Environmental Justice Challenge in East Boston: Recommendations for Community Action

1. Overview.

This Community Report aims to advise the people of East Boston on what actions they can take against the electrical substation Eversource is trying to build in the Eagle Hill neighbourhood.

• East Boston suffers from Too Much In My Backyard (TMIMBY)
• Community opposes the proposed Electrical Substation
• Victims of environmental injustice – víctimas de la injusticia ambiental
• Community excluded from the public process
• What action can the community take? – ¿Qué acción puede tomar la comunidad?

2. The Urban Community.

East Boston is an urban community located within Boston, Massachusetts, in the northeastern United States. Boston is well known for its sustainability achievements and progressive goals for carbon neutrality, but there is not enough focus on the involvement of social and environmental justice in the State’s goals and actions (Walsh, 2019). East Boston has acutely felt the consequences of these injustices. The urban community is situated on the coast, North-East of the city centre, adjacent to the Boston airport, and built on reclaimed land (Project Bread, 2020).

The community is a diverse residential area with a long history of immigrant and working-class residents (Ramakrishna, 2019). In the mid-nineteenth century, East Boston was mainly populated by Irish immigrants but towards the end of the nineteenth century, it became home to a majority Italian population (Gahan, 2018). However, more recently, beginning at the end of the twentieth century, the population shifted to become primarily Latinx in origin (Gahan, 2018). The 2010 government census confirmed that 53% of East Boston were “Hispanic or Latino,” which was significantly more than the “White” population, 37.2% (City of Boston, 2010). This urban community stands in contrast to the rest of Boston’s population demographics where the statistics were reversed with more people identifying as white, 47%, and only 17.5% identifying as Hispanic or Latino, which shows that East Boston’s high density of Latinx residents is unique (City of Boston, 2010).

Over the years, immigrants have built a community within East Boston and become important drivers of the local economy and culture. However, this community faces many socio-economic challenges due to the systemic and structural conditions built into the political economy of the State and the Nation, including:

• Racial and ethnic inequity
• Gender inequity
• Social exclusion
• Uneven distribution of income and wealth

(Project Bread, 2020)

Redlining is an example of a systemic unjust process. The process was established in the 1930s to demean and restrict upward mobility of racial and ethnic minorities, as it identified their communities as a financial risk for loans and insurance (Taggart and Smith, 1981). Even though this policy was banned 50 years ago, the consequences, like the increased income gap, can still be felt today by the affected communities (Project Bread, 2020). East Boston was identified as one such high-risk community.

Due to the restrictions and injustices imposed on East Boston, there is a high rate of poverty. As a result, this minority, low- income community is often excluded from the decision-making processes determining policies that impact their welfare (Huizer, 2018). This neglect of the community’s opinions and experiences by their representatives has cemented a deep-rooted distrust in the government (Huizer, 2018). The community’s exclusion from policy decisions has made them vulnerable and allowed the State to capitalise on the lack of resistance by building industrial and polluting infrastructure nearby. As a result, many environmental burdens have been imposed on East Boston (Figure 2), such as:

• Noise and air pollution from the airport;
• Jet fuel, heating oil and salt stored next to Chelsea Creek;
• Noise and air pollution from truck traffic and highways.
  (Ramakrishna, 2019; Wasser, 2021a)

An increasing awareness around vulnerable communities in the State eventually resulted in the Massachusetts State Government identifying Environmental Justice Populations in 2010, which can be seen in the map in Figure 3 (Mass.gov, 2010). These communities were identified if they met one of the following criteria:

1. When the annual median household income for a block group is less than or equal to 65% of the statewide median (2010: $62,072); or
2. When “25% or more of the residents identify as a race other than white; or”
3. When “25% or more of the households have no one over the age of 14 who speaks English only or very well (English Isolation)”
   (Mass.gov, 2010)

Every neighbourhood in East Boston fell under one of more of these categories, demonstrating their need for increased assistance. However, the classification itself does not help the community unless it is acted upon by the State. The glaring inequity between East Boston and some of the surrounding communities was recently exposed and exacerbated as the urban community was disproportionately affected by coronavirus and the pandemic’s economic outfall (Project Bread, 2020).

3. Urban Sustainability Challenge.

East Boston faces many urban sustainability challenges, both social and environmental, but one of the most recent challenges affecting the community is a struggle against the construction of the East Eagle Substation that Eversource proposed in the Eagle Hill neighbourhood of East Boston (Wasser, 2021a).

