greater than the percentage of nonminorities in the rest ofthe county, we classified that difference as being significantly more. Likewise, if the percentage of nonminorities living within 1mile was at least 10percent lessthan the percentage in the rest of the county, we classified that difference asbeing significantly less. Weapplied the samecalculations to minority populations. Figure IV.1shows the datafor the absolute differences in our example. The figure shows that more than 60percent ofthe metropolitan landfills had apercentage of nonminorities within 1mile that was not significantly different from the percentage in the rest ofthe county. Only about 13percent ofthe landfills had apercentage of nonminorities within 1mile that was significantly lessthan the percentage in the rest ofthe county. The second setofthree bars, amirror image ofthe first set,shows the data for minorities.

Page 78 GAOIRCED-95-84 Demographics of People Near Waste FacilitiesAppendix N Relative Differences Between People Within 1 Mile of Landfills and in Rest of County

Figure IV.1: Degree of Difference Between People Within 1Mile of Metropolitan Landfills and in Rest of Host County, by Race 100 Percentage of Landfills 90 60 70 ta 60 50 40 30 20 62

Comparison of Comparison of Nonminorities Minorities

Note: N = 190.
aThe percentage in the l-mile area is at least IO percent less than the percentage in the rest of the host county. bThe percentage in the 1-mile area is at least 10 percent more than the percentage in the rest of the hoat county. The analysis of the relative differences isslightly more complicated. To calculate the relative difference for race, we subtracted the percentage of nonminorities in the county from the percentage within the l-mile area and divided the result by the percentage of nonminorities in the county. For race, we again defined a lo-percent relative difference assignificant. The example below shows how the calculations of absolute and relative differences yield different results.

l Absolute difference. If the percentage of nonminorities in the l-mile areais 84and the percentage of nonminorities in the county is 76,the absolute

Page 79 GAO/RCED-96-84 Demographics of People Near Waste FacilitiesAppendix IV Relative Differences Between People Within 1 Mile of Landfills and in Rest of County

difference is 84minus 76,or 8.This difference would not be considered significant in our analysis because it is lessthan 10percent. + Relative difference. If the percentage of nonminorities in the l-mile areais 84andthe percentage of nonminorities in the county is 76,the relative difference is 84minus 76divided by 76,or 10.5percent. This difference would be considered significant in our analysis because it is more than 10percent. Figure IV+2shows the data for the relative differences in our example. The figure shows adifferent picture than the absolute differences, particularly for minorities. In almost 60percent of the landfills, the percentage of nonminorities within 1mile is not significantly different from the percentage in the rest ofthe county. The percentage issignificantly lessin about 15percent of the cases;in almost 30percent ofthe cases,it is significantly more. The percentage of minorities living within 1mile is not significantly different only 7percent of the time. Thepercentage of minorities living within 1mile issignificantly less69percent ofthe time and significantly more 23percent of the time. The more extreme results for minorities (i.e., fewer instances in which the difference is not significant) probably occur because the percentage of minorities is generally lower than the percentage of nonminorities. Therefore, asmall difference between the percentages in the I-mile area and in the rest ofthe county is more likely to be large relative to the county.

Page 80 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesAppendix IV Relative Differences Between People Within 1 Mile of Landfills and in Rest of County

MiTeof Metropolitan Lmbfills Relative Iall Percentage of Landfills to Rest of Host County

80 70 60 51 69 

# r

n

Comparison of Nonminorities Comparison of Minorities

Note 1. N = 190. Note 2: Percentages for minorities do not add to 100 percent because of rounding.

aThe percentage in the l-mile area is at least 10 percent less, in relative terms, than the percentage in the rest of the host county. bThe percentage in the l-mile area is at least IO percent more, in relative terms, than the percentage in the rest of the host county. The data in figures IV.3through IV.8 represent the findings from our sample of landfills+ National estimates cannot beaccurately madewithout applying amargin of error. The approximate sampling errors for metropolitan and nonmetropolitan landf& can befound in tables III. 1and III.2 and should be applied to the data in the appropriate figure.

Page 81 GAOIRCED-96-M Demographics of People Near Waste FacilitiesAppendix IV Relative Differences Between People Within 1 Mile of Landfills and in Rest of County

Figure IV.3: Race of People Within 1 Mile of Metropolitan landfills Relative to Rest of Host County 100 Percentage ot Landfills 90 80 70 60 !a 60 40 30 211 20 10 0 69

Comparison of Comparison of Nonminorities Minorities

Note 1: N = 190. Note 2: Percentages for minorities do not add to 100 percent because of rounding.

BThe percentage in the 1-mile area is at feast 10 percent less, in relative terms, than the percentage in the rest of the host county. bThe percentage in the l-mile area is at least 10 percent more, in relative terms, than the percentage in the rest of the host county.

Page 82 GAO/RCED-95-M Demographics of People Near Waste FacilitiesAppendix IV Relative Differences Between People Within 1 MiIe of Landfills and in Rest of County

Figure IV.4: Race of People Within 1 Mile of Nonmetropolitan Landfills 1 1 100 Percentage of Landtills Relative to Rest of Host County 90
80
70 60
50
40 30 20 10 ,9 I

56

Xl

14

Comparison of Comparison of Nonminorities Minorities

Note: N = 105

aThe percentage in the 1-mile area is at least 10 percent less, in relative terms, than the percentage in the rest of the host county. bThe percentage in the 1-mile area is at least 10 percent more, in relative terms, than the percentage in the rest of the host county

Page83 GAO/RCED-95-84 Demographics of People Near Waste Facilities YAppendix IV Relative Differences Between People Within 1 Mile of LandfZlls and In Rest of County

Figure 1V.5:Median Household Income of Psople Within 1Mile of Metropolitan Landfills Relative to Rest of Host County 100 Percentage of Landfills 90 a0 70 60 50 40 40

35 3o 25 20 10 0 a

Note: N = 190
aThe median household income in the l-mile area is at least 10 percent less, in relative terms, than the median household income in the host county. bThe median household income in the i-mile area is at least 10 percent more, in relative terms, than the median household income in the host county.

Page 84 GAOAZCED-96-84 Demographics of People Near Waste FacilitiesAppendix IV Relative Differences Between People Within 1 Mile of LandfIlLs and in Rest of County

Figure IV.6: Median Household Income of People Within 1Mile of Nonmetropolitan Landfills Relative to Rest of Host County 100 Percentage of Landfills 90 $0 70 60 55 50 40 30 20 16

Note: N = 105.
aThe median household income in the I-mile area is at least 10 percent less, in relative terms, than the median household income in the host county. bThe median household income in the l-mile area is at least IO percent more, in relative terms, than the median household income In the host county.

