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Environmental Sociology

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‘We do ecology, not sociology’: interactions amongbureaucrats and the undermining of regulatoryagencies’ environmental justice efforts

Jill Lindsey Harrison

To cite this article: Jill Lindsey Harrison (2017): ‘We do ecology, not sociology’: interactionsamong bureaucrats and the undermining of regulatory agencies’ environmental justice efforts,Environmental Sociology, DOI: 10.1080/23251042.2017.1344918

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‘We do ecology, not sociology’: interactions among bureaucrats and theundermining of regulatory agencies’ environmental justice effortsJill Lindsey Harrison

Department of Sociology, University of Colorado-Boulder, Boulder, CO, USA

ABSTRACTEnvironmental justice (EJ) scholars have argued that agencies’ EJ efforts have done little toaccomplish core goals of the EJ movement: democratizing decision-making and reducingenvironmental inequalities. Scholars explain that agencies’ EJ efforts are undermined byindustry and political elites hostile to environmental regulations, shortcomings of existingEJ policy, and limited technical tools. I augment these explanations by taking a construc-tionist approach, identifying interactions through which bureaucrats – with each other andwith me – defend or contest their agency’s EJ reform efforts. Drawing on interviews withagency staff and observations of agency meetings, I show that EJ staff – those tasked withleading their agencies’ EJ efforts but wielding little authority over their colleagues – experi-ence working in an environment in which colleagues can challenge and dismiss EJ and thosewho promote it. I thus argue that scholars aiming to explain why agencies’ EJ efforts havefailed to meet EJ advocates’ expectations must attend not only to factors other scholars haverightly noted but also to interactions among staff through which some define EJ as anathemato agency practice and hence stifle proposed EJ reforms.

ARTICLE HISTORYReceived 7 June 2016Accepted 11 June 2017

KEYWORDSEnvironmentaljustice movement;environmental justicepolicy implementation;environmental inequalities;regulatory agencies; racialideology

Introduction

The environmental justice (EJ) movement has foughtagainst the disproportionate environmental burdensborne by communities of color, low-income commu-nities, tribes, and other marginalized groups (Cole andFoster 2001; Mohai, Pellow, and Roberts 2009). Inresponse to EJ advocacy, some environmental regula-tory agencies have started to develop EJ policies,programs, and practices.

EJ scholars have argued that state and federal agen-cies’ EJ efforts in the United States have done little todemocratize decision-making or reduce environmentalinequalities – key EJ activist priorities (Bullard et al. 2007;Eady 2003; Gerber 2002; Harrison 2015, 2016; Holifield2004, 2012, 2014; Kohl 2015; 2016; Konisky 2015a; Lewisand Bennett 2013; Liévanos 2012; Liévanos, London,and Sze 2011; London, Sze, and Liévanos 2008; Payne-Sturges et al. 2012; Shilling, London, and Liévanos 2009;Targ 2005; Vajjhala 2010).

Critical analyses of these outcomes show that agen-cies’ EJ efforts are undermined by industry and politicalelites hostile to new environmental regulations that EJreforms could bring, weak EJ policy, and insufficientanalytical tools needed to more thoroughly target andtrack environmental inequalities, explanations reflectingthe United States’ unique historical and current context.A few studies taking a constructionist approach showhow the slow pace of agencies’ EJ efforts stems also

from how actors frame agencies’ EJ efforts as reasonableor not. They examine the discursive techniques throughwhich industry and political elites (Liévanos 2012) andsome leading EJ advocates (Harrison 2015) narrowlydefine the scope of what agencies’ EJ efforts shouldentail and press agencies to design EJ programs accord-ingly. Here, I similarly investigate how agencies’minimalapproaches to institutionalizing EJ principles come to beframed as reasonable. Whereas these other studiesfocused on actors external to the agencies, I follow thelead of organizational theorists who show that to under-stand organizations’ outputs, we must also examine theeveryday discursive and other interactions among staffwithin them (Lipsky 1980; Scott 2014).

Drawing on interviews with agency staff and obser-vations of agency meetings, I show that EJ staff –those tasked with leading their agencies’ EJ efforts –experience working in an environment in which col-leagues can challenge and dismiss EJ staff and theirrecommendations. EJ staff describe how some collea-gues undermine proposed EJ reforms by vocallydeclaring in meetings and private conversations thatEJ violates the agency’s purpose, racism is a thing ofthe past, and environmental problems are not serious;some managers threaten EJ staff; and colleagueswidely ignore EJ staff members’ recommendations.EJ staff also conveyed this point by speculatingabout how their colleagues’ disciplinary training,ideas about expertise, life experiences, beliefs about

CONTACT Jill Lindsey Harrison jill.harrison@colorado.edu

ENVIRONMENTAL SOCIOLOGY, 2017https://doi.org/10.1080/23251042.2017.1344918

© 2017 Informa UK Limited, trading as Taylor & Francis Group

racism, and professional commitments might moti-vate those practices. I thus argue that scholars aimingto explain why agencies’ EJ efforts have failed to meetEJ advocates’ expectations must attend not only toindustry pressure, formal policies, limited analyticaltools, and other factors scholars have rightly notedbut also to interactions among staff through whichsome undercut proposed EJ reforms.

Studies of agencies’ EJ efforts

Political economic pressure, weak EJ policy, andinsufficient tools

Scholars explaining agencies’ disappointing integrationof EJ principles into agency practice have shown thatelected officials hostile to new regulatory restrictionsthose programs might bring have neutered EJ programsand restricted their funding (Eady 2003; Faber 2008;Gauna 2015; Gerber 2002; Liévanos 2012; Liévanos,London, and Sze 2011; Shilling, London, and Liévanos2009). For example, Faber (2008, 134) argues that, shortlyafter President Clinton issued his 1994 Executive Order onEJ (EO 12898) directing each federal agency to make EJpart of its mission by reducing environmental problemsdisproportionately harming low-income and minoritycommunities, industry and political elites immediatelymobilized to undermine the Order by publicly protestingthe US Environmental Protection Agency’s (EPA) initial EJguidance documents.1 Gerber (2002) shows that theimplementation of the Executive Order correlates withpolitical elites’ priorities. He tracked how frequently theExecutive Order was cited in rulemaking and how sub-stantively it shaped final rule content, concluding that thisaspect of EJ policy implementation is shaped by the‘political climate federal agencies confront, as indicatedby presidential preferences and the partisan compositionof Congress’ (56). Such explanations echo scholarshipshowing that the ‘polluter-industrial complex’ and itspolitical supporters have achieved 35 years of neoliberalreformsweakeninggovernment protections for the envir-onment, labor, and the poor (Faber 2008; Harvey 2005).

Other scholars highlight how weak EJ policy under-mines agencies’ EJ efforts. Konisky (2015b) and Noonan(2015) observe that whereas statutes require federalagencies to reduce aggregate pollution levels, EO12898 only directs rulemakers to consider EJ concerns.Holifield (2004) demonstrated that the EJ efforts of theUS EPA Region 4 office (covering the southeasternUnited States) neutered community opposition to EPAdecisions and failed to redistribute material risk, out-comes he attributes to formal EJ policies and guidelinesthat framed EJ as securing community acceptance ofEPA decisions. Holifield (2012) and others have arguedthat EPA’s EJ efforts were undermined when the GeorgeW. Bush Administration stripped race and poverty out offederal EJ policy, redefining EJ as applying to ‘all people

regardless of race, color, national origin, or income’ (EPA(Environmental Protection Agency) 2016a, emphasisadded). These scholars argue that this move impliesthat EJ does not require prioritizing stronger environ-mental protections in low-income andminority commu-nities, in direct opposition to the language of theExecutive Order. Gauna (2015) attributes EPA’s failureto impose stronger permit conditions to reduce envir-onmental inequalities and otherwise integrate EJ intopermitting to the fact that statutes do not explicitlyinstruct EPA to adjust permits on EJ grounds (althoughshe and others argue that the agencies are implicitlyauthorized to do so; Lazarus and Tai 1999).

