We won’t achieve what we don’t measure

From federal investments and corporate policies to local regulations and small business initiatives, there is cross-sector momentum toward greater environmental justice (EJ), equity and inclusion. Making equity part of day-to-day business is becoming a critical strategy for staying competitive, building resilience and succeeding in a changing political climate. At all levels, employees, communities and governments are demanding that waste management companies implement measurable, quantifiable equity programs.

The U.S. Environmental Protection Agency (EPA) defines EJ as “the fair treatment and meaningful involvement of all people regardless of race, color, national origin or income concerning the development, implementation and enforcement of environmental laws, regulations and policies.” As solid waste management professionals, we work in an industry with significant implications for EJ. While our industry does a great deal to foster a healthy physical environment for all, waste management infrastructure and facilities have done disproportionate harm to poor communities and communities of color.

Our industry is fraught with examples of under-resourced communities that must live with the harmful effects of solid waste infrastructure—infrastructure that, in turn, provides essential services to an entire region. Communities near solid waste management facilities too often bear the burden of increased traffic, air pollution and declining property values. In fact, the first recognition of environmental racism was reported in 1983 by the U.S. General Accounting Office, which found that 75 percent of communities near landfill sites were predominantly African American.

Many solid waste professionals recognize the problems that we have inherited from the waste practitioners of the past. So, how do we address this legacy of injustice? How do we realize our intentions to do better? How do we know whether we’re succeeding? To start, it would be wise to focus on the facilities themselves.

The many values of pursuing equity

Solid waste management facilities operate in a complex regulatory landscape, which increasingly includes equity and EJ concerns. A growing number of policies are rewarding EJ efforts while creating higher barriers for companies with no proven equity tactics. Today, the cost of doing good in the solid waste sector is simply part of the cost of doing business. Policies on the national and state levels are compelling solid waste management companies to deploy effective EJ strategies.

In May 2022, the U.S. Department of Justice launched its Office of Environmental Justice and published a Comprehensive Environmental Justice Strategy.

The EPA also continues to offer EJ grants, funding and technical assistance. With the Bipartisan Infrastructure Law, the EPA has allocated $275 million for solid waste infrastructure and recycling grants, 40 percent of which is earmarked to under-resourced communities through the Justice40 Initiative.

May 31, 2022, Gov. Phil Scott signed Vermont’s first EJ policy into law. The law reads that “it is the policy of the state of Vermont that no segment of the population of the state should, because of its racial, cultural or economic makeup, bear a disproportionate share of environmental burdens or be denied an equitable share of environmental benefits.”

Sept. 18, 2020, New Jersey Gov. Phil Murphy signed the state’s environmental justice law requiring that the New Jersey Department of Environmental Protection evaluate the environmental and public health impacts of certain facilities, including most solid waste management facilities, on overburdened communities when reviewing permit applications.

Facility equity audits

One approach to help solid waste management companies evolve in a shifting ecological and political landscape is implementing facility equity audits, which are a novel approach to ensuring equity in the solid waste management sector.

Following is a series of suggested steps that facilities can take to conduct a facility equity audit. This process will help identify the impacts a site (be it a material recovery facility, transfer station, landfill or other type of facility) has had and continues to have on the community in which it is located. This understanding, in turn, can create a sense of urgency that is essential to developing an action plan to address inequities and measure the impacts of these efforts.

Step one: Commit to equity.

Establishing a company’s commitment to equity is essential to this process. An example of this can be found in Phoenix-based Republic Services’ “2020 Sustainability Report,” which highlights the company’s focus on EJ. In addition to statements of support and commitment to social justice, many companies also are seeking ways to understand internal equity challenges and take steps to address them. For instance, in May of last year, Houston-based WM approved a proposal that called for an independent civil rights audit. A few weeks later, Stericycle, Bannockburn, Illinois, shareholders voted in favor of a similar proposal, while Republic shareholders voted against an independent civil rights audit.

Publicly or internally committing to equity, sustainability and EJ is a starting point. In making these commitments, companies should identify the fiscal and human resources they are able to commit to implementation.

If properly resourced and executed with genuine intent, equity audits can help hold companies accountable to their employees for delivering on internal equity-related efforts.

Step two: Identify community effects.