Page 86 GAO/RCED-95-94 Demographics of People Near Waste FaciRtlesAppendix lV Relative Differences Between People Within 1 Mile of Landfills and in Rest of County

Figure IV.7: Poverty Rate of People Within 1Mile of Metropolitan Landfills Relative to Rest of Host County 100 Percentage of Landfills 90 80

Note 1: N = 190. Note 2 Percentages do not add to 100 percent because of rounding.

aThe poverty rate of individuals in the l-mile area is at least 10 percent less, in relative terms, than the rate in the host county. bThe poverty rate of Individuals in the l-mile area is at least 10 percent more, in relative terms, than the rate in the host county

Page 86 GAOiRCED-96-M Demographics of People Near Waste FacilitiesAppendix N Relative Differences Between People Within 1 Mile of Landfills and in Rest of County

Figure IV.8: Poverty Rate of People Within 1Mile of Nonmetropolitan 100 Landfills Relative to Rest af Host County 90 60 70 60 50 40 30 20 10 0 Percentage of landfills 

# 39

Note: N = f05.
BThe poverty rate of individuals in the l-mile area is at least 10 percent less, in relative terms, than the rate in the host county. Vhe poverty rate of individuals in the l-mile area is at least 10 percent more, in relative terms, than the rate in the host county.

Page 87 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesAppendix V 

# Cross-Tabulations of Income and Poverty Rateof PeopleWithin 1Mile of Landfills and in Restof County, by Race

This appendix provides specific data on our cross-tabulations of income and poverty by race. The purpose ofthis analysis was to determine whether the median household income and poverty rates of nonminorities and minorities living within 1mile of municipal landfills were lower or higher than those oftheir counterparts in the rest ofthe host county. Our sample of landfills showed that the incomes of nonminorities and minorities were not generally lower than the income in the rest of the county. Similarly, the poverty rates of nonminorities and minorities were not generally higher than the rate inthe rest ofthe county. Wealso compared the people living within 1mile of the landfills with those in the rest ofthe nation. Weused both absolute differences and relative differences in these comparisons. (The distinction between these approaches is explained in app. IV.) As in our previous analysis, sampling errors must be applied to the figures below when making estimates about the national universe of municipal landfills. The approximate sampling errors arefound in tables III. 1and III.2 in appendix III. 

# Median Household Income by Race Wefound that nonminorities and minorities living within 1mile of landfills generally had similar or higher median household incomes than nonminorities and minorities in the rest ofthe county. Wealsofound that nonminorities and minorities living near landfills often had incomes higher than the national median for their counterparts in the rest ofthe country. In metropolitan areas,we found that the median household income of nonminorities living within 1mile of landffls was aslikely to behigher than the income in the rest ofthe county asit was to belower. For nonmetropolitan landfills, the income was likely to be higher 57percent of the time. Furthermore, the median household income of nonminorities living within 1mile of metropolitan and nonmetropolitan landfills was higher than the national median household income for nonminorities 48 and 44percent ofthe time, respectively. (Seefigs.V.1andV.4.) For metropolitan areas, only 24percent of the landfills had nonminorities living within 1mile with amedian household income that was significantly lower in absolute terms than the income of nonminorities in the rest ofthe county. The median household income ofthe people living near the remaining landfills were either not significantly different or were significantly higher, In nonmetropolitan areas, only 10percent of the landfills had nonminorities living nearby with asignificantly lower income than the people in the rest of the county. (Seefigs. V.2andV.5.)

Page 88 GAO/RCED-96-84 Demographics of People Near Waste FszilitiesCross-Tabulations of Income and Poverty Rate of People Within 1 Mile of Landfflls and in Rest of County, by Race

Finally, for metropolitan areas we found that 27percent ofthe landfrrs had nonminorities living within 1mile whose median household income was significantly lessin relative terms than the income in the rest ofthe county. The remaining 73percent had anincome that was not significantly different or was significantly higher. For nonmetropolitan areas, 19percent ofthe landfills had nonminorities living nearby with a significantly lower income in relative terms than the people in the rest of the county. (Seefigs.V.3and V.6.) With respect to minorities, we found that the median household income near 67percent ofthe metropolitan landfills was higher than the median income of minorities in the rest of the county, For nonmetropolitan landfills, 43percent ofthe landfills showed this pattern. In metropolitan and nonmetropolitan areas,the median household income of minorities living within 1mile of landfills was higher than the national median household income for minorities 53and 37percent of thetime, respectively. (Seefigs.V.I and V.4.) The median income of minorities living with.in ! mile of metropolitan landfills was significantly lower than it was in the rest of the county 20percent of the time. For nonmetropolitan landfills, 28percent ofthe landfills showed this pattern. (Seefigs. V.2and V.5.) Finally, the median income of minorities living near metropolitan and nonmetropolitan landfills was significantly lower in relative terms than the income of the people in the rest ofthe county 26and 43percent ofthe time, respectively, Therefore, in the majority of instances, the median income was not significantly different or was significantly higher, in relative terms. (Seefigs.V.3andV.6.)

Page 89 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesAppendix V Cross-Tabulations of Income and Poverty Rate of People Within 1 Mile of LandfIlls and in Rest of County, by Race

Figure V.l: Metropolitan Landfills Where Median Household Income of Minorities and Nonminorities Living Within 1Mile Was Higher Than in Rest of Host County or Nation 100 Percentage ofLandfills
so 60 70 67 60 

# r
50 50 40 30 20 10 0 LL

landfills With Landfills With Peoples’ Peoples’ Incomes Higher Incomes Higher Than Host Than Nat’1 County Average

Note 1 N = 190 for nonminorities and 168 for minorities in the comparison with the income in the county. N = 190 for both in the comparison with national averages. Note 2: The income of nonminorities in the I-mrle area is compared with the income of nonmlnorities outside that area. Likewise, the income of minorities in the l-mile area is compared with the income of minorities outside that area.

Page 90 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesAppendix V Cross-Tabulations of Income and Poverty Rate of People Within 1 Mile of Landflll~ and in Rest of County, by Race

Figure V.2: Absolute Difference Between Median Household Income of People Living Within 1Mile of Metropolitan Landfills and in Rest of Host County, by Race 100 Percentage of Landfills 90 60 70 60

47

Nonminorities Minorities Y
Note 1: N = 190 for nonminorities and 168 for minorities. The percentages for nonminorities do not add to 100 percent because of rounding. Note 2: The income of nonminorities in the l-mile area is compared with the income of nonmrnoritjes outsrde that area. Likewise, the income of minorities in the l-mile area is compared wrth the income of minorities outside that area.
aThe median household income of the people in the l-mile area is at least $5,000 less than the median household income in the rest of the host county bThe median household income of the people in the l-mile area is at least $5,000 more than the median household income in the rest of the host county.