Several scholars have also attributed agencies’ disap-pointing EJ efforts to technical limitations. Some empha-size the inadequacy of EJ ‘screening tools’ – mappingprograms that use environmental and demographicdata to identify areas disproportionately burdened byenvironmental problems and disproportionately vulner-able to harm from those hazards due to racism, poverty,and other social factors (Eady 2003; Gauna 2015; Holifield2012; Payne-Sturges et al. 2012; Shadbegian andWolverton 2015). Holifield (2014) critically notes confu-sion over how agencies should use such analyses. Manyhighlight the need for cumulative impact analysis thatcould enable EPA to identify more accurately the fullscope of hazards to which communities are exposed(e.g. Shadbegian and Wolverton 2015).

This scholarship informs my own analysis. Indeed,agency representatives I interviewed identify thesesame factors – pressure by industry and political elitessupporting its interests, limitations of existing EJ pol-icy, and underdeveloped technical tools – to explainthe slow pace of agencies’ EJ efforts.

A constructionist approach

The explanations described above reflect a realistorientation – identifying the economic, policy, geolo-gical, and other material factors that produce environ-mental problems. I augment these explanations witha constructionist approach, demonstrating how EJstaff frame the slow pace of agencies’ EJ efforts asstemming also from ways their colleagues cast EJ asan unreasonable basis for revising regulatory practice.Constructionist analyses identify the discursive prac-tices through which actors publicly maintain certainshared meanings of the world (which Patterson (2013)calls ‘cultural knowledge’) and how others challengethose meanings to try to institutionalize change(Hannigan 2006; Pellow 2000; White, Rudy, andGareau 2016). Hannigan (2006) explains that construc-tionist research identifies the rhetorical techniquesthrough which actors present claims to persuadetheir audience and ‘the ability of a particular discourse(for example, sustainable development) to becomehegemonic and, hence, stifle debate’ (33).

2 J. L. HARRISON

As Hannigan implies, many constructionist analysesilluminate the intentional rhetorical strategies of politi-cal elites, industry actors, or social movement organi-zers to legitimize or delegitimize others’ environmentalconcerns. For example, scholars have shown that EJactivists vocally highlight scientific data gaps, valorizeresidents’ experiences of contamination, and employrights-based discourse to recast private illnesses aspublic problems and demand regulatory and environ-mental movement attention to environmental inequal-ities (Bell 2016; Brown 2007; Capek 1993; Cole andFoster 2001; Harrison 2011; Pellow 2000; Sandler andPezzulo 2007; Taylor 2000). Scholars also study every-day discursive practices through which people unin-tentionally reproduce environmental problems. Forexample, through ethnographic study of a smallNorwegian town, Norgaard (2011) demonstrates howdominant norms of acceptable emotional expressionand conversational practice, as well as popular claimsabout Norwegian national identity, prevent peoplefrom taking actions to fight climate change. Typically,constructionist approaches contextualize and criticallyevaluate competing narratives in light of other evi-dence and identify how they serve different actors’interests (White et al. 2016).

One rhetorical technique through which actors dele-gitimize competing arguments is ‘boundary work’.Gieryn (1983) showed that scientists actively drawboundaries between ‘scientific’ and ‘nonscientific’knowledge claims to maintain their own persuasive-ness and continually reestablish their intellectualauthority. Many scholars have shown that scientists,regulatory officials, and industry actors dismiss callsfor increased regulation of industry activity by drawingboundaries that cast EJ activists as unscientific, ‘politi-cal’, biased, irrational, or otherwise lacking authority(Allen 2003; Brown 2007). As I will show, some bureau-crats do boundary work to delegitimize proposed EJreforms, while EJ staff engage in their own boundarywork to explain their colleagues’ resistance to EJ.

To my knowledge, two scholars have taken a con-structionist approach to explaining agencies’ disap-pointing EJ efforts. To explain why California EPA’s(CalEPA) EJ efforts deviated substantially from thewishes of EJ advocates who fought for them,Liévanos (2012) observed CalEPA advisory committeeand other public meetings and identified the discur-sive techniques through which powerful industryactors and their political allies narrowed the meaningof ‘EJ’ away from longstanding EJ advocate principles.He demonstrates that industry actors used narrativesof ‘sound science’, procedural fairness, and ‘balance’to insist that CalEPA should eliminate from its EJdocuments any language of ‘precaution’, ‘cumulativerisk’, and other practices EJ advocates have longinsisted are essential for EJ policy implementation.Liévanos further showed that some political elites

echoed these narratives publicly, and that CalEPA’slimited EJ reforms ultimately dovetailed with theseelites’ claims.

To explain why agencies’ EJ grant programs deviatefrom the EJ movement’s longstanding pursuit ofchange through regulatory and policy protectionsand instead disproportionately fund voluntary, indus-try-friendly, and otherwise neoliberal projects, Harrison(2015) examines the rhetorical techniques throughwhich key actors legitimize this pattern in agencypractice. She shows how some leading EJ advocateswho played key roles in guiding the design of agencies’EJ grant programs contested traditional EJ movementclaims about appropriate solutions to environmentalinequalities. Specifically, some leading EJ advocatescharacterized neoliberal projects as ‘proactive’ and‘propositional’, led by the ‘new guard’, effective, and‘solutions-oriented’, while characterizing projectsfocused on regulatory and policy reform as ‘reactive’and ‘oppositional’, led by the ‘old guard’, ineffective,and lacking solutions. These framings helped legitimizethe narrow scope of agencies’ EJ grant programs.

As these previous studies demonstrate, the narrativesof elites and leading activist stakeholders influenceagencies’ EJ efforts. Yet organizational theorists showthat to fully understand organizations’ outputs, wemustalso examine the everyday cultural politics withinthem – the discursive and other forms of interactionaldynamics among agency staff. ‘Street-level bureaucrats’(Lipsky 1980) often wield considerable discretion andcan influence agency outcomes. Their efforts are shapedby organizations’ complex institutional environmentsthat impose material limits and institutional logicsabout ‘how things are done’ (Richard 2014).

Here, I follow organizational theorists’ lead to pro-vide another explanation for the disappointing extentto which agencies have integrated EJ principles intoregulatory practice in ways that could reduce environ-mental inequalities and democratize decision-making.Drawing on interviews with agency staff and observa-tions of agency meetings, I show that staff tasked withleading their agencies’ EJ efforts regularly face resis-tance to nearly all of their proposed EJ reforms – notonly from political and industry elites but also fromtheir own colleagues. EJ staff experience a workingenvironment in which coworkers are allowed to discur-sively and otherwise challenge proposed EJ reformsand those who promote them. Following Schwalbeet al. (2000), I make this case by identifying the typesof rhetorical and other everyday interactions throughwhich bureaucrats – with each other and with me –contest and delegitimize their agency’s EJ reformefforts. Specifically, EJ staff describe how some collea-gues undermine proposed EJ reforms by vocally declar-ing in meetings and private conversations that EJviolates the agency’s purpose, racism is a thing of thepast, and environmental problems are not serious;

ENVIRONMENTAL SOCIOLOGY 3

some managers threaten EJ staff; and colleagueswidely ignore EJ staff members’ recommendations. EJstaff elaborated this sentiment by speculating abouthow their colleagues’ disciplinary training, ideas aboutexpertise, life experiences, beliefs about racism, andprofessional commitments might motivate those prac-tices. These findings strengthen the extant scholarshipby demonstrating that the disappointing pace of EJpolicy implementation stems not only from the factorsothers have rightly noted but also from the discursiveand other everyday practices through which agencystaff and managers cast as unacceptable proposed EJreforms that would prioritize reducing environmentalhazards in the most overburdened and vulnerablecommunities and increase public influence over regu-latory decision-making.

Contemporary racial ideology in the UnitedStates

As I will show, narratives about racism and racialinequality feature prominently in debates amongagency staff about proposed EJ reforms. My analysis ofthese narratives is informed by critical race scholarshipdocumenting these narratives in US society and specify-ing how they naturalize racial inequalities in wealth,government services, and other material resources.

