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All hazardous waste politics is local

All hazardous waste politics is local: grass-roots advocacy and public participation in siting and cleanup decisions

by Robert C. Lowry

The American system of federalism and interest group pluralism often creates difficulties when it comes to local implementation of national environmental policies. Regulators must operate within the context of multiple political jurisdictions and are subject to public criticism, political end runs, and litigation at any one of many different points (Berry, 1989; Rosenbaum, 1995). Incorporating the concerns of private interests into policy implementation is made more difficult by the fact that there are no "official" representatives for private interests. Rather, private individuals and institutions may form any number of combinations that compete with each other for influence.

The combination of federalism and interest group pluralism causes particularly difficult problems for hazardous waste siting and cleanup decisions. The environmental organizations that are involved most directly in national policymaking have relatively little to do with local hazardous waste politics. Regulators at the local level must deal with local groups that have little incentive to consider interests beyond the borders of their own community. The number of local groups and the intensity of feeling have increased in recent years, in response to perceived injustices in past siting and cleanup decisions.

Both the Department of Energy (DOE) and the Environmental Protection Agency (EPA) have begun to encourage the formation of citizen advisory boards at hazardous waste cleanup sites (United States Department of Energy, 1994; United States Environmental Protection Agency, 1995, 1996). These boards provide increased opportunities for participation by individuals, community groups, and state and local government officials in remedial cleanup actions. Although this approach may lead to improved communication between regulators and local stakeholders, site-specific boards do not enhance incentives to consider the interests of other communities. Moreover, although some of the impetus for the EPA's program comes from the environmental justice movement, the slim evidence to date suggests that boards are most likely to form at Superfund sites in middle-class communities where public participation already exists (United States Environmental Protection Agency, 1996). Thus, the boards appear to provide a more structured forum for participation by those who already have achieved some level of organization, rather than a means of incorporating interests that previously have lacked a voice in local decisionmaking.

I will discuss first the "demand" side of hazardous waste politics, identifying differences between national and local environmental groups and the reasons why cooperation among them is limited. I then will turn to the "supply" side, focusing mostly on the recent use of site-specific citizen advisory boards for cleanup decisions at Superfund sites and facilities managed by the DOE. Finally, I will summarize the reasons why this approach may not be a sufficient remedy for the fractured politics that surround local hazardous waste siting and cleanup decisions.

The Demand Side: Interest Group Pluralism and Fractured Advocacy

Limited Involvement by National Environmental Groups

Historically, the environmental organizations that are most active in trying to influence national policy - groups such as the Sierra Club, the National Audubon Society, and the Environmental Defense Fund - have not focused much of their efforts on local hazardous waste issues. The oldest of these organizations began as clubs of outdoor enthusiasts, and only became politicized in the 1950s and 1960s by proposals to construct dams in scenic areas of the West. The newer organizations were founded in the 1960s and 1970s, as pollution issues became more prominent, wealthy patrons such as the Ford Foundation began funding work on environmental issues, and direct mail became available as a tool for recruiting mass memberships (Bosso, 1994; Mitchell, 1989). These newer groups often lack any sort of local organization, save for a few regional offices in major cities.

While national environmental groups have supported strong federal hazardous waste laws through lobbying (Bosso, 1994; Rosenbaum, 1995) and litigation (Environmental Defense Fund v. Gorsuch, 1983), their involvement in local siting and cleanup decisions has been limited. Local, "grass-roots" advocacy on hazardous waste issues tends to be led by activists such as Lois Gibbs, a homemaker with no previous experience in politics who lobbied for relocation assistance for residents of the Love Canal dump site (Foreman, 1995). Gibbs went on to found the Citizens' Clearinghouse for Hazardous Wastes (now known as the CCHW Center for Health, Environment, and Justice) to provide information and assistance to local groups across the country. She has little use for mainstream environmental groups and even proclaims herself an "anti-environmentalist" (Ingram, Colnic, & Mann, 1995, p. 127).

