NRES 424 US Environmental Justice & Policy#

To: Ms. Carol Alvarado, Texas State Senator, District 6

From: Ms. Miranda Johnson, Policy Analyst, Texas Commission on Environmental Quality

Date: March 30, 2021

Subject: Pollution relief in the Manchester neighborhood of Houston

Executive Summary#

In this memo, I will discuss and analyze the disproportionate burden of pollution that residents of the Manchester suburb in Houston face daily. This community is in the vicinity of 21 hazardous waste producers and polluters, that spew toxic chemicals into the air and water, especially following natural disasters like Hurricane Harvey. This memo explores how to relieve some of this burden from the low-income community, easing high rates of cancer and other health concerns from living their day-to-day lives. It is imperative that this issue is addressed, because it highlights the disjunction between the poorer, primarily non-white Hispanic community and the unaffected wealthy, primarily white community in West Oaks-Eldridge. These inequities should not exist in District 6, let alone in the rest of the state or country, and these residents deserve to have their voices heard so that they are not confined to a dangerous and toxic life. I will argue the case of various policy options that can address this issue, such as maintaining the reliable collection of air quality and pollution prevalence rates in the suburb, buying out the residents, and investing in community organization between Manchester and West Oaks-Eldridge. This memo will begin with an in-depth analysis of the problem, a summary of the proposed policy options, a summary of the criteria, an analysis of each option regarding the criteria, and finally a conclusion and list of references.

Problem Definition#

In Manchester, Texas, a small suburban neighborhood of Houston, families breathe air that is so polluted it is akin to sitting in traffic for twenty-four hours a day. Manchester’s city limits are encircled by refineries, petrochemical plants, freight rail tracks, freeways, and a ship channel. Residents have reported that the air pollution is so bad that “you could literally smell it in the house” (Dart, 2018). Children in the town attend elementary schools surrounded by chemical plants and junkyards, while the other side of the bayou is flanked by multimillion-dollar mansions, unaffected by the problems that plague the smaller, low-income neighborhood. The median-income in Manchester is one-third less than that of the entire Houston area, and the residents are 98% nonwhite Hispanic. The Union of Concerned Scientists and Texas Environmental Justice Advocacy Services completed a recent study showing that concentrations of 1,3-butadiene were 174 times higher in Manchester than in the wealthy West Oaks-Eldridge neighborhood nearby, and that the risk of cancer was 30% less for majority white residents of those neighborhoods compared to Manchester (Dart, 2018). Besides suffering from health problems related to pollution, Manchester residents also face rising sea levels, frequent flooding, and increased risk from natural disasters like Hurricane Harvey. During the hurricane, air quality monitors were turned off and environmental regulations were lifted to allow the state to focus on flood prevention and reconstruction. This led to underestimates of pollution risk to underserved communities. As a result, any wastes produced by the polluters because of damaged facilities and equipment due to the hurricane are not counted in the overall air quality assessments, which means that residents breathe dangerous air while trying to rebuild their community. These residents cannot be left behind in their ultimate time of need.

In this memo, I will address the disproportionately high burden of pollutants facing the Manchester residents in comparison to whiter and wealthier communities. Texas has responded to this problem by encouraging residents to move but without providing the needed financial assistance. Even for residents who can afford to move out of the community, they prefer their strong ties with neighbors and enjoy the benefits of a welcoming, neighborly environment, despite all the hazards. It is necessary that immediate action is taken by the office of Senator Carol Alvarado to address the wrongs that have been inflicted on this community and many more like it. The Manchester suburb lies directly in District 6, the district over which you preside, and exists near your hometown of Houston. Between the years of 2002 and 2008, you made concerted efforts in District 6 to block the transport of hazardous chemicals and wastes through local communities, and to install air quality monitors in those communities most impacted by pollution. Addressing the burden of pollution that Manchester residents face is the next logical step, and it would provide justice to a community in peril. It is your duty as the senator for District 6 to provide equitable solutions to all residents, not just those on the greener side.

