Table of Contents
Cumulative Impacts Definitions, Indicators and Thresholds in the US
Tishman Environment and Design Center
May 24, 2022
I. Using this Tool
This document summarizes information about cumulative impacts found in federal and state legislation, government agency guidance documents, and selected journal articles from the academic literature. You can navigate this information by searching the table of contents on the left side of this page.Here you will find: (1) a timeline of federal and state CI legislation and agency documents, (2) a table with links to state CI legislation, (3) a table with links state CI reports and mapping tools, (4) three sections (state, federal and journals) with summary information about the methodologies, indicators, and thresholds used for determining cumulative impacts. In these sections you will also find information on the main purpose of the CI definition, tool, or guidance and web links to the source legislation and documents, along with supporting tables and images (if available).
The information contained in this tool is not exhaustive and thus does not include all possible definitions or methodologies related to cumulative impacts in use today or previously proposed. This data is meant as a representative snapshot of cumulative impacts, definitions, and methodologies in wide circulation.
If you have questions about this tool, please contact tedc@newschool.edu
Research Context
The issue of cumulative impacts (CI) has been a central focus of the environmental justice (EJ) movement for decades. Understanding CI requires consideration of the complex interplay between socio-demographic, environmental, and public health factors that impact EJ communities. EJ leaders and federal and state policymakers have increasingly turned their attention to developing CI definitions and methodologies for application in policies, agency guidance, and academic research. The information presented in this report is aimed at supporting EJ movement stakeholders and policymakers with a searchable site for definitions, indicators, thresholds, and benefits in various CI policies and reports developed in the U.S. from 1997-2022.
The research conducted shows that the definitions of CI have expanded to include more health disparities and socio-economic indicators, and that an increasing number of CI analysis reports, mapping tools, and policies have been released in the last decade. Most of these policies, tools, and agency guidance are intended to provide enhanced information and participation in decision-making processes. Some policies use these tools to allocate resources, such as funding or increased enforcement, while only a handful of policies aim to mitigate CI through permitting. Thirteen states (CA, HI ,IL, MA, MD, MI, MN, NJ, NM, NY, OR, VT, WA) were identified that have legislation, mapping tools, and/or agency guidance documents that include consideration of CI. Since 2012, CI bills have been enacted in California, New York, New Jersey, and Washington. However, the progress on the enactment of protective legislation has not been as rapid as the development of mapping tools and the increasing comprehensiveness of indicators. The enactment of protective legislation that addresses regulatory reform and substantive decision-making processes are necessary for addressing the legacy of cumulative impacts – yet these policies face significant legal and industry opposition. Key to the success of these policies is the leadership of EJ communities in the development of tools and legislation, including the processes for determining CI indicators and methodologies specific to their communities.
II. Purpose of Legislation Categories Glossary
The summary of CI legislation and reports in this tool includes information about their purpose, classified following Ringquist’s policy typologies: (1) redistributive, (2) protective, and (3) environmental/analytical. We include here a brief explanation of these categories. These typologies are a simplification of complex policies that can have multiple or overlapping purposes. The categories serve as a very general way to group policies for summary purposes according to their most prominent features.
Redistributve
Goal is to target investments, resources (i.e., enforcement actions, funding, etc.)Protective
Goal is to enact new or added protections through decision making powers of agencies (i.e. enhanced public participation, regulatory permitting, siting, etc.)Environmental
Goal is to promote further studies, increase analytic understanding of EJ related issues or concerns (i.e. mapping or modeling of risk, etc.)
These categories are based on the policy typologies described in Ringquist, E. J., & Clark, D. H. (2002). Issue definition and the politics of state environmental justice policy adoption. International Journal of Public Administration, 25(2-3), 351-389.
III. Timeline
A timeline of federal and state CI legislation and agency reports, as well as academic articles is included here. It is organized from oldest to most recent, with the purpose of aiding the understanding and analyzing the evolution in the past two decades of CI policies in the US. A full description of the legislation, reports and articles listed here can be found by clicking on each title to navigate to the Federal/State/Journal Definitions, Indicators, and Thresholds sections.
A. Federal
1997
1. Environmental Justice Guidance
Under the National Environmental Policy Act (NEPA)
In light of Executive Order 12898 (1994 - Federal Actions to Address
Environmental Justice in Minority Populations and Low-Income
Populations) the CEQ issued this guidance that includes six principles
for environmental justice analyses to determine any disproportionately
high and adverse human health or environmental effects to low-income,
minority, and tribal populations.
2. Considering Cumulative Effects
Under the National Environmental Policy Act (NEPA)
The Council on Environmental Quality (CEQ) regulations implement the
procedural provisions of NEPA, which defines cumulative effects. This is
a handbook providing a framework for advancing environmental impact
analysis by addressing cumulative effects in either an environmental
assessment or environmental impact statement.
3. EPA Guidance on Cumulative Risk
Assessment, Part 1.
Planning and Scoping, Science Policy Council, U.S. Environmental
Protection Agency Guidance initially focuses (Part 1.) on risk
assessments that integrates risks of adverse health and ecological
effects from the narrower set of environmental stressors.
1999
1. Consideration Of Cumulative Impacts
In EPA Review of NEPA Documents - U.S. Environmental Protection Agency,
Office of Federal Activities (2252A) EPA 315-R-99-002.
Guidance is to assist EPA reviewers of NEPA documents with an emphasis
on the effects of projects on ecological resources, specific issues, and
critical areas of EPA’s review of NEPA documents under Section 309 of
the Clean Air Act. This guidance offers practical suggestions on how to
prepare comments to address cumulative impacts in NEPA documents.
2003
1. EPA Framework for Cumulative Risk
Assessment (2003)
This framework for cumulative risk assessment emphasizes chemical risks
to human health in its discussion and also in the context of the effects
from a variety of stressors, including non-chemical stressors. Some
important topics that could be characterized as “cumulative risk,” such
as global climate change, are beyond the scope of this report. The
report provides a ‘flexible structure for the technical issues and
defines key terms associated with cumulative risk assessment.’
2004
1. National Environmental Justice
Advisory Council (NEJAC) - Ensuring Risk Reduction in Communities with
Multiple Stressors: Environmental Justice and Cumulative Risks/Impacts
(Report)
This report contains recommendations to the EPA that are not enforceable
but serve as a set of stakeholder comments for agency advisement and
consideration.
2016
1. EPA - Technical Guidance for
Assessing Environmental Justice in Regulatory Analysis
(Report)
This document identifies internal agency policies and recommended
procedures for EPA employees. The technical guidance presents key
analytic principles and definitions, best practices, and technical
questions to frame the consideration of environmental justice in
regulatory actions. It also includes recommendations that are designed
to enhance the consistency of our assessment of potential
environmental-justice concerns across all regulatory actions. This
document is not a rule or regulation but rather a guidance document
subject to ad hoc application on the agency.
2. Promising Practices For EJ
Methodologies in NEPA
This report reviews a compilation of methodologies gleaned from current
agency practices identified by the NEPA Committee concerning the
interface of environmental justice considerations through NEPA
processes.
It is not (and should not be viewed as) formal agency guidance;
practices exposed here are not legally binding, nor do they create
rights and benefits for any person.
2020
1. H.R.8271 - Environmental Justice
Legacy Pollution Cleanup Act of 2020
This act provides supplemental appropriations for the cleanup of legacy
pollution (including National Priority List sites, certain abandoned
coal mining sites, and formerly used defense sites), to replace lead
drinking water service lines, to provide grants under certain programs,
and to amend the Clean Air Act to prohibit the issuance of new major
source air pollution permits in overburdened communities, and for other
purposes.
2021
1. H.R.2021 - Environmental Justice
For All Act
This act aims to restore, reaffirm, and reconcile environmental justice
and civil rights, and other purposes.
2. S.2630 - Environmental Justice
Act of 2021
This act requires federal agencies to address environmental justice and
consider cumulative impacts in certain permitting decisions and for
other purposes. It reintroduces the S.2239 Environmental Justice Act of
2019.
2022
1. EJScreen 2.0
(Does not incllude a cumulative score.)
2. H.R 6548 Justice in Power Plant
Permitting Act
This act establishes new renewable energy federal purchase requirements,
supports the equitable transition to clean energy power generation, and
requires cumulative impact assessments for fossil fuel-fired power plant
permitting, and other purposes.
3. Cumulative Impacts: Recommendations
for ORD Research
This white paper informs the EPA Office of Research and Development’s
(ORD) FY23-26 Strategic Research Action Plans. The Cumulative Impacts
Scoping Workgroup was tasked to more fully understand how to grow ORD’s
existing cumulative impact research across the six National Research
Program Partners’ needs in the context of ORD’s FY23-FY26 research
planning process. The Workgroup synthesized in this report inputs from
multiple engagement events with ORD partners, both internal and
external, to the agency to identify research gaps and barriers to
conducting and translating the research, which formed the basis for the
workgroup’s recommendations.
B. State
2004
1. Massachusetts: Bill S.817: An Act to
Create Environmental Justice
2. New Mexico Environment Department
(NM ED): A Report on Environmental Justice in New Mexico
New Mexico Environment Department (NMED) conducted four listening
sessions in an effort to highlight environmental justice (EJ) concerns
in New Mexico. Listening sessions were designed to gather the EJ
viewpoint of grassroots organizations and were used to create this
report.
2008
1. Hawaii Environmental Justice
Initiative Report
To meet the requirements of Act 294, this report documents a definition
of EJ for Hawaii. This is an EJ guidance document that includes, among
other components, information on EJ screening analyses and community
benefits agreements, an overview of the legal foundations for EJ in
Hawaii, and recommendations for future EJ efforts in the state.
2. Minnesota: MPCA Cumulative Impact
Analysis Methodology (Webpage Description)
2009
1. New Jersey: Report: NJ DEP
STRATEGIES FOR ADDRESSING CUMULATIVE IMPACTS IN ENVIRONMENTAL JUSTICE
COMMUNITIES
This report reflects the research and findings of the subcommittee of
the EJ Advisory Council in NJ on cumulative impacts in NJ and their
recommendations to the State.
2. New Jersey: NJ Memorandum:
Cumulative Impacts in Permitting a Reply to Environmental Justice
Advisory Council March 2009 Report: “Strategies for Addressing
Cumulative Impacts in Environmental Justice Communities.”
This memorandum announces a preliminary
geographic-information-system-based screening tool that integrates
measures of environmental hazards and human exposures alongside
demographic and socioeconomic factors–as well as a list of EJ policies
and priorities.
Environmental regulation includes implementation in the following
divisions: Division of Solid and Hazardous Waste-Recycling, Division of
Air Quality - Diesel Program, Division of Air Quality - Air Quality and
Permitting.
2010
1. California: CalEPA Cumulative
Impacts: Building a Scientific Foundation Report
This report by OEHHA is a basis for further scientific evaluation and
technical discussion. It is not a regulatory action, but presents the
first step in developing a screening methodology to evaluate the CI of
multiple sources of pollution in specific communities or geographic
areas.
2012
1. New York: NYDEC - Part 487 Analyzing
Environmental Justice Issues in Siting of Major Electric Generating
Facilities Pursuant to Public Service Law Article 10
The purpose of this Part is to establish a regulatory framework for
undertaking an analysis of EJ issues associated with the siting of a
major Electric Generating Facility (EGF) in New York State pursuant to
article 10 of the Public Service Law, enacted in the Power NY Act of
2011. In addition it is intended to enhance public participation and
review of environmental impacts of proposed major electric generating
facilities in environmental justice communities and reduce
disproportionate environmental impacts in overburdened communities. It
is not intended to, nor shall it be construed to create any right to
judicial review involving the compliance or noncompliance of any person
with this Part.
2014
1. Maryland: SB 706.
This environment permit determinations cumulative impact assessment
requires the Department of the Environment to require a specified
applicant to conduct and submit to the Department a cumulative impact
assessment before the Department prepares a tentative determination on a
specified permit application. It requires a cumulative impact assessment
to address the likely impact on the environment and on human populations
that will result from specified incremental impacts.
2015
1. Minnesota: Minnesota Pollution
Control Agency: Environmental Justice Framework
This framework provides direction and guidance to modify MPCA practices
and integrate EJ principles into MPCA work over the next 2-3
years.
2. Maryland: SB 693. Environment - Ambient Air Quality
Control - Cumulative Air Impact Analysis
This legislation prohibits the Department of the Environment from
issuing a specified air quality permit until specified requirements have
been met. It prohibits the Department from recommending specified
licensing conditions until specified requirements have been met, and it
requires the Department to conduct a Cumulative Air Impact Analysis
under specified circumstances in accordance with specified requirements,
etc.
2016
1. New Jersey: Environmental Justice and
Cumulative Impact Ordinance
This ordinance amends the City of Newark Municipal Code to include the
requirements which assist the Environmental Commission, Newark Central
Planning Board, and Zoning Board of Adjustment in better understanding
the environmental impacts of development projects, and support improved
long-term planning in order to enhance, protect and preserve a healthy
urban environment for the benefit of all present and future residents
and workers.
2. California: SB-1000 An act to amend Section 65302 of the
Government Code, relating to land use.
This act requires local governments to identify environmental justice
communities (called “disadvantaged communities”) in their jurisdictions
and address environmental justice in their general plans through an
environmental justice element or related policies in other elements.
This new law has several purposes, including to facilitate transparency
and public engagement in local governments’ planning and decision-making
processes, reduce harmful pollutants and the associated health risks in
environmental justice communities, and promote equitable access to
health-inducing benefits, such as healthy food options, housing, public
facilities, and recreation.
3. California: AB-1550. An act to amend Section 39713 of
the Health and Safety Code, relating to greenhouse gases
This act modifies the investment minimums to disadvantaged communities
and increases percentage of funds directed–at least 25 percent–that
should go to projects within and for the benefit of disadvantaged
communities and at least an additional 10 percent to go for low-income
households or communities.
4. Oregon: State of Oregon Environmental Justice Task
Force Environmental Justice: Best Practices for Oregon’s Natural
Resource Agencies (2016)
The purpose of the handbook is to provide specific tools and approaches
to better identify potential disparate impacts and engage in
intentional, targeted outreach to all stakeholders to ensure equitable
outcomes and equal opportunity for meaningful participation.
2018
1. Michigan: Michigan EJ Work
Group Report (2018)
This report makes recommendations submitted to the Governor for
consideration that present an implementation roadmap of short, medium,
and long-term actionable tasks that meaningfully and effectively advance
EJ across Michigan and its communities.
2019
1. California: SB 673 An act to add
Sections 25200.21 and 25200.23 to the Health and Safety Code, relating
to hazardous waste.
This legistlation enhanced regulations to hazardous waste facilities to
include analysis of CI/impacts on vulnerable populations.
2. New York: S6599. Climate Leadership and Community
Protection Act
This Act amends the environmental conservation law, the public service
law, the public authorities law, the labor law, and the community risk
and resiliency act, to establish the New York State Climate Leadership
and Community Protection Act.
3. Washington: Washington Environmental Health Disparities
Map Project (2019)
The University of Washington Department of Environmental &
Occupational Health Sciences (DEOHS) collaborated with partners across
Washington to develop an interactive tool that ranks the cumulative risk
each neighborhood in Washington faces from environmental factors that
influence health outcomes.
2020
1. New Jersey: S.232 AN ACT concerning
environmental permits in certain areas, and supplementing Title 13 of
the Revised Statutes.
Under the bill, the DEP would not be able to grant permits to
new/expansions of facilities that cause or contribute to adverse
cumulative environmental or public health stressors in the overburdened
community that are higher than those borne by other communities within
the state, county, or other geographic unit of analysis.
2021
1. Massachusetts: S.2135 An Act relative
to energy facilities siting reform to address environmental justice,
climate, and public health
This act proposes permitting regulations for energy facilities. These
include cumulative impact assessments and environmental justice impact
statements.
2. Hawaii: SB 1277 Environmental Justice, Mapping, Data
Collection This legislation establishes the environmental justice
mapping task force and an advisory council to develop high-quality data
relating to environmental justice concerns, identify environmental
justice communities, and devise a method to correct for racist and
unjust practices leading to historical and current environmental
injustices.
3. Minnesota: SF. 2127
This is a bill that provides for environmental justice considerations in
determining certain state permitting. It amends Minnesota statutes 2020,
sections 116.06, by adding subdivisions; 116.07, subdivision 6; and
proposing coding for new law in Minnesota Statutes, chapter 116.
It also amends state statutes to include consideration of cumulative
impact analyses, and adverse impacts to EJ communities for permitting of
emitting facilities, and adds language relating to the powers of the
Pollution Control Agency to ensure consideration of CI.
4. California: SB 673 Cumulative Impacts and Community
Vulnerability Draft Regulatory Framework
SB 673 directs the Department of Toxic Substances Control to update its
criteria to consider “the vulnerability of, and existing health risks
to, nearby populations” when deciding whether to issue new or modified
permits or permit renewals of hazardous waste facilities. This document
is an informal proposal for regulations that enable the Department to
“implement, interpret, or make specific” provisions of Health and Safety
Code sections 25200.21(b) and (c) in SB 673.
6. Washington: SB5141 The Healthy
Environment for All Act
This is an Act relating to reducing environmental and health disparities
and improving the health of all Washington State residents by
implementing the recommendations of the environmental justice task
force. The act seeks to prevent and mitigate cumulative environmental
health impacts and to reduce exposure to environmental hazards within
Indian country.
7. Illinois: HB4093.
The EPA Environmental Justice Amends the Environmental Protection Act
requires EPA to annually update the indicators used to determine whether
a community is designated as an environmental justice community. It
requires Environmental Justice Assessment for permit applications, and
it contains provisions regarding public participation requirements for
permitting transactions in an environmental justice community.
8. Maryland (Journal Article): Payne-Sturges, D. C.,
Sangaramoorthy, T., & Mittmann, H. (2021). Framing Environmental
Health Decision-Making: The Struggle over Cumulative Impacts Policy.
International journal of environmental research and public health,
18(8), 3947.
Thi article examins the social context of policy challenges related to
cumulative risks and impacts in the state of Maryland between 2014 and
2016. Findings illustrate that policy impasse over cumulative impacts is
highly dependent on how policy-relevant actors come to frame issues
around legislating cumulative impacts, rather than the “standard
narrative” of external constraints. Findings show that the emphasis of
development of analytical tools to measure CI has led to a ‘paralysis of
analysis,’ where the process of attempting to assess risk significantly
slows down or even prevents government interventions.
2022
This is a response to Bill S6599 (above). The Environmental Justice working group and state agencies were tasked with establishing criteria to identify ‘disadvantaged communities.’ In Feb 2022, the working group voted unanimously to move forward with its proposal for how to identify disadvantaged communities. March 9, 2022, marks the beginning of a 120-day public comment period for New Yorkers to provide feedback on the draft before the criteria is finalized. A draft of Disadvantaged Communities Map is also available for public comment.
Subdivision 2 of section 8-0113 of the environmental conservation law
is amended by adding a new paragraph that includes cumulative health
effects analysis in required burden reports for permitting.
3. Maryland: SB. 528 - An Act concerning Climate Solutions
Now Act of 2022
The Act calls for Maryland to reduce greenhouse gases (GHG) by 60% (compared to a 2006 baseline) by 2031 and for the Maryland economy to reach net-zero emissions by 2045. Threaded throughout the Act are provisions designed to reduce impacts on overburdened communities. For the first time, definitions are provided for those terms. The Act requires the Commission on Environmental Justice to establish goals for the percentage of state funding that will be used for these communities and to develop strategies for reducing GHG and co-pollutant emissions in those communities.
4. Vermont: SB.148 - An act relating to environmental
justice in Vermont
This bill proposes to establish an environmental justice policy for the State of Vermont and require the state agencies to incorporate environmental justice into their work. It would establish the Advisory Council on Environmental Justice within the Agency of Natural Resources to advise the state on environmental justice issues. It also would require the creation of an environmental justice mapping tool.
IV. Table: State Legislation Status
This table lists the title and status of all state CI legislation included in this tool. You can click on a title to navigate to a complete description of any piece of legislation. “Enacted” refers to any legislation that was made law, while “Introduced” refers to legislation that has not been adopted. In some cases the legislative body may have passed the bill in both chambers but it awaits the Governor’s signature, or sometimes the bill is introduced but never gets passed committees, etc…
Click on a title to navigate to a complete description any piece of legislation.
| State | Title | Status |
|---|---|---|
| California | SB-1000 | Enacted (2018) |
| AB-1550 | Enacted (2016) | |
| SB 673 | Enacted (2019) | |
| Hawaii | SB 1277 | Introduced(2021) |
| Illinois | HB4093 | Reintroduced (2021) |
| Maryland | SB 706 | Not Reintroduced (2014) |
| SB 693 | Not Reintroduced (2015) | |
| SB. 528 | Enacted (2022) | |
| Massachusetts | Bill S.817 | Not Reintroduced (2004) |
| S.2135 | Introduced (2021) | |
| Minnesota | SF. 2127 | Introduced (2021) |
| New Jersey | Environmental Justice and Cumulative Impact Ordinance | Enacted (2016) |
| S.232 | Enacted (2020) | |
| New York | NYDEC-Part 487 | Enacted (2012) |
| S6599 | Enacted (2019) | |
| S.1031C | Passed (2022) | |
| Vermont | SB.148 | Introduced (pending amendments) (2022) |
| Washington | SB5141 | (2019) |
V. Table: State Reports and Tools
This table includes a list of all the state reports and mapping tools included in this document. You can click on a title to navigate to a complete description of any report and mapping tool.
Click on a title to navigate to a complete description any report or tool.
VII. State Definitions, Indicators and Thresholds
This section contains the definitions of CI found on state policies and or reports (see Type subtitle), as well as the indicators, thresholds, and threshold calculations used for determining CI that are outlined in these policies/reports. The policies are organized by state, and chronologically for each state.
A. Bill S.817: An Act to Create Environmental Justice
Authority: The Senate of Massachusetts
State: Massachusetts
Type: Legislation
Status: Not Reintroduced
Year: 2004
Definition:
Cumulative Impact is not defined. However, Section 5b, Notice to the
Department, states the department may designate areas near vulnerable
populations where certain projects, or the cumulative impact of
projects, require notice to the department when an environmental
notification is not required.