Once a company makes a broad commitment to equity and EJ, the work to implement this general intention begins.

A company first should assess the environmental health of the community in which the facility is located and compare these findings with a comparable neighborhood in another part of the region. While all environmental health risks cannot be attributed to the facility in question, an overall assessment provides a baseline understanding to better identify the facility’s impacts.

Next, a business should examine historical documents, such as the environmental impact statement written before the facility’s construction (if one exists), to better understand the elements and scale of the facility’s impacts on the community over time. Then, it should create a list of the facility’s impacts on the community, including air quality, property values, increased traffic, noise pollution, public health risks, odor and other hardships. To do this, companies may use the EPA’s environmental justice screening and mapping tool, EPA EJScreen, to select the impacts to measure and supplement the tool’s list as needed. Companies also can use the EPA Toxics Release Inventory Toxics Tracker, which identifies industrial facilities in a community that release chemicals into the air, water and land.

Finally, a company can capture remediation efforts by identifying the corrective environmental improvement efforts the facility has undertaken. Step two also should include significant community outreach. This outreach must be openly and transparently conducted and welcome criticism and honest feedback through a variety of methods, such as virtual and in-person listening sessions or community organization meetings. The company also should engage longtime residents and organizations to share the company’s historical effects on the community. This is an opportunity to approach community groups, coalitions and organizations focused on addressing the facility’s impact on the community.

Identifying the facility’s community impacts is a complex, multifaceted endeavor. Many nuances need to be considered, and issues often overlap. It might not always be clear if and how the facility’s various outputs have impacted overall health and wellness. However, a clear methodology that is consistently applied can help create a general understanding of how the facility has affected its neighbors.

Step three: Quantify the facility’s impact.

If a company completes steps one and two but does not quantify the impact, it is challenging to measure and track progress. The most powerful approach to quantifying impact is assigning it a monetary value. This complex process involves looking at various indicators, including health care costs, property value loss and the cost of remediation. The outcome of this process is the community equity impact, which is an estimate of the costs to the community arising from its proximity to the facility.

It is essential to quantify the facility’s negative impacts and the positive effects of any corrective measures to arrive at the final number. This final monetary figure is not a precise cost to the community because many aspects of quality of life and health can be neither monetized nor adequately quantified. However, a company has little hope of reaching targeted milestones and creating accountability without measurement. Therefore, the community equity impact represents the amount the company can consider investing to improve equity outcomes in the community and use as the baseline for measuring those improvements.

Step four: Map and layer impact.

After quantifying impact, the company can take steps to understand the people and places the facility has affected most. This typically entails indicating on a map the areas that are most affected, moderately affected and mildly affected by the facility. This map can then be overlayed with additional maps for race, income or other indicators that can help determine specific characteristics of the impacted community. The facility can then bear these findings in mind when developing corrective strategies.

Step five: Develop a strategy and operationalize equity.

This final step is where the research and measurements are put into action. The facility now has a measuring tool to understand its impact and can set the net-zero adverse community impact goal. While the facility can find ways to minimize negative externalities, some are likely unavoidable. However, the facility’s benefits to the community can outweigh its negative impacts. When a company strategizes to alleviate its facility’s negative consequences on the community, these efforts require continued community outreach.

The facility should develop open and transparent communication channels with the community.

Benefits of facility equity audits

Operationalizing equity and correcting past injustices requires a commitment of fiscal and human resources. Most critically, a person on the staff must oversee this process and move it forward.

In addition to a point person, a committee can be formed to support these efforts and help maintain internal and outward-facing accountability.

New programs, actions and interventions can take many forms. It is wise to commit resources to these efforts and listen to the community members because they already could be making demands.

Implementing a facility equity audit can help companies build critical community and regional ties that can unlock funding sources from government programs to further EJ efforts.

While measuring and implementing equity come with a cost, long-term gains can be leveraged with technological improvements to act as mutually reinforcing benefits. Transparent facilities that have community support are more effective, resilient and attractive to customers and investors.

As local, state and federal governments ramp up their investments in EJ, a clear, attainable equity strategy offers solid waste management facilities a strong competitive advantage.

The author is a project manager at Gershman, Brickner & Bratton, based in Vienna, Virginia. She can be contacted at emanwelyan@gbbinc.com.