Page 91 GAO/RCED-96-84 Demographics of People Near Waste FacilitiesAppendix V Cross-Tabulations of Income and Poverty Rate of People Within 1 Mile of Landfills and in Rest of County, by Race

Figure VA Rdative Difference Between Median Household Income of People Living Within 1Mile of Metropolitan Landfills and in Rest of Host County, by Race 100 90 60 Percentage of Landfills

70 60 50 40 30 20 10

Nonminorities Minorities

Note 1: N = 190 for nonmlnorities and 168 for minorities. Note 2: Percentages for minorities do not add to 100 percent because of rounding Note 3: The Income of nonminorities in the l-mile area is compared with the income of nonminorities outside that area. Likewise, the income of minotilies in the 1-mile area is compared with the incomes of minorities outside that area.
aThe median household income rn the l-mile area is at least 10 percent less, in relatrve terms, than the income in the rest of the host county. bThe median household income in the 1-mile area is at least IO percent more, In relative terms, than the income in the rest of the host county.

Page 92 GAO/RCED-95-94 Demographics of People Near Waste FacilitiesAppendix V Cross-Tabulations of Income and Poverty Rate of People Within 1 Mile of LandfilLs and in Rest of County, by Race

Figure V.4: Nonmetropolitan Landfills Where Median Household Income of Minorities and Nonminorities Living Within 1Mile Was Higher Than in Rest of Host County or Nation 100 go 80 70 60 50 40 30 20 10 0 Percentage of Landfills

b7 

# 43

37 

# .ll Lb

Landfills With Landfills With Peoples’ Peoples’ IncomesHigher Incomes Higher Than Host Than Nat’1 County Average

Note 1: N = 105 for nonminorities and 89 for minorities in the comparison with county incomes. N
= 105 for both in comparison with national averages. Note 2: The income of nonminorities in the l-mile area is compared with the income of nonminorities outside that area. Likewise, the income of minorities in the l-mile area is compared with the income of minorities outside that area.

Page 93 GAOIRCED-96-84 Demographics of People Near Waste FacilitiesAppendix V Cross-Tabulations of Income andPoverty Rate of People Within 1 Mile of Landfills and in Rest of County, by Race

Figure V.5: Absolute Difference Between Median Household Income of People Living Within 1Mile of Nonmetropolitan Landfills and in Rest of Host County, by Race 100 Percentage of Landfills 90 80 70 62 60 55 50 40 30 28 20

Nonmlnorities Minorities

Note 1: N = 105 for nonminonties and 89 for minorities Note 2: The income of nonminorities in the 1-mile area is compared with the income of nonminorities outside that area. Likewise, the income of minorities in the l-mile area is compared with the income of minorities outside that area.
dThe median household income of the people in the l-mile area is at least $5,000 less than the median household income in the rest of the host county. bThe median household income of the people in the l-mile area is at least $5,000 more than the median household Income in the rest of the host county.

Page 94 GAOIRCED-SS-84 Demographics of People Near Waste FacilitiesAppendix V Cross-Tabulations of Income and Poverty Rate of People Within 1 Mile of Landfills and in Rest of County, by Race

Figure V.6: Relative Difference Between Median Household Income of People Living Within 1Mile of Nonmetropolitan Landfills and in Rest of Host County, by Race 100 90 80 70 60 50 40 30 20 10 Percentage of Landfills

Nonminorities Minorities

Note 1: N = 105 for nonmlnorities and 89 for minorities Note 2: The income of nonminorities in the 1-mile area is compared with the income of nonminorities outside that area. Likewise, the income of minorities in the l-mile area is compared with the income of minorities outside that area.
=The median household income in the l-mile area is at least 10 percent less, in relative terms, than the income in the rest of the host county. bThe median household income in the l-mile area ISat least 10 percent more, in relative terms, than the income in the rest of the host county. 

# Poverty Ratesby Race Wefound that the poverty rates of both nonminorities and minorities living within 1mile of landfills were higher than the rates of their counterparts in the rest of the county lessthan half of the time, This was alsotrue when we compared the poverty rates of nonminorities and minorities living within 1mile of landfills with the rates oftheir counterparts across the country.

Page 95 GAOIRCED-95-84 Demographics of People Near Waste FacilitiesAppendix V Cross-Tabulations of Income and Poverty Rate of People Within 1 Mile of Landfllls and in Rest of County, by Race

For metropolitan landfills, the poverty rate of nonminorities living within 1 mile were higher than they were in the rest ofthe county 39percent of the time.1For nonmetropolitan landfills, the rate of nonminorities living nearby was higher 46percent of thetime. Thepoverty rate of nonminorities within 1mile of both metropolitan and nonmetropolitan landfills was higher than the national rate of nonminorities 45percent of the time. (Seefigs. V.7and V.10.) The poverty rate of nonminorities within 1mile of metropolitan and nonmetropolitan landfills was significantly higher than the rate of nonminorities in the rest ofthe county 22and30percent ofthe time, respectively. Consequently, they were not significantly different orwere significantly lower about 78and 70percent ofthe time, respectively. (See figs.V.8and V.11.) In relative terms, the poverty rate of nonminorities near metropolitan landfills was significantly lower 53percent ofthe time and significantly higher only 32percent ofthe time. For nonmetropolitan areas,the poverty rate of nor-minorities was significantly lower 40percent ofthe time and significantly higher 35percent ofthe time. (Seefigs.V.9andV.12.) The poverty rate of minorities living near metropolitan landftis was higher than the rate in the rest of the county 26percent ofthetime. The rate of minorities living near nonmetropolitan landfills was higher 42percent of the time. Minorities in metropolitan and nonmetropolitan areas had poverty rates higher than the national average of minorities 15and 22percent ofthe time. (Seefigs.V.7and V.10.) The poverty rate of minorities was significantly lower within 1mile of metropolitan and nonmetropolitan landfills than it was in the rest ofthe county 71and 51percent ofthe time, respectively. (Seefigs.V.8and V.11.) In absolute terms, the poverty rate of minorities in metropolitan and nonmetropolitan areaswas significantly lower than it was in the rest ofthe county 72and 51percent ofthe time, respectively. (See,figs.V.9and V.12.)

‘Nationally, poverty ties reported inthe 1990censuswere much higherfor minorities thanfor nonminorities: about 25percent compared with about 9percent.

