The Great Lakes Environmental Law Center visited two mosques in Detroit and Hamtramck before Friday prayer on July 20, 2018 and spoke to the respective congregations about the proposal to expand U.S. Ecology’s hazardous waste facility, as well as the need for the Michigan Department of Environmental Quality to provide translation services to the Yemeni and Bengali communities.
U.S. Ecology is a hazardous waste treatment and storage facility that is located at 6520 Georgia Street on Detroit’s east side. The facility has proposed a 9-fold expansion in its storage capacity, and a 3-fold expansion in its treatment capacity. The Michigan Department of Environmental Quality held a public hearing regarding the proposal in 2015, but has refused requests from the Great Lakes Environmental Law Center and the Coalition to Oppose the Expansion of U.S. Ecology to hold another public hearing.Pursuant to Title VI of the Civil Rights Act of 1964, the U.S. Environmental Protection Agency has enacted regulations that requires any state environmental department that receives EPA assistance, including the MDEQ, to not discriminate on the basis of national origin. The prohibition against discrimination on the basis of national origin specifically prohibits conduct that has a disproportionate effect on people that speak or understand limited English. As such, EPA regulations affirmatively requires the MDEQ to provide people that speak or understand limited English with the ability to meaningfully access its programs.
While the MDEQ has held a public hearing regarding the proposed expansion, as required by law, it did not provide any notice of the public hearing in Arabic or Bengali. It also did not translate other vital documents, such as the fact sheet that describes the basic information about U.S. Ecology’s proposal, into Arabic or Bengali.
According to data from the U.S. Census Bureau, there are significant number of immigrants nearby U.S. Ecology, most of which are Yemeni or Bengali. One mosque that we visited on Friday is approximately 1,600 feet from the fence line of U.S. Ecology. Additionally, in the neighborhood surrounding the Hamtramck Public Library, which was the location of the MDEQ’s public hearing regarding U.S. Ecology in 2015, approximately 47% of people are immigrants and 20% speak limited English.
While the Center wrote a letter detailing these concerns to the MDEQ in early June, we have not received any response. We are urging concerned residents to contact Richard Conforti and Katie Kruse at the Michigan Department of Environmental Quality, whose contact information is provided below. Concerned residents should urge the MDEQ to:
- Comply with EPA non-discrimination regulations, which prohibits the MDEQ from discriminating on the basis of national origin.
- Hold an additional public hearing, with notice of the hearing provided in both Bengali and Arabic
- Provide information regarding the proposed expansion of U.S. Ecology in both Arabic and Bengali so that all community residents can provide the MDEQ with meaningful input.
Richard Conforti, Waste Management and Radiological Protection Division
- Email: firstname.lastname@example.org
- Regular Mail: Constitution Hall, 545 West Allegan St., Lansing, MI 48909
Katie Kruse, Environmental Justice Liaison:
- Email email@example.com
- Regular Mail: Constitution Hall, P.O. Box 30473, Lansing, MI 48909-7937
Concerned residents can also distribute flyers with information about U.S. Ecology and the MDEQ’s obligation to provide information in Bengali and Arabic to others in their community. Flyers are available in Arabic, Bengali, and English via the links below: