Beyond Sacrifice Zones: Rethinking Pollution through a Cumulative Impact Lens

Abstract

In Chicago's environmental sacrifice zones, activists and residents are rethinking pollution through a cumulative impact lens to capture the multiple, overlapping harms affecting fenceline communities, organize resistance, and make remediation demands.

Keywords

environment sacrifice zone social movements cumulative impact public policy environmental justice environmental racism urban land use

Everyone knows pollution is harmful for human health and the environment, but how much is too much? Since the first environmental laws were passed in the 1970s, the dominant approach to regulating pollution in the United States has centered on “one-pollutant-at-a-time” and “one-facility-at-a-time” analyses, where regulators check for minimal compliance with federal standards without considering how pollution is cumulatively experienced by people who are exposed to it. Yet environmental justice activists and their allies are increasingly challenging such approaches. Emphasizing “cumulative impacts,” these activists are pushing industry and government agencies to consider how residents of “fenceline communities”—neighborhoods adjacent to environmental hazards—simultaneously experience multiple environmental threats and pollution burdens, further compounded by stressors rooted in social inequality.

In our study, we examine how environmental justice activists are advocating for new zoning and permitting tools to recenter the connection between place and health when cities regulate pollution and make decisions about industrial land use. Focusing on efforts to introduce a cumulative impact ordinance in Chicago, we trace how activists and allies’ fight against the relocation of one polluting facility led to federal civil rights investigations into patterns of environmental racism in local policies. We then turn to a broad-based initiative to reconceptualize the limits of pollution and consider the future of industrial land use across the city. Our research is based on interviews with activists and stakeholders working to introduce cumulative impact policies, as well as participant observation at public meetings, protests, and community education events organized by environmental justice (EJ) organizations in Chicago between 2021 and early 2025. We also draw on archival sources, including government documents, letters, public comments, news media articles, and legal files.

a permit proposal,

a hunger strike,

and a civil rights complaint.

On February 18, 2022, we joined a small crowd gathered outside Chicago’s City Hall. The protesters were bundled up against the city’s infamous winter cold and many still wore masks to mitigate the spread of COVID-19. Together, we listened to local organizers leading the fight to stop General Iron, a large metal-shredding facility, from relocating to Chicago’s Southeast side. Anticipating the city’s approval of the permit, some held signs declaring: “ya basta de tanta contaminación a nuestras comunidades!!” (enough pollution in our communities!!) and “ecological devastation is immoral.” The permit in question would have allowed the metal recycler to move away from the edge of an affluent, majority-White North side area slated for a new megadevelopment project to a new site near a working-class residential area in an already pollution-burdened, predominantly Latine community.

“We deserve clean air” sign hangs along Commerical Ave. in South Chicago.

The proposed site, which already hosts other metal and electronics recycling operations, is a 175-acre property formerly occupied by a steel mill. Located along the eponymous river in the Calumet Industrial Corridor, its census tract was ranked in the 99th percentile—indicating nearly the greatest overall rank combining environmental burden, social vulnerability, and pre-existing chronic disease burden relative to other census tracts nationwide—by the

Centers for Disease Control and Prevention (CDC). This rating reflects the area’s high concentration of Superfund (that is, toxic waste clean-up) sites, facilities that routinely release chemicals into the environment, and sites used to handle hazardous wastes. The city’s health department found that adding a new facility to process large volumes of scrap metal here would affect almost 2,000 people living in fenceline communities in East Side, Hege-wisch, and South Deering, including students at an elementary school and high school within a mile of the site. Some of these residents are especially vulnerable to pollution exposure, such as those with chronic health conditions and a relative lack of access to healthcare.

The concentration of heavy industry and contaminated land—along with the perception that their neighborhoods have become a dumping ground protected by little environmental enforcement or accountability—has led some longtime EJ organizers like Peggy Salazar, former director of the Southeast Environmental Task Force (SETF), to dub Chicago’s Southeast side a “sacrifice zone.” As Valerie Kuletz documents in The Tainted Desert and Steve Lerner writes in Sacrifice Zones, the term was initially used in the U.S. context to refer to radioactive landscapes where uranium was mined and processed to produce nuclear weapons during the Cold War. Robert Bullard and other environmental justice scholars used the term to highlight unequal exposures to industrial pollution and hazardous waste by low-income communities and people of color in the United States. Activists worldwide now use “sacrifice zone” as a relational frame highlighting how the communities they value are perceived and treated by government and industry.

Sam Corona speaks in front of George Washington High School while leading an environmental justice tour on the Southeast side of Chicago.