Policy Options#

In response to the problem elaborated on above, I propose four policy options:

Option 1: Status quo

In this instance, pollution data will remain sporadically collected, no community action groups will be established, and the residents will remain in Manchester, facing their current burdens of pollution. This would require no change to regulatory implementation.

Option 2: Sustain continual/uninterrupted monitoring on polluters

In partnership with EPA Region 6, the Texas Senate should maintain that air quality monitors remain turned on after natural disasters, as they are during non-disaster times, so that the risk to residents is adequately always assessed. Continuing to monitor air quality during natural disasters will allow the EPA to enforce polluting restrictions on the major air polluters that directly align with consistently collected data.

Option 3: Uniting the communities of Manchester and West Oakes-Eldridge

The wealthier, more politically powerful residents of West Oaks-Eldridge could get involved with a community organization that is introduced to connect the suburbs. This would allow residents of both communities to work together to solve pollution issues in the region, with the assistance of industry representatives and local government officials.

Option 4: State-funded relocation of residents

A state buy-out would source federal funds from FEMA’s Hazard Mitigation Grant Program. It would include a purchase offer and relocation cost for any of the 6,000 households that apply and would be determined on a case-by-case basis.


To evaluate the policy option noted above, I used four distinct criteria:

Effectiveness refers to the degree to which a particular policy option is successful in solving the problem at hand. This would involve an option that substantially reduces the burden of pollution on the residents of Manchester and improves the health and well-being of the community.

Efficiency constitutes the financial costs of a particular option. This would involve a cost-benefit analysis of the option to understand how the costs of the policy balance with the benefits to all the involved stakeholders.

Justice can also be described as equity, and it represents to what extent the residents of Manchester can obtain equitable solutions to their concerns. It makes sure that the policy option we choose will address the unique justice perspectives of the affected residents, such as their racial and ethnic identity, socioeconomic status and income level, cultural and communal ties to the suburb, and preexisting health conditions, or those created or exacerbated by the surrounding pollution.

Finally, political feasibility refers to how advantageous or disadvantageous each option will be to your position as the District 6 Texas State Senator. It will be important to analyze what effect, if any, a particular policy decision could have on your political reputation, and the feasibility of pursuing any one option.


For this case, the presented analysis is primarily concerned with effectiveness and equity. Those criteria are weighted more heavily in the following section.

Policy OptionsEffectivenessEfficiencyEquityPolitical Feasibility
RegulationsHighLowVery HighHigh
Status QuoVery LowMediumVery LowMedium
AssistanceVery HighVery LowLowLow

The status quo option is moderate in terms of political feasibility. Ignoring the issues of the Manchester community has been the status quo for years, but you have distinguished yourself as a senator cognizant of the environmental concerns of communities. This option is also efficient, because it requires no extra money to mitigate the impacts of pollution on these residents. However, as this area continues to be polluted and the residents continue to observe the adverse effects, future costs could arise. Where this option ranks poorly is in effectiveness and equity. Doing nothing to help this community has led to disproportionately high rates of cancer and other health conditions in an already-struggling neighborhood. Especially with an affluent community prospering without pollution directly across the bayou, this is a clear indication that the Manchester residents lack equitable and just treatment in their relationship to the polluters. Maintaining the status quo is also ineffective if the goal is to reduce the burdens of pollution on residents, accomplishing nothing to address their concerns and assist them.