“Communities Health Index” is a cumulative evaluation of the health of communities based on health outcome indicators that ranks communities based on their health status so as to identify communities whose residents suffer disproportionately high rates of disease and premature death.
“Health Impact Assessment,” or “HIA,” is a combination of procedures, methods, and tools by which a regulation, program, or other project is assessed as to its potential effects on the health of a population, and the distribution of those effects within the population. A HIA evaluates the potential health effects of a project before it is built or implemented. HIA encompasses a heterogeneous array of qualitative and quantitative methods and tools to focus on health impacts and outcomes. Health impacts and outcomes are the overall effects of a regulation, program, or other project, directly and indirectly, on the health of a population.
Social/Environmental Indicators:
A “most vulnerable community” is a community identified in the
communities health index (CHI) as being in the percentile of having the
worst health outcomes.
The Community Health Index (CHI) are based off of the following primary and secondary indicators for a most vulnerable community:
Primary indicators: total age adjusted mortality, total age adjusted emergency room visits, elevated blood lead levels in children age 13 and younger, asthma and asthma-related hospital admissions or prevalence in children age 14 and younger, and infant mortality
Secondary indicators: total age adjusted non-congenital cardiovascular disease and stroke morbidity, total age adjusted heart attack hospitalizations, total age adjusted stroke and stroke-related hospitalizations, and bronchitis and bronchitis-related hospitalizations in children age 14 and younger and adults age 65 and older
Other indicators: other health outcome indicators, and environmental indicators (such as elevated levels of particulate matter in the air)
Thresholds:
Community Health Index Thresholds
A community in the top 50th percentile of the index for poor health
outcomes is determined to have the worst health outcomes and deemed to
be most vulnerable. The department may adjust the percentile up or down
by no more than 10% to identify the communities with the worst health
outcomes in the commonwealth.
As part of the expedited and Enhanced Massachusetts Environmental Policy Act Review included in Bill S.817 the following actions shall be taken by the secretary of environmental affairs:
Develop enhanced public participation for any project that requires an environmental notification for air, solid and hazardous waste, other than remediation projects, or wastewater and sewage sludge treatment and disposal, if
- located within 1 mile of a MVC or projects exceeding said threshold
for air
- is gauged within 5 miles of a most vulnerable community (MVC)
- and require enhanced analysis of impacts and mitigation in the scope
of an environmental impact report required by sections 62A or 62B of
chapter 30 of the Massachusetts Environmental Policy Act (if located
within 1 mi of MVC)
- or in the case of projects exceeding a mandatory threshold for air, within 5 miles of MVC
Threshold Calculations:
The department shall adopt regulations to implement the community health
disparities program and create a Community Health Index (p.4 line
56-58). Threshold values will be based off of commonwealth rates (See
Section 4 of the Bill for Commonwealth Rate Thresholds).
For the purpose of creating community health index: • community shall include 10,000 residents, or less than will be clustered with contiguous municipalities to create a combined 10,000, and no more than 100,000 residents. • community shall not exceed 100,000 residents or department shall divide municipality into geographically contiguous communities (GCC) of 10,000 to 50,000 residents • department may divide municipalities of 50,000 - 100,000 into GCC of 10,000 to 50,000 residents if there are distinct differences in indicators within areas of the municipality
Purpose/Application:
Environmental & Protective
Enhance participation plan, establish a community health disparities program, and create a communities health index
B. S.2135 An Act relative to energy facilities siting reform to address environmental justice, climate, and public health
Authority: Massachusetts State Senate
State: Massachusetts
Type: Legislation
Status: Introduced
Year: 2021
Definition:
The cumulative impact assessment seeks to demonstrate that there is no
adverse public health, environmental, or climate impact to the impacted
communities; it is consistent with the policies stated in section
sixty-nine H to provide a necessary energy supply for the commonwealth
with a minimum impact on the environment at lowest possible cost.
The environmental justice impact statement demonstrates a finding of
environmental and energy benefits to the impacted environmental justice
populations without any environmental or energy burden.
Social/Environmental Indicators:
A petition to construct a generating facility shall include: (i) a
description of the environmental impacts and the costs associated with
the mitigation, control, or reduction of the environmental impacts of
the proposed generating facility (ii) a description of the project
development and site selection process used in choosing the design and
location of the proposed generating facility (iii) either (a) evidence
that the expected emissions from the facility meet the technology
performance standard in effect at the time of filing, or (b) a
description of the environmental impacts, costs, and reliability of
other fossil fuel generating technologies (iv) an environmental justice
impact statement detailing all potential impacts to environmental
justice populations as defined in section 62 of chapter 30 (v) impacts
of the facility with respect to mitigating climate change (vi) plans for
the facility to adapt to a changing climate including current and future
flooding, storm surges, and sea level rise (vii) public health impacts
of the proposed facility (viii) a cumulative impact assessment that
considers an exposure, public health or environmental risk, or other
effect occurring in a specific geographical area, including from any
environmental pollution emitted or released routinely, accidentally, or
otherwise, from any source, and assessed based on the combined past,
present, and reasonably foreseeable emissions and discharges affecting
the geographical area
Thresholds:
No specific thresholds mentioned in bill text. There is currently (April
2022) a stakeholder engagement process going on for on incorporating
cumulative impact analysis (CIA) in its review of applications for
certain categories of air permits and approvals, that includes the
review of thresholds and methodologies.
Threshold Calculations:
No specific threshold calculations mentioned. Yet, as a method for
environmental justice impact statement, it is recommended to compare the
proposed site to other potential sites that do not impact environmental
justice populations.
Purpose/Application:
Protective
C. New Mexico Environment Department (NM ED): A Report on Environmental Justice in New Mexico
Authority: New Mexico Environment Department
State: New Mexico
Type: Report
Year: 2004
Definition:
CI are described as multiple sources of exposure to environmental
hazards in low income and people of color communities in which the roles
of multiple agencies should require an inter-agency response in
addressing the causes and factors that compromise environmental health
and quality of life in these communities.
The report recommends that NM laws/regulations should include assessments of CI for both existing and proposed facilities to accurately reflect impacts on public health and safety.
Social/Environmental Indicators:
Consider demographics, social impacts, secondary impacts, nuisance
impacts (e.g., noise, odor), impacts to cultural and traditional uses of
the impacted area; impacts to vulnerable populations, such as the ill,
children and the elderly; known future land uses; proper emergency
response, such as capacity of fire department; water quantity and
quality impacts of the facility
Thresholds:
No specific thresholds mentioned.
Threshold Calculations:
No specific threshold calculations mentioned.
Purpose/Application:
Environmental & Protective
As part of the NM EJ toolkit: encourage partners to undertake community
characterization projects and analysis; draft qualitative frameworks to
evaluate EJ (such as surveys, community impact statements, comparative
assessment, findings and recommendations); develop qualitative review
guidelines for environmental health, socio-economic, and other quality
of life indicators
Environmental Benefits Districts (EBD) are recommended and described. EDBs could achieve the following results: increased environmental protection via coordinated effort and attention; better assessment and evaluation of community concerns (i.e., characterizations of health, environment, quality of life); community-based planning; stabilization of neighborhoods, homes, and jobs; less programmatic and regulatory fragmentation; less contestations; comprehensive response to community concerns; improved economic development in communities; and enhanced quality of life through a vision of land-use and growth that encourages environmental protection and economic development which the community supports.
D. Hawaii Environmental Justice Initiative Report
State: Hawaii
Type: Report
Year: 2008
Definition:
Cumulative and indirect impacts can be determined by combining past,
present, and future impacts with the impacts of the proposed project.
The report notes that these impacts may affect the cultural, health, and
occupation-related aspects of underrepresented populations, discussed
further in the ‘Social and environmental indicators’ section.
The general definition of characterizing CI in terms of the chemical and
physical environment is also noted. Consideration of community
dependence on natural resources from the perspective of cultural values
in addition to economic base (tourism and/or agriculture) is
recommended. Some elements to support this point include:
What are the emotional and/or spiritual impacts on the fourth generation who has grown up in an environment surrounded by dumps?
Impacts are defined differently, depending on one’s perspective or cultural viewpoint. From a Western mindset, for example, the impacts are monetary–the cost will be passed down the line. From an indigenous perspective, the land is worth something.
Social/Environmental Indicators:
Some suggested cultural, health, and occupation-related factors
include:
- Diets, or differential patterns of consumption of natural resources,
which may suggest increased exposures to environmental pathways
presenting potential health risk
- Health data reflective of the community (e.g., abnormal cancer
rates, infant and childhood mortality, low birth weight, blood-lead
levels, asthma)
- Occupational exposures to environmental stresses, which may exceed
those experienced by the general population
- Sensitive populations that include the elderly, children, or
disabled
- Poverty as a leading indicator of income
- Clusters of illness as an indicator of EJ
Additional factors to inform indicators were mentioned, such as: air emissions, diversion of water/water rights, non-point source pollution, cesspools/septic systems and golf course chemicals that impact groundwater quality, over development of resorts, tourism marketing that is racist and exploits the culture, tourism that creates service jobs that do not pay high enough wages for residents to afford decent housing, diesel and gasoline in the water, etc.
Thresholds:
Low-income populations should be identified with the annual statistical
poverty thresholds from the Census Bureau’s Current Population reports,
Series P-60 on Income and Poverty.
Annual statistical poverty thresholds from the Bureau of the Census Current Population Reports, Series P-60 on income and poverty
Threshold Calculations:
No specific threshold calculations mentioned.
Purpose/Application:
Environmental & Protective
(Related to permitting, but this is only a guidance document)
Guidance on identifying EJ target populations and impacts, also an
outline for a community-involvement methodology is presented. Targeted
at ensuring that principles of environmental justice are systematically
included in all phases of the environmental review process (for
permitting).
Description of Graphic:
Example of CBA relationships during meetings for the neighborhoods
surrounding the proposed project to discuss its impact and determining
“give back”
E. SB 1277 Environmental Justice, Mapping, Data Collection
Authority: Sate of Hawaii Senate
State: Hawaii
Type: Legislation
Status: Introduced
Year: 2021
Definition: Cumulative impacts are referenced in the context of integrated demographic, public health, pollution and environmental effects vulnerabilities.
Social/Environmental Indicators:
The task force shall integrate indicators into the tools that fall into categories, including:
demographics, particularly relating to socioeconomic hardship and social stressors, such as race and ethnicity, income, unemployment, home ownership, rent burden, transportation, educational attainment, linguistic isolation, energy insecurity, food insecurity, and health insurance status
public health, particularly data that are indicative of sensitive populations, such as rates of asthma, rates of cardiovascular disease, child leukemia or other cancers that correlate with environmental hazards, low birth weight, maternal mortality, rates of lead poisoning, and rates of diabetes
Pollution burdens, such as those created by toxic chemicals, air pollutants, water pollutants, soil contaminants, and perfluoroalkyl and polyfluoroalkyl substances
Environmental effects, such as effects created by proximity to risk management plan sites, hazardous waste facilities, and sites on the national priorities list developed in accordance with section 105(a)(8)(B) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, 42 U.S.C. 9605(a)(8)(B); Task Force shall investigate how further indicators of vulnerability to the impacts of climate change, including proximity and exposure to sea level rise, wildfire smoke, flooding, drought, rising average temperatures, extreme storms, and extreme heat; and identify and consider the effects of other indicators relating to environmental justice, including:
Safe, sufficient, and affordable drinking water, sanitation, and stormwater services
Access to and the quality of green space and tree canopy cover, healthy food, affordable energy; transportation; reliable communication system, such as broadband internet, child care; high-quality public schools; and health care facilities
Length of commute
Indoor air quality in multi unit dwellings
Mental health
Labor market categories, particularly relating to essential workers
Each type of utility expense
Thresholds:
No specific thresholds mentioned.
Threshold Calculations:
This bill mentions that the mapping/methodology should (1) generate a
map and environmental justice score based on a subset of indicators,
particularly for the purpose of using the tool in addressing various
policy needs and investment goals and (2) account for conditions that
are not captured by the quantitative data used to develop maps and
environmental justice scores comprising the tool, by developing and
executing a plan to perform outreach to relevant communities; and
establishing a mechanism by which communities can self-identify as
environmental justice communities in the tool and that may include
citing qualitative data on conditions for which quantitative data are
lacking, such as cultural loss in native Hawaiian communities.
Purpose/Application: Environmental &
Protective
This bill seeks to establishment an environmental justice mapping task
force within the department of health. The task force, in consultation
with relevant stakeholders, shall establish an interactive, transparent,
integrated, and statewide tool for assessing and mapping environmental
justice communities based on the cumulative impacts of all indicators
selected by the task force to be integrated into the tool.
F. MPCA Cumulative Impact Analysis Methodology (Webpage Description)
Authority: Minnesota Pollution Control Agency (MPCA)
State: Minnesota
Type: Tool/Methodology
Year: 2008
Definition:
Cumulative impacts: exposures, public health or environmental effects
from the combined emissions and discharges in a geographic area,
including environmental pollution from all sources, whether single or
multi-media, routinely, accidentally, or otherwise released. Impacts
will take into account sensitive populations and socioeconomic factors,
where applicable and to the extent data are available (Cal EPA,
2012).
Cumulative risk assessment: the combination of risks posed by aggregate exposure to multiple agents or stressors (biological, chemical, physical, and psychosocial) in which aggregate exposure is exposure by all routes and pathways and from all sources of each given agent or stressor. The term “cumulative risk assessment” is defined as an analysis, characterization, and possible quantification of the combined risks to human health or the environment from multiple agents or stressors (U.S. EPA 2003).
Cumulative effects: the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (federal or non-federal) or person undertakes such other actions (National Environmental Policy Act)
Cumulative impact analysis as described by the MPCA is the investigation of outside factors that contribute to people’s health. These factors include multiple sources of pollution and other social conditions and stressors. In addition to investigating pollution and social stressors these differentials are considered for the higher burdens on some people and communities. Potential CI are analyzed when facilities and other emission-generating projects or rules are proposed that might affect pollution levels in an area.
Social/Environmental Indicators:
The MPCA’s analysis methods depend on the type of project and the
conditions in the community involved. A full CI analysis would include
all of the elements described below:
Sensitivity: the magnitude of response to a stimuli (e.g., standards based on sensitive life stages)
Additivity: the practice of summing impacts across many chemicals (e.g., multiple contaminants with similar effects)
Multiple pathways: people are exposed to environmental chemicals by breathing, eating, touching, etc. This element refers to the inclusion of more than one way people are exposed (e.g., total exposure via eating, drinking, swimming)
Multiple sources: the inclusion of more than one source of pollution (e.g., added effects of cars, factories, runoff)
Non-chemical stressors: physical or biological agents (i.e., non-chemical) that can cause an adverse impact. Examples might be radon (physical), noise (physical), or bacteria (biological) (e.g., impacts from noise, traffic, aesthetics)
Community vulnerability: a community’s ability to recover or repair. Health disparities are both an outcome of and a contributor to vulnerability in a community. Economic insecurity and fear of personal safety are also part of community vulnerability (e.g., greater susceptibility to pollution due to health care, housing, other challenges).
The environmental permitting processes assess one environmental medium (air, water, land) at a time. MPCA requires that (some facilities) use the Air Quality Index (AQI) developed by the U.S.EPA to report daily air quality conditions. Minnesota AQI numbers are determined by hourly measurements of the following five pollutants: fine particles (PM2.5), ground-level ozone (O3) sulfur dioxide (SO2), nitrogen dioxide (NO2), carbon monoxide (CO).
Note: Water quality, soil contamination, or community health is not included unless a larger environmental review analysis (e.g., an environmental assessment worksheet) is triggered.
Thresholds:
No specific thresholds mentioned.
Threshold Calculations:
Methods of analysis and steps are detailed in this Cumulative Levels and
Effects Analysis document. Steps include: (1) determining pollutant and
emission rates (2) computer calculates maximum air concentrations or
risks using an “air dispersion model” (3) determination of study area
(4) environmental health information included in the cumulative levels
and effects analysis–environmental health information includes health
vulnerability and pollution exposure indicators.
Purpose/Application: Protective
Description of Graphic:
The graphic (below) shows how each of the elements used by MPCA
(sensitivity, additivity, multiple pathways, etc…) ranges along three
spectrums: quantitative/qualitative analysis, data availability, and
level of MPCA influence.
G. Minnesota Pollution Control Agency: Environmental Justice Framework
Authority: Minnesota Pollution Control Agency (MPCA)
State: Minnesota
Type: Report/Framework
Year: 2015
Definition:
The MPCA considers cumulative impacts of pollutants as a way to provide
additional context for decision-making.
General description: The effects of multiple pollutant sources, multiple exposure pathways (where the exposure occurs and how: through inhalation, ingestion, or skin contact), and multiple contaminants with similar effects are regular considerations in many of MPCA’s environmental decision making processes. These factors are taken into account when developing standards, in air and water permitting, risk assessment, environmental review, and remediation activities.
Comprehensive risk assessment and CI analysis in areas of concern for EJ: determine if additional analysis of pollution from multiple sources and the evaluation of non-chemical stressors and community vulnerability will better inform decisions.
Social/Environmental Indicators:
Specific indicators for CI are not listed, however, the report notes
that MPCA did not commonly consider non-chemical stressors,
socioeconomic conditions, or differences in community vulnerability when
evaluating the cumulative impacts of a project. MPCA’s stated goal is to
consider more comprehensive risk assessment and cumulative impact
analysis and determine if additional analysis of pollution from multiple
sources and the evaluation of non-chemical stressors and community
vulnerability will better inform decisions.
These indicators are not used to directly determine CI, instead they are used to assess MPCA’s progress:
Pollution and health: the changes over time in environmental conditions, potential exposures, and effects. Possible indicators include: levels of key air pollutants (PM2.5, formaldehyde, ozone, nitrogen dioxide), predicted (modeled) health risks, emissions of criteria pollutants, asthma healthcare use rates and other respiratory disease, statewide and in areas of potential EJ concern and other environmental and health-related measures, to be determined.
Meaningful involvement: the activities and satisfaction of community members related to public participation and engagement with members of the environmental justice community. Possible indicators include: participation in community events and activities (number of meetings or community events that the MPCA attended or participated in, number of community members attending MPCA events or meetings, number of people from environmental justice communities routinely engaging in MPCA work).
Programmatic measures: progress made integrating EJ into the MPCA’s work. Possible indicators include: use of screening tools to determine if a project is in an area of concern for EJ, number/portion of MPCA programs that have developed and fully incorporated EJ strategies, creation and documentation of tools/guidance/procedures for addressing EJ in identified program areas to implement the strategies identified in this framework, number of staff trained in multicultural competency, and employee survey of attitudes.
Thresholds:
No specific thresholds mentioned.
Threshold Calculations:
No specific threshold calculations mentioned. However, there are
recommendations to develop data-driven screening methodology. Identify
data sources and procedures to provide information about possible
environmental justice concerns in a geographical area using demographic
and environmental variables. Variables provide information on race and
income levels, potential environmental exposures, number of facilities
and contamination sites in the surrounding area, and other factors to
characterize the potential burdens and vulnerabilities faced by
residents. Data sources should include other state agency data, county
and city data, and EPA-developed tools such as EJSCREEN.
Purpose/Application:
Environmental and Protective
Mapping risk by developing data-driven screening methodology,
increasing/enhancing public participation and creation of Environmental
Justice Advisory group and related programming
H. SF. 2127 A bill for an act relating to environment; providing for environmental justice considerations in determining certain state permitting.
Authority: Minnesota State Senate
State: Minnesota
Type: Legislation
Status: Introduced
Year: 2021
Definition:
Cumulative impacts means the potential public health and environmental
impacts from combined pollutant exposures and risks, incorporating the
context of community vulnerabilities, assessed from publicly accessible
data based on the past, present, and reasonably foreseeable future
levels, emissions, and discharges affecting the geographical area.
Social/Environmental Indicators:
Pollutant exposures and risks
Income (federal poverty level)
Race
Thresholds:
EJ area of concern thresholds: 40 percent of people reported income less
than 200 percent of the federal poverty level, wherein at least 45
percent of the people identify as people of color in the most recent
data from the United States Census Bureau–or that are in Indian country,
as defined in United States Code, title 18, section 1151.
Threshold Calculations:
No specific threshold calculations mentioned.
Purpose/Application:
Protective
I. Report: NJ DEP STRATEGIES FOR ADDRESSING CUMULATIVE IMPACTS IN ENVIRONMENTAL JUSTICE COMMUNITIES
Authority: Environmental Justice Advisory Council to the New Jersey Department Environmental Protection (Cumulative Impacts Subcommittee of the EJAC)
State: New Jersey
Type: Report
Year: 2009
Definition:
CI represent the reality of living in burdened communities where
socioeconomic, environmental, and health factors combine to create
deleterious effects on the most vulnerable populations in NJ (p.4).
There is no definitive model for assessing CI, so various studies were
pulled together to identify “vulnerable” and “burdened” communities as
“hot spots.”
“Cumulative” means growing by successive additions. This could mean additions over time, additional pollutants, additional sources of pollution, or additional routes of impact. The term could also be used to describe an individual’s integrated exposure to pollutants as he or she engages in daily activities and moves through successive microenvironments.
Authors use CalEPA’s definition of cumulative impact (see row for California Cumulative Impacts–CalEPA CalEnviroScreen).
Social/Environmental Indicators:
The recommendation from the working group is to use publicly available
data to define and then ID populations in NJ who are (a)
disproportionately burdened by pollution (b) especially vulnerable to
harm from pollutants because of their circumstances. The following
definitions of vulnerable and burdened population were provided:
* “Vulnerable populations” mean populations who may be more susceptible
to the adverse effects of exposures because they are infants, children,
women of childbearing age, elderly, ailing, of low income, or subject to
socioeconomic stressors such as occupation, race, ethnicity and other
aspects of the ““social determinants of health”” as defined by the World
Health Organization.
- “Burdened populations” mean populations who are disproportionately subjected to multiple stressors (e.g., diesel soot, ground-level ozone, lead, brownfields, pesticides, mold, contaminants in drinking water, and other toxic exposures).
