Page 26 - Legal Aid CRP EJ Toolkit

Issue Identified Number of Percentage of
Table 5. This table illustrates the Properties Total
qualitative environmental experience on
the sites inspected by the industry TCEQ complaints made 4 1%
investigators (i.e., sight, sound,
smell, general cleanliness).
Odors present on site 2 6%

Visible air pollution 3 9%

Piles of waste on site 3 9%

Discussion and Limitations

The toolkit is limited in a few different ways:

I. Identifying the industrial sites: As outlined in the methodology, we tried to identify all
industrial sites in our target areas. However, because of limited resources and time, the
precise number was hard to attain. To mitigate only using digital means of identifying
industrial sites, we collaborated with community leaders to do the site visits. Potentially
submitting an open records request for all the industrial sites in the target area would
provide a comprehensive inventory to conduct the analysis.

II. Site Surveys: To capture the qualitative experience of being onsite or near the sites of
these industrial operations, we conducted site surveys as part of the industry investigator
trainings. These are limited because the trainings were conducted only once, mostly on
weekends, and therefore could not fully capture the range of conditions (e.g., time of day,
weather, frequency) that could alter the experience onsite. We only have a small sample
size, so it is a snapshot at a given site at a specific time. To better assess the overall
qualitative impact, further site visits would need to be documented at different times of
the day and during various weather conditions. Similarly, as in the case of Shingle
Mountain, which is an illegal land use and dumping operation, to capture illegal uses on
non-industrially zoned lots, we need community and compliance enforcement.
III. General Overview: There are several ways that the information collected could likely be
used that are not presented in this toolkit. Because of this, some categories are grouped
together in ways that could be separated with further analysis. For example, “TCEQ
Complaint” groups together all past complaints, investigations and noncompliance issues.
For the sake of this toolkit, simply identifying documented concerns in the TCEQ per

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