Electrical Substations

Electrical Substations are a necessary part of the energy infrastructure that provide communities with power. They convert high- voltage electricity, traveling quickly from generators to a lower voltage for local distribution (Eversource, 2020; Wasser, 2021a).

Environmental Burdens

Residents of East Boston are heavily opposed to the substation being built in their densely populated neighbourhood because the infrastructure is prone to fires and explosions, while there is also a high risk of flooding from Chelsea Creek (Wasser, 2021a). Also, the site location is across the street from one of the few community green spaces called an Urban Wild, a popular sports field, and a children’s playground (Ramakrishna, 2019). Eversource’s flood analysis claimed that the substation’s foundation elevation would exceed the flood elevation standards of the Federal Emergency Management Agency’s (FEMA) 500-year storm water levels (Figure 4) (Eversource, 2020). However, FEMA’s flood maps are notoriously controversial, as they only consider historic flooding and not the potential increase in future flooding, which is highly likely due to climate change and the location of East Boston (Ramakrishna, 2019).

In response to Eversource’s technical claims and depictions that the substation is not at risk of flooding, a geography professor living in Eagle Hill, Dr. Marcos Luna, argued that the flood analysis they conducted did not actually confirm that it was a good location for the substation and that it was inaccessible to a non-expert audience (Ramakrishna, 2019). Therefore, Dr. Luna conducted his own analysis and distributed the representation (Figure 5) around East Boston residents (Wasser, 2021b).

This map accounted for future flood projections and established that the substation location is within the city’s sea level rise predictions for 2050 to 2070, proving that the substation is at risk of future flooding (Ramakrishna, 2019). This debate over flood risk demonstrates Eversource’s lack of transparency and how data analysis can be distorted to obtain siting approval.

Some outsiders could see the substation debate as a case of Not In My Backyard (NIMBY), because this community wants electricity, but not the infrastructure to supply it (Hermansson, 2007). However, it is actually a case of Too Much In My Backyard (TMIMBY) due to the density of polluting sources around the community. Since East Boston is an overburdened urban community, battling both polluting sources and the effects of climate change, the construction of this substation is an environmental justice challenge.

Environmental Justice

The United States Federal Environmental Protection Agency (EPA) defines Environmental Justice (EJ) as the right of all people to be protected from environmental and health hazards and to have equal access to the decision-making process impacting their well-being, regardless of their race, national origin, or income (EPA, 2002). Under this definition Massachusetts has not provided East Boston with EJ.

The EJ Movement in America arose in the 1960s primarily from communities of colour who aspired to highlight the inequity of environmental protection since these communities face some of the nation’s worst environmental impacts (EPA, 2002). Activists have exposed that this was no accident as communities of colour and high poverty are habitually targeted to host polluting facilities, an act justly referred to by the movement as environmental racism (Skelton and Miller, 2016). The movement was catalysed by the Civil Rights Movement when people of colour started to protest the many ingrained systemic injustices they faced (EPA, 2002).

Massachusetts’ long history of environmental racism and exclusion of minorities from public processes is unjust and has left community members feeling like their health, wellbeing, and opinion are not a priority for the State (Wasser, 2021b).

4. The Current Policy.

This case is extremely technical, both in terms of its material components, but also the governing bodies behind the process that have allowed it to develop (Ramakrishna, 2019). To understand how the project has been systematically progressed through state approval, it is important to understand the policy and administrative groups behind the decisions. The Massachusetts State adopted an EJ Policy in 2002 which is maintained by the State’s Executive Office of Energy and Environmental Affairs (EEA) (Mass.gov, 2002). The policy seeks to provide the necessary resources to low-income communities and communities of colour to actively and aggressively combat the environmental burdens unduly placed upon them (Mass.gov, 2002).

In 2010, the State enhanced the policy by classifying EJ Populations with census data, which, as previously mentioned, all the East Boston neighbourhoods satisfied (Mass.gov, 2010). In this update the EEA committed to enhanced public participation in EJ Populations under the Massachusetts Environmental Policy Act (MEPA) (Mass.gov, 2017). This requires actions such as the translation of official documents and interpretation of public meetings in EJ Populations with primarily non-English speakers (Mass.gov, 2017).

EEA

The EEA is the parent agency of the two State bodies permitting the East Boston substation: The Department of Public Utilities (DPU) and The Energy Facilities Siting Board (EFSB) (Wasser, 2021c).

DPU

The DPU oversees electrical power, water, and natural gas companies in Massachusetts. In addition, the DPU provides administrative support for the EFSB, but the nine member EFSB makes their decisions independently (Mass.gov, 2021).