The regulations option ranks highest in terms of equity and justice. This option out of all that are presented prioritizes the needs of the affected residents the most. It would ensure equity in environmental burdens across the suburb since air quality monitors and pollution regulations on the nearby polluters would remain in effect during natural disasters, thus providing a better estimate of pollution in the region and triggering more action from the EPA. When monitors are turned off and regulations are lifted temporarily, pollution levels are underestimated in communities like Manchester and the EPA is not forced to act. Thus, making sure that consistent data is being collected would prove that pollution levels in Manchester are actionable by regulatory agencies and require action. This option is also quite effective, as it would provide regulatory bodies like the EPA with more consistent pollution analysis. In terms of political feasibility, this seems to be directly in line with your past efforts to install air quality monitors in neighborhoods near chemical plants. This policy option would encourage consistent use and data collection of the very monitors you worked to install in District 6 communities, thus aligning well with your past work and political reputation. This option is less attractive in terms of efficiency. Disaster relief funds would have to be more equitably distributed so that environmental concerns are addressed as much so as reconstruction. Funds would need to be directed to keep all regulations in place, while still providing adequate support to help the community recover from the natural disaster.

The community group option links residents of the West Oaks-Eldridge suburb to the residents of Manchester. This option is somewhat efficient, but it would require organizing costs to implement the group, and the involvement of a local environmental group to facilitate trust. Funding could be directed towards developing a working group with prominent voices from both suburbs that can unite the interests of each community. The working group would establish a partnership between the residents so that they can compile resources and knowledge to figure out how to address environmental burdens. Ideally, the more affluent residents would eventually be interested in aiding in funding these projects, so that financial burdens to the state are not too significant. In terms of political feasibility, this option presents a great opportunity to engage two very different sides of Houston's suburbs and promote unity and community engagement, which tend to be looked upon positively by prospective voters. This option is average when it comes to effectiveness because there is unfortunately no guarantee that the West Oaks-Eldridge and Manchester residents would be willing and able to effectively work with one another. Similarly, there is the potential that actions undertaken by the residents do not hold enough political or financial power to combat entrenched systems of inequitable distribution of pollution. Where this option struggles are in terms of equity, since engaging privileged citizens in the interests of the disenfranchised is likely to not be a favorite solution of Manchester residents. A possible pitfall could occur if the organization does not address the problems in a way that best suits the needs of the Manchester residents.

The relocation option is for the state to buy out any Manchester residents who wish to leave, providing relocation costs and purchasing their houses on a case-by-case basis. This option is highly effective, because it relieves the burden of pollution from the residents by removing them from the area. However, this option does not rank well in terms of equity and justice. A lot of the residents of Manchester speak to the thriving community they have built, and how much they enjoy the sense of neighborhood and culture in the suburb. It could be deemed by some to be unjust to encourage them to leave a community they have built and love, especially if they could not all move to the same area when they leave. On the other hand, the assistance check could also be used to cover healthcare costs associated with the pollution, thus allowing residents to stay while their health is not severely affected. Residents could file all health conditions that can be attributed to pollution in Manchester and receive a check to fund their healthcare costs to some extent. This also ranks low in terms of political feasibility because it would require substantial finances to be donated to this community. It also ranks very poorly in terms of efficiency, for the same reasons.


Considering each of the different options presented above, it is my belief that the most logical decision for your office is to engage policy option #2, which intends to create more reliable and consistent pollution and air quality tracking regulations in Manchester. This report prioritizes effectiveness and equity above the other criteria, and this option ranks highly in both categories. Above all else, this option will eliminate any doubt surrounding the substantial pollution risk in the suburb. The goal of this policy option will be to record such high levels of pollution in Manchester, especially following natural disasters, that the Region 6 EPA will be required to step in per regulatory proceedings and enforce restrictions on polluters. Thus, this option is most effective in alleviating environmental burdens from Manchester residents, since it will ideally trigger a chain-reaction of pollution relief in the community. It is also the option that best addresses the concerns of the residents from a justice perspective, seeing as they get to remain in their homes and live their lives as normal while not feeling the harmful health effects of high pollution. Similarly, although the political feasibility was not weighed as much as effectiveness and equity, this option is most in line with your past work as the State Senator in District 6. Your implementation of air pollution monitors in communities that are located near hazardous waste producers and polluters directly correlates with this policy option, as you would simply be advocating for the state to keep these monitors running all the time to track the most consistent and reliable pollution data. Overall, this policy option makes the most sense in terms of how effective it will be in aiding the residents of Manchester, its political feasibility for you as senator, and its ability to be equitable and just.