That February afternoon, however, EJ organizers tallied a surprising—though hard-won—victory. The city denied General Iron the permit that would have enabled its move to the Southeast side. The denial had taken tireless organizing, protests in multiple neighborhoods, and a hunger strike by nine Southeast-side residents and allies (and more than 300 others who joined with one-day solidarity strikes). These efforts, and the controversy they generated, brought widespread media coverage. More than 4,000 written comments about the permit application were submitted to the city. Community leaders from the SETF, the Southeast Side Coalition to Ban Petcoke, and People for Community Recovery (PCR) collaborated with environmental lawyers to file a federal civil rights complaint with the Department of Housing and Urban Development (HUD), arguing that the relocation would continue a broader pattern of siting heavy industry and polluting land uses in majority Black and Latine areas. Indeed, HUD found the city noncompliant with both Title VI of the Civil Rights Act (1964) and Section 109 of the Housing and Community Development Act (1974) and the parties came to a voluntary compliance agreement. The city committed to carrying out a cumulative impact study as the first step toward remedying the patterns described in HUD’s findings.

As happened in so many Rust Belt communities, Chicago’s manufacturing sector declined just as rapidly as it had risen.

The outcome of the permit application continues to be challenged in court. Yet, by marking the first time city officials denied an industry a permit due to environmental risk and health equity concerns, the decision signified something larger: a potential shift in Chicago’s approach to industrial land use going forward. The HUD settlement also solidified “cumulative impact” as a lens through which to interpret urban land use, opening up a conversation about how to measure and incorporate it into local policy. In Southeast Chicago, home to the city’s largest industrial corridor, this conversation about cumulative impact would be key to the area’s future and inextricably connected with its past.

industrial land use, post-industrial landscape

Growing up, Gina Ramírez wondered why her neighborhood looked the way it did. “I’m a lifelong resident of the Southeast Side of Chicago. I’m actually a third-generation resident. I kind of was always curious about the space I grew up [in] because it was so deindustrialized and gritty and ugly. And my father and grandfather and great-grandfather worked at the steel mills that existed in my neighborhood.” While community members the longtime SETF organizer grew up around spoke nostalgically about the past, Gina said the area was already in decline by the time she was seeing it. “I got, like, the deindustrialization, the loss of jobs, the food desert, more polluters coming in. And so, from a young age, I was just very curious about, like, why are there all these abandoned warehouses and steel mills, and are we ever going to get jobs here, and why do my parents have to travel so far to work?”

As William Cronon recounts in Nature’s Metropolis, Chicago is a city shaped by the region’s history as a major industrial hub and by its relationship to the region’s natural geography. While grain, lumber, and meat from rural areas initially drove the local economy, stockyards and steelworks transformed Chicago into a manufacturing town. The first steel mill was established on the banks of the Calumet River in the 1870s. By the turn of the century, the now-enormous steel industry was joined by a boom in shipyards, grain mills, and other businesses. It’s no wonder this major industrial area would be devastated by the later forces of deindustrialization. As happened in so many Rust Belt communities between the late 1960s and the mid-1990s, Chicago’s manufacturing sector declined just as rapidly as it had risen. Wisconsin Steel closed in 1980, U.S. Steel’s South Works in the early 1990s, and Acme Steel Coke Plant lasted until 2001. Thousands of workers lost unionized jobs and had to seek new employment, with consequences for their financial stability, access to health insurance, and mental health.

The city tried to retain industry by leveraging zoning tools. For instance, “planned manufacturing districts,” or PMDs, were introduced during Mayor Harold Washington’s administration. The first PMD, created in 1988 in the Clybourn Corridor along the Chicago River’s north branch, came as a response to concerns that gentrification would displace local industry and affect the affordability of workers’ housing. More than a dozen would spring up around the city. While the businesses in North side PMDs tended to operate on a smaller scale, with fewer overall emissions, the Southeast side PMDs were inundated with heavy industrial and waste-related uses. City council formally designated certain areas as “industrial corridors” in the 1990s to signal that Chicago would remain an industrial hub and to incentivize industry to remain. Today, the Calumet Industrial Corridor hosts industrial land uses including chemical manufacturing, cement and concrete companies, metal manufacturers and recyclers, rubber and plastics manufacturers, and waste management facilities. All this industry abuts residential and commercial areas along with the marshes, wetlands, and parks of the biodiverse Calumet ecological region.