EFSB

The EFSB is run as an independent state agency that evaluates proposed large energy facilities. To obtain EFSB approval, a new facility needs to demonstrate that it would generate a reliable energy supply, at the lowest possible cost, with the least impact on the environment (Mass.gov, 2021; Ramakrishna, 2019).

With all of these state laws on EJ and administrative groups tasked with protecting the environment, it is surprising that the substation got approval on February 22nd, 2021 with a unanimous EFSB vote (Wasser, 2021a). However, this approval process was not simple as the substation was first proposed back in 2014. To understand how the process developed it is important to highlight the significant events leading up to the project’s recent approval.  

6. Policy Shortcomings.

1) The EFSB fail to acknowledge the residents’ grievances and the possibility that the substation’s location is flawed (Wasser, 2021a).

While Eversource claimed the substation was necessary to address the increasing energy demand, both in housing and industry development in the area. Many have questioned this, as seven years later there has still been no sign of any problems in the distribution of power (Edwards, 2020).

The Union of Concerned Scientists were also sceptical, so they collated data from the New England power grid operator showing that, even with development, the new efficiency in appliances and buildings has caused energy demand to plateau (Edwards, 2020).

2) Eversource fail to provide proof and transparency of their reports on whether the substation is actually needed (Ramakrishna, 2020).

Eversource supposedly ran an analysis to confirm that East Boston requires a new substation to manage demand. However, the utility has not made its analysis available to the public (Edwards, 2020). 

If the substation is needed, Eversource should have to share its analysis, and if the main energy demand is coming from the Airport, the substation should be built there instead (Wasser, 2020).

3) The EFSB fail to uphold the Civil Rights of the EJ communities by belatedly providing Spanish language translations and restricting their involvement in the so-called “public process”.

At the beginning of siting process, the state did not provide interpretation services, claiming that it would be “too disruptive.” Also, it was not until five years after the project was first proposed that the first meeting was held in East Boston (Wasser, 2021a).

This was challenged by the environmental NGOs when they filed a lawsuit against the EPA for violating the 1964 Civil Rights Act for not investigating the EFSB and the DPU due to their lack of jurisdiction, as they do not give money directly to those state agencies. However, this is an extremely narrow interpretation because the EPA provides substantial federal funding to the EEA, their parent agency (Wasser, 2021c). 

4) Eversource and the EFSB fail to address the EJ issues and try to buy off the community instead. 

Instead of listening to the community and reducing their environmental impacts, it was decided that Eversource would be required to engage with the community to compensate for its impacts (Wasser, 2021a). 

This is just a stopgap so they can say they are doing something for the community, while, in reality, nothing is going to happen as the circumstances have not changed. If there is no agreement in the next five months, Eversource can build the substation anyway, which provides them with no incentive to engage with and reimburse the community (Wasser, 2021a).

Ultimately, the East Boston substation debate demonstrates how technical public processes are incompatible with how residents see and experience their urban environment (Ramakrishna, 2019).

5. Timeline.

7. Recommendations For Action.

The State has a history of pushing through polluting infrastructure under the radar in low-income and minority communities, especially as Massachusetts likes to publicly promote its cutting-edge sustainability initiatives. However, urban sustainability cannot be reached with solely technological advances. Instead, a more holistic approach is needed that simultaneously progresses social change (Williams, 2010). While it sometimes seems like an impossible task to take on State agencies and large corporations, one of the most effective ways of combatting them is for communities to expose injustices and environmental impacts of new infrastructure and make it newsworthy. Therefore, building a collective force against the construction.

3 Steps For Success.

1) Form a united activist group with a social media presence.

This will unite residents’ voices, ultimately making their opposition more disruptive. One way the group can be initiated is through a community Facebook page, which can generate a wide virtual network throughout the community and can serve as a platform to streamline communication, share information, and organise events. It will also provide a basis for a wider coalition of support to grow from residents, non-profits, councillors, and senators. 

The success of this recommendation is evidenced by a nearby Massachusetts community activist group called Fore River Residents Against the Compressor Station (FRRACS) (FRRACS, 2021). FRRACS formed in response to the proposal of the natural gas compressor station in Weymouth, MA in 2015 and have fought the siting process for years with a significant social media presence and online community (FRRACS, 2021). They managed to garner support from surrounding towns and raise alarm bells in the news, ultimately gaining support from Senators Ed Markey and Elizabeth Warren (Wasser, 2019). While the compressor station was unfortunately built in 2020, due to a massive payout by Enbridge to politicians, it is currently not in use after three unplanned releases of harmful gas in just eight months (McKenna, 2021). The Massachusetts state Senators consequently re-introduced the federal Compressor Act, which bans the Weymouth station from operating and stops any others being built, calling for the Weymouth site to close (McKenna, 2021). Ultimately, the community group’s efforts to raise public awareness around the risks the compressor station poses to the community’s health was successful.