The ‘color-blind’ and ‘post-racial’ narratives in mystudy reflect the dominant forms of racial ideology inthe United States today. Bonilla-Silva (2014), Lipsitz(1995), and Omi and Winant (2015) show that popularnarratives like ‘I don’t see race,’ ‘I didn’t own anyslaves,’ and ‘Things are different now’ frame racismas limited to conscious prejudice and located in thepast. Such narratives recast civil rights policy as‘reverse racism’ – unfairly discriminating against andtaking resources away from whites. They obscure andnaturalize the ‘racialized social system’ (Bonilla-Silva2014) in which industry practices and social demo-cratic government reforms have systematicallyafforded material resources to whites and not to non-whites – including government urban ‘renewal’ pro-grams, highway development, corporate tax abate-ments, hazardous facility siting decisions, unevenenforcement of environmental and civil rights laws,and neoliberal attacks on public education, welfare,affirmative action, and voter rights legislation (seealso Mascarenhas 2016; Pulido 2000).

Others have emphasized the need to demonstrateempirical links between ideas and outcomes – themechanisms through which color-blind racial narra-tives and symbols produce material racial inequalities(Hughey, Embrick, and “Woody” Doane 2015).Accordingly, in my findings below, I identify howpost-racial and color-blind racial narratives, alongwith others, are used in ways that undermine

proposed EJ reforms that could help agencies reduceenvironmental inequalities.

Study context

Environmental regulatory agencies are responsible forenforcing environmental laws. They design regula-tions establishing acceptable practices and pollutionlevels, assign permits to polluters to restrict theirpollution, monitor regulated entities’ compliancewith permit conditions and regulations, and otherwiseencourage environmentally beneficial practices. Theyhave significantly reduced aggregate levels of manyenvironmental hazards. However, they have notsought to reduce environmental inequalities, whichare widespread (Bullard et al. 2007; Mohai, Pellow,and Timmons Roberts 2009) and contribute to healthdisparities along lines of race and class (Morello-Frosch et al. 2011).

In the past 20 years, some environmental regulatoryagencies in the United States have started to adopt EJpolicies, programs, and practices in response to the EJmovement’s demands that the government democra-tizes environmental decision-making and reduces envir-onmental inequalities disproportionately harmingvulnerable communities. The US EPA has led suchefforts, propelled by President Clinton’s 1994 ExecutiveOrder on EJ. EPA provides EJ guidance to federal, state,and tribal agencies, many of which have started tointegrate EJ principles into their own policies, programs,and practices (Bonorris 2010). Federal EJ efforts wanedduring the George W. Bush Administration, while theObama Administration’s first EPA Administrator, LisaJackson, put EJ on the agency’s priorities and infused itwith resources (Konisky 2015b, 247). Prospects look dimunder the TrumpAdministration, which has proposed toslash EPA’s 2018 budget by a third and eliminate itsOffice of EJ (Meyer 2017).

Agencies’ EJ efforts are led by EJ staff, who proposeEJ policies, programs, and reforms to regulatory prac-tice, and solicit feedback about and support for thoseproposals from staff, managers, and agency leadership.EJ staff members’ efforts are shaped by their subordi-nated structural position within the agencies. They donot possess authority to impose reforms; instead, theymust educate their colleagues about EJ and convincethem that EJ reforms are worth their support andcooperation. Additionally, EJ staff are few in number –out of hundreds or thousands of employees in anyagency, only one or a few are formally assigned to EJefforts – and have little funding to work with.

Most commonly, agencies undertaking EJ effortshave created formal EJ policies, convened communityadvisory groups to advise the agency on integrating EJprinciples into agency practice, and developed EJ train-ings for staff (Bonorris 2010; Konisky 2015a). Per EJadvocates’ insistence that agencies make their

4 J. L. HARRISON

decision-making processes more democratic, manyagencies have developed public participation guide-lines to disseminate information more widely and soli-cit community input on regulatory decisions; agencies’EJ efforts to date have spent considerable effort on this(Bonorris 2010; London, Sze, and Liévanos 2008). Somehave developed EJ screening tools to identify commu-nities that are environmentally overburdened andsocially vulnerable (Holifield 2012; 2014; Payne-Sturges et al. 2012; Shadbegian and Wolverton 2015).A few have created EJ grant programs allocating fundsto community-based and tribal organizations aiming toreduce environmental inequalities (Harrison 2015;2016; London, Sze, and Liévanos 2008; Vajjhala 2010).A few have started to develop EJ protocol for the coreregulatory functions of permitting, enforcement, andrulemaking (Bonorris 2010; EPA 2016b). EJ advocatesinform these processes through advisory committeesand public meetings, and occasionally by being hiredto administer EJ programs.

Despite the determined efforts of EJ staff and advo-cates, agencies’ EJ efforts have been criticized for fail-ing to democratize decision-making or reduce hazardsin poor communities and communities of color(Bullard et al. 2007; Eady 2003; Gerber 2002; Harrison2015; 2016; Holifield 2004; 2012; 2014; Kohl 2015;2016; Konisky 2015a; Lewis and Bennett 2013;Liévanos 2012; Liévanos, London, and Sze 2011;London, Sze, and Liévanos 2008; NEJAC 2011; Payne-Sturges et al. 2012; Shilling, London, and Liévanos2009; Targ 2005; Vajjhala 2010). Most agencies haveno EJ policy (Bonorris 2010), and those that do existare of ambiguous legal status relative to other lawsand regulations. EJ advisory groups and other publicengagement efforts invite community members toinvest significant time but rarely help reduce environ-mental hazards in overburdened communities(Holifield 2004; Kohl 2016; Liévanos 2012; Liévanos,London, and Sze 2011; London, Sze, and Liévanos2008; NEJAC (National Environmental JusticeAdvisory Council) 2011). Agencies’ EJ grant programstend to emphasize and fund projects pursuing changethrough voluntary, market-based, and industry-friendly collaborative measures, despite EJ advocates’longstanding emphasis on reducing environmentalhazards through regulatory and policy protections(Harrison 2015; 2016).

Significantly, aside from strengthening opportu-nities for public comment, no agency in the UnitedStates has integrated EJ principles into core regulatorywork in ways that could reduce hazards in the mostoverburdened and vulnerable communities. Agenciescould promulgate stronger regulations to decreasepermissible pollution levels or impose stronger pollu-tion permit conditions on facilities in overburdenedcommunities to reduce the cumulative impacts theyexperience. Legal scholars have shown that EPA has

not used its authority to do so (Gauna 2015; Lazarusand Tai 1999). Additionally, agencies could prioritizetheir enforcement and compliance efforts in overbur-dened and susceptible communities but display littleprogress in doing so (Konisky and Reenock 2015). EJadvocates have long insisted that agencies makethese practices mandatory and create accountabilitymeasures to track their progress (NEJAC (NationalEnvironmental Justice Advisory Council) 2011). Insum, agencies’ EJ efforts create the appearance ofchange and ways for people in overburdened andmarginalized communities to invest more time buthave required no concessions from industries thatprofits off of hazards and little meaningful change tothe regulatory practices that authorize them to do so.In other words, while starting to redress inequality inhow state actors interact with different stakeholders,agencies’ EJ efforts have done little to improve mate-rial equity through prioritizing the reduction ofhazards in the most overburdened and vulnerablecommunities.

Methods

To help explain the slow pace of agencies’ EJ efforts, Iconducted confidential, semi-structured interviewswith staff from environmental regulatory agenciesand ethnographic observation at agency meetings inthe United States. Ethnographic observation andinterviews help illuminate how staff interpret andreact to new programs, variations in these interpreta-tions and reactions, and the cognitive ‘logics’ thatpredominate the agencies (Emerson, Fretz, and Shaw1995). The semi-structured nature of the interviewsallowed me to pursue certain themes of interestwhile also allowing the participants to narrate andinterpret their experiences, and to develop the rap-port necessary to discuss politically controversialissues. Confidential interviews and internal (i.e. notpublic) meetings gave staff the space to expressbeliefs they do not (and cannot) express in formalagency documents or public events.