Page 96 GAOIRCED-95-84 Demographics of People Near Waste FacilitiesAppendix V Cross-Tabulations of Income and Poverty Rate of People Within 1 Mile of Landfills- and in Rest of County, by Race

Figure V.7: Metropolitan Landfills Where Poverty Rate of Minorities and Nonminorities Living Within 1Mile Was Higher Than in Rest of Host County or Nation 100 PercentageofLandlills SO 80
70
60 50

Landfills With Landfills With People’s People’s Poverty Rate Poverty Rate Higher Than Higher Than Host Co. Nat’1Ave.

Note 1: N = 190 Note 2: The poverty rate of nonminorities in the 1-mile area is compared with the rate of nonminorities outside that area. Likewise, the poverty rate of minorities in the l-mile area is compared with the rate of minorities outside that area.

Page 97 GAO/RCED-96-84 Demographics of People Near Waste FacilitiesAppendix V Cross-Tabulations of Income and Poverty Rate of People Within 1 Mile of Landfills and in Rest of County, by Race

Figure V-8:Absolute Difference Between Poverty Rate of People Living Within 1Mile of Nonmetropolitan Landfills and in Rest of H&t County, by Race 100 Percentage of Landfills 90 80 70 80

Nonminorities Minorities ‘1

Note 1: N = 190 for nonminorities and 180 for minorities The percentages for nonminorities do not add to 100 percent because of rounding. Note 2. The poverty rate of nonminorities in the l-mile area IScompared with the rate of nonmlnorities outside that area. LIkewise, the poverty rate of minorities in the l-mile area is compared with the rate of mlnorlties outside that area.
aThe poverty rate of the people in the l-mile area is at least 2.5 percent less than the rate in the rest of the host county. bThe poverty rate of the people in the l-mile area is at least2.5 percent more than the rate in the rest of the hostcounty.

Page 98 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesAppendix Y Cross-Tabulations of Income and Poverty Rate of People Within 1 Mile of Landfills and in Rest of County, by Race

Figure V.9: Relative Difference Between Poverty Rate of People Living Within t Mile of Metropolitan Landfills and in Rest of Host County, by Race 100 Percentage of Landfills 90 80
70 60
50 40 30
20 10 5.3 -

32

Nonminorities Minorities

Note 1: N = 190 for nonminorities and 180 for minonties. Note 2: The poverty rate of nonminorities in the l-mile area is compared with the rate of nonminorities outside that area. Lrkewise, the poverty rate of minorities in the l-mite area is compared with the rate of minorities outside that area.
“The poverty rate of the people in the l-mile area is at least 10 percent less, in relative terms, than the rate in the rest of the host county. bThe poverty rate of the people in the I-mlie area is at least 10 percent more, in relative terms, than the rate in the rest of the host county.

Page 99 GACVRCED-SC-84 Demographics of People Near Waste FacilitiesAppendix V Cross-Tabulations of Income and Poverty Rate of People Witbin 1 Mile of Landfills and in Rest of County, by Race

Figure V.10: Nonmetropolitan Landfills Where Poverty Rate of Nonminorities and Minorities Living Within 1Mile Was Higher Than in Rest of Host County or Nation 100 Percentage of Landfills 90 60 70 60 

# 50 46

42 40 30 20 10 0

# 1

Landfills With Landfills With People’s People’s Poverty Rate Poverty Rate Higher Than Higher Than Host Co. Nat’1Ave. I5

22 

# L

Note 1: N = 105 for nonminorities and 96 for minorities in the comparison with the poverty rate in the county. N = 105 for both in the comparison with national averages. Note 2: The poverty rate of nonmlnorities in the l-mile area is compared with the rate of nonminorities outside that area. Likewise, the poverty rate of minorities in the i-mile area is compared with the rate of minorities outside that area

Page 100 GAOKRCED-96-84 Demographics ofPeople Near Waste FacilitiesAppendix V Cross-Tabulations of Income and Poverty Rate of People Within 1 Mile of Landfills and in Rest of County, by Race

Figure V.11: Absolute Difference Between Poverty Rate of People Living Within 1Mile of Nonmetropolitan Landfills and in Rest of Host County, by Race 100 Percentage of Landfills 90 60 70 60 50 -.

4o 35 34 35 30 30
20 14 10 0 ELI -A

Nonminorities Minorities

Note 1: N = 105 for nonminorities and 96 for minorities. The percentages for nonminorities do not add to 100 percent because of rounding. Note 2: The poverty rate of nonminorities in the l-mile area is compared with the rate of nonminorities outside that area. Likewise, the poverty rate of minorities rnthe l-mile area is compared with the rate of minorities outside that area.
aThe poverty rate of the people in the l-mile area is at least 2.5 percent less than the rate in the rest of the county. bThe poverty rate of the people in the 1-mile area is at least 2.5 percent more than the rate in the rest of the county.

Page 101 GAO/RCED-95-84 Demographics of People Near Waste Facilities /

/

/

/

/

P /Appendix V Cross-Tabulations of Income and Poverty Rate. of People Within 1 Mile of Landfills and in Rest of County, by Race

Figure V.12: Relative Difference B&een Poverty Rate of People Within 1Mile of Nonmetropolitan Landfills and in Rest of Host County, by Race 100 Percentage of Landfills 90 80 70 60 50
40 4o 35 30 25

20 10 0 DLi 51

35

14

Nonminorities Minorities

Note 1’ N = 105 for nonminorities and 94for minorities Note 2: The poverty rate of nonminorities in the l-mile area is compared with therate of nonminorities outside that area. LIkewise, the poverty rate of minorities in the l-mile area is compared with the rate of minorities outside that area.
aThe poverty rate of the people in the l-mile area is at least IO percent less, in relattve terms, than the rate in the rest of the host county. bThe poverty rate of the people in the 1-mile area is at least 1Clpercent more, in relative terms, than the rate in the rest of the host county

Page 102 GAOIRCED-95-84 Demographics of People Near Waste FacilitiesAppendix Vl 

# Results From GAO’sSurveyon Public Participation at Municipal Landfills

The majority of our survey’s questions about public participation concerned those landfills that began receiving waste after January 1,1988.’ Weselected this timeframe because it more accurately reflects relatively current state and local decision-making procedures, As mentioned in appendix II, about 70percent ofthe landfills in our sample were established before 1980,Only 45of the 633respondents fit our criterion. Therefore, the responses to our questions cannot be usedto generalize about the facilities nationwide that began operation after 1988. The small number of respondents to our questions on this issue indicated that local governments or landfii owner/operators took avariety of steps to encourage public participation in the site selection and permit approval processes. However, without knowing more about the specific conditions at each ofthese landfills, which was beyond the scope of our review, we are not able tojudge the adequacy ofthe actions they took. Our questions on public participation can bedivided into two categories, The first setof questions addressed public involvement in the decision to place the facility in aparticular location (siting). The second setof questions addressed public involvement in decisions about the construction and operation ofthe facility. Only afew ofthe questions were intended to determine how the facilities’ owner/operators addressed concerns about environmental justice. AUofthe percentages presented below reflect only those respondents who reported that they could answer our questions. 

