Climate Justice and the Green New Deal: Organizational Culture in Regulatory Agencies

Climate Justice and the Green New Deal: Organizational Culture in Regulatory Agencies

Jill Lindsey Harrison

The Green New Deal (GND) calls for protecting the “frontline and vulnerable communities” most affected by climate change and other environmental harms: low-income, Indigenous, and racially marginalized communities. These well-documented environmental inequalities contribute to vast racial and class disparities in illness and death. Discussions about the GND focus on its calls for green jobs and economic growth. Yet its goal of clean air and water for everyone also requires stronger environmental laws and regulation prioritizing the reduction of environmental inequalities – to accomplish what industry and individuals will not and/or cannot do on their own. Yet the call for government to reduce environmental inequalities is not new. So why do government agencies allow climate injustice and other deadly environmental inequalities to persist? Conventional wisdom focuses on conservative political elites’ attacks on environmental regulations and the U.S. Environmental Protection Agency. My research demonstrates that “environmental justice” (EJ) reforms that would make government agencies reduce environmental inequalities – such as those the GND rightly calls for – are also undermined by elements of regulatory workplace culture that transcend changes in elected leadership. In everyday workplace interactions, staff within environmental regulatory agencies reject EJ reforms as offending their notions of fairness and successful environmental regulation.

To be sure, anti-regulatory elites have eviscerated agencies’ budgets and legal authority to regulate. Yet agencies have the resources and authority to implement many more EJ reforms than they currently do. They could impose stronger permit conditions on hazardous facilities in communities most overburdened by environmental hazards and vulnerable to the effects of exposure to those hazards, focus enforcement efforts in those areas, allow the public to shape regulatory decision-making as much as industry does, and track environmental improvement in terms of both equity and the aggregate measures currently used. Yet agencies do not systematically do these things. Something else also undermines EJ reforms in government agencies.

How Regulatory Culture Impedes Environmental Justice

Through in-depth confidential interviews with and observations of staff at state and federal environmental regulatory agencies across the U.S., including agencies whose leadership has explicitly endorsed EJ principles, I have found that EJ reforms are also thwarted by staff themselves. At every agency in my study, nearly all the “EJ staff” I interviewed – those few staff in any agency tasked with leading the design of EJ reforms to regulatory practice – characterized their EJ reform efforts as “a constant battle” with their coworkers. EJ staff are few in number and possess little authority within their organizations. Unable to require coworkers to implement EJ reforms, they must negotiate reforms their colleagues will accept. More coworkers have become actively supportive of some EJ reforms over time, such as increasing outreach to low-income communities affected by pending regulatory decisions, yet they are still relatively few.

Staff denigrate EJ reforms as conflicting with their agency’s identity. For example, staff disparage EJ as trivial and distinct from the agency’s “true” work, referring to EJ as afad,” “trend,” or “the flavor of the month.” Staff also routinely ignore recommended EJ reforms, and managers do not hold their staff accountable for implementing them. Additionally, EJ staff described being formally sanctioned and informally bullied by coworkers precisely for their EJ reform efforts.

Staff resist EJ reforms in these ways for many reasons. Budget cuts cause downsizing, which leaves staff feeling that they do not have the time to implement EJ reforms. Industry’s constant threats to sue agencies for doing anything not unequivocally mandated by law make staff fearful of trying new practices. Also, being from relatively privileged backgrounds and trained in engineering and science leave most staff unfamiliar with environmental inequalities and how to design EJ reforms. Yet staff even resist EJ reforms that take few resources and are approved by agency attorneys and leadership. Something else is going on.

I found that staff resistance to EJ reforms is also principled. Notably, at all organizations in my study, much of the pushback against EJ reforms that I witnessed and was told about focused on the fact that proposed EJ reforms explicitly identify and seek to reduce racial environmental inequalities (among others). Environmental regulatory agency staff are predominantly white, and many argue that the race-conscious nature of EJ reforms violates their organization’s need to be neutral. For instance, one EJ staff person told me that when she has proposed EJ reforms such as increasing outreach in communities of color to be affected by a pending regulatory decision, “some staff and managers” allege that doing so constitutes “reverse racism” and say, “Why should those communities of color get this extra treatment? We need to protect that middle-class white community, too.” In my observations of staff meetings about proposed EJ reforms, as well as in private interviews, I observed white staff use these same arguments to reject EJ reforms. Such statements reflect “colorblind” racial ideology pervasive in the United States today, which defines racial fairness as ignoring race and racial inequality, and casts explicitly attending to race as unfair. That is, ideas of racial fairness popular among bureaucrats and U.S. society broadly turn a blind eye to racial inequality. Thus, staff reject proposed EJ reforms as unfairly providing “extra” resources to overburdened and vulnerable communities – even though industry and government practices have systematically, disproportionately afforded environmental protections and other material resources to whites.

Lessons for the GND

Staff pushback against EJ reforms illuminates an important lesson for the GND: Even the most innovative and important new policies will fail if government agency staff refuse to implement them. While some reforms can be implemented by just a few people, others require changing the way agencies’ core regulatory work is done and thus require most staff to adjust their daily work practices. If staff refuse, the reforms do not happen. These findings reinforce what Michael Lipsky, Celeste Watkins-Hayes, and other organizational scholars have shown in other contexts: organizations are not simply run from the top, but are also shaped by workplace culture – by widespread ideas among staff about how things should be done. A successful GND will require not only legislative action but also support from regulatory agency staff. To foster this organizational commitment, agencies must formally endorse EJ principles, give EJ staff more authority over their coworkers, hire staff with diverse life experiences and training, give staff the resources and legal support needed to implement EJ reforms, hold staff at all levels accountable for implementing them, and engage staff in serious conversation about how regulatory practice should be done differently – to protect everyone.

Jill Lindsey Harrison is an Associate Professor of Sociology at the University of Colorado, Boulder.