Deindustrialization has been accompanied by efforts to address the social and ecological consequences of heavy industry. For example, the Grand Calumet River, having hosted steel and meatpacking plants and oil refineries for more than a century, was listed among the nation’s most polluted waterways in the late 1980s. It has required massive cleanup efforts to address legacy pollutants such as heavy metals and polychlorinated biphenyls (PCBs), with EPA-led soil remediation and habitat restoration projects still under way. Many contaminated, or “brownfield,” sites on the Southeast side remain in limbo, while others have started to be remediated. For instance, the 67-acre Schroud site, formerly used to dump slag from steel manufacturing, was designated a Superfund site in 2019. The 100 acres containing the Acme Steel Coke Plant, overgrown and abandoned, were finally placed on the government’s Superfund priority cleanup list in 2024. Meanwhile, places like Indian Ridge Marsh, Hegewisch Marsh, and Big Marsh, previously used as waste disposal sites for steelmaking, dredged material, and informal dumping, have been undergoing environmental restoration for more than a decade, with the Chicago Park District collaborating with a range of stakeholders to create new recreational spaces and natural environments. Community-based groups are also collaborating with the University of Illinois Chicago Great Cities Institute, the National Park Service, and other partners to create more recreation access and public amenities along the Calumet River.

Organizers on the Southeast side have continued to raise awareness among residents about how environmental exposures affect their well-being. They have also mobilized to bring affordable housing and healthier jobs to their neighborhoods, to pressure government agencies to restore contaminated land and create new green spaces, and for more specific changes, such as calling for larger buffer zones between industry and residential areas and introducing rules for storing hazardous materials. Yet there are contradictory understandings of the area’s future, even within families. As Amanda McMillan Lequieu writes in Who We Are Is Where We Are, industry continues to be deeply intertwined with local economies and place-based identities. Gina, for example, said her parents often defended where they lived, dismissing concerns about pollution: “My dad is always like, ‘it’s not that bad here, and your mom doesn’t have asthma because of where she lived.’ My parents are in denial, and they get mad at me when I bring it up.” Still, these “uncomfortable” conversations are important, Gina contends. “If people can have conversations with their friends and family about the injustices here, then people are going to stand up for what is right.”

A rally held in front of Chicago’s City Hall on the day the General Iron permit was denied.

More than 20 years ago, David Naguib Pellow’s Garbage Wars traced the history of conflicts over waste dumping, landfills, and recycling in Chicago, highlighting the work of activists like Hazel Johnson, recognized as the “mother of Environmental Justice,” and her daughter Cheryl Johnson, who continues her advocacy leading the People for Community Recovery. Community-based organizations like PCR, SETF under Olga Bautista and Óscar Sánchez’s leadership, and their allies have been working for years to fight polluters and elevate public health concerns to protect overburdened communities. These EJ leaders are now asking the city to reverse discriminatory patterns in zoning and permitting and to recognize cumulative impacts. They have named the proposed ordinance the “Hazel M. Johnson Cumulative Impacts Ordinance” to honor Johnson’s legacy of environmental justice leadership in Chicago.

defining and measuring cumulative impacts

“We want people to understand what the actual impact is when our neighborhood is sacrificed for other neighborhoods to get beautified.” At the office of the Alliance of the Southeast (ASE), organizer Samuel Corona prepares our group for an “environmental justice tour.” EJ groups worldwide—from Detroit, Michigan, and “Cancer Alley” in Louisiana to the Ecuadorian Amazon—have long organized such activist-guided field visits through heavily contaminated areas to make environmental inequality more palpable by inviting participants to smell, hear, and even taste the pollution they experience every day.

A statue created by Roman Villarreal stands in Steelworkers Park, built on U.S. Steel’s former South Works site. The statue’s label reads: “Tribute to the Past: To all the union men and women and their families who shared the steel dreams.”

As we set off, Sam talks about being a lifelong resident of the Southeast side. Through his stories, we hear how, in overburdened communities, toxic exposures cause outrage yet also become routine. “Asthma vans” come to local schools to provide greater access to care. Dump sites become local landmarks. And, despite industry claims, pollution is not well contained. It seeps into people’s homes, schools, and recreational spaces—as in the case of the baseball fields in the area, whose soil was contaminated with arsenic, lead, and manganese. Sam first got involved in EJ organizing when he discovered that petroleum coke, a byproduct of oil refining, was being stored near his home. He was leading an anti-violence march with other neighborhood parents when he was approached by SETF organizers. As Sam learned more about the issue, he couldn’t help but start asking himself if air pollution had triggered his daughter’s asthma. When local organizers led a demonstration along Ewing Ave to bring attention to the petcoke issue, he joined them. He started learning about other cases where community health was at stake.