Central to this paper are interviews I conductedsince 2012 with 73 current and former agency repre-sentatives who helped design and/or administeragency EJ programs or closely observed their admin-istration. I used snowball and purposive sampling torecruit such staff, seeking variation in institutionalaffiliation, race, gender, tenure at the agency, levelof authority within the agency, and degree of appar-ent enthusiasm for agency EJ programs (based oncoworkers’ characterizations). I formally interviewed10 of these representatives a second time becausewe were unable to cover all key questions in thefirst interview. I had follow-up email or phone corre-spondence with many participants to clarify particularpoints from the interview. Interview participants

ENVIRONMENTAL SOCIOLOGY 5

included representatives from US EPA (including EPAheadquarters, eight regional offices, and one othersatellite office), two other federal agencies, sevenstate-level agencies, and substate agencies in threestates. These agencies vary in how longstanding, welldeveloped, and publicized their EJ efforts are; thenumber of appointed EJ staff; and whether theyhave a formal EJ policy endorsed by agency leader-ship or the legislature. Of the 73 interview partici-pants, I identified 28 as men and 45 as women. Iidentified 36 as white, 22 as black, 8 as Latino/a, 5 asAsian American, and 2 as Native American.

I recruited most participants by contacting themdirectly; in several cases, interview participantsrecruited coworkers for me to interview. I askedthem to describe their involvement with agency EJefforts, which EJ reforms they view as important,which challenges face agency EJ efforts, and howtheir coworkers react to proposed EJ reforms. I con-ducted interviews at locations chosen by each parti-cipant (their office, a meeting room at work, or arestaurant), except for 14 interviews conducted bytelephone. Each interview lasted up to 2 h and wasaudio recorded, except for 16 participants who didnot give permission to be recorded or of whom I didnot request such permission. I wrote fieldnotes for allinterviews and transcribed the recorded interviews.

I observed numerous agency meetings relating totheir EJ efforts, including two public informational ses-sions about EJ grant programs (one teleconference andthe other in person), four public agency-convened EJadvisory committee meetings, one public participationevent about an EJ controversy, four internal (not pub-lic) EJ planning meetings, and one internal EJ trainingsession for staff. These varied from 90 min to two fulldays. I observed these events, taking extensive notesduring the event of actors’ claims and nonverbal beha-vior, and I wrote fieldnotes afterward. Generally, myparticipation was limited to introducing myself and myresearch interests when asked, and chatting casuallywith other participants before and after the meetings.The exceptions were two of the internal EJ planningmeetings, where I was invited to guide discussion forabout 30 min; I invited the group to share their opi-nions about what agency EJ efforts should entail andtook notes about their responses.

To analyze the interview and observational data, Iread and coded my transcripts and fieldnotes. Somecodes emerged from the literature: their claims aboutwhat their agencies’ EJ efforts should include, andabout political economic, EJ policy, and analytical tech-nological factors they identified as constraining theirwork. Several themes emerged unexpectedly in inter-views with EJ staff: their stories about colleagues’ prac-tices that undermine their EJ efforts, their claims aboutthe associated consequences, and the boundaries theydrew to distinguish themselves from staff less

supportive of EJ. With other staff, several themesemerged unexpectedly, including discursive techni-ques through which they deride proposed EJ reforms.I then recoded transcripts and fieldnotes for theseemergent themes. I use secondary data to help explainmy findings and triangulate bureaucrats’ claims.

All uncited quotations are from my own interviewsor observations. Because staff I interviewed expressedacute, repeated concerns about the need to maintaininternal confidentiality (Tolich 2004), I use pseudo-nyms and obscure identifying characteristics.

A few notes on terminology: Environmental regula-tory agencies are arranged hierarchically, with staffreporting to ‘managers’, who report to ‘senior manage-ment’ (which includes political appointees and senior-level ‘career’managers). I use the term ‘staff’ genericallyto refer to any agency representative; I specify someindividuals as ‘managers’ when that status is relevantto the discussion. I use the term ‘EJ staff’ to refer to thosewho actively work on their agency’s EJ efforts and arecommitted to a vision of EJ that generally aligns with themovement; most were formally appointed to work onthe agencies’ EJ programs, while some elected to beinvolved. I refer to other agency representatives as ‘col-leagues’, ‘coworkers’, or ‘other staff and managers’.Where I use the term ‘bureaucrat,’ following Lipsky(1980) and others, I do so non-pejoratively.

Findings and analysis: bureaucrats’explanations for the shape of EJ programs

In this section, I show how bureaucrats tasked withimplementing their agencies’ EJ reforms describe howsome colleagues undermine their EJ efforts. I analyzethe stories staff tell me about their interactions witheach other in relation to proposed EJ reforms, and myown observations of such interactions in agencymeetings.

The standard narrative: industry hostility, weakEJ policy, and analytical limitations

When I asked staff to identify the factors limitingagencies’ EJ efforts, all initially noted one or more ofthe material factors scholars of EJ policy implementa-tion have emphasized: pressure by industry and poli-tical elites hostile to environmental regulations,shortcomings of existing EJ policy, and limited tech-nical tools. I call this ‘the standard narrative’ becausesome version of it appeared in all of my interviews.

Many expressed this narrative regretfully, notingthey would like to change environmental regulatorypractice and laws to better support EJ principles.Regardless, this framing implies that staff members’hands are tied and that the slow pace of EJ policyimplementation stems from factors beyond their con-trol. Most managers I interviewed stated this matter-

6 J. L. HARRISON

of-factly and expressed no interest in discussing theissue further, thereby establishing this official narra-tive with authority. Yet I show below that nearly all EJstaff subsequently complicated this story in ways thatcast agency staff and managers’ behaviors as partiallyresponsible for the slow pace of agencies’ EJ efforts.

EJ staff members’ stories about regulatorycultural challenges to EJ

EJ staff concur that agencies’ EJ efforts are limited inpart by the material factors identified above, and theyfully acknowledge that their colleagues face dwind-ling resources and increasing workloads. Yet EJ staffalso describe all of their EJ proposals as underminedby things some colleagues say and do. Indeed, theonly type of agency EJ effort that EJ staff did notmention experiencing significant resistance to is EJgrant programs, which give funding to communitygroups and require no change from the agency.

Framing EJ as contrary to the agency’s mission oridentityMany EJ staff stated that their EJ reforms are stymiedby colleagues’ assertions that EJ proposals violate themission or identity of the agency. Regarding the pos-sibility of designing regulations to reduce pollutionspecifically in overburdened communities, Heatherasserted that some of her colleagues would objectby vocally asserting that the agency’s responsibilityis not to reduce inequalities but to reduce hazards inan aggregated sense: ‘The skepticism there would be,“Well, we are reducing burden for everyone. Whyshould we specifically focus on low-income and min-ority [communities]? They are also seeing a reductionin the burden”’. Such narratives dismiss environmentalinequalities as unproblematic and imply that proposedEJ reforms that would prioritize environmentalimprovements in overburdened communities areunjustified. Heather disagreed with this perspective,arguing that the agency’s mission should be to createmore equal environmental conditions.

Other EJ staff described how some colleagues situ-ate EJ beyond the scope of the agency’s work bydrawing disciplinary boundaries between EJ staffand the rest of the agency. In separate interviews,two staff at one agency noted that someone wrote a(now famous) memo to an EJ staff person rejectingtheir EJ recommendations by asserting, ‘[This agency]does ecology, not sociology’. Such narratives echo theboundaries between ‘politics’ and ‘science’ that otherscholars have observed scientists use to cast EJ poli-tics beyond the realm of agency responsibility(Holifield 2004, 295; Ottinger 2013). Although mydata do not enable me to state how prevalent thesepractices are within these agencies, EJ staff describethem as sufficiently common to stall their EJ efforts,

and I did observe staff doing exactly what these EJstaff describe. For example, in the middle of an EJtraining for a team of staff, the team’s manager, Bob,interrupted the training immediately after a shortvideo that argued that poverty stems not from anindividual’s work ethic but largely from racism, resi-dential segregation, funding for local public educa-tion, and other social structural factors. Visibly upset,Bob stridently instructed the EJ staff leading the train-ing to ‘be careful’ with how they present the material,proclaiming that ‘there aren’t any data to back upthose stats’ shown in the video (about average salaryvarying by educational attainment) and assertingtwice, ‘You’re talking to scientists’. By asserting theprofessional status of himself and his staff, Bobauthorizes himself to discredit the arguments madein the EJ training video, despite the fact that the topicwas beyond his realm of expertise. As the seniorperson in the room, he thus implicitly authorized hisstaff to challenge or ignore the EJ training materialand made it difficult for them to defend it. Managers’practices matter considerably, because they have theauthority to require EJ practices of their staff – andalso the discretion to not do so.