Divisions between national groups and local environmental activists came to a head in 1990, when a New Mexico group known as the Southwest Organizing Project sent a letter to 10 national organizations accusing them of discriminatory hiring practices and of ignoring the environmental concerns of Blacks and Hispanics. The letter followed unsuccessful efforts to obtain technical assistance from the national groups on issues concerning chemical wastes in the Rio Grande Valley (Ingram et al., 1995; Natural Resources Defense Council, 1995). Several national groups responded by hiring more minorities and seeking to provide some assistance to local groups.

There are inherent limits, however, to the extent to which national groups can deviate from their traditional agendas and constituencies. All of these groups are organized as nonprofit corporations that rely heavily on voluntary donations or membership dues (Bosso, 1994; Lowry, 1997; Mitchell, 1989). Their financial solvency depends on their ability to convince supporters to donate money or time without any explicit quid pro quo, and despite the temptation to free ride on the contributions of others. To continue to attract donations, these groups must prove themselves worthy of their donors' trust by pursuing a clearly defined agenda and producing identifiable results (Gallagher & Weinberg, 1991; Hansmann, 1987). Even groups that provide magazines and other benefits in return for member dues must maintain a clear "brand name," or risk losing members to other organizations. Thus, while existing organizations often are sympathetic to new concerns, they rarely deviate far from their traditional agenda or supporters (Mitchell, 1989).(1)

These internal organizational dynamics appear to play a significant role in limiting the involvement of national environmental groups in local hazardous waste disputes. Graham Cox, vice president for public affairs at the National Audubon Society, explained his organization's position as follows: "If Peter Berle, our president, walked into a board meeting and announced that we were going to stop caring for birds and more for humans, he would be fired" (Rees, 1992, p. 16). One national organization that did make a serious effort to aid local groups working on hazardous waste issues was Greenpeace. Later, however, Greenpeace announced that it was closing its branch offices and laying off more than three-quarters of its U.S. staff. The budget deficits that necessitated these moves were blamed in part on a decision to help local environmental groups behind the scenes, which lowered Greenpeace's public profile and created confusion about its agenda. At the same time it announced the layoffs, Greenpeace said that it would be concentrating more on global warming and forest destruction, and less on toxic waste (Goldberg, 1997).

Groups that seek to influence national environmental policy also are unlikely to form lasting coalitions with local, grass-roots organizations. Professional staff for the former become used to working inside the Washington, DC, beltway, where politics is the art of the possible and compromise often is required to accomplish anything at all. This attitude often makes them objects of scorn by local activists, who fear that the national groups are too willing to negotiate away issues to maintain a seat at the table (Bosso, 1994; Greider, 1992; Ingram et al., 1995).

For all of these reasons, most national environmental groups tend to have limited involvement with local hazardous waste politics, and it is unlikely that this avoidance will change quickly. The national organizations that do make local hazardous waste politics a major part of their agenda are groups like CCHW or the National Toxics Campaign that were founded for the explicit purpose of providing information and assistance to local organizations. Cases in which more mainstream national groups provide assistance to local groups are the exceptions that prove the rule: The Sierra Club provides support through its local chapters (Baxter, 1997), while the Natural Resources Defense Council helped to found two umbrella organizations that supply information to local groups (Natural Resources Defense Council, 1995). In both cases, support for local groups has been achieved in a way that minimizes the involvement of national staff and the impact on the national group's traditional agenda.

Conflicting Interests of Local Activists

Individuals with a personal stake in local siting and cleanup issues can be divided into two clearly distinct sets. One set of individuals lives in communities that already have one or more treatment, storage, and disposal (TSD) facilities or inactive waste sites that they want to shut down, keep from expanding, or clean up. The other set of individuals consists of people who live in communities that do not currently house a hazardous waste facility and who do not want one.