  1. Sansom G; Berke P; McDonald T; Shipp E; Horney JA; (n.d.). Evaluating the Impact of Race and Gender on Environmental Risk Perceptions in the Houston Neighborhood of Manchester. Environmental justice (Print).
  2. Dart, Tom. (2018, January 29). After Harvey, Houston suburb suffers a persistent problem: waves of foul air. The Guardian.
  3. Sansom G; Berke P; McDonald T; Shipp E; Horney J; (n.d.). Confirming the Environmental Concerns of Community Members Utilizing Participatory-Based Research in the Houston Neighborhood of Manchester. International journal of environmental research and public health.
  4. David J. Miller - Environmental Defense Fund, Author, C., David J. Miller - Environmental Defense Fund, [email protected], E., Authors, Blake Actkinson - Civil and Environmental Engineering, … Notes. (n.d.). Characterizing Elevated Urban Air Pollutant Spatial Patterns with Mobile Monitoring in Houston, Texas. Environmental Science & Technology.
  5. Srám, R. J., Binková, B., Dejmek, J., & Bobak, M. (2005, April). Ambient air pollution and pregnancy outcomes: a review of the literature. Environmental health perspectives.
  6. National Research Council; Division on Earth and Life Studies; Commission on Geosciences. (1992, January 1). Rethinking the Ozone Problem in Urban and Regional Air Pollution. The National Academies Press.
  7. Sansom, G. T., Dr. Garett T. Sansom is associate director at Institute for Sustainable Communities, Kirsch, K. R., Katie R. Kirsch is a research associate at Department of Epidemiology and Biostatistics, Stone, K. W., Kahler W. Stone is a graduate research assistant at Department of Epidemiology and Biostatistics, … Stone, K. W. (2018, October 16). Domestic Exposure to Polycyclic Aromatic Hydrocarbons in a Houston, Texas, Environmental Justice Neighborhood. Mary Ann Liebert, Inc., publishers.
  8. Sansom, G., Cizmas, L., Aarvig, K., Dixon, B., Kirsch, K. R., Katare, A., & Sansom, L. (2019, August 1). Vulnerable Populations Exposed to Lead-Contaminated Drinking Water within Houston Ship Channel Communities. International journal of environmental research and public health.
  9. Impact of mobile source emission inventory adjustment on air pollution photochemical model performance, Urban Climate - X-MOL. X. (n.d.).
  10. JJ; M. M. C. A. M. D. J. (n.d.). A review of the literature on the effects of ambient air pollution on fetal growth. Environmental research.
  11. National Research Council; Division on Earth and Life Studies; Commission on Life Sciences; Committee on Advances in Assessing Human Exposure to Airborne Pollutants. (n.d.). Human Exposure Assessment for Airborne Pollutants: Advances and Opportunities. Advances and Opportunities | The National Academies Press.
  12. Cairns, N. M. K. K., And MacKendrick, N., University, D. of S. R., Cairns, K., & University, D. of C. S. R. (n.d.). The Polluted Child and Maternal Responsibility in the US Environmental Health Movement. Signs: Journal of Women in Culture and Society.
  13. Stone, K. W., Address correspondence to: Kahler W. Stone, Casillas, G. A., Gaston A. Casillas is a Graduate Assistant Researcher at Department of Veterinary Physiology & Pharmacology, Karaye, I., Dr. Ibraheem Karaye is a Postdoctoral Researcher at Program in Epidemiology, … Malecha, M. L. (2019, August 14). Using Spatial Analysis to Examine Potential Sources of Polycyclic Aromatic Hydrocarbons in an Environmental Justice Community After Hurricane Harvey. Mary Ann Liebert, Inc., publishers.
  14. Foxhall, E. (2021, February 24). Add air pollution to the list of woes from the deadly Texas freeze. Houston Chronicle.