Cumulative impact, as a concept, is rooted in both lived experience and scientific expertise.

The petcoke fight, which took place over a decade ago, proved to be a key moment for the diffusion of the cumulative impact perspective. As an environmental lawyer closely involved in the case reflected, “You know, so much of the experience in that petcoke fight was finding... it really was this facility-by-facility Whac-A-Mole.” She explained that many aspects of emissions and potential exposures to pollutants were not governed by local or state permitting processes, and that many environmental impact metrics were inadequate. For instance, some pollutants didn’t have clear impact thresholds. In other cases, thresholds were so high they obscured meaningful variation below the threshold. As the lawyer recalled, residents were frustrated because “they were often sort of pushed into discussing only one impact and never getting into discussions about the broader context, never having tools to really even acknowledge that all these things [multiple environmental and sociodemographic stressors] were going on at once.” The General Iron case built on these years of prior conversations, revealing just how wrong existing land use assumptions were. The lawyer continued: “It was so egregious that it was very obvious to anyone, from an overall justice perspective, that this shouldn’t happen. And yet somehow the process was set up to allow it to happen.” What was missing was a concept that would make the experience of multiple exposures and vulnerabilities more legible to decision-makers. As the EJ tour concluded, Amalia Nieto Gómez, ASE’s executive director, drove this point home. She encouraged participants to call city council representatives and ask them to support a cumulative impact policy that is community-led, includes health impacts and increased public health resources, and coordinates city agencies to monitor pollution and enforce laws holding industry accountable.

Cumulative impact, as a concept, is rooted in both lived experience and scientific expertise. As noted earlier, in connecting place and health, it has emerged as a technical term that describes how people living in fenceline communities experience pollution and other environmental exposures. Specifically, emphasizing the geospatial determinants of health, “cumulative impact” refers to how environmental burdens, a community’s social characteristics, and preexisting health disparities interact to affect quality of life. If incorporated into local ordinances and state legislation, the concept may help analysts determine when a given spatially defined area has reached a level of cumulative burden that disqualifies it from being subjected to further pollutants. Yet methodologies for calculating cumulative impact, determining what is fair and just, and even defining what “cumulative” means are not obvious. Its interpretation and measurement require consensus building. Which indicators best capture environmental exposures? Which population characteristics matter most? These are the questions advocates of cumulative impact proposals in Chicago have been working to answer by looking to similar efforts nationwide.

Most cumulative impact models include two types of place-based indicators—one capturing environmental burdens and the other considering social factors—though the specific variables included vary across jurisdictions. Environmental indicators typically capture conditions like air quality, water pollution, potentially hazardous sites, and related characteristics of the built environment. Geographic context matters. For instance, an area with agricultural activity may include pesticide use, whereas areas near flood hazard zones are more likely to include flood risk. Social vulnerability indicators often include socioeconomic status—for example, the proportion of households that spend more than 30% of their income on housing and utilities, or the proportion that lack health insurance—as well as racial and ethnic composition and the extent of a household’s English language proficiency, which have been shown to affect how much influence community members may have in decision-making processes such as facility siting. Health indicators measure the prevalence of conditions such as asthma, cardiovascular disease, cancer, and poor mental health. Together, these variables produce a relative measure of cumulative burden across communities.

Map created by Juanita Vivas Bastidas using ArcGIS Pro 3.0 based on data from the Chicago Health Atlas (2023). The CEJI score is based on a combination of pollution burdens (environmental exposure and environmental conditions indicators) and population characteristics (sensitive populations and socioeconomic factor indicators) at the census tract level.

In Chicago, EJ organizations, government officials, and other stakeholders collaborated to develop the city’s cumulative impact model. They built on earlier conversations around air quality mapping and a zoning ordinance targeting air pollution, but it was the General Iron controversy and HUD settlement that accelerated their work. Southeast-side concerns were not the only ones represented; long-standing EJ groups like the Little Village Environmental Justice Organization led by Kimberly Wasserman and newer groups like Neighbors for Environmental Justice led by Alfredo Romo also put in many hours of work on the assessment, with coalitions like the Southwest Environmental Alliance, led by Theresa Reyes McNamara and Mary Gonzales, likewise providing public comment. As an epidemiologist involved in designing the assessment recounted to us, the group began with multiple landscape assessments comparing existing approaches to measuring cumulative impact and collectively generated a list of 130 potentially relevant variables, which they reduced to 28 core indicators. The resulting Environmental Justice Index portrays the distribution of cumulative impact across the city (see the map at left, showing EJI scores at the census tract level, with higher scores representing greater combined pollution effects and community vulnerability). Angela Tovar, the city’s chief sustainability officer, explained it this way during a rally in support of the ordinance resulting from the assessment: “The Hazel Johnson Cumulative Impacts Ordinance recognizes that pollution doesn’t exist in a vacuum. It compounds over time. It stacks up in the same neighborhoods, in the same lungs, in the same families.”