Local groups that advocate on behalf of individuals in communities that already have toxic waste facilities or sites often identify with what is known as the "environmental justice movement." The origins of this movement usually are traced to Warren County, North Carolina, where a 1982 dispute over construction of a hazardous waste facility in a predominately Black county drew protests from the United Church of Christ, the Southern Christian Leadership Conference, and the Congressional Black Caucus (Ringquist, 1997a). The movement achieved increased recognition with the publication of a 1987 study showing correlations between income and race and proximity to toxic wastes throughout the United States (Commission for Racial Justice, United Church of Christ, 1987). While claims of environmental injustice may refer to inequitable exposure to a variety of environmental "bads," (Bowman & Crews-Meyer, 1997; Ringquist, 1997b), most attention has focused on hazardous wastes. A large number of studies since have examined the relationships between race, income, and proximity or exposure to hazardous wastes (Boer, Pastor, Sadd, & Snyder, 1997; Bowman & Crews-Meyer, 1997; Hamilton, 1995; Ringquist, 1997a, 1997b; Zimmerman, 1993). While several studies find that areas adjacent to TSD facilities or abandoned waste sites tend to have higher percentages of minorities or low-income residents than other areas (but see Cutter, Holm, & Clark, 1996; Zimmerman, 1993), these variables do not always prove to be statistically significant or substantively important in a multivariate analysis. Still less certain is the question of causation, which requires information on the characteristics of the population surrounding hazardous waste sites at the time siting decisions were made.

Many local advocacy groups nonetheless have rallied around the environmental justice banner without waiting for conclusive evidence. Some groups emphasize alleged correlations between race and exposure to environmental hazards, while others view environmental justice in terms of economic power and local control (Bosso, 1994; Greider, 1992). All environmental justice advocates share a belief that some individuals have been exposed disproportionately to adverse environmental conditions, and that these inequities are not merely the byproduct of technical considerations or random chance.

There are no systematic empirical data on the members or supporters of environmental justice organizations, but a number of sources agree that they bear little resemblance to the traditional supporters of the national groups (Bosso, 1994; Greider, 1992; Ingram et al., 1995; Natural Resources Defense Council, 1995). Whereas members and supporters of national groups tend to be White, upper-middle-class, highly educated professionals, members and supporters of environmental justice groups are more likely to be minorities, hold blue-collar jobs, and have moderate to low incomes. Whereas members and supporters of national policy groups respond to fund-raising pleas focusing on unique natural wonders, endangered species, and global issues like biodiversity, supporters of environmental justice groups are much more focused on human health concerns present in their families and neighborhoods.

The differences go beyond socioeconomics and substantive concerns to include attitudes toward government regulators and normative standards. Whereas supporters and staff members of environmental groups focused on national policy often are comfortable working within the existing regulatory framework, supporters of environmental justice groups often are distrustful of government and do not think that their concerns are likely to be heard. Moreover, environmental justice activists are more likely to view the issues surrounding hazardous wastes in moral, as opposed to technical, terms.(2) The fundamental issue for a prototypical environmental justice activist is not how to minimize the aggregate costs of hazardous wastes, but whether those persons responsible for subjecting specific local communities to health hazards can be held accountable and prevented from committing such acts in the future (Bosso, 1994; Greider, 1992; Ingram et al., 1995). As a result, environmental justice activists tend to shun compromise in favor of confrontation and protest. Their motivation and adversarial stance bear a closer resemblance to protest groups to such as ACT-UP (which seeks to promote public awareness of AIDS and secure federal funding for research) than to the national environmental groups active in Washington, DC (Foreman, 1995).

The other individuals active at the local level personify the "not in my backyard," or NIMBY, phenomenon. These are people who live in communities that are being considered as possible sites for new waste facilities but who organize to keep the facilities out.(3) There is little systematic evidence on the socioeconomic characteristics of these individuals, but Rosenbaum (1995, p. 258) describes them as "well educated, socially active, [and] organizationally experienced." These are the same middle-class, concerned citizens who might protest a new freeway extension or adult book store.

NIMBY activists nonetheless are similar to environmental justice activists in that often they are unwilling to accept the reassurances of technical experts and government officials. This distrust may be due in part to inaccurate beliefs about the nature of the risks involved, but it also stems from differences in the way that risks are perceived. Technical analysts often view risks in terms of the expected number of injuries per year per capita, while community residents focus on the possibility, however remote, of irreversible harm to themselves or members of their family (Andrews, 1997). Unwillingness to accept official reassurances also stems from a lack of confidence in the veracity of business and government spokesmen (Rosenbaum, 1995). This lack of trust is particularly strong in states where prior decisions on hazardous waste management or disposal were made without significant public participation (Mazmanian & Morell, 1994; Rabe, 1994).

Given that more hazardous wastes are being generated constantly, it is inevitable that the interests of individuals in different communities will conflict, and evidence is accumulating that decisions regarding the siting or expansion of TSD facilities are influenced by the extent to which affected persons exert political pressure (Hamilton, 1995; Rabe, 1994; Ringquist, 1997a). Rabe (1994, p. 21) argues that the evidence on correlations between race, income, and proximity to hazardous waste facilities supports the notion that past siting decisions were made "on the basis of weakest political resistance rather than optimal technical criteria." Similarly, Ringquist (1997a, p. 244) reviews several possible explanations for TSD facility siting patterns and concludes that "nearly all of the available evidence" supports the importance of neighborhood political power in siting decisions.

From the perspective of both environmental justice and NIMBY activists, the best solution to hazardous waste disputes therefore may appear to be more, and more strident, political opposition. Until recently, more affluent neighborhoods had a distinct advantage in exerting political pressure, but the growth of the environmental justice movement and organizations such as CCHW has tended to level the playing field. Thus, regulators increasingly are placed in the position of being met with vocal opposition no matter what they propose.

The Supply Side: Public Participation in Local Siting and Cleanup Decisions

Dilemmas for Public Officials

The fractured demand side of hazardous waste politics makes the job of regulators a difficult one. National groups that claim the mantle of spokesmen for the environmental movement often have little to do with local hazardous waste politics, and sometimes there is open antipathy between the national organizations and local activists. At the local level, pluralism means that there is no designated public representative, and different local interests may be in conflict with one another. Many local groups are more concerned with public participation, access to information, and the perceived fairness of outcomes than with the technical issues of minimizing aggregate exposure to health hazards (Mazmanian & Morell, 1994). Their tendency to oppose any proposal that fails to meet their demands on procedural or equity dimensions leads to what Rosenbaum (1995, p. 255) describes as "a disturbing contradiction between the [environmental] movement's commitment to participatory democracy and its insistence on rapid, effective environmental regulation."

One solution to this dilemma might be to provide for public participation in siting and cleanup decisions at an early stage. In addition to providing a forum for public input, this approach might result in increased understanding of the different viewpoints of technical experts, political officials, and individuals having different backgrounds and concerns. Rabe (1994) argues that providing meaningful opportunities for public participation in siting decisions is just as important as providing technical information, and that local groups are much more likely to accept new TSD facilities if there are adequate assurances that other communities will have to share some of the burden. Mazmanian and Morell (1994) argue that giving local activists a role in the decision process also might lessen the tendency to adopt an uncompromising, "anywhere-but-here" stance. This may not be the case if those who participate hold extreme views, but any attempt to restrict participation to the more "reasonable" members of the community would not satisfy the need for a decisionmaking process that is perceived to be fair and open.

Government agencies responsible for regulating the handling, disposal, and cleanup of hazardous wastes have not been noted for their eagerness to invite participation by members of the public in affected communities. Although the EPA develops regulations on the handling and disposal of hazardous wastes under the Resource Conservation and Recovery Act, decisions about the actual siting of TSD facilities are a matter for local land use authorities, with increasing involvement by state legislatures and agencies. In the past, these decisions often have been made by local officials and developers, with little public involvement until after a site has been chosen (Mazmanian & Morell, 1994; Rabe, 1994).

A similar lack of public participation has characterized federal efforts to clean up former waste disposal sites. After a site is designated for the Superfund National Priority List, the EPA is required to make remedial cleanup plans available for public comment, and community groups who want to participate can obtain technical assistance grants authorized by the 1986 Superfund Amendments (5 U.S.C. [section] 9617). Nonetheless, there appear to have been few proactive attempts to solicit public input from diverse interests before responsible officials become committed to a particular approach. Finally, the Department of Defense (DOD) and the DOE have been notorious for the lack of information provided about the risks posed by hazardous materials at nuclear weapons sites within their jurisdictions (Rosenbaum, 1995).