## SiteSelection

. For about two-thirds of the landfills that had begun operations after 1988, respondents saidthat they held public hearings to discuss alternative locations before the final location was selected. Over 70percent

‘Weaskedall landfills whether their stateandlocal governments currently require public notice and hearings onthe planned siting oflandfills. About 90percent of633respondents saidthat they knew about their stateand local public notice andhearing requirements. Wellover 90percent of respondents who saidthey knew answeredthat their statecurrently requires public notice ofthe planned siting of landfills A smaller number, but still over 90percent who saidthey knew, answered that their state currently requiresapublic hearing regarding the planned siting andoperation of municipal landfills. About 68percent ofthosethat saidthey knew answered that the local community requires public notice ofthe planned siting ofalandfill. About 64percent ofthose who saidthey knew answeredthat the local community requires public hearmgs It isimportant to recognize at leasttwo factswhenanalyzing theseresponses.First, the high percentage ofstate andlocal laws requiring notices andhearings isthecurrent condition anddoesnot necessarily meanthat these requirements were ineffect when most landfills weresited. Second,local governments that do not havelaws requirmg notice or hearings maybe bound bystate lawsthat do require them.

Page 103 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesAppendix VI ResuJts From GAO’s Survey on Public Participation at Municipal Landfills

responded that written and/or verbal comments from the public onthe selection ofthe sitewere collected or recorded.

. About half of the respondents saidthat more than one sitewas formahy considered for the landfti. One-third ofthose saidthat at least one ofthe locations was rejected because of public opposition.

l Respondents reportedly used avariety of methods to make announcements about the proposed landfill site. They placed announcements in newspapers in over 80percent ofthe easesbut used radio, television, or public meeting places asameansfor disseminating information much lessoften.

l Siting boards or commissions responsible for selecting the site were formed in lessthan two-thirds of the cases.However, few respondents saidthat aprivate citizen from the landfill community served on such a board or commission.

l Nearly all of respondents that held public hearings saidthey were at locations and times that were easily accessible to the public. About three-fifths of respondents said that they madepresentations to neighborhood groups and established apublic repository of information on the proposed site at an accessible location. Three-fifths also saidthat they used channels of communication that the community relies onfor its information, such aschurches or particular radio ortelevision stations, although these answers appear to becontrary to the respondents’ answer to the previous question on methods of disseminating information.

l Lessthan onequarter of the respondents saidthat they encouraged the formation of acommunity advisory panel. None saidthat they provided funding to the public for analyzing the proposed site,About two-fifths said that multilingual fact sheets and interpreters for public meetings were not applicable (implying that the community did not haveasignificant foreign-language population). Ofthe other respondents, only two saidthat interpreters were provided. 

## SiteConstruction and Operation . Three-quarters ofthe respondents said that public hearings were held to review the details ofthe construction and operation ofthe landfill before its construction. Over 80percent saidthat written and/or verbal comments from the public were collected or recorded. With this high level of public participation, about half saidthat public comments led to modifications in how their landfill was constructed or operated. Most commonly modified were the transportation routes approaching the facility, followed by the hours of operation. For asmaller number of landfills, respondents reported modifications to the sizeofthe facility, the distance between the waste units and nearby property used for specific purposes, the type of /
i

Page 104 GAO/WED-95-84 Demographics of People Near Waste FacilitiesAppendix VJ Results From GAO’s Survey on Public Participation at Municipal Landpills

waste accepted, or the useofvisual screening devices such astrees or berms to obscure the view ofthe facility.

l About half of the respondents said that aboard or commission was formed to make decisions about the facilily’s construction or operation. Lessthan half of those, in turn, saidthat private citizens from the landfill community served onthe board.

l The responses to our questions about the techniques used to help people participate in issues concerning the construction and operations ofthe landfill were similar to the questions about site selection. Overhalf of all respondents said that they had held public hearings ataccessible times and locations, provided fact sheets and made presentations to neighborhood groups, and established an accessible repository of information onthe proposed landfill.

l About half said that they used channels of communication that the community relies onfor information. Fewer than one-fifth saidthat they encouraged the formation of acommunity advisory panel. Finally, none of the respondents provided funding to the public for analyzing the proposed site.

Page 105 GAOLRCED-96-M Demographics of People Near Waste FsetJitJesAppendix VII 

# Cross-Tabulations of Demographic Dataatid Landfill Characteristics

Chapter 5discusses the issue ofthe potential health effects associated with hazardous and nonhazardous waste facilities. Weindicate that few data exist to support the assumption that these facilities causenegative health effects. Wealso indicate that we cross-tabulated the demographics of the people living near municipal landfills with data obtained from our survey of landfills. These data included answers to our questions about five landtill characteristics: the type of waste accepted atthe landfill; the useof liners, leachate collection systems, and groundwater monitoring; andthe incidence of groundwater contamination. Wechose these characteristics because oftheir possible implications for the risks posed by the landfills. For example, alandfill without liners might pose more risk than onewith liners. Wecaution, however, that the presence or absence of any ofthese characteristics does not necessarily increase or decrease risk. For each cross-tabulation, we stratified the data from chapter 2and appendix III according to the answers respondents provided to our question about the landfills’ characteristics. For example, we determined whether the landfills where ahigher percentage of minorities lived within 1mile than lived in the rest of the county were more likely to haveliners than the landftis where alower percentage of minorities lived nearby than lived in the rest of the county. Our analysis produced 30cross-tabulations: the five IandEll characteristics cross-tabulated with race, income, and poverty status for both metropolitan and nonmetropolitan landfills. The data on metropolitan and nonmetropolitan landfills havebeen combined in the figures below. We were able to test for statistically significant associations between landfill characteristics and demographic data in 25of the 30cross-tabulations. In the other five cross-tabulations, the data were not sufficient to conduct suchtests (either our sample sizewas too small ortoo few landfills had the relevant characteristic). Ofthe 25statistical tests we conducted, only one test indicated that the 1andfYlcharacteristics were associated with the demographic data We found that in nonmetropolitan areas,the landfii where ahigher percentage of minorities lived nearby than lived in the rest ofthe county were significantly more likely to have groundwater monitoring than the 1andfiIls where ahigher percentage of nonminorities lived nearby. (Seefig. VII.5.) The remaining tests for both metropolitan and nonmetropolitan landfills showed that the racial and economic data were not significantly