Because this is a compilation of studies, various indicators were named in the recommendation. Dr. Faber defines quantitative and qualitative data to assess relative risk. These three categories of indicators are abbreviated below. The full chart of recommendations uses census tract data in the assessment of vulnerabilities such as: (1) pollution burden (2) health problems (3) social determinants of health (4) limited availability of prevention services (5) basic demographic information (full assessment found p. 19-20):
Category 1. Pollutants: lead in blood of children age six or younger; Resource Conservation & Recovery Act (RCRA) sites; Toxic Release Inventory (TRI) sites; U.S. EPA National Priorities List (NPL) sites; power plants; treatment, Storage & Disposal Facilities (TSDFs); Brownfields; known contaminated sites; municipal incinerators; resource recovery landfills; incinerator ash landfills; sewer service areas; dry cleaners; sewage treatment plants; gasoline stations; municipal solid waste landfills; trash transfer stations
Category 2. Health vulnerabilities including: total cancer incidence rate; death rate due to cancer; asthma; hospitalization rate; emergency department visits; chronic lower respiratory disease; carbon monoxide poisonings; all-cause mortality rate; coronary heart disease rate; low birth weight rate; infant mortality rate; birth defect rate; some measure of violence/crime
Category 3. Social vulnerabilities including: age of housing; proportion of population who are children, over age 60; poverty rate; median family income; racial and ethnic composition of population; unemployment rate; some measure of parks/recreational space
Morello-Frosch and Shenassa combined qualitative and quantitative indicators for assessing cumulative impacts such as:
Community-level stressors/buffers built environment, land use/zoning, traffic density, housing quality, social environment, civic engagement/political empowerment, poverty concentration, access to services, food security regulatory enforcement activities, neighborhood quality, social capital
Individual-level Stressors/Buffers Social support, Poverty/SES, Working Conditions, Health Care Access, Diet/Nutritional Status, Psycho-social Stress, Health Behaviors, Reproductive Events (12-13)
Thresholds:
The committee found there was no definitive model for assessing
cumulative impacts and recommended a hybrid model for defining
“Hotspots.” Some examples are provided here:
Census data with a variety of environmental data should be tested for both income and racially-based biases per geographic environmental variability, hazardous sites, and industrial facilities. This would allow the state to make initial determinations about the areas of greatest concern requiring immediate attention.
A composite measure of cumulative exposure to compare the relative overall risk of each community looks at the percentage of total population made up of people of color as a determinant of the racial composition of a community–then coded by Faber and Krieg as: (1) low minority, less than 5% people of color (2) moderately low minority, 5–14.99% (3) moderately high minority, 15–24.99% (4) high minority, 25% and greater. Points for rating severity of each facility or cite and detailed charts by Faber and Krieg, shown in a separate works (p. 278-279).
Other suggested models for CI thresholds by Morello-Frosch and Shenassa looked at three factors: hazard proximity and land use, health risk measures, and social vulnerability. The study combined estimated long-term annual average outdoor concentrations of 148 air toxics, or hazardous air pollutants (HAP concentrations from mobile, industrial manufacturing and small sources were included) with demographic and land use information. They combined modeled concentration estimates with cancer toxicity information to derive estimates of lifetime cancer risks and analyzed their distribution among populations in the region.
Threshold Calculations:
The Report recommended using Dr. Faber’s point system to rank cumulative
exposures:
Faber and Krieg developed a point system to rank cumulative exposures from multiple media and sources for every municipality in the state, including smaller neighborhoods within larger cities. The study also controls for the intensity of hazards in each community by accounting for the area across which hazards are distributed per square mile and town to determine most intensively overburdened communities. (Source: Faber and Krieg)
Morello-Forch used data to create composite maps of two regions, including six air basins where people are exposed in Southern California. They calculated ranked scores for each of the indicators in these three categories on a scale from 1 to 4 and then added them together and ranked into a score ranging from 1 to 6 with 6 representing the highest relative levels of impact.
Purpose/Application:
Environmental/Protective
Description of Graphic: P. 10 of the report cites the work by Faber and Craig “Unequal Exposure to Ecological Hazards: EJ in the Commonwealth of Massachusetts”–the image below is from the Faber and Craig report, which describes the social and geographic distribution of ecological hazards across 368 communities in the Commonwealth of Massachusetts. This combines census data with a variety of environmental data, identification and testing of both income-based and racially-based biases to the geographic distribution of 17 different types of environmentally hazardous sites and industrial facilities.
Used a point system as a means for measuring and ranking cumulative exposures and a way to composite measure of cumulative exposure
Used to compare the relative overall risks characteristic of each community
Study controls for the intensity of hazards in each community by accounting for the area across which hazards are distributed
Findings indicate ecologically hazardous sites and facilities are disproportionately located and concentrated in communities of color and working-class communities.
J. NJ Memorandum: Cumulative Impacts in Permitting
Authority: New Jersey Department of Environmental Protection
State: New Jersey
Type: Memorandum
Year: 2009
Definition:
Cumulative impacts (CI) is not directly defined. However, the memorandum
states that cumulative exposure to pollution from multiple sources
creates a disproportionate impact on the health, well-being, and quality
of life of persons living in some minority and poor communities in New
Jersey.
Social/Environmental Indicators:
The preliminary geographic information system-based screening tool
integrates measures of environmental hazards and human exposures
alongside demographic and socioeconomic factors to identify
Environmental Justice Communities of Concern, but indicators are not
explicitly mentioned in the memo. The NJ Department of Human Services
(DHSS) and academics continue to improve the GIS-based screening tool by
incorporating additional indicators of environmental concern and
vulnerability as these data become available.
Key issues for the state to address include:
Cumulative public health impacts from multiple sources of exposure including environmental contamination, personal life choices, and occupational sources
Local land use decision-making that may perpetuate the existence of environmentally burdened communities into the future
Challenges to education and access to economic opportunities
Equal access to proper health care
Meaningful public participation and access to decision makers by impacted communities
Thresholds:
No specific thresholds mentioned.
Threshold Calculations: No specific threshold calculations mentioned.
Purpose/Application: Environmental &
Redistributive
This screening tool was developed to identify communities of
concern.
The Policy Planning and Science section notes the following benefits and
co-benefits:
Part of DEP’s efforts to meet GHG reduction goals statewide, and these set priorities for policies should have additional benefits for communities that are most affected by environmental pollution (i.e., urban tree planting not only helps to sequester CO2 but it also reduces urban heat island effect and contributes to urban quality of life).
Proceeds from RGGI auctions should be used to fund projects at the municipal and county level that result in integrated land use/transportation planning and adoption of related ordinances that reflect the statewide GHG limits. NJDEP rule making allows the Department to assign extra points for projects that will provide co-benefits to the State. Extra points will be awarded to applications for projects located in EJCOCs.
Description of Graphic:
No tables or scores provided.
GIS-based screening tool was created with additional indicators of EJ concern, health data available through states public website, ICC multimedia screening risk assessment models to determine priorities for risk reduction.
K. Environmental Justice and Cumulative Impact Ordinance
Authority: City of Newark
State: New Jersey
Type: Legislation
Year: 2016
Definition:
In this ordinance, ‘cumulative impacts’ is used to refer to
environmental cumulative impacts: the combined total effect of many
sources of pollution, from stationary sources such as power plants to
mobile sources such as cars and trucks creates a cumulative impact that
may be more harmful to human health than the impact of any one source of
pollution in isolation.
“This document shall provide information to be used by the Newark Environmental Commission, City staff and members of the Central Planning Board and Zoning Board of Adjustment to improve public understanding of the potential cumulative environmental impacts of proposed development and provide a basis for more informed policy decisions on municipal land use.”
Social/Environmental Indicators:
Permit Applicant shall provide information for the categories below
(only if a permit is involved for the category):
Air Pollution: chart listing tons per year of all criteria pollutants and hazardous air pollutants to be emitted as a result of project operation
Stormwater Retention and Discharge: brief narrative summary of onsite storm water capture including total volume to be controlled; brief narrative summary of permitted sewer and storm water discharge including total volume to be discharged
Hazardous and Toxic Materials: list including name and estimated quantity of any substance used or stored onsite that must be registered with either the state or a local emergency responder office pursuant to state or federal law, such as the Toxic’s Release Inventory or the New Jersey Worker and Community Right to Know Act, N.J.S.A.34:5A1t seq
State whether an emergency management plan has been filed with the City’s Office of Emergency ManagementTruck Trips: estimated number of truck trips per day anticipated during normal operations; indicate if trucks will be owned or contracted
Fuel Use: list type of fuel to be used for heating, cooling, and operations (e.g., Number 4 or 6 Heating Oil; Natural Gas, Solar or Wind)
Waste & Recycling: provide copy of applicable waste permit or application, if applicable and available; brief narrative description of plan for compliance with City of Newark Recycling Ordinance Title XV, Chapter 12
Nuisance Issues: provide a brief description of both projected impact of and plans to avoid, minimize, and control the following: dust, noise, light, and odors
Thresholds:
No specific thresholds mentioned.
Threshold Calculations:
No specific threshold calculations mentioned.
Purpose/Application: Protective
L. S.232 AN ACT concerning environmental permits in certain areas, and supplementing Title 13 of the Revised Statutes
Authority: The Senate and General Assembly of the State of New Jersey
State: New Jersey
Type: Legislation
Year: 2020
Definition:
CI definition mentioned refers to: “Using the publicly-available data
(including NJDEP’s EJ mapping tool), determine whether an Overburdened
Community is subject to adverse environmental and public health stressor
levels that are higher than the appropriate geographic point of
comparison”
Environmental or public health stressors means sources of environmental pollution, including but not limited to: concentrated areas of air pollution, mobile sources of air pollution, contaminated sites, transfer stations or other solid waste facilities, recycling facilities, scrap yards; point-sources of water pollution, including but not limited to: water pollution from facilities or combined sewer overflows; conditions that may cause potential public health impacts, including but not limited to: asthma, cancer, elevated blood lead levels, cardiovascular disease, and developmental problems in the overburdened community
Social/Environmental Indicators:
Proposed Environmental & Public Health Stressors (from draft
rules)–page 40 of the document has a table of 31 stressors–this list has
been reduced to 26 indicators for the proposed rule: Ozone, PM 2.3,
Cancer Risk from Diesel, Cancer Risk excluding Diesel, NATA Non-Cancer
Risk, Permitted Air Sites, Traffic/Major Roadways, Truck Traffic,
Railways, (Warehouses/Goods Movement/Storage), Surface Water Quality,
Combined Sewer Overflows, All NJPDES Sites, Solid Waste Facilities,
Scrap Yards, Contaminated Sites, Soil Contamination, Groundwater
Restricted Areas, (Total Regulated Facilities under the EJ Law - changed
to Major facilities), Drinking Water Quality, Extraordinary Hazardous
Facilities, Age of Housing, Lack of Recreational Open Space, Lack of
Tree Canopy, Impervious Cover, Flooding, (Poverty), Unemployment,
Education, (Minority), (Limited English Proficiency)
Thresholds:
This legislation will deny a permit for a new facility upon a finding
that approval of the permit, as proposed, would, together with other
environmental or public health stressors affecting the overburdened
community, cause or contribute to adverse cumulative environmental or
public health stressors in the overburdened community that are higher
than those borne by other communities within the State, county, or other
geographic unit of analysis as determined by the department pursuant to
rule, regulation, or guidance adopted or issued pursuant to section 5 of
this act.
Overburdened community means any census block group, as determined in
accordance with the most recent United States Census, in which: (1) at
least 35 percent of the households qualify as low-income households (2)
at least 40 percent of the residents identify as minority or as members
of a State recognized tribal community (3) at least 40 percent of the
households have limited English proficiency.
Low-income household means a household that is at or below twice the
poverty threshold as that threshold is determined annually by the United
States Census Bureau.
Threshold Calculations:
The proposed rule requires the department to determine whether
environmental or public health stressors are ”higher than” those borne
by other communities within the state, county, or other geographic unit
of analysis as determined by the department. The rule determines if each
stressor in an Overburdened Community (OBC) is higher than the most
protective geographic point of comparison (State or County Non-OBC).
(“Higher than” means greater than the 50th percentile). Then sum the
number of stressors “higher than” geographic comparison for an OBC for
the Combined Stressor Total (CST). The rule determines if OBC’s CST is
higher than the most protective geographic point of comparison (State or
County Non-OBC) at the 50th percentile (second level of statistical
analysis. E.g.: If an OBC’s CST is 18 and its geographic point of
comparison is 15, that OBC is “higher” and is subject to “adverse
cumulative environmental or public health stressors that are higher
than” the geographic point of comparison. (Slide #50 in NJDEP
presentation on proposed rule, https://www.nj.gov/dep/ej/docs/ej-pres-20210624.pdf)
Purpose/Application:
Type: Protective/Regulatory
This act stipulates that the NJ Department of Environmental Protection
shall not grant a permit for a new facility, or for the expansion of an
existing facility, located in whole or in part in an overburdened
community unless the permit applicant first: (1) prepares an EJ impact
statement assessing the potential environmental and public health
stressors associated with the proposed new or expanded facility or
expansion of an existing facility and the environmental or public health
stressors already borne by the overburdened community as a result of
existing conditions located in or affecting the overburdened community
(cumulative), (2) transmits the report required to governing bodies and
the public (3) organizes and conducts a public hearing in the
overburdened community.
M. CalEPA Cumulative Impacts: Building a Scientific Foundation Report
Authority: California Office of Environmental Health Hazard Assessment (OEHHA) within CalEPA
State: California
Type: Report
Year: 2010
Definition:
CI means exposures, public health, or environmental effects from the
combined emissions and discharges, in a geographic area, including
environmental pollution from all sources, whether single or multimedia,
routinely, accidentally, or otherwise released. Impacts will take into
account sensitive populations and socio-economic factors, where
applicable and to the extent data is available.
A discussion of purpose behind selected calculation methods described in detail p. 27-28. As indicated in the formula below, the five scores are added and then multiplied to yield a final score representing the CI of multiple pollution sources in that community.
Cumulative Impact = [Exposures + Public health effects + Environmental effects] x [Sensitive populations + Socioeconomic factors]
Social/Environmental Indicators:
Table 2 of the report describes potential indicators for different
cumulative impact components. Below is a list of the components (bold)
and some selected indicators. Full table located in Appendix.
Socioeconomic Factors: percentage over age 24 with less than high school education, median household income (MHI), and percentage of residents below 2x national poverty level
Sensitive Populations: percentage under age 5 and percentage over age 65
Exposures: PM 2.5 concentrations (average of quarterly means), ozone concentrations (average of 8-hour monthly maximum), toxic releases from industrial facilities, traffic (vehicles per day), pesticide use (lbs/km^2)
Environmental Effects: hazardous waste and cleanup sites; presence of leaking underground; fuel tanks; impaired water bodies
Public Health Effects: low birth weight rate, heart disease mortality rate, cancer mortality rate, asthma hospitalization rate
Thresholds:
The California Environmental Quality Act (CEQA) thresholds of
significance (assessing risks and hazards) for new sources and receptors
adopted by the Air District (June 2010) are used to determine whether
the project under consideration may cause significant environmental
impacts (p. 65).
BAAQMD’s (Bay Area Air Quality Management District) Air Quality CEQA thresholds of significance for local risks and hazards are categorized under Pollutant, Construction-Related, and Operational-Related (Table 7).
Risks and Hazards for New Sources and Receptors (Individual Project) are the same as Operational Thresholds
Increased cancer risk of >10.0 in a million
Increased non-cancer risk of >1.0 Hazard Index (Chronic or Acute)
Ambient PM2.5 increase: >0.3 µg/m3
Zone of influence: 1,000-foot radius from property line of source or receptor
Risks and Hazards for new sources and receptors (Cumulative Threshold) are the same as operational thresholds
Increased cancer risk of >100.0 in a million (from all local sources)
Increased non-cancer risk of >10.0 Hazard Index (from all local sources (Chronic)
Ambient PM2.5 increase: >0.8 µg/m3 (from all local sources)
Zone of influence: 1,000-foot radius from property line of source or receptor
The Air District thresholds include thresholds for single source impacts and cumulative thresholds (multiple-source impacts) for both sources and receptors of pollution to assess and mitigate project level impacts.
Threshold Calculations:
Based on CEQA guidelines, outlined in Appendix D.
A desired emissions reduction is first calculated, and the threshold needed to reach this desired reduction is calculated by conducting a sensitivity analysis of the numeric GHG mass emissions.
Purpose/Application:
Environmental
Descriptions of Graphic:
The overall range of scores (6-120) had to be large enough to
distinguish communities. The range of 1 to 3 for socioeconomic factors
and sensitive populations scores was based on scientific evidence
suggesting that several-fold differences in response to environmental
pollutants exist for certain populations based on either socioeconomic
factors or biological traits.
N. SB-1000 An act to amend Section 65302 of the Government Code, relating to land use
Authority: California State Senate
State: California
Type: Legislation
Year: 2016
Definition:
Identify objectives and policies to reduce the unique or compounded
health risks in disadvantaged communities by means that include, but are
not limited to: the reduction of pollution exposure, including the
improvement of air quality, and the promotion of public facilities, food
access, safe and sanitary homes, and physical activity.
Social/Environmental Indicators:
Uses CalEnviroScreen 4.0 criteria.
Thresholds:
See CalEnviroScreen 4.0.
Threshold Calculations:
See CalEnviroScreen 4.0.
Purpose/Application:
Protective
Requires that cities and counties include EJ strategies when updating
general plans–-either through stand-alone environmental justice elements
or through policies embedded in other elements–-and these must address
the needs of disadvantaged communities. Also requires the engagement of
disadvantaged communities in the development of general plans.
O. AB-1550. An act to amend Section 39713 of the Health and Safety Code, relating to greenhouse gases
Authority: California State Senate
State: California
Type: Legislation
Year: 2016
Definition:
This amendment builds on the CA Health and Safety Code § 39711, which
defines “disadvantaged communities.” These communities are identified by
the California Environmental Protection Agency through CalEnviroScreen
4.0.
Social/Environmental Indicators:
Uses CalEnviroScreen 4.0 criteria.
Thresholds:
See CalEnviroScreen 4.0.
Threshold Calculations:
See CalEnviroScreen 4.0.
Purpose/Application:
Redistributive
This bill would instead require the investment plan to allocate (1) a
minimum of 25% of the available moneys in the fund to projects located
within, and benefiting individuals living in, disadvantaged communities
(2) an additional minimum of 5% to projects that benefit low-income
households or to projects located within, and benefiting individuals
living in low-income communities located anywhere in the state (3) an
additional minimum of 5% either to projects that benefit low-income
households that are outside of, but within a 1/2 mile of, disadvantaged
communities, or to projects located within the boundaries of, and
benefiting individuals living in, low-income communities that are
outside of, but within a 1/2 mile of, disadvantaged communities.
P. SB 673 An act to add Sections 25200.21 and 25200.23 to the Health and Safety Code, relating to hazardous waste
Authority: California State Senate
State: California
Type: Legislation
Year: 2019
Definition:
The understanding of CI is pegged to other indicators of community
vulnerability, to potential risks, and to health and well-being.
Social/Environmental Indicators:
General indicators mentioned in bill text include: risks to health and
well-being, and land use/exposure indicators such as minimum setback
distances from sensitive receptors like schools, child care facilities,
residences, hospitals, elder care facilities, and other sensitive
locations. Health Risk Assessments focused on cancer and non-cancer
toxicity criteria. See: Chapter 50, Article 1. Toxicity Criteria for
Human Health Risk Assessments, Screening Levels, and Remediation
Goals
Thresholds:
Toxicity criteria and thresholds for Health Risk Assessments can be
found in Section 69021: Appendix I. California OEHHA Toxicity
Criteria
Threshold Calculations:
Completion of Health Risk Assessment is considered for permitting.
Different methodologies are applied to different contaminants. There is
no calculation of cumulative score.
Purpose/Application:
Protective
The department shall adopt regulations establishing or updating criteria
used for the issuance of a new or modified permit or renewal of a
permit, which may include criteria for the denial or suspension of a
permit. To do this, the department shall: (a) establish transparent
standards and procedures for permitting decisions, including those that
are applicable to permit revocation and denial (b) establish terms and
conditions on permits to better protect public health and the
environment, including in imminent and substantial endangerment
situations (c) employ consistent procedures for reviewing permit
applications, integrating public input into those procedures, and making
timely permit decisions. (d) enhance public involvement using procedures
that provide for early identification and integration of public concerns
into permitting decisions, including concerns of communities identified
pursuant to Section 39711.
Q. SB 673 Cumulative Impacts and Community Vulnerability Draft Regulatory Framework
Authority: California State Senate
State: California
Type: Report/Framework
Year: 2021
Definition:
Understanding of Cumulative Impacts is pegged to other indicators of
community vulnerability and to potential risks to health and
well-being.
Social/Environmental Indicators:
General indicators mentioned in bill text include: risks to health and
well-being, and land use/exposure indicators such as minimum setback
distances from sensitive receptors like schools, child care facilities,
residences, hospitals, elder care facilities, and other sensitive
locations. Health risk assessments focused on cancer and non-cancer
toxicity criteria. See: Chapter 50, Article 1. Toxicity Criteria for
Human Health Risk Assessments, Screening Levels, and Remediation
Goals
Thresholds:
Toxicity criteria and thresholds for Health Risk Assessments can be
found in Section 69021: Appendix I. California OEHHA Toxicity
Criteria
Threshold Calculations:
Completion of Health Risk Assessment is considered for permitting.
Different methodologies are applied to different contaminants. There is
no calculation of cumulative score.
Purpose/Application:
Protective
The department shall adopt regulations establishing or updating criteria
used for the issuance of a new or modified permit or renewal of a
permit, which may include criteria for the denial or suspension of a
permit. To do this, the department shall: (a) establish transparent
standards and procedures for permitting decisions, including those that
are applicable to permit revocation and denial
(b) establish terms and conditions on permits to better protect public
health and the environment, including in imminent and substantial
endangerment situations
(c) employ consistent procedures for reviewing permit applications,
integrating public input into those procedures, and making timely permit
decisions
(d) enhance public involvement using procedures that provide for early
identification and integration of public concerns into permitting
decisions, including concerns of communities identified pursuant to
Section 39711
R. CalEnviroScreen 4.0 by OEHHA on behalf of the California Environmental Protection Agency (CalEPA tool)
Authority: California Office of Environmental Health Hazard Assessment (OEHHA) within CalEPA
State: California
Type: Tool/Methodology
Year: 2021
Definition:
CI definition is the same as CalEPA Cumulative Impacts Report 2010.
Social/Environmental Indicators:
CalEnviroScreen indicators fall into four broad categories which are
designed to measure a community’s cumulative impacts. One more exposure
indicator has been added since version 3.0.
8 Exposure Indicators:
Ozone concentrations in air
PM 2.5 concentrations in air
Diesel particulate matter emissions
Drinking water contaminants
Children’s lead risk from housing
Pesticide use
Toxic releases from facilities
Traffic density
5 Environmental Effects Indicators:
Toxic cleanup sites
Groundwater threats; underground storage site leakage and cleanups
Hazardous waste facilities and generators
Impaired water bodies
Solid waste sites and facilities
3 Sensitive Population Indicators–measure the number of people in a community who may be more severely affected by pollution because of age or health:
Asthma emergency department visits
Cardiovascular disease (emergency department visits for heart attacks)
Low birth-weight infants
5 Socioeconomic Indicators–conditions that may increase people’s stress or make healthy living difficult:
Educational attainment
Housing burdened low income households
Linguistic isolation
Poverty
Unemployment
Thresholds:
To find the CA census tracts (CTs) with the highest levels of cumulative
impacts, CalEnviroScreen scores all the CTs for each indicator and
calculates an overall score, then ranks the CTs with these scores.
CalEPA designates the highest scoring 25% of census tracts from
CalEnviroScreen as disadvantaged communities. Additionally, 22 census
tracts that score in the highest 5% of CalEnviroScreen’s Pollution
Burden, but do not have an overall CalEnviroScreen score because of
unreliable socioeconomic or health data, are also designated as
disadvantaged communities.
Threshold Calculations:
For the process of ranking CTs, each indicator is scored separately. The
overall CalEnviroScreen score is calculated by multiplying the Pollution
Burden and Population Characteristics scores:
CalEnviroScreen Score = Pollution Burden x Population Characteristics
Where pollution burden is determined using average of exposures and environmental effects indicators and population characteristics is determined using the average of sensitive populations and socioeconomic factors indicators.
Examples of how they are scored and how the combined CalEnviroScreen score is produced can be found in the CalEnviroScreen 3.0 report, page 19.
General organization of ranking:
The maximum CalEnviroScreen Score is 100.
The geographic areas are ordered from highest to lowest, based on their overall score.
A percentile for the overall score is then calculated from the ordered values.
Maps are developed showing the percentiles for all the census tracts of the state.
Maps are also developed highlighting the census tracts that score the highest.
Purpose/Application:
Environmental & Redistributive
This is a mapping/screening tool to help identify California communities that are disproportionately burdened by multiple sources of pollution.
Examples of Applications:
In 2012, the legislature passed Senate Bill 535, directing that 25% of proceeds from the Greenhouse Gas Reduction Fund (state cap and trade program selling GHG emissions allowances) go to projects that provide a benefit to disadvantaged communities. This legislation gave CalEPA responsibility for identifying those communities, which they defined as the top 25% scoring areas from CalEnviroScreen along with other areas with high amounts of pollution and low populations. For the purpose of SB 535, CalEPA developed a map of disadvantaged communities based on this definition.
In 2016, the legislature passed AB 1550, which requires that 25% of proceeds from the fund be spent on projects located in disadvantaged communities.
S. NYDEC-Part 487 Analyzing Environmental Justice Issues in Siting of Major Electric Generating Facilities Pursuant to Public Service Law Article 10
Authority: NY Department of Environmental Conservation (NYDEC)
State: New York
Type: Legislation
Year: 2012
Definition:
Cumulative impacts (CI) are defined in the context of ‘Cumulative
Impacts Analysis of Air Quality.’ If the applicant is required to
complete an EJ analysis and if the proposed facility is an air emission
source, the applicant shall conduct a CI analysis of air quality in
accordance with an air modeling protocol. Here CI language refers to
combined effects of air pollutants and proximity to emitting
facilities/sources.
Social/Environmental Indicators:
The comprehensive demographic, economic, and physical descriptions of
the impact study area and the comparison areas shall accurately
represent the community character and environmental setting of each
area, including land use and zoning information, population densities,
income statistics, and environmental or physical conditions.
population, including total population and population density
racial and ethnic characteristics
income levels
physical conditions for example, public health, including available data on asthma and cancer, air quality, including national-scale air toxicity assessment data
any other information reasonably necessary to provide an accurate and complete representation of the demographic, economic, and physical characteristics of the impact study area and the comparison areas; extensive detail found under section 487.9 “Comprehensive demographic, economic and physical descriptions”
Thresholds:
CI analysis shall take into account the following air emission sources
from the proposed facility:
a designated facility located in the circular area extending from the EJAIA plus 10 kilometers (6 miles)
any major stationary source located in circumference extending from the EJAIA plus 10 kilometers (6 miles) not yet commenced operations but has a permit from the department 60 days prior to the date of the application
any other permitted stationary source located within the EJAIA that emits an air pollutant in an amount at or above the significant project thresholds
on a site-specific basis and at the department’s discretion, any air emission source that is located contiguous to the proposed facility Subpart 231-13 Tables and Emission Thresholds Official Compilation of Codes, Rules, and Regulations of the state of New York, as part of Title 6 Department of Environmental Conservation, Chapter III Air Resources, Subchapter A. Prevention and Control of Air Contamination and Air Pollution, Part 231 New Source Review for New and Modified Facilities. The following tables are provided:
major facility thresholds and offset ratios for ozone non-attainment areas and the ozone transport region
major facility thresholds and offset ratios for PM non-attainment areas
significant project thresholds, significant net emission increase thresholds, and offset ratios for ozone nonattainment areas and the ozone transport region.
significant project thresholds, significant net emission increase thresholds, and offset ratios for PM nonattainment areas.
major facility thresholds for attainment and unclassified areas.
significant project thresholds and significant net emission increase thresholds for attainment and unclassified areas
federal class I variance maximum allowable increase concentrations
maximum allowable increase in SO2 concentrations for gubernatorial variances
global warming potential values for calculating CO2 equivalents
Threshold Calculations:
Cumulative impact analysis of air quality: the total cumulative air
impacts for each of the applicable air pollutants are determined by
adding the impacts associated with such pollutants from: (1) the
proposed facility
(2) the other air emission sources identified in subdivision (d) of this
section
(3) reasonably available background air quality concentrations for each
applicable pollutant, in accordance with the applicant’s approved air
modeling protocol
The total cumulative air emissions impacts determined pursuant to subdivision (e) of this section shall be used by the applicant in accordance with its approved air modeling protocol to evaluate the significant and adverse environmental impacts of the proposed facility on the impact study area as required pursuant to section 487.9(d) of this part and to evaluate any significant and adverse disproportionate environmental impacts as required pursuant to section 487.10 of this part.
Purpose/Application:
Protective
The applicants to permits shall determine whether the impact study area contains one or more EJ areas. If the applicant is required to complete an EJ analysis and the proposed facility is an air emission source, the applicant shall conduct a cumulative impact analysis of air quality in accordance with an air modeling protocol approved by the department and consistent with the requirements of this section. Additional resource: DEC rules for including EJ in permitting.
This legislation will enhance public participation and the review of environmental impacts from proposed major electric generating facilities in EJ communities.
Description of Graphic:
As noted in analyzing EJ issues in siting of major EGF pursuant to
public service law article 10 any other permitted stationary source
located within the EJAIA that emits an air pollutant in an amount at or
above the significant project thresholds as defined in tables 4 and 6 of
6 NYCRR sections 231-13.4 and 231-13.6
Example of tables of emissions threshold: 231-13.4 Table 4—Significant project thresholds, significant net emission increase thresholds, and offset ratios for PM nonattainment areas
T. S6599. Climate Leadership and Community Protection Act
Authority: New York State Senate
State: New York
Type: Legislation
Year: 2019
Definition:
Greenhouse gas emission offset projects must consider the potential for
direct, indirect, and cumulative emission impacts from this mechanism,
including localized impacts in disadvantaged communities. (“Cumulative”
refers to the aggregated impacts of emissions.)
The act also refers to cumulative impacts of climate change in disadvantaged communities:
“Climate change especially heightens the vulnerability of disadvantaged communities, which bear environmental and socioeconomic burdens as well as legacies of racial and ethnic discrimination. The complexity of the ongoing energy transition, the uneven distribution of economic opportunity, and the disproportionate cumulative economic and environmental burdens on communities mean that there is a strong state interest in setting a floor statewide for labor standards.”
Social/Environmental Indicators:
There are no specific indicators mentioned in this bill. Yet, it is
stated that The Environmental Justice working group, in consultation
with the department of Environmental Protection, the departments of
health and labor, the New York State energy and research development
authority, and the environmental justice advisory group, will establish
criteria to identify disadvantaged communities for the purposes of
co-pollutant reductions, greenhouse gas emissions reductions, regulatory
impact statements, and the allocation of investments related to this
article (see row below).
Thresholds:
No specific thresholds is mentioned. The act states that the
Environmental Justice Working Group, in consultation with the
departments of Health and Labor, the New York State Energy and Research
Development Authority, and the Environmental Justice Advisory Group,
will establish criteria to identify disadvantaged communities and
thresholds.
Threshold Calculations:
No specific threshold calculations is mentioned. The Environmental
Justice Working Group “will meet no less than annually to review the
criteria and methods used to identify disadvantaged communities and may
modify such methods to incorporate new data and scientific
findings.”
Purpose/Application:
Protective & Redistributive
Creates an Environmental Justice/Just Transition Working Group that includes representatives from environmental justice communities and several state agencies
establishes that the Department of Environmental Conservation, in consultation with the climate justice working group, prepares a program demonstrating community air monitoring systems, and a strategy to reduce emissions in disadvantaged communities
directs benefits of clean energy program spending to front-line communities that have been historically burdened by pollution and/or are at high risk from the effects of climate change; 40% of the available programmatic resources shall be spent in disadvantaged communities; no less than 35% of the overall benefits of spending on clean energy and energy efficiency programs shall be spent on disadvantaged communities
allows for strictly defined offsets to reduce pollution beyond 85 percent by 2050, with guidelines that ensure the projects create permanent and verifiable pollution reductions, benefit New York directly, and do no harm to overburdened communities
U. Definition and Mapping of ‘Disadvantaged Communities’
Authority: New York Department of Environmental Conservation
State: New York
Type: Tool/Methodology
Year: 2022
Definition:
Based on the understanding of cumulative emission impacts in S.6599
(above)
Social/Environmental Indicators:
Settled on 45 different indicators
Environmental Burdens and Climate Change Risks:
potential pollution exposures: vehicle traffic density, diesel truck and bus traffic, PM2.5, Benzene concentration, waste water discharge
land use and facilities associated with historical discrimination or disinvestment: remediation sites, regulated management plan (chemical) sites, major oil storage facilities, power generation facilities, active landfills, municipal water combustors, scrap metal processors, industrial/manufacturing/mining land use (zoning), housing vacancy rate
potential climate change risks: extreme heat projections (>90 degree days in 2050, flooding in coastal and tide influenced areas (projected), flooding in inland areas (projected), low vegetation cover, agricultural land, driving time to hospitals or urgent/critical care
Population Characteristics and Health Vulnerabilities:
Income, Education & Employment: pct <80% area median income, pct <100% of federal poverty line, pct without Bachelor’s degree, unemployment rate, pct single-parent households
Race, Ethnicity & Language: percent latino/a or Hispanic, percent black or African American, percent Asian, percent Native American or indigenous, limited English proficiency, historical reading score
Health Impacts & Sensitivities: asthma ED visits, COPD ED visits, heart attack hospitalization, premature deaths, low birth weight, percent without health insurance, percent with disabilities, percent adults age 65+
Housing, Energy & Communications: percent renter-occupied homes, housing cost burden (rental costs), energy poverty/cost burden, manufactured homes, homes built before 1960, percent without internet
Officials from the New York State Energy Research and Development Authority and the Department of Environmental Conservation have proposed including Indigenous populations by automatically designating 19 census tracts that are either reservations or tribal-owned land recognized by the state.
Thresholds:
The DAC designation threshold is the percentile above which census
tracts are included in the draft DAC list, to achieve the overall goal
of designating 35% of the state as a draft DAC. A tract is designated as
a DAC if its Combined Score Percentile Rank is greater than 73.6. A
Combined Score Percentile Rank of 73.6 or greater would indicate that
the census tract’s Combined Score is within the top 27.4% of all tracts
across the state or within the tract’s region. A tract considered to be
Low Population are designated as a DAC if its Burden Score Percentile
Rank is greater than 73.6. A Burden Score Percentile Rank of 73.6 or
greater would indicate that the Low Population Area census tract’s
Burden Score is within the top 27.4% of all tracts across the state or
within the tract’s region (pg. 22 of Technical Documentation).
Threshold Calculations:
The percentile ranks of these indicators for each census tract were
combined to produce a value that measures a census tract’s score
relative level of Environmental Burdens and Climate Change Risks as well
as Population Characteristics and Health Vulnerabilities relative to
other tracts. Tracts with higher scores relative to (a) other tracts in
the State (b) their region (NYC or Rest of State) were identified as
DACs. Census tracts must rank relatively high in terms of both
“Environmental and Climate Change Burdens and Risks” and “Population
Characteristics and Health Vulnerabilities” (or very high on one of
these) to be identified as a DAC. Pursuant to the CLCPA, the criteria
includes an interactive map and a list of covered communities for
directing programs, economic development opportunities, and clean energy
investments. (See page 21 of Technical Documentation for more details on
calculations.)
Purpose/Application:
Environmental & Protective
Mapping/designation of ‘disadvantaged communities’
The intended use is for permitting regulation (see bill S.6599
above).
Description of Graphic:
DAC Designation Using Statewide and Regional Score Threshold
Reports: New York State Climate Justice Working Group
Draft Disadvantaged Communities Criteria and List Technical
Documentation (March, 2022)
V. S.1031C AN ACT to amend the environmental conservation law, in relation to the location of environmental facilities.
Authority: New York State Senate
State: New York
Type: Legislation
Year: 2022
Definition:
CI mentioned in the context of ‘Cumulative Health Effects’ of pollution:
“The existing burden report shall include baseline monitoring data
collected in the affected environmental justice community or
disadvantaged community within two years of the application for a permit
or approval; shall identify each existing pollution source or categories
of sources affecting the community and the potential routes of human
exposure to pollution from that source or categories of sources; the
potential or documented cumulative human health effects of such
pollution; and the potential or projected contribution of the proposed
action to existing pollution burdens in the community and potential
health effects of such contribution, taking into account existing
pollution burdens” (pg. 3).
Social/Environmental Indicators:
The burden report shall identify:
each existing pollution source or categories of sources affecting an environmental justice community or a disadvantaged community and the potential routes of human exposure to pollution from that source or categories of sources
ambient concentration of regulated air pollutants and regulated or unregulated toxic air pollutants
traffic volume
noise and odor levels
exposure or potential exposure to lead paint
exposure or potential exposure to contaminated drinking water supplies
proximity to solid or hazardous waste management facilities, wastewater treatment plants, hazardous waste sites, recycling facilities, waste transfer facilities and petroleum or chemical manufacturing, storage, treatment or disposal facilities
the potential or documented cumulative human health effects of the foregoing pollution sources
the potential or projected contribution of the proposed action to existing pollution burdens in the community and potential health effects of such contribution, taking into account existing pollution burdens
Thresholds:
“Minority community” shall mean any census tract, census block, or
census block group that includes twenty-five percent or more of any
ethnic group. “Economically distressed area” shall mean an area
characterized by a poverty rate of at least twenty percent or an
unemployment rate of at least one hundred twenty-five percent of the
statewide unemployment rate.
Threshold Calculations:
No specific threshold calculations mentioned.
Purpose/Application:
Protective
All agencies (or applicant as hereinafter provided) shall prepare or
cause to be prepared by contract or otherwise an environmental impact
statement on any action they propose or approve which may have a
significant effect on the environment,including a burden report which
“shall include baseline monitoring data collected in the affected
environmental justice community or disadvantaged community within two
years of the application for a permit or approval; shall identify each
existing pollution source or categories of sources affecting the
community and the potential routes of human exposure to pollution from
that source or categories of sources; the potential or documented
cumulative human health effects of such pollution; and the potential or
projected contribution of the proposed action to existing pollution
burdens in the community.”
No action shall be carried out or approved if it may cause or contribute to, either directly or indirectly, a disproportionate or inequitable or both disproportionate and inequitable pollution burden on an environmental justice community or a disadvantaged community.
W. SB 706. Environment - Permit Determinations - Cumulative Impact Assessments
Authority: Maryland State Senate
State: Maryland
Type: Legislation
Year: 2014
Definition:
The Cumulative Impact Assessment addresses likely impact on the
environment and on human populations that will result from the
incremental impact of the proposed facility or activity authorized under
the permit when added to the impact of other past, present, and
reasonably foreseeable future past and present sources of pollution.
Social/Environmental Indicators:
Air quality, truck and automobile traffic, proximity to major highways,
public transportation and parkways
Thresholds:
The bill only applies when the proposed facility or activity authorized
under the permit would be located in an unincorporated community in
Prince George’s County that:
is bordered to the north by a US Highway and to the couth by a state highway
is within 2 miles of a parkway maintained by the National Park Service
is within 1 mile of a metro station
is within 1.5 miles of the District of Columbia
has experienced air quality alert days of dangerous air quality for sensitive populations
is located near several heavily trafficked state and county roads that carry both truck and automobile traffic
Threshold Calculations:
No specific threshold calculations mentioned.
Purpose/Application:
Protective
The Department of the Environment shall require the permit applicant to
conduct a Cumulative Impact assessment. On the basis of the Cumulative
Impact Assessment, the department shall make a determination to issue or
not a permit and/or to provide permit limitations or conditions to
mitigate the adverse impacts on the environment and human
populations.
X. SB 693. Environment - Ambient Air Quality Control - Cumulative Air Impact Analysis
Authority: Maryland State Senate
State: Maryland
Type: Legislation
Year: 2015
Definition:
The Cumulative Air Impact Analysis shall include six months of air
quality sampling according to the air quality sampling plan issued by
the department; determination of the air quality impacts of the expected
pollutant emissions from the proposed activity, including any mobile
source air emissions resulting from the proposed activity and the
current air pollutant load for similar pollutants in the immediate area;
and determination the potential health effects of any air quality
impacts.
Social/Environmental Indicators:
This bill only applies to “protected communities” defined by the
following indicators:
economic disadvantage by Medicaid enrollment
participation in SNAP, WIC and other public benefits
life expectancy
low birth weight
areas near schools, child care facilities, elder care facilities, community centers
Air Pollutants:
“If the permit involves PM, NOx or VOC air pollutants, the Department of
the Environment shall require the major source permit applicant to
conduct an air sampling plan for at least 12 months before the issuance
of a tentative determination on the permit or 6 months for a
non-major.”
Thresholds:
The Department shall identify factors that contribute to the negative
effects of cumulative impacts of pollution and other stressors on a
community, including traffic and asthma. This bill only applies to
“protected communities” defined as zip codes that:
have economic disadvantage by Medicaid enrollment rates above state median
participation in SNAP, WIC and other public benefits programs at rates above state median
poor health status by life expectancy below the median for the state
or percent of low birth weight above state median
or an area determined to be “protected” by the Department
AND areas that include schools, child care facilities, elder care facilities, community centers within 0.25 miles of nonmajor air quality permit applicant source OR Within 1 mile of a major air quality permit applicant source Air Quality Sampling Plan of any pollutant of concern, including any pollutant for which the potential to emit exceeds the major source threshold set by the Department and the Federal Clean Air Act
Threshold Calculations:
No specific threshold calculations mentioned.
Purpose/Application:
Protective
A Cumulative Air Impact Analysis is required to be conducted by the
Department of the Environment and reviewed by the Department of Health
Mental Hygiene before the Department of the Environment issues a permit.
The Department of the Environment and the Department of Health and
Mental Hygiene will conduct research to identify factors that contribute
to the negative effects of cumulative impacts of air pollution and other
stressors on a community; review state of the science for environmental
justice screening tools; review statewide health and demographic data;
and update all of these reviews every 5 years.
This bill only applies to “protected communities.” This bill calls for enhancement of public participation.
Y. SB. 528 - AN ACT concerning Climate Solutions Now Act of 2022
Authority: Maryland State Senate
State: Maryland
Type: Legislation
Year: 2022
Definition:
Commission on Environmental Justice and Sustainable Communities shall
use data sets and mapping tools to review and analyze the impact of
current state and local laws, permits, actions, and policies on the
issue of environmental justice and sustainable communities, including
cumulative impacts, effects, and exposure. (Terms not specifically
defined. Yet, in page 11, the term ‘cumulative’ is referenced
specifically in the context of pollution, mentioning the identification
of areas burdened by cumulative environmental pollution.)
Social/Environmental Indicators:
In evaluating methodologies for identifying communities
disproportionately affected by climate change and establishing
strategies to address climate justice plan, the department shall
consider geographic, public health, environmental hazard, and
socioeconomic criteria, including:
areas burdened by cumulative environmental pollution and other hazards that can lead to negative public health effects
areas with high concentrations of: (i) people experiencing poverty, high unemployment rates, high rent burdens, low levels of home ownership, or low levels of educational attainment, or (ii) populations that have historically experienced discrimination on the basis of race or ethnicity
areas that are vulnerable to the impacts of climate change, such as flooding, storm surges, and urban heat island effects, due to low levels of tree coverage, high levels of impervious surfaces,or other factors.
Thresholds:
No specific thresholds mentioned.
Threshold Calculations:
No specific threshold calculations mentioned.