Use of Citizen Advisory Boards at Cleanup Sites by the EPA and DOE

Recent initiatives by the EPA and the DOE provide case studies of attempts to use citizen advisory boards to improve the success of hazardous waste cleanup efforts. Some of the impetus for the EPA's new approach appears to come from the claims of the environmental justice advocates. EPA's Office of Solid Waste and Emergency Response (OSWER) established an Environmental Justice Task Force in 1993 to analyze environmental justice issues specific to hazardous waste programs and to develop recommendations (United States Environmental Protection Agency, 1995). On February 11, 1994, President Clinton issued Executive Order 12898, which directed each federal agency to develop strategies that identify and address "disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations," and to ensure that relevant information is readily accessible to the public (Clinton, 1994, [sections] 1-103, 5-5(c)). In April 1994, the OSWER Environmental Justice Task Force recommended that the EPA develop a program involving Community Advisory Groups (CAGs) and provide guidance and support for their activities (United States Environmental Protection Agency, 1995).

The EPA has published guidelines for the establishment and operation of CAGs (United States Environmental Protection Agency, 1995). The purpose of these groups is to provide opportunities for public input and the exchange of information, but the EPA notes that it is prohibited by law from abrogating responsibility for final decisions (see 5 U.S.C. Appendix, [section] 2(b)(6)). The EPA must certify that the CAG is representative of the diverse interests of the community for the group to be recognized. The EPA recommends that at least half of the CAG members should be from the local community, and asserts that nonlocal representatives of national groups or persons without a direct, personal interest in the site generally should not be included because they have "obvious" conflicts of interest (United States Environmental Protection Agency, 1995, [section] 4.2).

Once a CAG has been certified, the EPA may provide training for members on technical issues and other forms of administrative support. Group meetings are open to the public and should be announced in advance. EPA representatives may be present at meetings and may respond to questions or comments, although their responses are not considered part of the formal agency "Response to Comments" required under Superfund's public participation provisions. Where a community group previously has received a technical assistance grant, the EPA regional office is to encourage a representative of that group to become a member of the Citizen Advisory Group (United States Environmental Protection Agency, 1995).

The CAG program has been slow to develop. By the end of Fiscal Year 1997, only 33 of approximately 1,400 Superfund sites had CAGs, and some EPA regions had none at all (Leahy, November 28, 1997, conversation with the author).(4) While EPA regional offices provide administrative assistance for CAGs, there is no dedicated funding for the program, and the initiative must come from the community. Even where interest exists, successful CAGs require a substantial commitment by individual members to receive training and to become familiar with all of the planning documents; it is not always easy to find people willing to make this commitment (United States Environmental Protection Agency, 1996).

The EPA has published a set of five case studies of "successful" CAGs that provide further insight into the program. None of these cases involves sites with significant environmental justice issues, and each CAG appears to be focused solely on the effect of cleanup plans on the local community. Four of the five communities studied are characterized as being middle class, while the fifth is described as having "a large number of well educated and highly skilled people..." (United States Environmental Protection Agency, 1996, p. 70).(5) None of the communities is described as having more than 5-10% minorities. At three of the five sites, the CAG appears to be a continuation of a previously established community task force or ad hoc oversight committee. None of the persons interviewed for the case studies is identified as a representative of national environmental groups or of communities other than the one where the site is located. The only interests outside the immediate community that are represented are state and local government agencies and potentially responsible parties.

The DOE decided in 1993 to establish a system of Site-Specific Advisory Boards for the contaminated nuclear weapons facilities it manages. The first such board was the Rocky Flats Citizens Advisory Board, which held its first meeting in November 1993. The Board is supported jointly by the DOE, the EPA Region VIII, and the Colorado Department of Public Health (Rocky Flats Citizens Advisory Board, 1997). A similar board was established for the Hanford Site in Richland, Washington, as a joint effort of the DOE, the EPA, and the Washington State Department of Ecology. In May 1994, the DOE established a national Site-Specific Advisory Board to hold periodic public meetings at different sites around the country (United States Department of Energy, 1994).