Numerous times in other agency meetings and ininterviews, I witnessed staff protest proposed EJreforms on the grounds that they violate the agency’smission. For example, Richard was active in hisagency’s EJ efforts but stridently opposed most ofthe EJ staff members’ EJ reform proposals. In ourinterview, he explained that the proposed EJ reformsviolate the agency’s responsibility to ensure a ‘levelplaying field’ for industry:

It would be very unfair of any government agency togo out to this area and say, just because you [facility]are in an industrial area, and just because there is asocioeconomic problem, if you will call it a problem,whereby the poor have to live in your area becausethat is all they can afford – We can’t enforce a stricterset of standards on them based on [compared to]somebody [another facility] that is not in that area.Because that does not create a level playing field,from a business standpoint. [It is] unethical, in myopinion, for us to do something like that.

Throughout our interview, he reiterated this insistencethat the agency must maintain a ‘level playing field’ forindustry and thus should not take community contextinto account when determining a facility’s permit con-ditions, identifying enforcement priorities, or other reg-ulatory work. Doing sowould violate his commitment tothis sense of fairness. He disparaged as unfair EJ staffmembers’ proposals that the agency make an extraeffort to reduce environmental hazards in low-incomecommunities, communities of color, or environmentallyoverburdened communities, because they wouldrequire concessions from polluters in those areas andnot others. I attended multiple EJ meetings at his

ENVIRONMENTAL SOCIOLOGY 7

agency and personally observed him and others stri-dently reject all but the most minimal EJ efforts pro-posed in their meetings by proclaiming the need to‘maintain a level playing field’ for industry. EJ staffthere told me that such denouncements have stymiedtheir efforts to design and implement EJ programs. Staff,like Richard, who lack formal authority over EJ staff cannonetheless undermine proposed EJ reforms by stone-walling, especially because agencies usually develop EJreforms through consensus-based decision-making.

Denying the severity of environmental problemsMany EJ staff stated that their colleagues regularly chal-lenge EJ proposals by denying the severity of environ-mental inequalities. For example, Jamie, a black EJ staffperson, noted that, when he first started working on hisagency’s EJ efforts, managers would belittle EJ concerns:

I remember very vividly people saying that environmen-tal equity, and then it became environmental justice,was not a real issue. That there was no way that in ourcountry that these types of things could actually behappening. That these folks were exaggerating theimpacts that were happening inside their communities.

Although Jamie insisted that this is less commontoday, Paul, a white EJ staff person in that sameagency, stated that permitting staff still vocally rebukehis proposed EJ programs by denying the existence ofenvironmental inequalities.

They say, ‘I already do EJ. I give everybody the sameopportunity.’ Many agency staff don’t believe it is reallyan issue anyway. … [They say,] ‘We treat everyoneequally. We write permits that protect everyone thesame.’ … It is the assertion that everybody benefitsequally. The problem is that that perspective doesn’tlook at disproportionate impacts on certain communities.

John, a black EJ staff person, related that his collea-gues regularly reject his proposed EJ reforms as unne-cessary by denying environmental inequalities in theirgeographic region. He said that they assert ‘that weare different here, that we don’t have the same issuesas other regions’, and thus that proposed EJ reformsare unnecessary. He disputes this: ‘But we do havethese issues’. Although not necessarily intending toundermine EJ proposals, such claims effectively do.

One variation on this narrative is that proposed EJreforms are unnecessary because the agency alreadyprotects the environment. Sara described how hercolleague Tim, a manager who volunteered to helpsteer the agency’s EJ efforts, often used this narrativeto reject EJ reforms mandating changes to regulatorypractice. For example, Sara told me about Tim’s lividreaction to the agency’s new public participation pol-icy that adds some requirements over and above theagency’s (rather vague) EJ policy:

He was furious about it…. He said, ‘We have staff whospend thousands of hours putting together a community

meeting where no community shows up. Is that becauseof a lack of methodology on our part or strategy on ourpart? No. (voice rises) That’s because the community trustsus to do our job.’… To say that thatmeanswe are doing agreat job and people trust us I think is a little bit of ajump. He was really enraged about this [public participa-tion] policy! [He said,] ‘This is exactly why I hate this stuff. Ithought we agreed on this comprehensive [EJ] policy. Iread it, and the reason I signed on to it is because youwere leaving flexibility, and there was going to be aguidance document, but it wasn’t going to be heavy-handed and tell us what we have to do’.

To Sara, Tim’s narratives that the agency is effectivelydoing its job consistently undermined her EJ efforts.Indeed, in an email to me, Tim rejected the need fornew EJ rules: ‘We know (and believe) that our regulatoryprograms, when properly complied with, will protectpeople and the environment’. Thus, proposed EJ reformsare unnecessary. Tim’s actions matter: he was often thehighest ranking person on the agency’s EJ steering com-mittee, thus functioning as a de facto gatekeeper. Othercommitteemembersmay have felt persuaded to defer tohis opinion, and he could instruct his own staff to notimplement proposed EJ reforms. Indeed, the agency’s EJpolicy is still only a set of voluntary guidances. Saraexplained: ‘We intentionally had to make the policybroad and flexible to get it passed. It was the only way itwas going to happen’. Yet, this flexibility also means thatstaff do not need to comply with it. The narrative thatagencies already protect the environment is widespreadwithin them; in interviews with me, regulatory staffemphasize that they take great pride in being environ-mental stewards and in having improved environmentalconditions over time. While true, this narrative obscuresproblematic environmental inequalities that still exist.

Managers at numerous agencies expressed thisnarrative to me to reject proposed EJ programs.Lucy, a white senior manager, asserted stridently,‘We do not need a statute directing us to protectenvironmental justice or to advance environmentaljustice, because protecting human health applies toeverybody…. We protect public health’. She assertedrepeatedly that communities’ concerns about toxichot spots are ‘usually’ unwarranted. To make thiscase, she used a hypothetical scenario of a facilitythat, to comply with regulations, must keep its airemissions below ‘seven’ units (e.g. parts per billion).

Seven is probably the right number in real life, becausewe protect human health. … But how can we help thecommunity feel safer? By letting them know what’s outthere. They may see that there is actually a problem, or(voice rises) they may see it’s actually okay! That thefacility can be trusted. They actually are usually at five,or four!, which is usually the case. … So then they’ll seethat things are actually okay.

This statement asserts that regulatory standards areproperly set to protect public health and thus thatproposed EJ reforms that would increase restrictions

8 J. L. HARRISON

on hazardous activities in overburdened communitiesare unnecessary, despite extensive evidence of humanexposure to harmful levels of environmental chemicals(Morello-Frosch et al. 2011; WHO 2016) and critiques ofexisting environmental regulatory standards (Brown2007; Vogel 2009). Additionally, although she acknowl-edges the possibility that monitoringmay show that thefacility’s emissions exceed a regulatory standard, sheinsists that this is unlikely – despite evidence that facil-ities often violate regulatory standards (EPA 2016c).Indeed, Lucy repeatedly stated that existing regulatorystandards are effective, communities’ concerns aboutcumulative risks are unfounded, and the only actionneeded to address communities’ concerns is informingthem about how safe things actually are. She elaboratedthat the ‘real problem’ is that residents and industrydon’t ‘trust each other’ and just need to talk:

The businesses are as afraid of the communities as thecommunities are afraid of them. We can see you guysjust want the same thing! Can you just talk to eachother? … (Gleefully) Communicate communicate com-municate communicate! It’s the answer to so manythings!… Those kinds of good neighbor principles[are] what we are strongly encouraging facilities toadopt…. Let’s get to the problem where it actually is.