Purpose/Application:
Protective & Redistributive
Creates the Climate Catlytic Fund
The purpose of the fund is to promote Environmental Justice and to
leverage increased private capital investment in technology development
and deployment. It creates an Environmental Justice (EJ) &
Sustainable Communities Commission to advice department and establish
methodologies for identifying disproportionately affected
communities–this includes analysis of CI. The act includes provisions
for increased public participation: in carrying out its responsibilities
under this section, the department shall solicit input from all segments
of the population that will be impacted by the policies developed under
subsection (a) of this section, including individuals living in areas
that may be identified as disproportionately affected.
Z. State of Oregon Environmental Justice Task Force Environmental Justice: Best Practices for Oregon’s Natural Resource Agencies (2016)
Authority: Multiple: State of Oregon Natural Resource Agencies
State: Oregon
Type: Report
Year: 2016
Definition:
Cumulative Impacts: Environmental regulations and risk assessment
policies tend to focus on single pollutants, single “bad actors,” and
single exposure pathways. Yet communities of color tend to be
disproportionately exposed to multiple pollutants, through multiple
pathways, from multiple sources, on top of existing background
pollution. While current agency practice is to address single pollutants
across a single medium, EJ communities often experience CI, from
multiple pollutants across multiple media, or due to existing pollution
levels. CI assessment offers the opportunity to consider both
quantitative and qualitative concerns. While agencies are adept at
considering quantitative risk, quality of life impacts can be more
difficult, because they require subjective input from potentially
impacted communities.
Social/Environmental Indicators:
This report suggest using the U.S. EPA matrix:
known pollution sources in the area
existing health problems and conditions
unique exposure pathways
potential quality of life impacts (i.e., noise, odor, stress)
social/cultural traditions and conditions
existing social capital and community capacity
While the state of scientific understanding may not yet provide for an understanding of synergistic impacts of cumulative exposure to multiple pollutants, these factors can help agencies balance potentially disadvantageous assumptions that are built into most standard risk assessment models.
Additional Demographic Consideration: EJ communities, including other demographic characteristics indicative of vulnerability or under-representation, such as tribal communities, as well as those with significant concentrations of elderly, youth, and those with physical or mental disabilities. Agencies should determine the area of impact, demographics of the population and ground truthing.
Thresholds:
Once an agency has identified an action’s geographic scope of impact,
the agency must then overlay current demographic information, preferably
using Geographic Information Systems (GIS) mapping, to determine if
there are communities of color and low-income communities within the
impact area that are experiencing disparate impacts relative to whiter
and/or more affluent communities. The purpose of this assessment is to
determine whether “host” populations (those at risk within the area of
impact) are disproportionately people of color or low-income relative to
“non-host” populations (those not at risk of impacts).
Identifying Communities of Color
Consider the Portland metropolitan area as an example. As of the 2010
Census, the Portland metro area was 76.3% (non-Hispanic) white, and
23.7% people of color. This means that the minimum threshold for
communities of color should be 23.7%. Each Census tract in the region
that has at least 23.7% people of color should be identified as a
community of color (for purposes of EJ & Title VI assessments).
Identifying Low-Income Communities
Socioeconomic percentages should be based on regional data where
available.
Advanced Lens Census tracts that fall just below the threshold are up to
agency discretion for applying margin of error (within one standard
deviation). Units are included within EJ community designation.
Threshold Calculations:
No specific threshold calculations mentioned.
Purpose/Application:
Environmental & Protective
This report scopes issues and enhanced participation of the public
throughout the entire process to ensure the affected community has the
ability to meaningfully participate.
Requirements for ‘Meaningful Participation’:
The affected community must have access to full information in plain
language and the ability to influence the outcome.
The decision maker must consider public’s concerns before deciding and
seek out to facilitate public involvement.
AA. Michigan EJ Work Group Report (2018)
Authority: Michigan Environmental Justice Working Group (EJWG)
State: Michigan
Type: Report
Year: 2018
Definition:
CI is not directly defined. However, the report includes recommendations
to determine CI, directed to the Interagency Working Group (IWG). Among
these are developing a screening tool (e.g., U.S. EPA’s EJSCREEN, Cal
EPA’s CalEnviroScreen, etc.) that can be adapted to Michigan to measure
the cumulative impacts of environmental hazards, pollutants, and
discharges.
Social/Environmental Indicators:
The report recommends using Indicators from CalEnviroScreen (see Row for
CalEPA CalEnviroScreen 4.0).
It also recommends indicators from EJ Screen.
Pollution Burden Indicators:
National-Scale Air Toxics Assessment (NATA) air toxics cancer risk
NATA respiratory hazard index
NATA diesel PM
Particulate matter
Ozone
Traffic proximity and volume
Lead paint indicator
Proximity to Risk Management Plan sites
Proximity to hazardous waste treatment, storage and disposal facilities
Proximity to National Priorities List sites
Wastewater Dischargers Indicator
Demographic indicators
Percent low-income
Percent minority
Less than high school education
Linguistic isolation
Individuals under age 5
Individuals over age 64
Thresholds:
EJ area/community: any census tract with a 30% or greater minority
population or 20% or greater at-or-below the federal poverty level
Area of concern is considered an area located within ½ mile, or 4 miles in rural areas, of any of the following:
the boundary of a site where a regulated activity affecting human health and/or environment is/will occur
areas where the State, or local government body, is authorized to determine impacts to human health and the environment (e.g., traffic corridors, groundwater plumes, significant air impact, etc.)
areas impacted or reasonably expected to be impacted by drainage, watersheds, visual, noise, subsidence, vibration, or odor associated with the regulated activity affecting human health and/or environment
Threshold Calculations:
The work group recommended using CalEnviroScreen methodology to score
and rank state census tracts and to identify disadvantaged
communities.
Purpose/Application:
Environmental, Redistributive, and Protective
The report recommends creating an air, water, and soil quality
mitigation fund, in which a majority of the funds should be allocated
towards grants to local community organizations, local nonprofits, local
health departments, and local environmental departments where the
violation occurred to support the development of health impact
assessments, pollution mitigation and remediation programs, and
education and training programs for community residents and local
environmental regulators. Recommendations also include screening
tool/mapping and environmental justice analysis in permitting
applications.
BB. Washington Environmental Health Disparities Map Project (2019)
Authority: UW Department of Environmental & Occupational Health Sciences (DEOHS)
State: Washington
Type: Tool/Methodology
Year: 2019
Definition:
The tool defines Cumulative Impacts (CI) as the combined impact of
multiple environmental health indicators on a population.
Social/Environmental Indicators:
The interactive tool uses state and national data to map 19 indicators
of community health:
Environmental exposures: diesel emissions, ozone, particulate matter 2.5 (PM2.5), toxic releases from facilities, traffic density
environmental effects: lead risk and exposure, proximity to hazardous waste generators and facilities, proximity to superfund sites, proximity to facilities with highly toxic substances, wastewater discharge
sensitive populations: cardiovascular disease, low-birth-weight infants
socioeconomic factors: poor educational attainment, housing burden, linguistic isolation, poverty, race (people of color), transportation expense, unemployment
Thresholds:
The tool does not show specific thresholds, however it does show ranking
by deciles ranging from 1 (least impacted) to 10 (most impacted)
relative to other communities in Washington State (p.19). These rankings
reflect the risk each community faces from multiple environmental
hazards and the degree to which a community is more vulnerable to those
hazards due to socio-demographic factors.
Threshold Calculations:
To derive the final composite score, the pollution burden score is
multiplied by population characteristic score:
pollution burden score × population characteristics score = composite
score
To derive the pollution burden and population characteristic score
the following equations are used:
Pollution burden score = (Average percentile of environmental exposures
indicators +0.5 × average percentile of environmental effects
indicators)/2 Population characteristics score = (Average percentile of
sensitive population indicators + average percentile of socioeconomic
factors indicators)/2
The final composite score is based on the product of the pollution burden and population scores and the Information By Location (IBL) tool on WTN ranks all of the indicators, themes, and final scores using deciles (1 decile = 10 percent). Each decile represents about 10% of the values in the dataset. There are 1,463 census tracts in Washington as of 2018. This results in approximately 146 census tracts in each rank.
Purpose/Application:
Environmental
Description of Grphic:
Image of how the final composite score is derived from pollution burdens
and population characteristic
Interactive map for assessing air quality daily concentration data for particulate matter, ozone, nitrogen oxides, nitrogen dioxide and carbon monoxide through the Puget Sound Clean Air Agency website
CC. SB5141 The Healthy Environment for All Act
Authority: The Senate of the State of Washington
State: Washington
Type: Legislation
Year: 2021
Definition:
“Cumulative environmental health impact” means the combined, multiple
environmental impacts and health impacts on a vulnerable population or
overburdened community.
Social/Environmental Indicators: “Environmental harm” means the individual or cumulative environmental health impacts and risks to communities caused by historic, current, or projected: (a) exposure to pollution, conventional or toxic pollutants, environmental hazards, or other contamination in the air, water, and land (b) adverse environmental effects, including exposure to contamination, hazardous substances, or pollution that increase the risk of adverse environmental health outcomes or create vulnerabilities to the impacts of climate change (c) loss or impairment of ecosystem functions or traditional food resources or loss of access to gather cultural resources or harvest traditional foods (d) health and economic impacts from climate change.
Thresholds:
Consider threshold information in the Washington Environmental Health
Disparities Map (above).
Threshold Calculations:
Consider the threshold calculations in the Washington Environmental
Health Disparities Map (above).
Purpose/Application:
Protective
When considering a significant agency action initiated after July 1,
2023, a covered agency must conduct an environmental justice assessment
in accordance with this section to inform and support the agency’s
consideration of overburdened communities and vulnerable populations
when making decisions and to assist the agency with the equitable
distribution of environmental benefits, the reduction of environmental
harms, and the identification and reduction of environmental and health
disparities. Where applicable, use cumulative environmental health
impact analysis, such as the environmental health disparities map or
other data that considers the effects of a proposed action on
overburdened communities and vulnerable populations.
Increased participation must solicit feedback from overburdened communities.
The Department of Health must continue to develop and maintain an environmental health disparities map with the most current available information necessary to identify cumulative environmental health impacts and overburdened communities.
DD. HB4093. EPA - Environmental Justice
Authority: State of Illinois House of Representatives
State: Illinois
Type: Legislation
Year: 2021
Definition:
The Environmental Impact Review evaluates the direct, indirect, and
cumulative environmental impacts to the environmental justice community
that are associated with the proposed project.
An Environmental Justice Assessment identifies the potential environmental and health impacts to the area associated with the proposed project.
Social/Environmental Indicators:
The environmental justice assessment shall consist of the following:
air dispersion modeling, examining the air quality-related impacts from the proposed project in combination with existing mobile and stationary air emitting sources to determine estimated emissions of the following pollutants: (A) PM10 or PM2.5 (B) ozone precursors (C) emissions of any individual Hazardous Air Pollutant listed in subsection (b) of Section 112 of the federal Clean Air Act (D) emissions of diesel exhaust constituents from non-road and on-road mobile sources as well as stationary sources
a modeling protocol submitted to the Agency for review and consideration prior to performance of the air dispersion modeling
an Environmental Impact Review which shall include: (A) a qualitative and quantitative assessment of emissions-related impacts to the area from the project, including identifying the maximum allowable emissions of criteria pollutants and hazardous air pollutant emissions to be anticipated from the proposed new source. (B) an assessment of the health-based indicators for inhalation exposure, including, but not limited to, impacts to the respiratory, hematological, neurological, cardiovascular, renal, and hepatic systems and cancer rates
Thresholds:
A) Emissions of PM10 or PM2.5 that will be equal to or greater than 25
tons per year.
Emissions of ozone precursors that will be equal to or greater than 25 tons per year.
Emissions of any individual Hazardous Air Pollutant listed in subsection (b) of Section 112 of the federal Clean Air Act that will be equal to or greater than 10 tons per year.
Threshold Calculations:
Air quality modeling shall be performed using accepted USEPA
methodologies.
“To meet the requirements of this subsection with respect to monitoring, the permit shall Incorporate and identify all applicable emissions monitoring and analysis procedures or test methods required under the Clean Air Act, regulations promulgated thereunder, this Act, and applicable Board regulations, including any procedures and methods promulgated by US EPA pursuant to Section 504(b) or Section 114 (a)(3) of the Clean Air Act.”
Purpose/Application:
Protective
This legislation requires the EPA to annually review and update the
underlying data for, and use of, indicators used to determine whether a
community is designated as an environmental justice community and to
establish a process by which communities not designated as environmental
justice communities may petition for such a designation.
The legislation provides that an applicant for a permit for the construction of a new source that will become a major source subject to the Clean Air Act Permit Program to be located in an environmental justice community or a new source that has or will require a federally-enforceable state operating permit and that will be located in an environmental justice community must conduct a public meeting prior to submission of the permit application and must submit with the permit application an environmental justice assessment identifying the potential environmental and health impacts to the area associated with the proposed project.
EE. SB.148 - An act relating to environmental justice in Vermont
Authority: State of Vermont Senate
State: Vermont
Type: Legislation
Year: 2022
Definition:
The cumulative impacts of environmental harms, including air and water
pollution, low-quality housing stock, and greater exposure to extreme
weather events disproportionately and adversely impact the health of
BIPOC and low-income communities. These disproportionate adverse impacts
are exacerbated by lack of access to affordable energy, adequate
transportation, healthy food, and green spaces.
Social/Environmental Indicators:
Reference to indicators such as:
low access to grocery stores
lack of adequate transportation
land ownership
‘nature-deprived’ census tracts
access to quality health care, employment, and housing
higher risk of COVID19 infection
extreme weather events
flood hazards to mobile homes
lack of heating/electricity
Thresholds:
No specific thresholds mentioned.
Threshold Calculations:
No specific threshold calculations mentioned.
Purpose/Application:
Environmental & Protective
This legislation aims to create an Advisory Council on EJ within agency of Natural Resources. The council shall identify and define ‘environmentally distressed communities,’ policies to promote meaningful participation, advice agencies on EJ procedures. Agencies shall report to the General Assembly all actions taken to incorporate EJ into the agencies’ policies or determinations, rulemaking, permit proceeding, or project review. State agencies shall submit annual summaries to the Advisory Council on EJ, detailing all complaints alleging environmental justice issues and the action taken to address those concern.
Agencies shall determine indices and criteria to be included in a State mapping tool to measure EJ impacts at the local level. (The tool shall be available for public use by July 1, 2023.)
This policy requires the meaningful participation of all individuals in the development, implementation, or enforcement of any environmental law,6 regulation, or policy.
Agencies of Natural Resources, of Transportation, of Commerce and Community Development, and of Education and the Departments of Health, of Public Safety, and of Public Service shall report to the General Assembly all actions taken to incorporate environmental justice into the agencies’ policies or determinations, rule making, permit proceeding, or project review, including incorporation of Title VI of the Civil Rights Act of 1964.
VI. Federal Definitions, Indicators and Thresholds
This section contains the definitions of CI found on federal policies and or reports (see Type subtitle), as well as the indicators, thresholds, and threshold calculations used for determining CI that are outlined in these policies/reports.
A. Environmental Justice; Guidance Under the National Environmental Policy Act (NEPA)
Authority: Council on Environmental Quality (CEQ)
State: Federal
Type: Agency Guidance
Year: 1997
Definition:
Cumulative environmental exposure means exposure to one or more
chemical, biological, physical, or radiological agents across
environmental media (e.g., air, water, soil) from single or multiple
sources, over time in one or more locations, that have the potential for
deleterious effects to the environment and/or human health.
Social/Environmental Indicators:
No specific indicators. Broad categories of indicators: agencies should
(1) recognize the interrelated cultural, social, occupational,
historical, or economic factors that may amplify the natural and
physical environmental effects of the proposed agency action (2)
consider the composition of the affected area to determine whether
low-income, minority, or tribal populations are present and whether
there may be disproportionately high and adverse human health or
environmental effects on these populations and (3) consider relevant
public health and industry data concerning the potential for multiple
exposures or cumulative exposure to human health or environmental
hazards in the affected population, as well as historical patterns of
exposure to environmental hazards.
Thresholds:
Neither the Executive Order nor this guidance change the prevailing
legal thresholds and statutory interpretations under NEPA and existing
case law. For example, for an EIS to be required, there must be a
sufficient impact on the physical or natural environment to be
“significant” within the meaning of NEPA. Agency consideration of
impacts on low-income populations, minority populations, or Indian
tribes may lead to the identification of disproportionately high and
adverse human health or environmental effects that are significant and
that otherwise would be overlooked.
Threshold Calculations:
No specific threshold calculations mentioned
Purpose/Application:
Protective
B. Considering Cumulative Effects Under the National Environmental Policy Act (NEPA)
Authority:Council on Environmental Quality (CEQ)
State: Federal
Type: Report
Year: 1997
Definition:
The impact on the environment which results from the incremental impact
of the action when added to other past, present, and reasonably
foreseeable future actions regardless of what agency (federal or
non-federal) or person undertakes such other actions.
Social/Environmental Indicators:
Cumulative effects need to be analyzed in terms of resources,
ecosystems, and human communities; environmental and socio-economic
stress factors; governmental regulations, standards, and plans; and
environmental and social trends. See pages 27-35 (Characterization of
Stress Factors). Indicators of environmental stress can be either
exposure-oriented (e.g., contamination levels) or effects-oriented
(e.g., loss or degradation of a fishery) (page 28).
Thresholds:
No specific thresholds mentioned
Threshold Calculations:
No specific thresholds calcuations mentioned
Purpose/Application:
Protective: outlines CI principles and provides information on methods
of cumulative effects analysis and data sources
Description of Graphic:
Table 3-2 on page 33 - Possible sources of existing data for cumulative
effects analysis
C. EPA Guidance on Cumulative Risk Assessment. Part 1. Planning and Scoping , Science Policy Council, U.S. Environmental Protection Agency
Authority: US EPA
State: Federal
Type: Agency Guidance
Year: 1997
Definition:
The term “cumulative risk assessment” covers a wide variety of risks.
EPA assessments describe and where possible quantify the risks of
adverse health and ecological effects from synthetic chemical,
radiation, and biological stressors. As part of planning an integrated
risk assessment, risk assessors must define dimensions of the
assessment, including the characteristics of the population at risk.
These include individuals or sensitive subgroups which may be highly
susceptible to risks from stressors or groups of stressors due to their
age (for example, risks to infants and children), gender, disease
history, size, or developmental stage.
Cumulative impacts, included in risk assessment terminology are the
sum of all individual impacts occurring over time and space, including
those of the foreseeable future (CEQ, 40 CFR Sect. 1508.7).
Cumulative effects, included in the same terminology are 1) the sum of
all environmental effects resulting from cumulative impacts (Liebowitz
et al., 1992) and 2) the combination of effects from all pesticide
chemical residues which have a common mechanism of toxicity (Food
Quality Protection Act, 1996).
Social/Environmental Indicators:
Six dimensions for analysis are used: sources, stressors, pathways,
population, endpoints, and time frames.
Population has three categories: 1) Humans 2) Ecological Entities and 3) Landscape or Geographic Concerns expanded in detail on page 7-9.
Source have two categories: 1) single source (point sources (for example, industrial or commercial discharge, superfund sites) and nonpoint sources (for example: automobiles, agriculture, consumer use releases) and natural sources (for example: flooding, hurricanes, earthquakes, forest fires) 2) multi-sources (combinations of those above)
Stressors have ten categories: 1) chemicals 2) radiation 3) microbiological or biological (these range from morbidity to ecosystem disruption) 4) nutritional (for example: diet, fitness, or metabolic state) 5) economic (for example: access to health care) 6) psychological (for example: knowledge of living near uncertain risks) 7) Habitat Alteration (for example: urbanization, hydrologic modification, timber harvest) 8) Land-use changes (for example: agriculture to residential, public to private recreational uses) 9) global climate change 10) Natural Disasters (for example: floods, hurricanes, earthquakes, disease, pest invasions)
Pathways have three categories: 1) pathways, more than one of the following involved: air, surface water, groundwater, soil, solid waste, food, non-food consumer products, pharmaceuticals 2) routes of human and single species exposures, ingestion (both food and water), dermal (includes absorption and uptake by plants), inhalation (includes gaseous exchange), non-dietary ingestion (for example:"hand-to-mouth” behavior) 3) routes of exposure within communities and ecosystems: direct contact or ingestion (without accumulation), bioaccumulation, biomagnification, vector transfers (for example: parasites, mosquitoes)
Endpoints have two categories: 1) human health effects, for example: as based on animal studies, morbidity, and disease registries, laboratory and clinical studies, or epidemiological studies or data (i.e. carcinogenic, neurotoxicology, reproductive dysfunctional, developmental, cardiovascular, immunologic, renal, hepatic, and others) 2) ecological effects such as: population or species, community, ecosystem
Timeframe has three categories to assess relevant time frames: frequency, duration, intensity, and overlap of exposure intervals for a stressor or mixtures of stressors such as 1) acute 2) subchronic 3) chronic or effects with a long latency period 4) intermittent
Thresholds:
No specific thresholds mentioned
Threshold Calculations:
No specific threshold calculations mentioned
Purpose/Application:
Protective
D. Consideration Of Cumulative Impacts In EPA Review of NEPA Documents- U.S. Environmental Protection Agency, Office of Federal Activities (2252A) EPA 315-R-99-002
Authority: U.S. EPA
State: Federal
Type: Agency Guidance
Year: 1999
Definition:
This guidance emphasizes the effects of projects on ecological
resources, other resources, and areas that should be considered include
socioeconomic resources, human health, recreation, quality of life
issues, and cultural and historical resources.
Cumulative impacts result when the effects of an action are added to or interact with other effects in a particular place and within a particular time. It is the combination of these effects, and any resulting environmental degradation, that should be the focus of CI analysis. CI differ from direct and indirect impacts as it takes into account all disturbances since cumulative impacts result in the compounding of the effects of all actions over time. CI can be viewed as the total effects on a resource, ecosystem, or human community of that action and all other activities affecting that resource no matter what entity (federal, non-federal, or private) is taking the actions.