The 1996 annual report of the Rocky Flats Citizens Advisory Board provides a good deal of information about how the Board operates and its successes and frustrations to date. Six members were chosen originally by a selection committee from approximately 190 applicants, and these members selected the remainder of the Board. The Board consists of 18 members, including representatives of academic institutions, businesses, the surrounding community, government agencies, the health industry, public interest groups and environmental organizations, Rocky Flats employees, and technical experts. Interest group representatives include one member of the local Sierra Club chapter and one member of the Rocky Mountain Peace Center. The Board operates according to a consensus decisionmaking process, with the help of a trained, neutral facilitator (Rocky Flats Citizens Advisory Board, 1997).

During 1996, the Board made a total of 18 recommendations covering a variety of topics. While it is difficult to know how to interpret the diplomatic language in the annual report, it appears that in several instances the DOE responded in a manner satisfactory to the Board. For example, a Department representative stated in response to a longstanding community concern that the Department would not seek permanent disposal of nuclear waste materials at Rocky Flats. On the other hand, the Board noted its "disappointment" that there were no enforceable milestones for the handling and removal of special nuclear materials at the site (Rocky Flats Citizens Advisory Board, 1997).

Discussion

Effective public participation in hazardous waste siting and cleanup decisions can occur only at the local level because of the unique technical issues associated with each site, and because there is no organization that can speak effectively for local interests at the national level. Groups that operate at the local level not only are distinct from the national environmental policy groups, but they represent different constituencies, pursue different concerns, emphasize different normative standards, and often do not trust the national organizations. A focus on purely local interests, however, cannot solve the problems created by NIMBY politics, and may tend to perpetuate the very inequities that have fueled the environmental justice movement. While both the EPA and the DOE recently have made use of citizen advisory boards at hazardous waste cleanup sites, questions remain regarding regulators' commitment to public participation, the extent to which the boards result in an increase in meaningful public participation, and the absence of mechanisms for bringing together concerned members of the public from different communities having conflicting interests.

Both the EPA and the DOE have adopted the use of CAGs through administrative fiat, prompted in part by President Clinton's Executive Order 12898. There has been no legislative action by Congress, although President Clinton's order technically will remain in effect until it is repealed by a successor. Moreover, few states have addressed the problem of public participation in hazardous waste siting and cleanup decisions (Mazmanian & Morell, 1994; Rabe, 1994; Rosenbaum, 1995).(6)

It is risky to generalize from a small number of cases, but the evidence to date suggests that "successful" EPA CAGs are most likely to be found at Superfund sites located in middle-class communities where some form of community involvement already exists. Thus, the program appears to have done little so far to address inequities in participation. The cases studied by the EPA include a variety of methods for selecting members. All seem to have worked reasonably well, although in one case there was a "mutiny" against an attempt by potentially responsible parties to organize the CAG (United States Environmental Protection Agency, 1996, p. 39). It must be remembered, however, that these cases were selected as examples of successful CAGs. The manner in which members are selected is a potential source of controversy should the program spread to more heterogeneous communities.

None of the advisory boards is allowed to make decisions binding on government regulators, and some boards may prove to be little more than public relations vehicles. It is likely that the degree of satisfaction with agency responses will vary by site. Several of the CAG members interviewed by the EPA mentioned that communications between regulators and community members improved over time. Several of the government officials interviewed saw an advantage in having a CAG that can serve as the designated forum for community participation, rather than having to deal with different stakeholders one at a time (United States Environmental Protection Agency, 1996).