2) Translate all policy materials into Spanish and all campaign material from Spanish to English to help residents’ voices be heard.

Throughout the substation siting process, the State has proved that it is ill-equipped to provide residents with the proper language translation services they require and are promised under the EJ Population policies (Mass.gov, 2017). Thus, the community must adapt and find their own translators, preferably residents with a scientific background, to understand both sides of the debate while prioritising the community’s understanding. Translation will go both ways: policy documents and decisions will be translated into Spanish so the community can be informed and included, while the community’s experiences will be translated back into English, amplifying their voices and impacts. This will help outsiders empathise with the community and support their fight. 

Every encounter between different cultural and social groups is centred around translation. However, translation has become increasingly politicised (Carcelén-Estrada, 2018). Historically, translation was used as an imperial tool for the colonisation of people as language was a weapon to assert dominance and reduce difference (Carcelén-Estrada, 2018). However, more recently, it has been used to preserve difference and encourage exclusion to assert dominance (Carcelén-Estrada, 2018). Minority communities can break through this oppressive cycle by taking hold of the power of translation through using community interpreters and translating their own stories back to the public. Ultimately empowering themselves. 

3) Hold high visibility community events and in-person activist meetings.

These in-person events will help the community gather to support each other, share their concerns, and empower residents to speak out. The community would benefit from holding events at the sports field and playground adjacent to the substation lot. Here they can share their personal stories about what this rare green space in their community means to them and why it is important to their mental and physical health (Ramakrishna, 2019). The community activists should invite all the local politicians, businesses, and news agencies to connect with a wider audience and encourage them to empathise with their fight against the substation.

Success of this recommendation can be seen through an initiative by a community activist group nearby in Massachusetts called Sustainable Weston Action Group (SWAG). The group aspired to expose the prevalence of gas leaks in their town to encourage the utility company, National Grid, to fix them (SWAG, 2018). SWAG actioned this initiative by identifying 292 unrepaired gas leaks and creating a map of their classification and location in town (SWAG, 2018). This analysis and map were presented at events hosted near the worst leaks, like the local public school and the town green (SWAG, 2018). Families could also look at the map to see if there were leaks near their house, which helped them realise their kids were breathing toxic gas in every day. These events and visuals brought the issue to the community’s doorstep causing an almost instantaneous outburst of support. This helped them spread the word and generate pressure on National Grid who, as a result, commenced fixing the leaks (SWAG, 2018).

These recommendations aim to inspire action at the local scale by uniting and amplifying community voices to create change in East Boston.

8. References.

Carcelén-Estrada, Antonia. “Translation and activism.” In The Routledge handbook of Translation and Politics, edited by Fruela Fernández and Jonathan Evans, 254-267. Routledge Handbooks, 2018.

City of Boston. “East Boston Data Profile: Population Demographics.” Last modified 2010. https://www.cityofboston.gov/images_docu ments/East_Boston_Planning_District_Profi le_tcm3-12989.pdf

Edwards, Lydia. “Eastie needs straight answers from Eversource.” CommonWealth, May 21, 2020. https://commonwealthmagazine.org/opinion/ eastie-needs-straight-answers-from- eversource/

Environment Protection Agency (EPA). “Environmental Justice.” Last Modified 2002. https://www.epa.gov/environmentaljustice

Eversource. “East Eagle Substation: Addressing the concerns of the Community.” Last modified March, 2020. https://www.eversource.com/content/docs/d efault-source/tranmission/addressing- community-concerns—meec-2-27-20-web- version.pdf?sfvrsn=5187d562_2

Fore River Residents Against the Compressor Station (FRRACS). ‘No Compressor Station’. Accessed February 20, 2021. https://www.nocompressor.com/

Gahan, Daniel. “Ethnic Identity in Boston Neighborhoods.” Irish Literary Supplement 37, no. 2 (2018): 10. Gale Academic OneFile

Huizer, R.T. “Building Bridges: Creation of linking social capital in East Boston.” Master thesis, Utrecht University Repository, 2018.