Claiming that residents and industry simply need tocommunicate ignores environmental inequalities, andshe used these framings to dismiss EJ staff members’and EJ advocates’ calls for stronger regulations in over-burdened communities. Through these rhetorical prac-tices, Lucy defines increased public outreach as the onlylegitimate EJ reform to regulatory practice and all otherproposed EJ reforms as unwarranted. She referenced anagency EJ document advocating more communicationbetween permitted facilities and concerned communitymembers, stating, ‘That’s what I talk from. That’s wheremy passion is. I really don’t think law is the answer’. Incontrast, EJ staff and advocates view increased publicparticipation as an initial step in EJ policy implementa-tion, but that meaningfully doing EJ requires the agencyto promulgate stronger regulations and impose stron-ger permit conditions on facilities in overburdenedareas. Lucy related that she voluntarily joined theagency’s EJ efforts despite it being beyond her realmof expertise and that she regularly makes these argu-ments to her colleagues to shape her agency’s EJ efforts.Lucy’s actions warrant special attention given thepowerful position she holds. She is able to authorize orterminate EJ programs in her agency inways that EJ staffcannot. EJ efforts are vulnerable to such cooptation,because EJ staff generally accept the participation ofanyone interested – for better or worse – to maximizestaff involvement in EJ efforts that receive few resources.

Post-racial and color-blind narrativesEJ staff at all agencies in my study described howsome colleagues vocally denounce and discredit

proposed EJ reforms by using the widespread post-racial narratives critical race scholars have problema-tized and with the same effect of legitimizing existingregulatory practice that ignores environmentalinequalities (Bonilla-Silva 2014; Lipsitz 1995; Omi andWinant 2015). Brian asserted:

The bureaucrats say, ‘Oh, and EJ’s important nowagain…. Here we go again.’ … It will take a longtime to change. We have so many of these peoplewho’ve been around here for years…. Layer afterlayer of people who are just gatekeepers and do notthink that racism exists [or that the] color of your skinhas anything to do with anything, that that’s all backin the ‘60s, [that] we shouldn’t be worried about thatstuff, and you should speak English. Not in leadership,but in the ranks, and the ranks control a lot ofstuff. … They call themselves the ‘we-bes’: ‘We behere before you; we be here after you.’ … They say,‘We’ll wait out this administration. We’ll wait out thelegislators. Let’s just wait them out. They’re going tobe turned out in a year. We’ll just punt it’.

Brian’s account describes colleagues using such narra-tives against EJ generally – i.e. not strictly against oneor more specific EJ reform proposals. This was commonin my interviews with EJ staff. Similarly, Malcolm, ablack EJ staff person, described how his colleaguesreact to his EJ proposals: ‘People will say: “…Wehaven’t done anything wrong. There aren’t any EJissues, because we didn’t do anything wrong. We arenot treating them differently.” … A lot of peopleobviously equate it with something akin to affirmativeaction and those types of things – privileges’. Suchstatements frame ‘justice’ in terms of treating everyonethe same and in so doing ignore what EJ staff and EJadvocates see as a more important task: reducingmaterial inequalities. Indeed, EJ staff of color andwhite EJ staff alike noted that colleagues frame racismand other forms of inequality as limited to discrimina-tory treatment to denounce as unwarranted EJ reformsthat are race-conscious or otherwise strive to reducematerial inequalities. Framing ‘equality’ in this way – astreating everyone the same – ignores what EJ advo-cates see as a more important task: reducing unequalmaterial conditions that disproportionately harm low-income communities and communities of color.

To illustrate such rhetoric, one EJ staff person whohas led video-guided EJ trainings for staff showed methe following anonymous feedback from a colleaguewho used strident post-racial arguments to reject thetraining and other proposed EJ reforms that seek toreduce racial environmental inequalities:

The whole idea of this thing is based on a lie. There aremany people that I have spoken to about this trainingthat fundamentally disagree with what EJ purports todo. In the minds of many common sense folk this isnothing but propaganda. The lady in the video basi-cally eludes that everything we do is racist, whetherthat’s in the work environment, during our leisure

ENVIRONMENTAL SOCIOLOGY 9

time, or just as individuals. Not true at all. … Thetraining also concludes that when in doubt justblame a white person for your life circumstances ifthey are bad. I think that is the most racist thing I’veseen in a long time. What I would change would [be]to have this training be taken out of the department.Having it be mandatory is the type of social engineer-ing BS that the department and country does notwant. It’s Hitler-eske. … Working hard and gettingahead in life is color-blind and not racist, just like thevast vast majority of people in this country.

EJ staff explained that colleagues rarely express suchbeliefs beyond the setting of a private conversation.Elizabeth, a woman of color, stated that ‘some staffand managers’ disparage proposed EJ reforms bycharacterizing them as

reverse racism. [They say,] ‘Why should those com-munities of color get this extra treatment? We needto protect that middle-class white community too.’ …I have heard people make these kinds of statementsin meetings and in one-on-one conversations, [but]behind closed doors, people will be much more frankthan in a meeting.

I asked her to recommend a colleague who expressessuch claims and would talk with me about them. Shepaused, considered a few possibilities, and decided shecouldn’t: ‘They know to avoid saying those things toyou’. Elizabeth’s statements characterize her workplaceas one in which colleagues use color-blind racial narra-tives to discredit proposed EJ reforms, but that theywould rarely express these ideas in settings researchersmight be able to observe. Thus, EJ staff members’ ownaccounts provide crucial insights into their experiencesof trying to do EJ work in agencies, which cannot easilybe observed by outside researchers.

Bullying EJ staff of colorWhen I asked EJ staff to describe what it is like towork on EJ in their agency, a few told me stories ofracist mistreatment and stated that staff of color areretaliated against and threatened for working on EJefforts. In a pained conversation with me, Michaelexplained that this is both frequent and increasinglydifficult to prove:

There are plenty of examples, … instances in which Iknow persons have said that a manager has toldthem, ‘Don’t work on EJ because that may affectyour career.’ … People have been called ‘trouble-makers’…. When you have a manager that just saysit when you are walking down the hall and youhaven’t talked to that manager in weeks, you don’tfollow up with them to say, ‘Why would you saysomething like that?’ They don’t say, ‘Still causingtrouble in that particular project?’ No! He just says,‘Still causing trouble?’ … They weren’t precise whenthey said it. That’s how most discrimination occurs.That’s why you can’t prove it. It’s because whensomeone does something that is discriminatory,they are not trying to be obvious about it…. They

don’t want to give you an obvious red flag by whereyou would record and document what they did. Itcould be written off as, ‘Well, maybe he didn’t meananything by it.’ Or, ‘Maybe you’re just interpreting itthe wrong way. I wouldn’t think anything of it.’ Orthey’ll just get dismissive: ‘Don’t worry about it.Maybe he was having a bad day.’ But he said it.Most of the time is has been in the context of EJ.…You have to consider the timing, whether it hap-pened in the 1980s or 1990s. Persons became a littlemore savvy in terms of how they would cover theirstripes around the mid-1990s.

He explained that these aggressions undermine EJ pol-icy implementation by compelling staff who wouldotherwise champion EJ efforts to find other assignmentsin the agency or find other employment: ‘People leave.It gets grinding. People burn out…. Those who aretrying to focus on EJ feel a pervasive sense of tension,friction, of personalities clashing. Some of those peoplehave moved on. Some stayed and didn’t make anyheadway. It is a huge emotional drain’.

Only black EJ staff shared such stories with me(and, to be clear, not all expressed such experiences).In contrast, white EJ staff expressed frustration anddisappointment at the slow pace of their agencies’ EJefforts, but none noted being bullied or threatenedfor their EJ work. These observations suggest that theexperience of working on agencies’ EJ efforts variesalong racial lines, where black EJ staff experiencemore hostility than their white colleagues do. Thiscould stem from discrimination directed at blackstaff members because of their own racial identity,from colleagues’ post-racial resentment of race-conscious proposed EJ reforms, both, and/or otherfactors. I elaborate on staff members’ speculationsabout the roots of their colleagues’ hostility to EJproposals later in this article.