Page 106 GAO/RCED-96-84 Demographics of People Near Waste FacilitiesAppendix VII Cross-Tabulations of Demographic Data and Landfill Characteristics

associated with the landffl characteristics. Wedid not find, for example, that landfills where ahigher percentage of minorities lived nearby were more likely to lack liners than those landfills where ahigher percentage of nonminorities lived nearby. The figures that follow provide the data from our cross-tabulation of the race of the people living within 1mile of landfills with the five landfill characteristics. Wedid not include the cross-tabulations for median income and poverty. Wedid not find that the percentage of low-income people living near landfills that havecharacteristics that might increase the risk of harmful exposure was disproportionate relative to the rest of the county. While reading the following figures, it is important to keep in mind the percentage of landfills that haveor do not havewhat we havedefined as “risky” characteristics. For example, infigure VII.1,78percent ofthe metropolitan and 62percent ofthe nonmetropolitan landfills had accepted some ?-i&y” categories ofwaste. Our intent was not to make comparisons between metropolitan and nonmetropolitan landfills, although such comparisons can be made if the sampling errors of the estimates are considered. The sampling errors for the estimates are provided intables III.1and III2 in appendix III. 

## Typeof WasteAccepted by A characteristic that could beassociated with potential risk isthe type of 

## Landms waste that alandfill hasaccepted over the years. Respondents to our survey provided information on over 10types of waste they haveaccepted. Thesetypes include household garbage, commercial waste, construction and demolition debris, nonhazardous industrial waste, hazardous industrial waste from both small- and largequantity generators, incinerator ash,infectious waste, asbestos, and sewage sludge.Although it is not possible to sayconclusively that the presence of onetype ofwaste will increase the potential for risk, for the purposes of our analysis we placed each landhll into one oftwo categories depending onthe types of waste that it had accepted. The first category was landfills that reported having received only household garbage, commercial waste, construction and demolition debris, and nonhazardous industrial waste. Weestimate that 22percent ofthe metropolitan landfills and 38percent ofthe nonmetropolitan landfills were in this category. The second category was landfills that reported having also received any ofthe other more “risky”

Page 107 GAOIRCED-95-84 Demographics of People Near Waste FacilitiesAppendix VII Cross-Tabulations of Demographic Data and Landfill Characteristics

wastes. Weestimate that 78percent ofthe mekropolitan landfills and 62percent ofthe nonmetropolitan landfills were in this category. Wedid not find astatistically significant association between the percentage of minorities living within 1mile of landfills compared with the rest ofthe county and the acceptance ofany ofthe “risky” wastes. These data arepresented in figure VII.1.
Figure VII.1: Landfills Where Percenlase of Minorities or Nonminokies Living Within 1Mile Was Higher Than Percentage in Rest of Host County, Stratified by Type of Waste ACcepted 100 Percentage of Landfills 90 80
70

50
40
3o 26 20 10 0 Municipal, Commercial, and/or Industrial Waste All Types at

Waste Municipal,

Commercial, and/or Industrial Waste All Types of

Waste

Metropolitan Landfills Nonmetropolitan Landfills 

## I, Pet Mlnorlty Is Higher In I-MIlea

Pet. Nonminonty Is Higher In I-Mllet

Note: N = 187 for metropolitan landfills and 103 for nonmetropolitan landfills.

aN = 50 lor metropolitan landfills and 39 for nonmetropolitan landfills. bN = 137 for metropolitan landfills and 64 for nonmetropolitan landfills Although only one of the figures below illustrates astatistically significant association, it may be helpful to point out some ofthe data contained

Page 108 GAOIRCED-95-84 Demographics of People Near Waste FacilitiesAppendix VII Cross-Tabulations of Demographic Data and Landfill Characteristics

within them. Taking figure VII.1asan example, note that the four clusters of bar graphs represent metropolitan and nonmetropolitan landfiis. Each cluster represents those landfik that had accepted the two categories of waste that we established. There aretwo bar graphs for each category of waste: one representing the landfills that had apercentage of minorities living within 1mile that isequal to or higher than lived in the rest ofthe county, and one representing landfills that had ahigher percentage of nonminorities living within 1mile than lived in the rest ofthe county. Finally, the notes indicate the number of landfills that fell into each category. The data in figure VII.1could bedescribed in the following manner: Ofthe 50metropolitan landfills where the percentage of minorities living within 1 mile was equal to or higher than the percentage in the rest ofthe county, 26percent (13) received only municipal, commercial, and/or industrial waste, and 74percent (37) received other types ofwaste. Ofthe 137 landfills where the percentage of nonminorities living within 1mile was higher than the percentage in the rest of the county, 21percent (29) received only municipal, commercial, and/or industrial waste, and 79percent (108) received other types ofwaste. The sametype of description could be made ofthe nonmetropolitan landfills in figure VII.1, aswell asin the rest of the figures. 

## Liners BeneathWasteCells Landfills arelocated in different geological settings, contain different types 

## in Landfills ofwaste, and were designed and built to different specifications. Nevertheless, some landfill features are generally accepted asimportant for protecting human health and the environment. Oneofthose features is aprotective liner beneath the waste cell. Liners can be made ofsynthetic materials or compacted clay. Both are intended to berelatively impermeable to liquids moving through the landfill. For the purposes of our analysis, we placed each landfill into one of two categories: (1) landfills that had no liners and (2) landfills that had liners for atleast one waste unit. Among the metropolitan landfills, we estimate that about 53percent ofthe landfills had liners and about 47percent did not. Among the nonmetropolitan landfills, we estimate that about 34percent had liners and about 66percent did not. Wefound no statistically significant association between the useof protective liners and the percentage of minorities living within the 1mile

Page 109 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesAppendix VII Cross-Tabulations of Demographic Data and Landfill Characteristics

of the landfills compared with the percentage in the rest ofthe county. These data arepresented in figure VII.2.

Figure Vll.2: Landfills Where Percentage of Minorities or 100 Percentageof Landfills Nonrnino~ities Living Within 1Mile Was Higher Than Percentage in Rest of Host County, Stratified by Presence of Lined Waste Cells 90 80 70 60 50 40 30 20 10

Some Cells No Cells Have SomeCells No Cells Have Have Liners Liners Have Liners Liners Metropolitan Landfills Nonmetropolitan Landfills 

# L-L Pet Mlnorlty Is Higher In I-MIlea

Pet. Nonminority Is Higher Ifl 1-Mlleb

Note: N = 175 for metropolitan landfills and 98 for nonmetropolitan landfills

aN = 46 for metropolitan landfills and 38 for nonmetropolitan landfills. “N = 129 for metropolitan landfills and 60 for nonmetropolitan landfills.