Markey, Edward J., Elizabeth Warren, Ayanna Pressley, Katherine Clark, Joseph P. Kennedy III, Adrian C. Madaro, Joseph A. Boncore, Sal N. DiDomenico, Jamie B. Eldridge, Daniel J. Ryan, Liz Miranda, Michelle DuBois, Lydia Edwards, Julia Mejia, Michelle Wu, and Annissa Essaibi- George. “Letter.” Congress of the United States. (December 2020): 1-4. https://d279m997dpfwgl.cloudfront.net/wp/ 2020/12/LETTER-Proposed-East-Boston- Substation-12.7.20.pdf

Mass.gov. “Environmental Justice Policy.” Last modified 2002.
https://www.mass.gov/service- details/environmental-justice-policy

Mass.gov. “Environmental Populations In Massachusetts.” modified 2010. https://www.mass.gov/info- details/environmental-justice-populations- in-massachusetts

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Mass.gov. ‘Energy Facilities Siting Board’. Accessed February 21, 2021. https://www.mass.gov/orgs/energy- facilities-siting-board

McKenna, Phil. “Will a Recent Emergency Methane Release be the Third Strike for Weymouth’s New Natural Gas Compressor?” Inside Climate News, April 16, 2021. https://insideclimatenews.org/news/1604202 1/will-a-recent-emergency-methane-release- be-the-third-strike-for-weymouths-new- natural-gas-compressor/

Project Bread & Children’s HealthWatch. “The State of Hunger in Massachusetts: Massachusetts Trends & East Boston Community Snapshot.” Last modified May 2020. https://www.projectbread.org/uploads/attach ments/ckewxxld702k61c4lnirukepx-the- state-of-hunger-in.pdf

Ramakrishna, Saritha. “East Boston Substation Fight Exposes Inequalities in Public Sitting Process.” Conservation Law Foundation, March 5, 2020. https://www.clf.org/blog/language-justice- east-boston-eversource/

Skelton, Renee and Vernice Miller. “The Environmental Justice Movement.” NRDC, March 17, 2016. https://www.nrdc.org/stories/environmental- justice-movement

Sustainable Weston Action Group (SWAG). “Weston Gas Audit Analysis.” Last modified June 2019.

https://www.westonma.gov/DocumentCenter/View/20032/Gas-Audit-Analysis-Summary-PDF?bidId=

Taggart, Harriet Tee and Kevin W. Smith. “Redlining: An Assessment of the Evidence of Disinvestment in Metropolitan Boston.” Urban Affairs Quarterly 17, no. 1 (September 1981): 91-107.

Walsh, Martin J. “Climate Action Plan: 2019 Update.” City of Boston. Last modified October 2019. https://www.boston.gov/sites/default/files/e mbed/file/2019- 10/city_of_boston_2019_climate_action_pla n_update_4.pdf

Wasser, Miriam. “Confused About The Weymouth Compressor? Here’s What You Need To Know.” WBUR Earthwhile, December 2, 2019. https://www.wbur.org/earthwhile/2019/06/1 9/proposed-weymouth-gas-compressor- explained

Wasser, Miriam. “16 Mass. Elected Officials Challenge State Agency on East Boston Substation.” WBUR Earthwhile, December 7, 2020. https://www.wbur.org/earthwhile/2020/12/0 7/east-boston-substation-efsb-covid- reexamine-project-need

Wasser, Miriam. “In a Blow To Environmental Justice Advocates, State Regulators Approve Controversial East Boston Substation.” WBUR Earthwhile, February 22, 2021a. https://www.wbur.org/earthwhile/2021/02/2 2/east-boston-substation-final-approval- eversource-environmental-justice

Wasser, Miriam. “As Final Vote On Electrical Substation Nears, East Boston Residents Say State’s Approval Process Has Left Them Out.” WBUR Earthwhile, February 3, 2021b. https://www.wbur.org/earthwhile/2021/02/0 3/substation-east-boston-chelsea-greenroots- efsb-environmental-justice

Wasser, Miriam. “Environmental group sue EPA over alleged civil rights violations in East Boston and Chelsea.” WBUR Earthwhile, January 14, 2021c. https://www.wbur.org/earthwhile/2021/01/14/east-boston-chelsea-substation-greenroots- clf-epa-civil-rights

WikiWand. “East Boston.” Accessed March 2, 2021. https://www.wikiwand.com/en/East_Boston

Williams, Katie. “Sustainable cities: research and practice challenges.” International Journal of Urban Sustainable Development 1, no.1-2 (May 2010): 128-132.