Social/Environmental Indicators:
Landscaping is used as an example for setting indicators. The following
indicators for landscaping were included:
The total change in land cover as an indicator of biotic integrity
Patch size distribution and distance as indicators of species change and level of disturbance
Estimates of fragmentation and connectivity as indicators of magnitude of disturbance, ability of species to survive in an area, and ecological integrity
Water quality and watershed integrity (i.e., levels of nitrogen, phosphorous, turbidity, dissolved oxygen, and temperature)
Condition of riparian buffer zones (i.e., soil erosion, sediment loading, and contaminant runoff)
Social indicators were mentioned as other resources that should be considered” (i.e., historic and archeological sites, socioeconomic services, and issues and community structure and character). Also mentioned as other resources and areas to be considered: socioeconomic resources, human health, recreation, quality of life issues, and cultural and historical resources.
Thresholds:
No specific thresholds mentioned
Threshold Calculations:
Change is evaluated in terms of both the total threshold beyond which
the resource degrades to unacceptable levels and the incremental
contribution of the proposed action to reaching that threshold. E.g.,
thresholds for determining adverse change in the functioning of a
wetland could include percentage of historic wetland loss in the region,
occurrence of species at risk, ambient water quality data that exceed
standards, and estuarine pollution susceptibility index.
Without a definitive threshold, the NEPA practitioner should compare the cumulative effects of multiple actions with appropriate national, regional, state, or community goals to determine whether the total effect is significant.
Purpose/Application:
Protective
Guidance is meant to assist EPA reviewers of NEPA documents in providing accurate, realistic, and consistent comments on the assessment of cumulative impacts.
E. EPA Framework for Cumulative Risk Assessment (2003)
Authority: US EPA
State: Federal
Type: Report/Framework
Year: 2003
Definition:
CI analysis was done in part to develop a framework of Cumulative Risk
Assessment (CRA) which the EPA’s Risk Assessment Forum committee of EPA
scientists were charged with developing for Agency-wide use.
In this report Cumulative Risk Assessment (CRA) means an analysis, characterization, and possible quantification of the combined risks to health or the environment from multiple agents or stressors.
A Cumulative Risk (CR) means the combined risks from aggregate exposures to multiple agents or stressors. There is no limitation that the “agents or stressors” be only chemicals; they may be, but they may also be biological or physical agents or an activity that, directly or indirectly, alters or causes the loss of a necessity (e.g., habitat).
A cumulative human health or ecological health risk assessment is different from a cumulative impact analysis (CIA) such as is conducted under NEPA, as changes in quality-of-life factors may affect the vulnerability of a population (i.e., health or ecological risks) and consequently may be part of the considerations in a cumulative risk assessment (CRA).
NEPA’s cumulative impact definition from CEQ 1997 is cited along with National Center for Environmental Assessment and Cumulative Risk Initiative of Illinois and Indiana.
Social/Environmental Indicators:
Six dimensions for analysis are used: sources, stressors, pathways,
population, endpoints, and timeframes.
Population has three categories: 1) humans 2) ecological entities 3) landscape or geographic concerns expanded in detail on page 7-9.
Source has two categories: 1) single source (point sources–for example: industrial or commercial discharge, superfund sites–and nonpoint sources–for example: automobiles, agriculture, consumer use releases) and natural sources (for example: flooding, hurricanes, earthquakes, forest fires) and 2) multi-sources (combinations of those above).
Stressors have ten categories: 1) chemicals 2) radiation 3) microbiological or biological (these range from morbidity to ecosystem disruption) 4) nutritional (for example: diet, fitness, or metabolic state) 5) economic (for example: access to health care) 6) psychological (for example: knowledge of living near uncertain risks) 7) habitat alteration (for example: urbanization, hydrologic modification, timber harvest) 8) land-use changes (for example: agriculture to residential, public to private recreational uses) 9) global climate change 10) natural disasters (for example: floods, hurricanes, earthquakes, disease, pest invasions).
Pathways have three categories: 1) Pathways, more than one of the following involved: air, surface water, groundwater, soil, solid waste, food, non-food consumer products, pharmaceuticals 2) routes of human and single species exposures, ingestion (both food and water), dermal (includes absorption and uptake by plants), inhalation (includes gaseous exchange), non-dietary ingestion (for example: “hand-to-mouth” behavior) 3) routes of exposure within communities and ecosystems: direct contact or ingestion (without accumulation), bioaccumulation, biomagnification, and vector transfers (for example: parasites, mosquitoes).
Endpoints have two categories: 1) human health effects as based on animal studies, morbidity and disease registries, laboratory and clinical studies, or epidemiological studies or data (i.e., carcinogenic, neurotoxic, reproductive dysfunction, developmental, cardiovascular, immunologic, renal, hepatic, and others 2) ecological effects such as: population or species, community, ecosystem.
Timeframes have three categories: frequency, duration, intensity and overlap of exposure intervals for a stressor or mixtures of stressors such as: 1) acute 2) subchronic 3) chronic effects or effects with a long latency period 4) Intermittent.
Thresholds:
No specific thresholds mentioned
Threshold Calculations:
No specific threshold calculations mentioned
Purpose/Application:
Protective
Description of Graphic:
Image of environmental hazards, vulnerability, health disparities
(p. 28, not shown here)
F. National Environmental Justice Advisory Council (NEJAC) - Ensuring Risk Reduction in Communities with Multiple Stressors: Environmental Justice and Cumulative Risks/Impacts (Report)
Authority: National Environmental Justice Advisory Council Report
State: Federal
Type: Report
Year: 2004
Definition:
NEJAC distinguishes between two common understandings of cumulative
risks and impacts:
Environmental regulators and risk assessors see cumulative risks and impacts as a set of stressors (risks, impacts, and burdens) that have already been combined into an output using qualitative or quantitative valuation.
Multimedia approaches: impacted communities and the general public see cumulative risks or impacts to mean a collection of individual stressors that occur simultaneously and multiply (synthesized output that combines multiple stressors, versus list of individual stressors that combine in some way). This report argues for this comprehensive, integrated, and unified approach towards multiple environmental hazards in overburdened communities.
NEJAC argues that the term ‘multiple stressors’ should be used as a starting point, because there are contradictory understandings of what is meant by cumulative risks and impacts.
The report discusses the 2003 EPA Framework for the Cumulative Risk Assessment definition of ‘stressor’ which encompasses socioeconomic stressors such as lack of health care to assess comprehensive risk. The report discusses aspects of this framework that make it key to ensuring the goal of environmental justice for all communities and includes recommendations for implementing the EPA Cumulative Risk Assessment Framework, such as adopting a community-based, collaborative problem-solving model.
Social/Environmental Indicators:
The report discusses four different types of vulnerability that may help to identify relevant indicators, including:
Susceptibility/sensitivity: facing an increased likelihood of sustaining an adverse effect due to a life state (e.g., pregnant, young, old), an impaired immune system, or a pre-existing condition, such as asthma.
Differential exposure: a subpopulation can be more vulnerable because it is living or working near a source of pollution and is therefore exposed to a higher level of the pollutant than the general population. Social, economic, cultural factors, background/historical exposures within a subpopulation can contribute to vulnerability (pg. 23).
Differential preparedness: refers to subpopulations less able to withstand an environmental insult. This is linked to what kind of coping systems an individual, population, or community has (e.g., poor access to preventive health care, poverty, poor nutrition, or psycho-social stress may affect the strength of one’s coping system).
Differential ability to recover: some subpopulations are more able to recover from an insult or stressor because they have more information about environmental risks, health, and disease; they have ready access to better medical and health care; they have early diagnosis of disease; or they have better nutrition. Related social factors can include income, employment status, access to insurance, discrimination in the health care system, language ability, the existence of social capital, and economic, racial, and linguistic isolation, which can be measured using a dissimilarity index.
In addition, the “Pollution Burden Matrix for Community Characterization” (p.36) and the Multiple, Aggregate, and Cumulative Risks and Impacts in the Mississippi River Industrial Corridor Matrix (p.5) names the following indicator categories:
- Demographics
- Pollution sources
- Existing health problems and conditions
- Unique exposure pathways
- Social/cultural conditions
- Community capacity and infrastructure/social capital
Specifically, suggested indicators for pollution include: total criteria air pollutant emissions (TCE), total toxic air contaminants emissions (TTE), population-weighted air emission burden (PWTE), facility density–high, medium, and low emitting sources (FDL, FD-M, FD-S), total length of major roadways (TLR), number of superfund sites (NSS), total release of toxic chemicals from Toxic Release Inventory (TRI) facilities, presence/number of QOL-reducing entities (QOL), acreage of parks/greenbelts (APG), total cancer risk (TCR), incidence of asthma (IOA), drinking water quality (DWQ), and number of leaking underground fuel storage tanks (LUST).
Thresholds:
Only pollution thresholds are mentioned. A report from the Environmental
Law Institute, “Opportunities for Advancing Environmental Justice: An
Analysis of U.S. EPA Statutory Authorities,” mentions a pollutant
threshold in chapters 13 and 17.
Threshold Calculations:
Carrying capacity analysis is proposed as a method to identify
thresholds (as constraints on development) and provide mechanisms to
monitor the incremental use of unused capacity.
A proposed method for pollution thresholds is to use the Pollution Burden Matrix, and for each selected pollution indicator, the top 25% of values would be considered as having “high” burdens, the middle 50% would be “medium,” and the bottom 25% have “low” burdens.
Purpose/Application:
Protective
Description of Graphic:
The image below describes the Framework for Cumulative Risk Assessment, USEPA.
Another image is from the “Evolution for Risk Assessment at EPA” by Thomas A. Burke, Johns Hopkins University, Bloomberg School of Public Health, Presentation to EPA Region 3 Cumulative Risk Workshop (p. 11, not shown here).
Another image depicts environmental hazards, vulnerability, health disparities (p. 28, not shown here).
G. EPA - Technical Guidance for Assessing Environmental Justice in Regulatory Analysis (Report)
Authority: US EPA
State: Federal
Type: Agency Guidance
Year: 2016
Definition:
Cumulative impact is characterized by minority populations, low-income
populations, or indigenous peoples that are impacted by exposure to
multiple environmental hazards, such as contaminants from industrial
facilities, landfills, and leaking underground tanks,
transportation-related air pollution, poor housing, pesticides, and
incompatible land uses (p. 18). The report notes that research and
community stakeholders advocated for the EPA to consider exposure to
multiple chemicals and other factors, as opposed to using a
single-chemical risk assessment approach.
To assess CI, the EPA’s Framework for Cumulative Risk Assessment (CRA) (U.S. EPA, 2003) can be used, where CRA is defined as “evaluating an array of stressors (chemical and non-chemical) to characterize–quantitatively to the extent possible –human health and ecologic effects, taking into account factors such as vulnerability and background exposures.” Categories of stressors can include chemical, physical, environmental, social, and biological.
Social/Environmental Indicators:
Examples of possible social and environmental indicator categories
include:
Exposure to a stressor (e.g., air emissions from several facilities in different industries, industrial facilities, landfills, and leaking underground tanks, transportation related air pollution, poor housing, pesticides, and incompatible land uses)
Non-chemical stressors, such as crime, may exacerbate the effects of some chemical exposures (e.g., changes in immunological response due to increased presence of stress hormones)
Potential risk-modifier: socioeconomic status, which does not by itself elicit a biological interaction, but has a complex association with health states
Susceptibility to an environmental stressor can be a determinant of the occurrence/severity of an adverse effect. Factors include: genetics, diet, nutritional status, pre-existing disease, psychological stress, co-exposure to similarly acting toxins or chemicals, and cumulative burden of disease resulting from exposure throughout life.
Environmental stressors encompass the range of chemical, physical, or biological agents, contaminants, or pollutants that may be subject to a regulatory action.
Population groups of concern are determined through “exposure pathways and”in some contexts” populations are analyzed by categories in combination. For example, categories may include low-income minority populations–or diversity within the population groups of concern (e.g., life stage, gender)–particularly when some individuals within population groups may be at greater risk for experiencing adverse effects.
Thresholds:
CEQ’s Environmental Justice: Guidance Under the National Environmental
Policy Act (1997) suggests analysts use “annual statistical poverty
thresholds from the Census Bureau’s Current Population Reports, Series
P-60 on Income and Poverty” to define low-income populations.
For purpose of E.O. 12898, the term “minority” means “individual(s) who are members of the following population groups: American Indian or Alaskan Native; Asian or Pacific Islander; Black, not of Hispanic origin; or Hispanic” as minority in an area affected by the policy action if “either:
the minority population of the affected area exceeds 50% or
the minority population percentage of the affected area is meaningfully greater than the minority population percentage in the general population or other appropriate unit of geographic analysis” (CEQ, 1997).
Threshold Calculations:
No specific threshold calculations mentioned. However, examples were
provided for ID of measurements and technical assessment in data rich
and data scarce environments. Models provided: “Spray Drift Modeling,”
“Risk Based, Multi Pollutant Modeling,” and “Data Quality and Spatial
Resolution in the Context of Air Regulations.”
- Analytical considerations: geographic and temporal scope, comparison group, spatial ID, aggregating effects, ID and analysis of potential hot spots, statistical significance and other considerations.
Purpose/Application:
Environmental & Protective
Mapping and technical guidance on integrating potential EJ concerns into
regulatory analyses
Description of Graphic:
* Noted in Text Box B.2: Pesticide Spray Drift Risk Assessment to
Bystanders, a Conceptual Model for Spray Drift Modeling (U.S. EPA,
2012c) is included allowing for calculation of the deposition pattern
concentration vs. distance downwind from treated field.
- Noted in Text Box B. 3 is the Risk-Based, Multi-Pollutant Modeling Framework (Fann et al., 2011) from the Detroit multi-pollutant pilot project incorporating EJ. Additional information can be found at Technical Air Pollution Resources USEPA
H. Promising Practices For EJ Methodologies in NEPA Reviews
Authority: Federal Interagency Working Group on Environmental Justice & NEPA Committee
State: Federal
Type: Report
Year: 2016
Definition: Cumulative impacts result from chemical and non-chemical stressors, exposures from multiple routes or sources, and factors that differentially affect exposure or toxicity to communities.
Social/Environmental Indicators:
Where an impact from a proposed action initially appears to be identical
to both the affected general population and the affected minority
population and low-income population, additional factors should be taken
into account. Some factors, such as unique exposure pathways, social
determinants of health, or even community cohesion, can actually make an
impact disproportionately high and adverse. Amplifying factors include
(page 43):
- Proximity and exposure to chemicals and other stressors
- Vulnerable populations
- Unique exposure pathways
- Multiple or cumulative impacts
- Ability to participate in the decision-making process, including
barriers to participation
- Adequacy of physical infrastructure, such as roads, housing, and
water
- Non-chemical stressors, such as economic or social impacts.
Agencies should also consider factors that could amplify the impact on minority populations and low-income populations of a proposed action, such as: social determinants of health, community cohesion, cultural practices, existing health conditions.
Thresholds:
For low income populations poverty data is used from the Census Bureau’s
poverty thresholds and the U.S. Department of Health and Human Services’
poverty guidelines. Methods for calculating thresholds for low income
populations and minority populations are mentioned in the Threshold
Calculation section.
Threshold Calculations:
Identify minority populations through: fifty percent analysis,
meaningfully greater analysis, or no-threshold analysis (see pages 23-25
for specific steps).
Identify low income populations through: alternative criteria analysis, low-income threshold criteria analysis (see pages 26-27 for specific steps).
Identifying appropriate comparison group or groups within the affected area can be helpful in determining disproportionality. (A comparison group is not the same as a “reference community,” which is used to determine the percentage of minority or low income persons or households present in an affected area). The comparison group allows consideration of likely differences in pathways and exposures with the minority population or low-income population. More than one comparison group may be appropriate in some instances.
Purpose/Application:
Protective
This report is intended as a way for agencies to compare and improve
their methodologies for considering environmental justice now and in the
future by applying methods established in federal NEPA practice (NEPA
impacts permitting decisions). It is also intended to provide guidelines
for ‘meaningful engagement’ of minority populations.
I. H.R.2021 - Environmental Justice For All Act
Authority: US House of Representatives
State: Federal
Type: Legislation
Status: Introduced
Year: 2021
Definition:
Cumulative impacts means any exposure to a public health or
environmental risk, or other effect occurring in a specific geographical
area, including from an emission, discharge, or release including:
environmental pollution released routinely, accidentally, or otherwise,
and from any source, whether single or multiple–and as assessed, based
on the combined past, present, and reasonably foreseeable emissions and
discharges affecting the geographical area. Lastly, it may be evaluated,
taking into account sensitive populations and other factors that may
heighten vulnerability to environmental pollution and associated health
risks, including socioeconomic characteristics.
Social/Environmental Indicators:
Includes language to amend the Federal Water Pollution Control Act and
the Clean Air Act, section 501 of the Clean Air Act (42 U.S.C. 7661), to
include submission of a CI analysis for each census tract or tribal
census tract located in or adjacent to the area of the major source when
applying for or renewing a permit, which considers the following
indicators:
Community demographics and locations of community exposure points such as schools, day care centers, nursing homes, hospitals, health clinics, places of religious worship, parks, playgrounds, and community centers
Air quality and the potential effect on that air quality of emissions of air pollutants (including pollutants listed under section 108 or 112) from the major source, including in combination with existing sources of pollutants
Potential effects on soil quality and water quality of emissions of lead and other air pollutants that could contaminate soil or water from the major source, including in combination with existing sources of pollutants
public health and any potential effects on public health from the major source.
Thresholds:
No specific thresholds mentioned.
Threshold Calculations:
No specific threshold calculations mentioned.
Purpose/Application:
Protective & Redistributive
Requires consideration of cumulative impacts in permitting decisions, enhanced reporting and participation, and EJ Grants programs
EJ Grants programs entity eligibility: shall be a nonprofit, community-based organization that conducts activities, including providing medical and preventive health services, to reduce the disproportionate health impacts of environmental pollution in the EJ community at which the eligible entity proposes to conduct an activity that is the subject of the application process found in paragraph (3)
Specific definitions apply to the benefits section: • Transit to Trails Grant Program • Access to Parks Outdoor Spaces and Public Recreation Opportunities
J. S.2630 - Environmental Justice Act of 2021
Authority: US Congress Proposed Legislation
State: Federal
Type: Legislation
Status: Introduced
Year: 2021
Definition:
Cumulative impacts means any exposure, public health or environmental
risk, or other effect occurring in a specific geographical area,
including from an emission or release, including environmental pollution
released either routinely, accidentally, or otherwise; and from any
source, whether single or multiple; and as assessed based on the
combined past, present, and reasonably foreseeable emissions and
discharges affecting the geographical area; and evaluated taking into
account sensitive populations and socioeconomic factors, where
applicable.
Social/Environmental Indicators:
Includes language to amend the Federal Water Pollution Control Act and
the Clean Air Act, section 501 of the Clean Air Act (42 U.S.C. 7661), to
include submission of a CI analysis for each census tract or Tribal
census tract located in or adjacent to the area of the major source when
applying for or renewing a permit, which considers the following
indicators:
Community demographics and locations of community exposure points such as schools, day care centers, nursing homes, hospitals, health clinics, places of religious worship, parks, playgrounds, and community centers
Air quality and the potential effect on that air quality of emissions of air pollutants (including pollutants listed under section 108 or 112) from the major source, including in combination with existing sources of pollutants
Potential effects on soil quality and water quality of emissions of lead and other air pollutants that could contaminate soil or water from the major source, including in combination with existing sources of pollutants
public health and any potential effects on public health from the major source.
Thresholds:
No specific thresholds mentioned.
Threshold Calculations:
No specific threshold calculations mentioned.
Purpose/Application:
Protective & Redistributive
Requires consideration of cumulative impacts in permitting decisions, enhanced reporting and participation, codifies the existing National Environmental Justice Advisory Council (NEJAC) and EJ Grant programs
(Since these grant programs and NEJAC have never been Congressionally authorized, they are susceptible to being discontinued by future Administrations.)
K. H.R.8271 - Environmental Justice Legacy Pollution Cleanup Act of 2020
Authority: Senate and House of Representatives of the United States of America in Congress
State: Federal
Type: Legislation
Status: Not re-introduced
Year: 2020
Definition:
Cumulative Impacts are discussed within the framework of their impact on
overburdened communities using Section 501 of the Clean Air Act (42
U.S.C. 7661)
Social/Environmental Indicators:
Suggests language to amend Clean Air Act so that ‘no permit shall be
granted by a permitting authority for a proposed major source that would
be located in an overburdened census tract.’ Overburdened census tract
identified within the National Air Toxics Assessment published by the
Administrator.
Thresholds:
An overburdened census tract is one that is a greater than 100 in
1,000,000 total cancer risk–or has been determined to have an annual
mean concentration of PM2.5 of greater than 8 micrograms per cubic
meter, as determined over the most recent three-year period for which
data are available.
Threshold Calculations:
No specific threshold calculations mentioned.
Purpose/Application:
Protective & Redistributive
This legislation intends to amend the Clean Air Act to prohibit the
issuance of new major-source air pollution permits in overburdened
communities. Supplemental appropriations were made available by the
Treasury for The Department of Interior, Environmental Protection
Agency, Department of Housing and Urban Development, Corps of Engineers,
Department of Agriculture, and Indian Health Services which include
environmental cleanup and remediation of threats to public health
including remedial actions, capitalization grants, reduction projects,
brownfields projects, and other grants and waivers.
L. EJScreen 2.0
Authority: U.S. Environmental Protection Agency
State: Federal
Type: Tool/Methodology
Year: 2022
Definition:
EJScreen 2.0 is not a CI tool. While it includes 12 environmental
justice indexes and one demographic index, these indexes are not
constructed by combining multiple environmental indicators. Despite
these limitations, we include it here because it allows us to see
various environmental and demographic indicators at a high spatial
resolution.
Social/Environmental Indicators:
EJScreen 2.0 uses 11 EJ indexes reflecting 12 environmental indicators.
Each EJ index is a combination of environmental and demographic data.
Socioeconomic indicators: % people of color, % low-income, unemployment,
% in linguistic isolation, % less than high school education, % under
age 5, % over age 64, demographic index. Environmental indicators:
PM2.5, ozone (level in air), diesel PM (level in air), air toxics
respiratory hazard index, traffic proximity and volume, lead paint (%
pre-1960 housing), Superfund proximity, Risk Management Plan (RMP)
facility proximity, hazardous waste proximity, underground storage tanks
(UST) and leaking UST, wastewater discharges indicator. Climate
indicators: wildfire hazard potential, drought, coastal flood hazard,
estimated 100-year floodplains, sea level rise. Health indicators: low
life expectancy, heart disease, asthma. Critical service gaps: broadband
gaps, food desert, medically underserved. See map description for more
details.