Ignoring EJAll EJ staff I interviewed asserted that their colleaguesoften ignore EJ staff and EJ reforms. John asserted thatmanagers intentionally shut EJ staff out of conversationsand investigations in which, in his opinion, they shouldclearly be involved. EJ staff are intentionally ‘not inte-grated. [Managers] are not using that expertise’.Although ‘they use my face’ to ‘build cache with’ com-munity groups, they involve him only superficially.During a recent regulatory violation investigation, hetold management that he and other EJ staff ‘have infor-mation that could be germane’. Management rebuffedhim, saying, ‘We will manage this from up here’. Thisexclusion prevents EJ staff –whoworkmore closely withcommunities than other staff – from being able to sharecommunity input relevant to cases.

Michael asserted that managers ignore EJ whensetting budget priorities: ‘Mid-level managers …didn’t speak up when [EJ] programs were at risk [ofbeing defunded]…. They are willing to just let

10 J. L. HARRISON

certain things just die on the vine.’ Like other EJ staffI interviewed, he feels that this forgetting of EJ isintentional: ‘Pushback … expresses itself throughinstitutional inertia’. Janine lamented, ‘EJ policy isignored by most people’. Where agency leadershiphas publicly endorsed EJ, it may not be acceptablefor staff or managers to vocally oppose that direc-tive. Yet, the ambiguous legal status of EJ policiesenables staff who disagree with them to quietlyignore them.

Sara reported that permitting staff decide whethera permit they are working on needs extra EJ reviewwithout actually doing the EJ analysis specified by EJstaff. Indeed, many EJ staff asserted that their collea-gues view EJ as ‘a box to check’ and follow EJ proce-dures unevenly and superficially. My interviews withstaff not assigned to lead EJ efforts further suggestthat this is common. For example, Hank, a recentlyretired senior manager with 30 years of experience athis agency, matter-of-factly stated that nearly every-one in his office viewed EJ as a pointless box to checkand did required EJ measures (specifically, holdingextra public hearings in enforcement cases locatedin communities with EJ concerns) with no intentionof changing anything about their plan based on whatthe public said:

There was just an attitude … of people treating thepublic hearing step as a box to check. ‘Before I get tomy endpoint, which is then something that counts forme and my performance, I have to have a publichearing.’ … My perception of quite a few peoplewas that a public hearing was something they hadto put on, they had to endure, and then they had towrite a document related to the comments. But Inever got much of a sense from a lot of the technicalfolks that they truly would consider what was said.

I asked how staff express this. He replied:

Private employee-to-employee grumbling in the waythey describe [needing to hold a public hearing in]the upcoming year. Certainly not at the hearing. Thehearing would say the things the hearings are sup-posed to say: we are here to hear, we love to hear.Just talking amongst themselves.

He added that staff comment to each other that oncethe hearing is over, they can continue on with theirwork and express sympathy and agreement by rollingtheir eyes and saying, ‘Oh yeah’. That is, staff under-mine agency EJ efforts by ignoring and verbally dis-missing proposed EJ procedures.

I witnessed this as well. For example, in the EJtraining I described above in which the manager,Bob, protested training content that he foundunscientific, my fieldnotes reveal how staff clearlydisplayed disinterest in EJ: ‘Attention was reallywavering throughout and the group seemed onlymoderately engaged – lots of yawning, staring offinto space, one person fell asleep, and two stepped

out of the room briefly’. Bob did not correct thatbehavior. Subsequently, the EJ staff person askedthe group to suggest how they could apply thevideo’s lessons to their own work. Immediately, Bobasserted firmly: ‘We already do it,’ explaining that theymeet directly with regulated entities at their site andhire bilingual interpreters when working with regu-lated entities who are not native English speakers.This assertion implies to his staff that they can ignorethe training – that it does not apply to them. None ofthe staff who subsequently spoke disputed Bob’spoint, and most reiterated it. One asserted, ‘We arean organization that already does this work. We justneed to acknowledge our successes’. Such narrativesimply that this team does not need to change itspractices in any way to support EJ and discourageother staff from brainstorming ways they could do so.

In sum, EJ staff describe colleagues’ hostility to EJreforms and those who promote them in various ways:vocally disparaging proposed EJ reforms as wrong,unwarranted, or unnecessary; intimidating EJ staff; andignoring EJ staff and their recommendations. Their pointwas not that all colleagues behaved in all of these ways,but that these practices were common enough to derailtheir EJ efforts. There were a few exceptions. Several EJstaff asserted that there was no staff resistance to EJ. Thisdivergence from other EJ staff could stem from self-protection:my research participants’ acute, repeated con-cerns about confidentiality suggest that a few would bereticent to speak critically of colleagues or otherwisedivulge information that could get them into trouble.This divergence could also stem from racial and profes-sional identity. All of these exceptions have advanceddegrees in law, engineering, or economics, and all butone are white. Their professional status likely confersrespectful treatment from colleagues. Those who arewhite do not experience the micro-aggressions andother pushback staff of color experience and thus areless likely than staff of color to see broader patterns ofdiscrimination and indifference to inequality.

Explaining colleagues’ resistance to EJ

EJ staff further convey this sense of working in anenvironment in which bureaucrats can challenge EJand those who promote it by speculating about rea-sons for their colleagues’ hostility to EJ, explanationsthey expressed with a mix of frustration and empathy.

Many EJ staff drew boundaries along lines of dis-ciplinary training to explain colleagues’ rejections ofproposed EJ reforms. EJ staff often noted that most oftheir colleagues are engineers, economists, and law-yers and thus aren’t trained in environmental inequal-ities, their structural roots, and how EJ reforms couldameliorate them. EJ staff also explained that proposedEJ reforms threaten their colleagues’ sense of profes-sional authority. For example, Janine noted that staff

ENVIRONMENTAL SOCIOLOGY 11

often balk at EJ reforms requiring them to solicitpublic opinion. They say, ‘Why should I solicit inputfrom the public when I was hired to make thesedecisions myself?’, insulted by the notion that theperspectives of community members lacking theirprofessional training could trump their own. Thisshows that some proposed EJ reforms – such as soli-citing public input on regulatory decisions – contra-dict some standards of professionalism.

EJ staff often drew boundaries along lines of lifeexperience to explain colleagues’ resistance to EJ. MostEJ staff (irrespective of racial identity) noted that most oftheir colleagues are from predominantly white, middle-,or upper middle class neighborhoods. Many EJ staffrevealed their own personal experience of racial oppres-sion, living in overburdened communities, or having adiverse social network, speculating that staff withoutsuch life experience are less likely to perceive proposedEJ reforms as urgent or even necessary. Cheryl, a black EJstaff person, reflected about her colleagues:

A lot of them just don’t have the cultural experi-ence…. If you have never lived there and don’tunderstand the lives of those that would beimpacted, how can you write a rule that is sympa-thetic to the lifestyles of those who live there? … Ifyou don’t leave where you live and you are comfor-table where you are, then you won’t see it. But forAfrican Americans, this is an everyday thing. If youdon’t have that lens and you don’t pay attention andyou don’t see that privileged lifestyle that you live,then you won’t understand EJ.

Sam, a black EJ staff person, echoed this sentiment.After I noted that EJ staff often told me that many oftheir colleagues do not support EJ proposals, I askedSam why this might be. He answered that the agencyis ‘the great plantation. Their record in diversity is notthat good’.

Many EJ staff attributed colleagues’ resistance to EJto post-racial or color-blind racial ideology, assertingthat many colleagues believe racism is a thing of thepast or limited to conscious, intentional discriminationand thus that proposed EJ efforts are unnecessary andinappropriate.2 For example, Barbara, a black EJ staffperson, commented that colleagues reject the EJ pro-posal that the agency reduce emissions from existingfacilities in overburdened communities, resistance sheattributes to post-racial ideology:

There is a core group of people who have spent mostof their careers learning environmental programs,doing environmental programs, and they feel that weshould not be focusing on EJ, that we should justimplement the [existing regulatory] programs. Evenwithin the government, there is racism. A lot of peoplebelieve that we shouldn’t be doing anything out of theordinary to address environmental injustice…. Theyreally do it color-blind…. They think everything isequal, that none of this is necessary…. When we say

‘EJ’, they think they [communities targeted in EJefforts] are getting something that they don’t deserve.

