A Holistic Statewide Approach to Understanding Pollution Issues

Many of our health disparities arise from or are exacerbated by exposures to harmful levels of pollution from multiple sources or increasing levels of environmental degradation. And often the communities and individuals most at risk from these harmful effects are those that are disadvantaged or have unique vulnerabilities that reduce their ability to withstand and recover from hazardous exposures. 

This is the key focus of environmental justice evaluations in the United States, and many local, state and federal agencies are grappling with appropriate approaches for tackling this complex issue.

Take air emissions permitting for example. Traditional air permitting procedures have focused on the impacts of an incremental increase in emissions from a facility. They use modeling to estimate the type, amount and timing of emissions from a proposed facility. These modeled emissions are then compared to federally established air quality standards that are often enforced by state agencies. Rarely do these permit decisions consider the existing air quality where the facility is located or other environmental health burdens from additional polluting sources that are imposed on the communities located on the other side of the facility’s boundary.  

Cumulative impact assessment, on the other hand, provides a more holistic approach to understanding environmental justice issues associated with pollution. Cumulative “impacts” encompass both the immediate environmental impacts in a given scenario and the context of the surrounding environs and their environmental history.

Benefiting From a Cumulative Impact Assessment

Requiring cumulative impact assessment within a permitting process has several benefits that include:

• Evaluating the current environmental, health and socioeconomic conditions to provide additional context (e.g. existing health disparities, poverty levels, presence of other polluting facilities in the area) that’s important to the community, the permit applicant and the regulating permitting agency.
• Using the assessment to fully understand the community whose residents live and work near the facility allows for the consideration of unique vulnerabilities that make these populations more susceptible to increased emissions.
• Doing an analysis of background environmental data (e.g., ambient air quality) to allow for better identification of “hot spots” or areas already overburdened by air or other types of pollution.

Additionally, it offers an opportunity to expand community engagement requirements during such assessments. This can improve the transparency of permit decisions while painting a more accurate picture of current environmental impacts.

A white paper released by the U.S. Environmental Protection Agency in January notes that the agency is setting its research agenda to evaluate how to implement cumulative impact assessments to identify and quantify environmental justice issues that the Biden administration seeks to address. While a handful of states like Massachusetts are exploring cumulative impact assessments, many are not meaning when EPA makes the switch they’ll have to quickly adapt to this process unless they start making changes now.  

Staying Ahead of the Curve

In spring of 2021, as a result of the new Massachusetts Climate Law, the Massachusetts Environmental Policy Act was revised to require the consideration of environmental principles with the objective of reducing the potential for unfair and inequitable effects on environmental justice populations. Specifically, MEPA will now require that an environmental impact report assess any existing unfair or inequitable environmental burden in a specific community, and whether any proposed project is likely to result in a disproportionate adverse effect on vulnerable populations.

The legislation also tasked the Massachusetts Department of Environmental Protection with developing a cumulative impact assessment for certain air permits. Both the legislature and the agency recognized an important opportunity to reshape how air emissions from new and existing facilities are evaluated. The goal is to expand the assessment of environmental impacts from a focus on specific projects to a broader view encompassing communities that historically have experienced elevated levels of pollution.

MassDEP is considering including environmental, public health, socioeconomic and climate indicators in its cumulative impact assessment framework. These indicators are essential for understanding the background ambient air quality, the unique vulnerabilities of surrounding communities, and the level of current pollution burdens the area near a facility is currently facing. Other issues being addressed include the appropriate approach for characterizing risks of increases in air emissions and revised permitting criteria like how to consider the results of a cumulative impact assessment (approve, approved with conditions, deny).

Designing a Cumulative Impact Assessment

States interested in integrating cumulative impact assessments into their permitting processes should strive to design processes that identify the cumulative impacts relevant to a specific permit decision.  They should also use the assessments to identify mitigation strategies to reduce potential environmental hazards before proceeding. Improving accessibility to relevant data sources and tools that can be used to complete an assessment and providing clear guidance and expectations on acceptable approaches and formats can help keep costs down for permit applicants.   

Environmental justice isn’t just a buzzword, it’s an issue that affects every state. While the EPA’s goals are admirable, states don’t have to wait for the agency to decide on an approach. Cumulative impact assessments can help identify these issues, and then generate the data needed to start taking a more holistic look at environmental justice issues within permitting processes.