Thresholds:
No specific thresholds mentioned.
Threshold Calculations:
EJ Index = (The Environmental Indicator) X (Demographic Index for Block
Group – Demographic Index for US) X (Population count for Block
Group)
Purpose/Application: Environmental
This tool is limited because its indicators only provide proxies for
actual exposure or risk. Also, EJSCREEN does not include all
environmental issues nor does it identify EJ communities.
M. H.R 6548 Justice in Power Plant Permitting Act
Authority: U.S. House of Representatives
State: Federal
Type: Legislation
Year: 2022
Definition:
Cumulative impacts means any exposure to a public health, environmental,
or climate risk, or other effect occurring in a specific geographical
area, including from an emission, discharge, or release, including (i)
environmental pollution released (I) routinely, accidentally, or
otherwise (II) from any source, whether single or multiple (ii) as
assessed based on the combined past, present, and reasonably foreseeable
emissions and discharges affecting the geographical area; and evaluated
taking into account sensitive populations and other factors that may
heighten vulnerability to environmental pollution and associated health
risks, including socioeconomic characteristics.
Social/Environmental Indicators:
CI Analysis should consider:
community demographics and locations of community exposure points, including schools, daycare centers, nursing homes, hospitals, health clinics, places of religious worship, parks, playgrounds, and community centers
air quality and any potential effects on that air quality of emissions of air pollutants from the fossil fuel fired power plant proposed to be permitted, including in combination with existing sources of pollutants
the potential effects on soil quality and water quality of emissions of lead and other air pollutants that could contaminate soil or water from the fossil fuel fired power plant proposed to be permitted, including in combination with existing sources of pollutants
public health and any potential effects on public health from the emissions of pollutants from the fossil fuel fired power plant proposed to be permitted, including in combination with existing sources of pollutants
the potential adverse impacts on health and well-being of residents of impacted environmental justice communities and populations with heightened vulnerability to pollution and associated health risks, which may be due to socioeconomic characteristics including housing insecurity, barriers to receive quality healthcare or afford health insurance, energy cost burdens that limit use of heat and air conditioning, long-term impacts of siting polluting sources in environmental justice communities, and public disinvestment and redlining
the potential effects of any proposed action on environmental justice communities, including if the action causes or exacerbates a disproportionate or inequitable burden on the environmental justice community
shall be based on an analysis of data that accurately describes the potential cumulative impacts of the proposed action, and may include a supplemental qualitative analysis.
Thresholds:
No specific thresholds mentioned.
Threshold Calculations:
No specific threshold calculations mentioned.
Purpose/Application:
Protective & Redistributive
Requires a Cumulative Impacts Analysis for any permit or renewal of a permit for a fossil fuel fired power plant that is, or is proposed to be, a major source of air pollution, or is within one mile of another fossil fuel-fired power plant or major source of air pollution. “A permitting authority shall not grant a permit or renewal unless the cumulative impacts analysis under paragraph (1) indicates a reasonable certainty that the permit or renewal will result in no harm to the health of the general population, or to any potentially exposed or susceptible subpopulation, including environmental justice communities, of a census block group or Tribal census block group.”
Eligibility requirements for governments to receive ‘Just Energy Transition’ funds include: projects that (1) supported by residents of impacted EJ communities (2) does not rely on fuels or technologies that create environmental harm, including greenhouse gas emissions, or contribute to health burdens on environmental justice communities and impacted communities (3) results in a quantifiable improvement to the health and well-being of residents of impacted EJ communities and other impacted communities as measured by the Advisory Council. Programs supported by residents of EJ communities that “result in a quantifiable improvement to the health and well-being of residents of environmental justice communities and other impacted communities, as measured by the Advisory Committee” are the second eligibility category. These can include programs that (1) apportion funds to individuals who face or are expected to face burdensome energy costs and (2) support ratepayer advocacy or intervenor compensation opportunities to lower energy costs and reduce pollution faced by residents of impacted environmental justice communities and other impacted communities.
N. Cumulative Impacts: Recommendations for ORD Research
Authority: U.S. EPA
State: Federal
Type: Draft
Year: 2022
Definition:
Cumulative Impacts refers to the total burden–positive, neutral, or
negative–from chemical and non-chemical stressors and their interactions
that affect the health, well-being, and quality of life of an
individual, community, or population at a given point in time or over a
period of time. Cumulative impacts include contemporary exposures in
various environments where individuals spend time and past exposures
that have lingering effects. Total burden encompasses direct health
effects and indirect effects to people through impacts on resources and
the environment that affect human health and well-being. Cumulative
impacts provide context for characterizing the potential state of
vulnerability or resilience of the community (i.e., their ability to
withstand or recover from additional exposures under consideration).
Cumulative Impact Assessment is the process of accounting for cumulative impacts in the context of problem identification and decision-making. It requires consideration and characterization of total exposures to both chemical and non-chemical stressors, as well as the interactions of those stressors over time and across the affected population. Cumulative impact assessment explores how stressors from the built, natural, and social environments affect people, potentially causing or exacerbating adverse outcomes. It also accounts for health-mitigating factors or solutions aimed at improving health and well-being. The posited elements of a cumulative impact assessment include: community role throughout the assessment, and in particular, identifying problems and potential intervention decision points to improve community health and well-being; combined impacts across multiple chemical and non-chemical stressors; multiple sources of stressors from the built, natural, and social environments; multiple exposure pathways across media; community vulnerability; past exposures, especially during vulnerable ages or life stages; individual variability and behaviors; health and well-being benefits/mitigating factors; and evaluation of potential interventions that reduce cumulative impacts and improve community health and well-being.
Social/Environmental Indicators:
Recommendations of factors to consider indicator categories for
Cumulative Impact Assessment:
Combine quantitative and qualitative data on stressors to inform a cumulative impact assessment
Characterize the cumulative impacts of multiple decisions at once (e.g., permitting multiple facilities in an area)
Develop and combine stressors/indicators for one or more health and well-being outcomes that provide relative or absolute measures of exposure or impact
Standardize (in absolute and relative ways) identification and characterization of disproportionately impacted and overburdened communities
Use biomarker identification for exposures to multiple chemical or non-chemical stressors
Integrate multiple streams of data, including data from community and citizen science and traditional ecological knowledge
Characterize health inequities within and across communities and at varying spatial scales
Characterize health-benefiting assets of a community, such as measuring the benefits of green space
Identify and account for historical stressor exposures in cumulative impact assessments
Evaluate the cumulative impacts/benefits of various types of interventions
Thresholds:
No specific thresholds mentioned.
Threshold Calculations: No specific threshold calculations mentioned in report. Yet, the following is mentioned regarding methodologies: The Health and Environmental Risk Assessment (HERA) Research Program has predominantly focused on single chemical assessments and a smaller number of assessments of chemical mixtures. HERA assessments of chemical mixtures such as dioxins, total petroleum hydrocarbons, and polycyclic aromatic hydrocarbons have advanced the application of chemical mixture approaches, including application of toxicity equivalence factors, relative potency factors, and hazard indexes (EPA, 1993, 2009, 2010). As the need for evaluating multimedia exposures that incorporate chemical and non-chemical stressor interactions has increased, the HERA program has focused research on cumulative risk assessment methods and practice (Genres et al., 2016).
Purpose/Application: Environmental
These recommendations provide definitions, research gaps and barriers to
implementing cumulative impact research at EPA, and recommendations for
advancing cumulative impact research going forward within ORD’s FY23-26
Strategic Research Action Plan.
Description of Graphic:
Figure 1. Positive/neutral/negative influences on health, well-being,
and quality of life from the total (built, natural, social)
environment
VIII. Journal Definitions, Indicators and Thresholds
This section contains the definitions of CI found in journal articles , as well as the indicators, thresholds, and threshold calculations used for determining CI that are outlined in these articles. The articles are organized chronologically.
A. Environmental Health Coalition: Building Healthy Communities from the Ground Up: Environmental Justice in California (2003)
Authority: Report. Asian Pacific Environmental Network, Communities for a Better Environment, Environmental Health Coalition, People Organizing to Demand Environmental & Economic Rights, Silicon Valley Toxics Coalition/Health and Environmental Justice Project
State: California
Type: Report
Year: 2003
Definition:
Cumulative impacts are defined as “those effects caused by the presence
of multiple sources of pollution.” CI are referenced in relation to
disproportionately impacted communities (i.e., assess cumulative
pollution burden for disproportionately impacted communities based on
the degree of threatened harm to human health and the environment the
communities experience).
Social/Environmental Indicators:
Landscaping is used as an example for setting indicators. The following
indicators for landscaping were included:
the total change in land cover as an indicator of biotic integrity
patch size distribution and distance as indicators of species change and level of disturbance
estimates of fragmentation and connectivity as indicators of magnitude of disturbance, ability of species to survive in an area, and ecological integrity
water quality and watershed integrity (i.e., levels of nitrogen, phosphorous, turbidity, dissolved oxygen, and temperature)
condition of riparian buffer zones (i.e., soil erosion, sediment loading, and contaminant runoff)
Social indicators were mentioned as “other resources that should be considered” (i.e., historic and archaeological sites, socioeconomic services, and issues and community structure and character). Also mentioned as other resources and areas to be considered: socioeconomic resources, human health, recreation, quality of life issues, and cultural and historical resources.
Thresholds:
California census tract and 2003 reports from Brookings Institute were used to gauged each metropolitan area by concentration of poverty.
The top 15 metropolitan areas were measured by increase in population of high-poverty neighborhoods, 1990-2000.
Poverty threshold and household size were used in determining the following percentages, although thresholds were not specifically defined:
43% of renters in Southern California pay more than 30% of their monthly incomes in rent, the highest level for a metropolitan area in the nation.
86% of Logan residents are Latino and their median household income is $19,000, less than half the $47,067 median income of San Diego County.
210 industries with regulated hazardous materials/waste are located in Logan’s 3 square miles; 129 are located in Barrio Logan, the 1.2sq mile area west of the highway.
Barrio Logan accounts for .07% of total land area in the county, it is host to 7% of the county’s air toxic “hot spots” and 90% of the total emissions of Chromium 6 in the county.
Threshold Calculations:
No specific threshold calculations mentioned.
Purpose/Application:
Protective
This report aims to ensure that transportation planning, investments,
and operation support and strengthen communities. It recommends that CI
should be emphasized.
In particular, the report suggests that infrastructure projects (such as the expansion of the 710 Freeway in Los Angeles County) that require substantial state funds, must adhere to principles of precaution and adopt cumulative impact analyses. It also recommends requirement of cumulative impact analysis for new permit applications.
Description of Graphic:
Chart 3: Academic Performance Index (API) Score by Environmental Ranking
for Los Angeles Unified School District, Spring 1999
B. The Environmental “Riskscape” and Social Inequality: Implications for Explaining Maternal and Child Health Disparities. (2006)
Authority: Journal article
Type: Academic Publication
Year: 2006
Definition:
Cumulative Impacts are mentioned in reference to ‘multiple exposures to
environmental hazards and the potential vulnerability of poor
communities to their toxic effects’ [National Environmental Justice
Advisory Council (NEJAC) 2004]. The potential interaction of elevated
environmental hazard exposures combined with socioeconomic stressors has
been described as a form of “double jeopardy.”
Social/Environmental Indicators:
Built environment:
- Land use/zoning
- Housing quality
- Social environment
- Civic engagement/ political empowerment
- Poverty concentration
- Access to services
- Food security
- Regulatory enforcement activities
- Neighborhood quality
- Social capital
Individual-level stressors/buffers:
- Social support
- Poverty/SES
- Working conditions/occupational health
- Health care access
- Diet/nutritional status
- Psychosocial stress
- Health behaviors
- Reproductive events
Thresholds:
No specific thresholds mentioned.
Threshold Calculations:
No specific threshold calculations mentioned.
Physiologic mechanisms are measured through allostasis*, which refers to the ability of the body’s stress–response systems to regulate internal physiology in response to psychosocial or physical stressors. The related concept of allostatic load refers to the cumulative physiologic degradation over a lifetime, which can result from chronic stress exposure, and the accompanying long-term shift that occurs in the body’s homeostatic functions, with harmful consequences.
Other individual factors cited from a study by Ponce et al. look at pollutant exposure’s effect on a neighborhood through measures of socioeconomic hardship. It found that preterm birth risk was affected by the interaction of residential traffic-related air pollution exposure and measures of neighborhood economic hardship.
Description of Graphic:
The framework in Figure 1 suggests how area-level and individual-level
stressors and buffers may combine to shape environmental hazard
exposures, affect individual allostatic load, and in turn enhance
susceptibility to the toxic effects of pollution exposures. At the
bottom of Figure 1 is a variation of the exposure–health outcome
continuum that outlines how environmental toxins might cause
disease.
The framework depicted in Figure 1 implies that the presence of an environmental contaminant must first lead to human exposure and then overcome the body’s defense systems to have an adverse health effect. The internal dose may not have an adverse health effect until it achieves a biologically effective dose that depends on rates of bioaccumulation, biotransformation, elimination, and, most relevant to our discussion, an individual’s susceptibility.
C. Faust, John B. “Perspectives on Cumulative Risks and Impacts.” International Journal of Toxicology 29(1): 58–64.
Authority: Journal Article
Type: Academic Publication
Year: 2009
Definition:
- US EPA and National Environmental Justice Advisory Council
definitions of Cumulative Risk Assessment are cited in historical
overview (see row 5 and 8)
- Reference to CalEPA definition of Cumulative Impacts that reflects a shift of emphasis and interest in moving from assessments focused on specific agents or sources of environmental pollutants originating from individual facilities to a community- or geography-based assessment that considers all the stressors potentially causing impact
Social/Environmental Indicators:
Cumulative impact assessment to consider:
- Exposures, public health effects, and environmental effects
- All sources of emissions and discharges of environmental pollution
in a geographic area
- All routes of exposure
- Routine and accidental releases
- Sensitive populations
- Socioeconomic factors
Thresholds:
No specific thresholds mentioned. However, the following analysis was
made regarding thresholds in CI assessment:
In practice the CI analyses of environmental documents have commonly
been cursory (i.e., health impact assessment due to lack of guidance
with standard methodology for evaluating impacts and their thresholds of
significance). Project-based approaches may permit the attribution of
any given source of impact from pollutants in a geographic area to the
total impact and allow for the consideration of alternatives, should
impacts be considered unacceptable.
Threshold Calculations:
No specific threshold calculations mentioned.
Description of Graphic:
Pollutant categories and potential sources of relevant information and
data; image found in appendix
D. Ragas, Ad M.J. et al. 2011. “Cumulative Risk Assessment of Chemical Exposures in Urban Environments.” Environment International 37(5): 872–81.
Authority: Journal Article
Type: Academic Publication
Year: 2011
Definition:
Cumulative risk assessment is defined as “an analysis, characterization, and possible quantification of the combined risks to health or the environment from multiple agents or stressors” (US EPA, 2003). Novel exposure models are required that focus on the exposed individual or population, instead of the traditional models that focus on single substances or pollution sources (Loos et al., 2010).
A range of health issues is suspected to be related to cumulative stress (i.e., neurodevelopmental disorders can be caused by heavy metals, dioxins, PCBs and pesticides) (Brent, 2004). Childhood cancer could be related to a number of physical, chemical, and biological agents (e.g., parental tobacco smoke, parental occupational exposure to solvents) (Pg. 872).
Social/Environmental Indicators:
Predicted exposure concentrations of the 11 substances were considered
in the cumulative assessment for three different age groups (0–6 years,
18–64 years and 65+ years).
Indoor and outdoor air pollutants: PM10, benzene, toluene, nonane and naphthalene
Pesticides in food: acetamiprid, carbendazim, chlorpyrifos, diazinon, imidacloprid and permethrin
Age: assessed the cumulative health risk for different target groups, i.e. young children (0–6 years), working adults (18–65 years) and elderly (65 years and older)
Thresholds:
Comparison with standards used by (inter)national organizations to
indicate a safe or acceptable chronic exposure level for the general
population
* Benzene standard is 5 μg/m3 and PM10 is 40 μg/m3 (EU directive
2008/50/EG)
Toluene and naphthalene were taken from US EPA’s IRIS database (US EPA, 2009), i.e., reference concentrations (RfCs) of 5000 μg/m3 and 3 μg/m3, respectively
The standard for nonane was extrapolated from a occupational threshold limit value of 1050 μg/m3 (ACGIH, 1994)
For the pesticides, acceptable daily intake (ADI) values were used, being 70, 30, 10, 5, 60 and 50 μg/kg body∙day for acetamiprid, carbendazim, chlorpyrifos, diazinon, imidacloprid and permethrin, respectively (EC (European Commission, 2004, WHO (World Health Organization), 2009b)
- Additionally, an issue with threshold is whether there is a threshold below which substances do not interact. Process of analysis revealed two conclusions regarding this issue: (1) environmental quality standards are not always based on comparable health effects and, consequently (2) an assessment that is based on the violation of standards may fail to identify those substances that have the largest health impact.
Threshold Calculations:
* Threshold calculations varied per indicator and scenario. One example
baseline starting point is that the standard for nonane was extrapolated
from a occupational threshold limit value of 1050 μg/m3 (ACGIH, 1994) by
taking into account the amount of hours per week (40 versus 168 h) and
amount of years the standard is designed for (40 versus 70 years),
resulting in a maximum lifetime average daily concentration of 143
μg/m3.
- Concentration addition was calculated using a Hazard Index (US EPA, 1986), which is defined as a weighted sum of the exposure concentrations for the mixture components (Eq. (1)).
Description of Graphic:
Six tables are provided on p. 875-878 and a number of supportive
equations.
Table 1
Relative time spent by the three different target groups in five
different microenvironments (%; mean± standard deviation)
Table 2
Concentrations of the selected substances in the five different
micro-environments (in μg/m3; median [25th percentile-75th
percentile])
Table 3
Probabilities of exceeding acceptable exposure levels for three
different age groups of Urbania under the assumption of three different
mixture models: concentration addition, response addition, and a mixture
of concentration and response addition
Table 4
Qualitative assessment of interactions in binary mixtures based on a
review of toxicity and metabolic data (N0: synergism; =0: no
interaction; b0: antagonism)
Table 5
Mean values of the Hazard Index (Mean HI) and the probability that the
HI exceeds unity (P{HIN1}) under the assumption of additivity without
interactions (Additive HI) and with interactions (HIint-EPA and
HIint-MULT). See text for explanation of HIint-EPA and HIint-MULT.
Table 6
The average number of days lost after 80 years of exposure to typical
indoor and outdoor PM10, benzene and toluene concentrations in
Urbania.
E. Sexton, Ken, and Stephen H. Linder. 2011. “Cumulative Risk Assessment for Combined Health Effects From Chemical and Non Chemical Stressors.” American Journal of Public Health 101(S1): S81–88.
Authority: Journal Article
Type: Academic Publication
Year: 2011
Definition:
Cumulative risk assessment is defined as a science policy tool for organizing and analyzing information to examine, characterize, and possibly quantify combined threats from multiple environmental stressors (Pg. S81).
The terms “allostasis” and “allostatic load” have been coined to help conceptualize the cumulative biological toll taken on the human body through physiologic responses to life’s everyday stress-provoking demands.Exposure to multiple environmental agents, including biologic, chemical, physical, radiologic, and psycho-social stressors, can, under the right circumstances, modify the toxic effects of these same agents acting alone so that combined outcomes are either antagonistic (less than additive) or synergistic (more than additive) (Pg. S81).
Social/Environmental Indicators:
Four tools were discussed in the context of the three key variables: the
Cumulative Environmental Hazard Inequality Index 46 (CEHII) developed at
the University of California–Berkeley; the World Health Organization’s
(WHO’s) Urban Health Equity Assessment and Response Tool 47 (Urban
HEART); the EPA’s Community-Focused Exposure and Risk Screening Tool 42
(C-FERST); and the Environmental Justice Strategic Enforcement Screening
Tool 48 (EJSEAT) from EPA’s Office of Enforcement and Compliance
Assistance. The following social and environmental indicators were named
within the tools:
Health effects/ indicators of impact:
Exogenous agents interfere with normal development and distort physiologic function, such as neuro-behavioral abnormalities and sex steroid hormonal disruption.
Those where exogenous agents cause direct cellular damage, such as neurodegenerative diseases and cancer
Those that contribute to illness through a combination of both physiologic disruption and cell damage, for example, in cardiovascular disease (Pg S81)
Socio-demographic Variables:
- Age, race/ethnicity, income, education, occupation, uninsured, unemployed, poverty, single mother (Pg. S84-85)
Biologic vulnerabilities:
- Pregnant women, infants and young children, elderly, infirm (Pg. S85)
Environmental exposure:
- AIRS (Aerometric Information Retrieval System), NATA (National-scale Air Toxics Assessment) TRI (Toxic Release Inventory), SDWIS (Safe Drinking Water Info System) Water system, SNAP (Superfund NPL Assessment Program) (Pg. S85)
Examples of various ways the tools distribute these indicators:
WHO Urban Heart Data are collected and analyzed for two categories of
“core” indicators:
health outcome indicators, including (a) summary indicators, such as infant mortality rate and (b) disease-specific mortality/morbidity indicators, such as age-standardized diabetes death rate per 100,000 persons
indicators of social determinants of health, including (a) indicators of environmental and physical hazards associated with living conditions, such as access to safe drinking water and sanitation services (b) indicators of social and human development, such as access to education and health services (c) indicators of economic status, such as job opportunities and potential for generating income (d) indicators of good governance, such as public participation in decision-making and government spending on health
C-FERST provides aggregate exposure or risk estimates so that users can examine the data collectively as part of a semi-quantitative cumulative risk assessment where a quantitative assessment spanning multiple environmental stressors is not possible.
