Abstract
The United States Environmental Protection Agency (EPA) has been the epicenter of national environmental justice (EJ) work since President Bill Clinton signed Executive Order (EO) 12898 in 1994. Despite this continued focus, black, Indigenous, and people of color and low-income communities still bear the brunt of environmental harms. Although the EO began to institutionalize EJ work within EPA and across the federal government, implementing EPA's EJ program through an EO leaves it particularly vulnerable to the whims of political appointees. In this article we draw on >100 interviews by >75 former and current EPA employees to examine how despite the lack of top-down systems of accountability, EPA employees relied on middle-out systems of accountability to maintain EPA's EJ work in an administration seen as hostile to it. We begin by briefly situating this research within critical EJ studies and literature on accountability. We then draw on qualitative analysis of interviews to examine how the Trump administration tried to exploit the lack of top-down systems of accountability to dismantle EPA's EJ program. However, our interviews show how pressure from within the EPA, as well as external to the agency countered the lack of top-down systems. We conclude that the development of formalized top-down systems of accountability are critical to establish for EPA's EJ activities.
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