The site-specific approach taken by the DOE and the EPA clearly does not address the larger issue of conflicting local interests. For example, the Rocky Flats Board's Annual Report cites positively a commitment from the DOE that waste materials will not be disposed permanently at Rocky Flats, but makes no mention of any plan to dispose of them somewhere else. CAGs established by the EPA normally must draw at least half their members from the surrounding community, and EPA's Guidelines specifically exclude nonlocal representatives of national organizations or other individuals who might take a broader perspective. While Mazmanian & Morrell (1994) and Rabe (1994) argue that local representatives who have meaningful participation in decisions will be willing to accept their "fair share" of the burdens, the approach adopted by the DOE and EPA does not appear to enhance the incentives for these persons to consider the impact of local decisions on other communities.

If anything, the use of purely site-specific boards would seem to reinforce the fractured nature of hazardous waste siting and cleanup decisions, in which DOE and EPA share responsibility with the states for cleanup at individual sites, while TSD facility siting is left to the states and local zoning boards. Neither DOE's nor EPA's citizen advisory board programs are intended to address siting or expansion of active TSD facilities, and state agencies generally have not established processes for bringing together individuals from different communities at an early stage in the decision process.

Solutions to the problems posed by NIMBY politics and unequal exposure to environmental risks require consideration of interests beyond the local community. Neither the demand side nor the supply side of current hazardous waste policy implementation offers a solution to this problem. On the demand side, national environmental organizations tend to concentrate on other issues that provide benefits to their longtime supporters, while local groups all look out for local interests. On the supply side, site-specific advisory boards established by the EPA and the DOE appear to offer benefits to both regulators and local community activists, but exist primarily in communities that already were most likely to have some degree of community involvement. Moreover, no overall process has been established to address the effects of decisions made at one site under one program on other communities or sites governed by other programs.

Notes

1 This argument contrasts with political scientist David Truman's "disturbance theory," which posits that new groups are formed in response to disturbances caused by shifts in economic or social conditions (Berry, 1989). Disturbance theory is incomplete, because it fails to explain how interest group entrepreneurs overcome collective action problems, or why existing groups do not simply expand their agendas to incorporate new issues.

2 Certainly there is variation among environmental groups that operate on a national scale, and any attempt to create a strict taxonomy of "mainstream" versus other national groups is suspect (Bosso, 1994; Ingram et al., 1995). Groups such as Greenpeace, Earth First!, and the Sierra Club are more likely to take a moral stance on issues, although the former two are not focused on directly influencing national policy. The important point is that those groups that are most likely to be at the bargaining table in Washington are perceived by local activists to be focused inordinately on purely technical concerns.

3 The term "not in my backyard" (NIMBY) is often used to describe the position of all local groups, including environmental justice groups (Rosenbaum, 1995). However, there is a clear difference in interests depending on whether a TSD facility or abandoned waste site already exists in the community, and the term "NIMBY" seems more appropriate for cases involving opposition to a new facility.

4 Leslie Leahy coordinates the CAG program for the EPA's national Office of Solid Waste and Emergency Response in Arlington, VA.

5 The sites studied include Brio Refining, Inc., Harris County, TX; Carolawn, Inc., Chester County, SC; Colorado School of Mines Research Institute, Golden, CO; Oronogo-Duenweg Mining Belt Site, Jasper County, MO; and the Southern Maryland Wood Treatment Superfund Site, Hollywood, MD.

6 One possible exception is California, which established a comprehensive planning process in 1986 that required each county to assume responsibility for hazardous wastes generated within its borders. This had the effect of forcing different interests within the same county to come to the same table. Mazmanian and Morell (1994) praise California's scheme, but Rabe (1994, pp. 118121) criticizes a decision by the Department of Health Services that requires all counties to develop plans for a wide range of TSD facilities independent of county needs, and allows a state appeals board to override decisions made at the county level.

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United States Environmental Protection Agency. (1995, December). Guidance for community advisory groups at superfund sites. OSWER Directive 9230.0-28.

United States Environmental Protection Agency. (1996, Winter). Community advisory groups: Partners in decisions at hazardous waste sites. OSWER 9230.0-75.

Zimmerman, R. (1993). Social equity and environmental risk. Risk Analysis, 13(6), 649-666.

Robert C. Lowry is a faculty member in the Department of Political Science at Michigan State University.

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