## LeachateCollection Leachate collection systems are another design feature that isintended to 

## SystemsBeneath Landfills protect against contamination from 1andfiIls.The systems collect liquid, known asleachate, after it percolates down through the landfill. The leachate ispumped out ofthe landfill and treated, thereby reducing the likelihood that it wiIl permeate the landfill and enter the groundwater.

Page 110 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesAppendix VII Cross-Tabulations of Demographic Data and Landfill Characteristics

Weestablished the sametypes of categories with regard to the landfills’ leachate collection systems: (1) landfills that had no leachate collection systems and (2) landfills that had leachate collection systemsfor at least onewaste cell. Among the metropolitan landfills, about 54percent did not haveleachate collection systems and about 46percent did. Among the nonmetropolitan landfills, about 82percent did not havesuch systems and about 18percent did. Wefound no statistically significant association between the useof protective leachate collection systems and the percentage of minorities living within 1mile of the landfills compared with the percentage in the rest ofthe county. These data arepresented in figure VII.3.

Page 111 GAO/RCED-96-84 Demographics of People Near Waste FacilitiesAppendix VII Cross-Tabulations of Demographic Data and Landfill Characteristics

Figure Vll.3: Landfills Where Percentage 01Minorities or 100 Percentage of Lenclfills Nonminokies Living Within 1Mile Was Higher Than Percentage in Rest of Host County, Stratified by Presence of Leschate Collection Systems

Some Cells No Cells Have Some tills No Cells Have Have Leachate Leachate Have Leachate Leachete Collection Collection Collection Collection Systems Systems Systems Systems Metropolitan Landfills Nonmetropolitan Landfills 

# II- Pet Mtnonty 1sHigher In I-Mile’

PC!. Nonminoriry Is Hbgher In 1-Mile@

Note: N = 182 for metropolitan landfills and 99 for nonmetropolitan landfills.

BN = 48 for metropolhn landfills and 38 for nonmetropolitan landfills. bN = 134 for metropolitan landfills and 61 for nonmetropolitan landfills. 

## Groundwater Landfills havethe potential to release contaminated materials evenif 

## Contamination atLandfills liners or leachate collection systems are used. Weasked survey respondents whether their facility had everbeen determined to have caused groundwater contamination. Wedivided the landfills into categories depending upon whether or not they had caused groundwater contamination. Among the metropolitan landfills, 18percent reported that such contamination had been detected, and 82percent reported that it had not. Among the nonmetropolitan landfills, 7percent reported that such contamination had occurred, and 93percent saidthat it had not.

Page 112 GAO/RCED-96-84 Demographics of People Near Waste FacilitiesCross-Tabulations of Demographic Data and Landfill Charactutstics

Again, we cross-tabulated these data with race. Wefound no statistically signiscant association between groundwater contamination and the race of the people living near metropolitan or nonmetropolitan landfills. These data are presented in figure VII.4.

Figure Vll.4: landfills Where Percentage ol Minoritie8 or Nonminorities Living Within 1 Mile Was Higher Than Percentage in Rest of Host County, Stratified by Groundwater Contamination Pwcwtage of Landfills 100 60 60
70 60
50 40 30 20 10 0 Har Been l Has Nat Been a HewBeen a Has Not Been a Source of Source of Source of Source of Qrcundwnter Groundwalsr Groundweier Groundwater Contaminetion Contamination Contamination Contamination Metropolitan Landfills Nonmetropolitan Landfills 1 1 :.

Pet Mmorlty Is Higher In l-Miles Pet. Nonminor~ty Is Higher In 1-MileD

Note: N = 171 for metropolitan landfills and 94 for nonmetropolitan landfills

aN = 47 for metropolitan landfills and 37 for nonmetropolitan landfills. bN =124 for metropolitan landfills and 57 for nonmetropolitan landfills. 

## Groundwater Monitoring atLandfills Groundwater monitoring is used by landfills to detect leachate that has been released by the waste units. Groundwater wells are installed atthe perimeter of the landffl sothat groundwater samples can be taken and

Page 113 GAOIRCED-95-94 Demographics of People Near Waste FacilitiesAppendix VII Cross-Tabulations of Demographic Data and Landfill Characteristics

analyzed for contaminants that might originate from the landfill. Ifthe monitoring detects contaminants, corrective measures can be implemented to reduce their spread. Among the metropolitan landftis, 92percent reported that they conduct some level of groundwater monitoring. Among the nonmetropolitan landfills, 67percent reported that they monitor the groundwater. Wecross-tabulated these data with the demographic data asbefore. We found astatistically significant association between groundwater monitoring and the race of the people living near nonmetropolitan landfills. Figure VII.5 shows that the landfills where the percentage of minorities living within 1mile was higher than the percentage in the rest of the county were significantly more likely (82 percent vs.58percent) to have groundwater monitoring than the landflls atwhich the percentage of nonminorities living nearby was higher than the percentage in the rest of the county.

Page 114 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesAppendix VII Cross-Tabulations of Demographic Data and Landfill Characteristics

Figure Wl.5: Landfills Where Percentage of Minorities or Nonminorities Living Within 1Mile Was Higher Than Percentage in Rest of Host County, Stratified by Presence of Groundwater Monitoring Percentage of Landfills 100 90 60
70
60

Landfills Have Groundwater Monitorhg Landfilts Do Not

Have Groundwater Monitoring Landfills Have

Groundweier Monitoring LandfIlls Do Not

Have Groundwater Moniloring Metropofitan Landfills Nonmetropolitan Landfills 1 1 .”

Pet Mlnonty Is Higher In I-Milea Pet. NonmInorIty Is Higher In I-Mlleb

Note. N = 186 for metropolitan landfills and 100 for nonmetropolitan landfills

“N = 49 for metropolitan landfills and 38 for nonmetropolitan landfills. bN = 137 for metropolitan landfills and 62 for nonmetropolitan landfills

Page 115 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesAppendix VIII 

# Comments From the Environmental Protection Agency

Note: GAO comments supplementing those in the report text appear at the end of this appendix.