While accounting for cumulative impacts has been demanded by groups all over the city, how to best interpret and apply the concept has nevertheless brought up disagreements. For some activists, like Lucky Camargo, a long-time resident of Little Village affiliated with the Southwest Environmental Alliance, there are concerns that like other technical jargon, cumulative impact metrics may simply be used to disempower residents, delaying action. Others emphasize concrete demands like eliminating by-right zoning for intensive manufacturing, recycling, and related uses. Meanwhile, data analysts have questioned the index’s validity and expressed concern that relying too heavily on aggregate scores may lead neighborhoods to be miscategorized or mask heterogeneity within them. Some fear that changing pollution metrics may simply displace pollution burdens to other communities with less political power, such as neighborhoods that just fall short of the EJ community designation threshold or those across the border in Indiana. One city official said it’s important not to lose sight of holding industry accountable to stricter standards for the sake of everyone’s health, which means investing more resources in enforcement. As Óscar Sánchez of SETF put it: “To end sacrifice zones is not to create new ones.”

beyond chicago

Cumulative impact promises to redefine pollution metrics and incorporate community-based knowledge and public health factors into land use decisions in historically unprecedented ways. Indeed, cumulative impact policies may be used in land use, permitting, and facility siting decisions, or to better redistribute resources, such as allocating funding for cleanup projects or deciding which areas to prioritize when sending inspectors out for enforcement. At the very least, they support the intuitive idea that residents of pollution-burdened communities do not experience toxic environments one pollutant at a time, and that intersecting social factors shape their vulnerability to environmental burdens. Cumulative impact frameworks upend the idea that it makes sense to concentrate heavy industry, especially when it is adjacent to residential and recreational land uses—and they force policymakers to provide place-specific answers to the question How much pollution is too much?

Beyond Chicago, city- and state-level cumulative impact policies are slowly gaining traction across the country, spurred by growing attention to historical patterns of environmental racism and concerns about climate impacts. For instance, in New Jersey, Newark’s Environmental Justice and Cumulative Impacts Ordinance and state legislation stipulate new restrictions for major polluting facilities seeking to establish sites in burdened communities. In Massachusetts, a cumulative impact analysis is now required for any air emissions permits in neighborhoods designated as “EJ communities.” Other states, such as Colorado, Maryland, and Vermont, have proposed bills and even achieved legislative victories related to cumulative impact. Cumulative burden assessments are gaining recognition internationally, especially as part of environmental impact studies.

While local efforts to address environmental inequality continue, sweeping policy changes at the federal level are difficult to ignore. Funding for environmental justice programming is being cut. Place-based EJ screening and mapping tools, designed to compile indicators for informed decision-making and to democratize data access about differential exposures and vulnerabilities, have been erased from federal government websites. Attempts to roll back environmental protections and the production of scientific research around unequal exposures to environmental hazards will undoubtedly affect community health, EJ organizing, and perhaps even public recognition of the links between environmental burdens and the social determinants of health. Nevertheless, EJ organizers emphasize that work must continue at the local level even as federal regulations are weakened and eliminated.

remediate and restore

For many of the EJ organizers involved, recent efforts centered on recognizing the cumulative impacts of environmental burdens and social stressors are part of multigenerational struggles to improve everyday living conditions on Chicago’s Southeast side. Studying cumulative impacts, passing protective policies, and ensuring they are enforced are part of deeper questions about the kind of world they want to live in and leave for the next generation. Local residents are also asking what kinds of employment and land uses they do want to see. For Sam and his team at ASE, decisions about any new development must be made with meaningful neighborhood-level engagement, including community benefits agreements: “We have to be observant of what we allow into our community, and we have to make sure that it benefits our community.” Gina echoes this idea in talking about how she and her neighbors are considering which new land uses would “give back not only to the community, but [also] give back to the land, because this has been a sacrifice zone for so long.” She continues, “It’s beautiful here... I live by Eggers Grove, which is this forest preserve, and there’s deer every night and turtles and snakes. And then you turn your head, and there’s a factory.... Now that I’m a mom, and my son loves to go for walks, I’m trying to find joy in the green spaces.. I don’t want to give my life to industry. I want to give it to the beauty that exists here.”