Like other EJ staff, Barbara distinguishes herself from hercolleagues in terms of their beliefs about whether racismis a contemporary phenomenon and the existence andrelative seriousness of racial environmental inequalities.To EJ staff, these produce differing beliefs about the fair-ness of existing regulatory practice and thus divergentsupport for proposed EJ programs that explicitly strive toreduce racial environmental inequalities.

Some EJ staff attribute their colleagues’ resistanceto proposed EJ reforms to different professional com-mitments. EJ staff expressed strong commitments toserving marginalized and overburdened communitiesand asserted that their colleagues do not. Paul noted,‘For me, our client is the community. That is not howmost people here see it’. Others asserted that theircolleagues’ commitment is to ‘the environment’ butnot public health. Other EJ staff emphasized that theircolleagues resist proposed EJ reforms because theircommitments are to industry, whose practices wouldbe more closely scrutinized, questioned, and regu-lated by proposed EJ reforms.3 Sara noted that hercolleagues identify and consult with industry as theagency’s legitimate ‘stakeholders’ and as a resultreject as unnecessary her new guidelines for expand-ing public participation:

All of them [regulators] see ‘stakeholders’ and ‘com-munity’ as almost synonyms…. [Because they believe]‘community’ equals ‘stakeholders’ equals ‘regulatedentities’, I can also see some divisions saying, ‘Well,we do [public participation] all the time. That is ourstatus quo. Before we change any regulation, we[already] have to have stakeholder meetings’.

In sum, when talking with me, EJ staff draw boundariesbetween themselves and their colleagues in variousways – along lines of disciplinary training and profes-sional authority, life experience, racial ideology, andprofessional commitments – to provide some logic totheir colleagues’ behaviors that undermine proposedEJ reforms. These explanations contribute to EJ staffmembers’ depiction of working in environments inwhich bureaucrats can and often do challenge andignore EJ staff and the reforms they propose.

Conclusion

EJ staff members’ stories about their colleagues’ prac-tices that undermine their EJ efforts, and their musingsabout why their colleagues’ views on EJ differ from theirown, convey their feeling that the slow pace of EJ policyimplementation stems in part from some colleagues’resentment of EJ, the discursive and other practicesthrough which they express it, and that such behavioris condoned in the agency by peers and supervisors.Through describing their work in these ways, EJ staff

12 J. L. HARRISON

challenge their colleagues’ behavior and defend pro-posed EJ reforms. To be clear, some EJ staff assert thatregulatory cultural change is happening – slowly. Forexample, John noted that some colleagues, especiallyyounger ones, ‘are becoming more willing to push theenvelope on EJ’, a sentiment others echoed. Yet, theirnarratives suggest that staff and managers who defendEJ reforms are still few and far between.

These findings contribute new insights to scholar-ship on EJ policy implementation. Other scholars’explanations for the slow pace of EJ policy implemen-tation cohere with the standard narrative circulatingwithin regulatory agencies and insisted upon by thosein positions of authority: that their agencies’ EJ effortsare limited by industry pushback, weak EJ policy, andinsufficient analytical tools – factors beyond the con-trol of agency staff and managers. EJ staff complicatethis narrative. By describing discursive and other prac-tices through which staff and managers reject anddelegitimize proposed EJ programs, they cast theircolleagues’ behaviors and views as partially responsi-ble for the slow pace of EJ policy implementation.

That is, the delegitimation of proposed EJ reforms isdone not only by industry and political elites but also bybureaucrats whose discursive and other practices frameEJ as an unreasonable basis for regulatory reform andanathema to agency responsibilities. EJ staff describehow their colleagues undermine their EJ efforts by vocallydeclaring in meetings and private conversations that EJviolates the agency’s purpose, racism is a thing of thepast, and environmental problems are not serious; occa-sionally threatening EJ staff; and widely ignoring theirrecommendations. EJ staff also speculated about howtheir colleagues’ disciplinary training, ideas about exper-tise, life experiences, beliefs about racism, and profes-sional commitments might motivate those practices.These factors I have identified function together withthe material factors other scholars have emphasized.Bureaucrats’ discursive and other practices that undercutEJ staff are acceptable in a context in which agencies arevulnerable to industry lawsuits and conservative politi-cians’ budget cuts. Moreover, given the ambiguous legalstatus of the Executive Order on EJ, EJ policy implemen-tation will depend on how committed staff and man-agers are to EJ, how they interpret EJ, and how activelythey support it among each other.

Given that these findings are influenced by theunique historical and current political, cultural, andlegal contexts of the United States, future researchcould investigate the shape of agencies’ EJ effortselsewhere (see Bulkeley and Walker 2005; Scandrett2007) and the factors constraining them. Futureresearch could also examine EJ staff members’ effortsto challenge these aspects of regulatory culture (seeKohl 2015). Some recruit EJ advocates into the agen-cies as fellow ‘institutional activists’ (Santoro andMcGuire 1997). Others mentor junior colleagues who

express interest in and support for EJ, creating whatKatzenstein (1999) called ‘habitats’ – safe spaces thatactivists build or find within mainstream institutions.Other EJ staff help their colleagues visit overburdenedand susceptible communities to better understandand support EJ reforms designed to redress environ-mental inequalities.

More broadly, these findings suggest that environ-mental sociologists should heed Coleman’s (2016) callfor acknowledging the ‘pervasively uneventful’ natureof state power and studying it ‘as a mode of slow,chronic killing’ rather than ‘catastrophic’ exercise.Bureaucrats’ narratives and other actions that indivi-dually might seem unremarkable add up in ways thatallow the persistence of environmental inequalitiesthat contribute to disproportionate illness, suffering,and premature death in low-income communities andcommunities of color.

Finally, these findings illustrate the value ofbreaking open the black box of environmental reg-ulatory agencies – a dimension of the state towhich environmental sociologists have paid rela-tively little attention. As Frickel (2004), Moore(2008), Scarce (2000), and others have done withinother conventional institutions relating to the envir-onment, environmental sociologists can illuminatefactors underlying environmental problems bydescribing norms, common interactions, presump-tions, and other aspects of regulatory culture.Additionally, acknowledging the diversity ofthought within government agencies helps locateresistance to change and the opportunities, cham-pions, and techniques for transformation.

Notes

1. In the United States, Executive Orders are issued byPresidents to direct the actions of federal agenciesand officers. They have the full force of the law, pro-vided they do not violate legislative statute or theConstitution.

2. Some US EPA Region 4 staff quoted in Holifield (2004,293, 295) employ a color-blind racial ideology.

3. This parallels Liévanos’ (2012) observations of CaliforniaEPA elites insisting that agency actions were permissi-ble only if they balance environmental protections andeconomic growth.

Acknowledgments

The author thanks to David Goodman, Ryan Holifield, StefMollborn, David Pyrooz, Rachel Rinaldo, Cedrick-MichaelSimmons, Christi Sue, Amy Wilkins, participants at theConference on the Plurality and Politics of EnvironmentalJustice at the University of East Anglia in 2015, and theanonymous reviewers for thoughtful comments on theseideas. Drafts of this paper were presented at the annualmeetings of the Association of American Geographers andthe American Sociological Association in 2016.

ENVIRONMENTAL SOCIOLOGY 13

Disclosure statement

No potential conflict of interest was reported by the author.

Notes on contributor

Jill Lindsey Harrison is Associate Professor of Sociology atthe University of Colorado at Boulder. Her research focuseson environmental sociology, sociology of agriculture andfood systems, environmental justice, political theories ofjustice, and immigration politics. She has used her researchon political conflict over agricultural pesticide poisonings inCalifornia, recent escalations in immigration enforcement inrural Wisconsin, and government agencies’ environmentaljustice efforts to identify and explain the persistence ofenvironmental inequalities and workplace inequalities inthe United States today. Her book, Pesticide Drift and thePursuit of Environmental Justice (MIT Press, 2011), wonbook awards from the Rural Sociological Society and theAssociation of Humanist Sociology.

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