See comment 1. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON. D.C. 20460

Mr. Peter f. Guerrero MWAGEMENT Director, Environmental Protection Iesuee Resourcee , Community and Economic Development Division U.S. General Accounting Office Washington, D.C. 20548 Dear Wr. GuerrerO: I am replying to your letter of April 16, 1995, requesting that the Environmental Protection Agency (EPA) review and officially comment on a General Accounting Office (GAO) draft report entitled m and Wo~&z -waste: Qf Peonls Li ina NMr mte Fw (GAO/RCED-95-84). Weare grateful forvyou and your staff meeting with members of EPA's Office of Solid Waste and Emergency Response, Office of General Counsel and Office of Environmental Justice to discuss earlier drafts of the report. As you know, EPA is working to integrate environmental justice into the mission of the Agency. Wedo not believe that environmental justice Is simply a waste issue, but a way the Agency conducts business. It is important that no community or population experiences disproportionately high adverse human health or environmental effects of pollution. 1. The text of the report leaves the reader rith tbo impreeeion that the Biting of rante faailitioe is thn primmy toaue of environmental juetioe. Since the focus of the GAO study is limited to issues related to non-hazardous municipal solid waste facilitiee and the analysis of past studies of hazardous and non-hazardous waste facilities, the report should clearly distinguish this subset of issues from the broader sets of issues comprising environmental justice. Wenote that there are over 5,300 municipal waste landfills in the country. These landfills are a small, relatively low-risk segment of the over 47,000 waste disposal sites in the country which include Superfund sites as well as Resource Conservation and Recovery Act (RCRA) regulated hazardous waste facilities. Weappreciate that the title of the report reflects the limited scope of the report: however, the text of the report, particularly in the Executive Summary, gives the impression that waste facilities comprise the universe of environmental ju6tice issues,

Page116 GAOIRCED-95-84DemographicsofPeopleNearWaeteFacilitiesAppendixVIII CommentsFromtheEnvironmentaI Protection Agency

Now on p. 2.

See comment 2.

Now on p. 55.

See comment 3. To correct this impression, we suggest that the report's Purpose section state that environmental justice concerns go beyond those relating to the location of waste facilities and the resulting exposure to pollutants from those facilities. For example, the short list of several environmental justice issues on page 15 of the report should be included in the Purpose section. In addition, this section should note that there are other important environmental justice issue6 such as concern over cumulative or multiple exposures to environmental hazards. The report's eguating of environmental justice to waste facilities also creates the impression on page 3 that Executive Order 12898, "Federal Actions to Address Environmental Justice in Kinority Populations and Low-Income Populations*, is limited to addressing issues raised in studies of wade facilities. while environmental justice issues relating to waste facilities or sites are important, the Order issued by President Clinton on February 11, 1994, addresses a larger set of issues. The Order was issued to focus Federal attention on the environmental and human health conditions in minority communities and low-income communities and to foster non-discrimination in Federal programs that substantially affect human haalth or the environment. Agencies, including EPA, have developed strategies to identify and address, as appropriate, disproportionately high and adverse human health or environmental effects in minority populations and low-incose populations. The Order is also intended to provide minority communities and low-income communities access to public information on, and an opportunity for public participation in, the environment. matters relating to human health or 2. Desoription of Zxaoutive order 12898 Webelieve the GAO report should consistently use the terminology of the Order. The Order is tailored to address specific situations; however, by paraphrasing the Order, the report tends to mischaracterize the scope and/or requirements of the Order. For example, on page 65, Order requires "Federal agencies, the report states that the whenever practicable and appropriate, to collect and analyze" demographic information vpfor areas surrounding facilities or sites expected to have a substantial local environmental, human health, or economic effect." while the report does not make it clear, the Order also imposes this data requirement for non-federal facilities *when such facilities become the subject of a substantial Federal environmental administrative or judicial action."

Page117 GAOIRCED-96-84 Demographicsof PeopleNearWasteFacilitiesAppendix VIII Comments From the Environmental Protection Agency

See comment 4.

See comment 5.

Now on p. 5 and pp. 49-50.

See comment 6.

Page118 GAO/RCED-95-84 Demographics of People Near Waste Facilities 3. Yothodology EPAcontinues to work on developing d8mographic datagathering and social statistical analyeie tools that can help identify and address environm8ntal juetice concerns. As noted in Chapter 111~0 reviaw of the methodological variations in other studies, it ~0Uld b8 premature t0 Suggest that the Study r8li88 on an eStabliShed methodok?qy. 4. Th8 report do88 Sot oWr8Utly oh8raoterire m sitieq end permitting proeaarmm The report do88 not clearly dietinguieh batween anvironmental justice ieeu8e related to the local land we process as compared to lacation standards. With regard to lend uS8, land areas are generally toned for residential, industrial, or other use by local or county authorities. By contrast, EPA has established some minimum standards for the type of locations that would provide a protective setting for a RCEUfacility (e-g., not in a flood plain, not on a fault line). The F8deral location standards do not control the local land uee process. The report, at page 6 and pages 56-57, should be clarified on th8S8 points. With regard to the witting process, th8 report euqqeete that no avenue exists pursuant to current Federal regulations for addressing environmental justice concerne. However, current EPA rcgulationli allow members of the public to comment on 8nVirOnUtental jUStiC8 and Other iS8U8S related to proposed RCRA permitting actions. EPAthen conriders all public comments prior t0 permit iS6UanCs, particularly those CormD8ntU With a nexus to the protection of human health. Thank you for providing the opportunity to cement on this draft report. I hop8 that this information assists in clarifying the issue6 for the final report.Sincerely,

J&athan 2, Cannon Arisietant Administrator and Chief Financial OfficerAppendix VIII Comments From the Environmental Protection Agency

The following are GAO'Scomments on the Environmental Protection Agency’s (EPA) letter dated May 1,1995. 

# GAO’sComments location ofwaste facilities and have revised the report to clarify this point, 2. Wehaverevised the report to reflect this information about the executive order. 3. Wehaverevised the report to include this clarification about the requirement in the executive order. 4. Wesupport EPA'Sefforts in this area and agreethere are limitations to existing methodologies. 5. Wehaverevised the report’s executive summary to include this information. Wealso believe that chapter 4ofthe report makes it clear that local governments havealarge role. 6. Wehaverevised the report to include this information about EPA'S regulations on public participation.

Page 119 GAO/RCED-95-84 Demographics of People Near Waste FacilitiesAppendix IX 

# Major Contributors to This Report

Resources, c Gerald E. Killian, Assistant Director 

# Community, and Economic Development Allan Rogers, A&&ant Director Ross Campbell, Evaluator-in-Charge Larry D. Turman, Senior Evaluator Mitchell B. Kaqman, Senior Operations Research Analyst 

# Division, Washington, Judy K. Pagano, Senior Operations Research Analyst 

# D.C. Kelly S.Ervin, Social T ientist Phyllis Turner, Comm n&&ions Analyst

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