Suggestion: on a national scale, ID high-priority communities and populations likely to be at increased cumulative risk from exposure to a mixture of chemical and non chemical stressors. Prioritization of generic at-risk populations (e.g., children who live in disadvantaged circumstances near major sources of pollution) and locations (e.g., poor, inner city neighborhoods), or it could be done at a local scale using available information on pollution sources, ambient concentrations, and socioeconomic characteristics to distinguish high-risk situations (e.g., immigrant families who are migrant farm workers) and settings (e.g., an economically depressed community adjacent to major freeways, industrial facilities, and abandoned waste sites–for example, WHO’s HEART 47 and EPA’s EJSEAT48).
Thresholds:
No specific thresholds mentioned. However, the following three key
variables are identified as strategies for intervention of environmental
health research studies:
the magnitude, duration, frequency, and timing of human exposure to environmental stressors
the prevalence or incidence of adverse health effects caused or exacerbated by exposure to environmental agents
the link between exposure and effect, with particular emphasis on variability in susceptibility and sensitivity for both individuals and communities.
Threshold Calculations:
The Cumulative Environmental Hazard Inequality Index (CEHII) is noted as
an index used to characterize disparities in CI for relatively large
geographic regions and is suitable for application at the regional
level. CEHII combines putative effects of individual environmental
hazards using either an additive or multiplicative model, and is
calculated using the cumulative proportion of the study population,
ranked by area-based racial/ethnic and socioeconomic
composition—-starting from the most disadvantaged—-in combination with
the cumulative environmental hazard aggregated based on specific
weighting factors.
Description of Graphic:
A number of figures and charts are provided.
FIGURE 1: conceptual model for the combined effects of multiple stressors on health
FIGURE 2: conceptual model incorporating allostatic load with the combined effects of chemical and non chemical stressors on health
TABLE 1: Comparison of Quantitative Methods for Assessment of Cumulative Health Risks from Chemical Mixtures
TABLE 2: Examples of Data Sources and Geospatial Levels Available for Analysis of Cumulative Health Risks
F. Ellickson, K.M., Sevcik, S.M., Burman, S., Pak, S., Kohlasch, F. and Pratt, G.C., 2011. Cumulative risk assessment and environmental equity in air permitting: interpretation, methods, community participation and implementation of a unique statute. International journal of environmental research and public health, 8(11), pp.4140-4159.
Authority: Minnesota Pollution Control Agency (MPCA)
State: Minnesota
Type: Journal Article
Year: 2011
Definition:
Cumulative Risk Assessment ranges from the incorporation of multiple sources to multiple environmental media exposures to the inclusion of existing health outcomes. The EPA Framework for Cumulative Risk Assessment is mentioned.
MPCA process of Cumulative Levels & Effects (CL&E) analysis addresses the “cumulative” issue through consideration of: incremental impact of a single source, pollutant, and pathway; combined impact of multiple sources of a single pollutant via one pathway; combined impact of multiple pollutants from a single source via one pathway; combined impact via multiple pathways of a single pollutant from a single source; combined impact of multiple pollutants from multiple sources via a single pathway; combined impact of multiple sources via multiple pathways of a single pollutant; combined impact of multiple pollutants via multiple pathways from a single source; combined impact of multiple pollutants from multiple sources via multiple pathways.
This statute is unique in its requirement to consider cumulative risk and environmental equity in the context of air permitting.
Social/Environmental Indicators:
Three categories of indicators are hazard, exposure and health
indicators.
- Exposure indicators are primarily biomarker data.
- Health indicators are comprised of statistics describing health
status of the population.
- Hazard indicators such as traffic count for road segways to derive Vehicle Miles Traveled (VMT) using GIS data.
Thresholds:
This statute describes the following 5 clauses for analyzing cumulative
levels and effects of past and current environmental pollution.
Environment and residents of the geographic area within which the
facility’s emissions are likely to be deposited in Hennepin County will
be considered if all of the following conditions are met:
is within a 1/2mi of a site designated by the federal government as an EPA superfund site due to residential arsenic contamination
a majority of the population are low-income persons of color and American Indians
a disproportionate percent of the children have childhood lead poisoning, asthma, or other environmentally related health problems
is located in a city that has experienced numerous air quality alert days of dangerous air quality for sensitive populations between February 2007 and February 2008
is located near the junctions of several heavily trafficked state and county highways and two one-way streets which carry both truck and auto traffic (Minn. Stat. § 116.07 subd. 4a)
Primary data: categorized in the same manner as the CDC Environmental Health Tracking Program (hazard indices, exposure indices and health indices) to improve readability of the Reference Document
Hazard indicators are pollutant concentrations or other surrogates for pollutant exposures.
Data types in Table 1:
Socioeconomic data: percentage below 2 times statewide average for
percent below poverty, percent above two times statewide average for
percent non-white population, etc. (from the US Census)
Generalized data, including tobacco use and percentage of the population uninsured averages, were collected from the Hennepin County Survey of the Health of All the Population and the Environment. The data reported and described in the Reference Document are continually being updated, but are not the only data a proposer should consider. Project proposers are expected to include any additional and available data together with those data sets in the Reference Document.
Threshold Calculations:
Air emissions risk analysis is used “Computing the Nowcast”:
https://www.pca.state.mn.us/sites/default/files/nowcast-formula.pdf
Traffic density was calculated from VMT by dividing the total VMT in each census tract by the tract area (miles2).
Decription of Graphic:
The environmental health data available for inclusion in CL&E
analyses and reports are summarized in Table 1.
Data types in Table 1: socioeconomic data (percent below two times statewide average for percent below poverty, percent above two times statewide average for percent non-white population, etc.) were collected from the US Census. Finally, more generalized data including tobacco use and percent of the population uninsured averages were collected from the Hennepin County Survey of the Health of All the Population and the Environment [9]. The data reported and described in the Reference Document are continually being updated, but are not the only data a proposer should consider. Project proposers are expected to include any additional and available data together with those data sets in the Reference Document.
G. Morello-Frosch, Rachel et al. 2011. “Understanding The Cumulative Impacts Of Inequalities In Environmental Health: Implications For Policy.” Health Affairs 30(5): 879–87.
Authority: Journal Article
Type: Academic Publication
Year: 2011
Definition:
Cumulative impacts (CI) is not directly defined. However, some key
points are mentioned concerning CI:
Communities often left with the burden of proof of cumulative impacts
Disadvantaged neighborhoods may lack political clout or the capacity for civic engagement to push for regulatory action
The use of CI screening could remove this burden of proof and refocus regulatory attention on vulnerable communities (p. 883)
Social/Environmental Indicators:
Suggested indicators to use:
Health Disparities:
Perinatal Outcomes
Cardiovascular Disease
Self-Rated Health
Environmental Hazard Inequalities:
Proximity To Polluting Land Uses And Toxic Emissions
Exposures To Pollutants
Neighborhood Environments
Intrinsic Factors/Biological Susceptibility:
Age
Genetics And Gene Expression
Preexisting Health Conditions
Extrinsic Factors/Social Vulnerability:
- Race, ethnicity, socioeconomic status, and sex
- Low neighborhood-level socioeconomic status related preterm births, lower birth weight, and adult mortality (pgs 880-882)
Thresholds:
No specific thresholds mentioned.
Threshold Calculations:
No specific threshold calculations mentioned. However, there were
recommendations for gauging:
The article suggests use a diverse array of evidence for analysis (similar to Health Impact Assessment): epidemiological, qualitative observations, and physical environment. Environmental conditions, health status, and vulnerabilities of the communities affected and health impact assessments should be considered in policy and regulatory decisions (p883).
The article suggests use of cumulative impact screening to map, characterize, and target vulnerable communities for interventions that improve existing conditions and prevent future harm. Strategies that use a more place-based, holistic, and proactive approach to environmental protection are suggested.
Two examples include:
- The Environmental Justice Ordinance in Cincinnati, Ohio requires new
or expanding industrial facilities to demonstrate that they will not
cause a “cumulative adverse impact” to the health and environment of the
community in order to receive a permit (p884).
- Los Angeles is considering a “green zones” ordinance, which would use cumulative impact screening to guide municipal planning, the issuing of permits, and enforcement strategies to mitigate and reduce environmental hazards in disproportionately affected neighborhoods.
H. Ma, Zhao, Dennis R. Becker, and MichaelA. Kilgore. 2012. “Barriers to and Opportunities for Effective Cumulative Impact Assessment within State-Level Environmental Review Frameworks in the United States.” Journal of Environmental Planning & Management 55(7): 961–78.
Authority: Journal Article
Type: Academic Publication
Year: 2012
Definition:
Cumulative environmental impacts are the incremental effects of a single
action in the context of other related past, present, and foreseeable
future actions regardless of who undertakes them. Cumulative impacts can
be additive or synergistic, resulting from direct or indirect effects of
multiple activities at different locations or sequential activities on
the same site (pg. 961).
Cumulative impact assessment (CIA), also referred to as cumulative effects assessment (CEA), is the process of systematically identifying and analyzing additive or interactive environmental effects resulting from the recurrence of actions over time (pg. 962).
Social/Environmental Indicators:
Social and environmental indicators are not named. However, an
assessment of current CI methods is provided.
Existing methods used for assessing CI may not be effective. One of these common methods is a checklist, a list of project-specific environmental indicators with little or no emphasis on assessing CI’s over time and across landscapes.
When a NEPA document is challenged in court (basis: insufficient CIA in the US judicial system) technical requirements met are assessed. It is recommended that technical validity of the assessment should also be examined.
This may incentivise appropriate use of CIA methods (p.965).
Thresholds:
No specific thresholds mentioned. Cited within the text: “Because CIs
are incremental, making them difficult to discern, public awareness of
such impacts is often minimal until a critical point or threshold is
exceeded” (Tollefson and Wipond [75]).
In these 37 states, 48 active environmental review programmes have been identified across a variety of agencies, with some states having only one programme and others having multiple programmes, each responsible for specific types of development activities. Among these 48 programmes, 19 do not have any CIA requirements and 29 contain explicit provisions for incorporating CIA into their review procedures.
Threshold Calculations:
No specific threshold calculations mentioned.
Description of Graphic:
Classification of states based on environmental review policy framework
adopted, 2007.
I. Stewart, Iris T., Christopher M. Bacon, and William D. Burke. 2014. “The Uneven Distribution of Environmental Burdens and Benefits in Silicon Valley’s Backyard.” Applied Geography 55: 266–77.
Authority: Journal Article
Type: Academic Publication
Year: 2014
Definition:
Cumulative impacts are defined as the combined public health exposures
of environmental effects stemming from the sum of all emissions and
discharges from all sources in a given geographic area.
Cumulative environmental impact assessments (CEIAs) analyze the complex relationships between the distribution and characteristics of environmental pollutants and diverse populations. All releases are integrated (routinely or accidently) and sensitive populations and socio-economic factors are considered (OEHHA, 2010). Additionally, spatial analysis is used to link human health exposures and sometimes health outcomes to land use patterns.
Social/Environmental Indicators:
Three indices provided: Social Vulnerability Index (SVI), Environmental
Hazards Index (EHI), and Environmental Benefits Index (EBI). These were
developed at the census tract scale (Census 2010) and combined into a
CEIA using GIS-based models (described in text T. 1). 372 census tracts
in Santa Clara County identified (average size and population of 3.5sq
mi and 4789 people). Data for the indices was compiled from government
sources, non-profit organizations, and mapped from aerial imagery. This
combination resulted in a CEI score which reflects the combined impact
of social vulnerability, environmental hazards, and lack of access to
environmental benefits. The relationship between environmental hazards,
access to environmental benefits, and measures of social vulnerability
was explored through correlation analysis.
Social Vulnerability Index:
Age
Language
Poverty
Education
Renter Status
Environmental Hazards Index:
Superfund (CERCLIS)
National Pollutant Discharge Elimination System (NPDES)
Resource Conservation and Recovery Act (RCRA)
Toxics Release Inventory System (TRI)
National Air Toxics Assessment (NATA) Cancer Risk
National Air Toxics Assessment (NATA) Respiratory
Airports
Freeways
National Highway Planning Network
Railroads
Intermodal Distribution
Pesticides
Environmental Benefits Index:
City Parks
County Parks, Open Space, Preserves(Pg. 269)
Thresholds:
Roadway-related air pollution: returns to background levels in 150–570 m (∼500–1870 ft) (Karner, Eisinger, & Niemeier, 2010)
Distance related changes in pollutant concentrations: greater than a 50% decrease in the edge-of-road concentration by 150 m (∼500 ft), followed by a gradual decay (e.g., carbon monoxide, some UFPs); consistent decay (e.g., benzene, nitrogen dioxide); or no trend with distance (e.g., particulate matter mass concentrations) (Karner et al., 2010, Merbitz et al., 2012). Thus a complex pattern of air pollutants exists around freeways.
Threshold Calculations:
- Buffers applied: to attempt to account not only for air pollution, but also noise impact, decreases in walkability, community cohesion, and safety from traffic. To arrive at the Environmental Hazard Index (EHI) score for each census tract the following was done: (1) summed the overlapping buffer weights for all hazard features in the study area (2) each distinct summed weight was then multiplied by the fraction of the area of the census tract that weight covered (3) the resulting values were then summed by census tract.
Total hazard score calculation:
- Subsequently, the total area-weighted hazard score per census tract was calculated by summing over all environmental hazard factors affecting a census tract, as given in equation 1 described in detail further. EHI is used to find complex air patterns around freeways and is expressed as the following (image included).
where: EHICT = Environmental Hazards Index score per census tract wi = Distinct buffer weight from overlapping hazards
n = Number of distinct weights occurring within a census tract.
Ai= Area in a census tract with weight wi [L2]
A Total= Total area of the census tract [L2]
SVI, EHI, and EBI described, mapped and charted in tables figures 1-5
Description of Graphic:
Environmental Hazards Index score per census tract, previously described
in threshold calculations
J. Cushing, Lara et al. 2015. “Racial/Ethnic Disparities in Cumulative Environmental Health Impacts in California: Evidence From a Statewide Environmental Justice Screening Tool (CalEnviroScreen 1.1).” American Journal of Public Health 105(11): 2341–48.
Authority: Journal Article
State: Overview of California tool: CalEnviroScreen 1.1
Type: Academic Publication
Year: 2015
Definition:
Cumulative impacts (CI) is not directly defined. However, references
CalEnviroScreen as a cumulative impact measurement tool.
- A CI approach that considers differential vulnerability and environmental stressors is important for assessing racial/ethnic environmental health disparities. Communities of color in the US experience lower average levels of education, wealth, and for some groups, higher rates of chronic health conditions that increase susceptibility to environmental health hazards.
Social/Environmental Indicators:
Consideration of pollution burden and population vulnerability:
Exposures:
- Ozone
- PM 2.5 ( 𝜇g/m3)
- Diesel PM
- Pesticide use
● Toxic releases
● Traffic density
Environmental Effects:
- Clean-up sites
- Groundwater threats
- Hazardous waste sites
- Impaired water bodies
- Solid waste sites
Sensitive Populations:
- Age: children and elderly
- Asthma
- Low birth weight
Socioeconomic Factors:
- Educational attainment
- Linguistic isolation
- Poverty (pg. 2342)
Thresholds:
CalEnviroScreen 1.1 combines 17 indicators created from 2004 to 2013 publicly available data into a relative cumulative impact score.
CI scores were compared across CA zip codes on the basis of their location, urban or rural character, and racial/ethnic makeup. The concentration index was used to evaluate which indicators were most unequally distributed with respect to race/ ethnicity and poverty.
Threshold Calculations:
Pollution Burden score (0-10) X Vulnerable Population Score (0-10) =
Cumulative Impact Score (0-100)
To arrive at the CI score, zip codes were assigned across CA a percentage ranging from 0 to 100 on the basis of their value for each indicator. Then percentages were averaged and divided by 10 to derive separate scores for pollution burden (0–10) and population vulnerability (0–10). Scores were then multiplied to arrive at a final relative CI score that ranged from 0 to 100 (Figure 1).
Formula for standard concentration index proportional to the area between the concentration curve and the diagonal line of equality found (p. 11)
Description of Graphic:
Visual description of threshold calculation
K. Gislason, Maya, and Holly Andersen. 2016. “The Interacting Axes of Environmental, Health, and Social Justice Cumulative Impacts: A Case Study of the Blueberry River First Nations.”Healthcare 4(4): 78.
Authority: Journal Article
Type: Academic Publication
Year: 2016
Definition:
- Cumulative Impacts are “changes to the biophysical, social,
economic, and cultural environments caused by the combination of past,
present and ‘reasonably foreseeable’ future actions. CI can be positive
or negative” (pg. 2).
- Variables to understand CI must reflect the realities and domains of relevance for the people and places that are impacted.
Social/Environmental Indicators:
The study qualitatively considers environmental, health, and social
justice impacts of various projects. Examples of each are provided:
Environmental considerations in the context of a large-scale hydropower
dam project include loss of bear habitat, mercury contamination, and
downstream effects health considerations include housing and food
instability, mental health, and three cornerstone impacts expressed
within Indigenous Determinants of Health scholarship, which are the
impacts of intensive natural resource extraction (IRE) on the
community’s: 1. connection to land 2. cultural continuity 3. ongoing
impacts of colonization social justice considerations include stability
of the resource economy, loss of hunting rights, the burden of
consultation for multiple EAs/IRE projects.
Measuring impact by a collection of indicators is referred to as discrete and dis-aggregated. Specifically, indicators assessed separately in terms of a threshold vs measuring impact cumulatively across a range of indicators where the overall impact of the indicators is considered in addition to whether any individual indicator crosses a threshold is questioned for its environmental ethics. Regarding environmental ethics, taking a reductionist approach may be inappropriate for biological systems including ecosystems.
Indicators serve to stand in for the axis as a whole. The way in which these indicators are chosen, how they are measured, and how impacts on them are assessed, comprise the methodology used to maintain the integrity of each axis.
Thresholds:
No specific thresholds mentioned. Information that may inform thresholds
includes:
The impacts of Intensive Natural Resource Extraction (IRE) are of concern at present but will also have an effect on future generations—-a fact which underscores the moral imperative of addressing these issues with focus and a sense of urgency, particularly in light of the possibility that thresholds and tipping points in the region may have already been reached.
According to BRFN members, cumulative industrial effects include, but are not limited to, the following changes:
Less water, dried up springs and creeks (waterway impacts of forestry and other landscape changes, surface and groundwater extraction by the oil and gas industry)
Contaminants in water, air, animals, and plants (from source including but not limited to: oil and gas well sites, flaring, spraying, hydroelectric dams, and agricultural runoff)
Access roads, seismic lines, well sites, and other land disturbances (p. 28).
Threshold Calculations:
No specific threshold calculations mentioned.
Capping pollutant release to certain threshold levels for indicators measuring environmental impacts fails to measure these further impacts on health and social justice, such as the intersecting social justice axis through the impedance of full exercise of traditional treaty rights (e.g., the right to hunt game and fish freely on BRFN lands is effectively abrogated when the game and fish cannot be safely consumed or even processed in clean waters in traditional ways).
Description of Graphic:
This map shows the cumulative impacts of industrial development
activities in 2015 in the Blueberry River First Nations traditional
territory.
L. Solomon, Gina M., Rachel Morello-Frosch, Lauren Zeise, and John B. Faust. 2016. “Cumulative Environmental Impacts: Science and Policy to Protect Communities.” Annual Review of Public Health 37(1): 83–96.
Authority: Journal Article
Type: Academic Publication
Year: 2016
Definition:
Cumulative impacts (CI) is not directly defined. However, four key
concepts underlying cumulative impacts are outlined, including:
- Health disparities are linked to social and environmental factors
for many diseases.
- Inequalities in exposures to environmental hazards are
significant.
- Intrinsic biological and physiological factors can modify the
effects of environmental factors.
- Extrinsic social vulnerability factors at the individual and community levels may amplify the effects of environmental hazards (pg. 84).
Social/Environmental Indicators:
The paper discusses multiple methods for measuring CI. Some cumulative
impact assessment methodologies focus on populations or geographic
areas, whereas others evaluate the impacts of emission sources,
chemicals, policies, or programs. Few approaches to cumulative impacts
aim to incorporate all types of stressors and vulnerabilities. Several
examples of the types of indicators used in various methods include:
Environmental Justice Screening Method (EJSM) which maps CI using a large set of health, environmental, and social vulnerability measures organized in five categories:
- hazard proximity and land use
- estimated air pollution exposure and health risk
- social and health vulnerability
- climate change vulnerability and
- drinking water quality.
The method results in a cumulative ranking based on all the census tract–level indicators, which is then presented visually as statewide and regional maps (p. 90).
Some researchers have taken the concept of effect biomarkers one step
further by proposing that cumulative impacts may soon be measurable as
“neighborhood-specific epigenetic markers” (p. 92).
Mention of other indicators:
Intrinsic vulnerability: genetic susceptibilities, underlying chronic health conditions (Pg. 85)
Extrinsic factors: poverty, food insecurity, poor housing quality, linguistic isolation, exposure to violence, and poor neighborhood quality can heighten vulnerability to environmental agents and outdoor pollutants such as ozone (Pg. 84, 85)
Cumulative physiologic degradation (allostatic load) resulting from chronic stress and exposure may result in long-term shift’s in homeostatic functions
Socioeconomic factors contributing to allostatic load: residential crowding, noise, poor housing quality, exposure to violence, or experiences of racial discrimination
Adverse effects of environmental chemical exposures due to allostatic load may be amplified (e.g., lead exposure on risk of hypertension among adults and the effect of housing quality on asthma risk in children) (Pg. 85)
Environmental factors included in the Global Burden of Disease (GBD): infectious diseases, malnutrition, and water quality, indoor and outdoor air pollution, lead poisoning, tobacco use, and occupational exposure to carcinogens, particulates, and noise (3). The Disability-adjusted life year (DALY) has been used in several studies to comparatively and quantitatively assess the CI of environmental pollution.
Thresholds:
No specific thresholds mentioned. Rather this is an analysis of how
health risk assessment is limited by the need for numerical estimates of
risk.
Data limitations make single chemical as well as multiple stressor tests difficult. Assumptions built into assessments may bias toward underestimation of CI (e.g., risk assessments of non carcinogens utilize a model that assumes a safe threshold in the population below which no health effects would occur). However, complex background exposures, when combined with differential vulnerability, may invalidate such thresholds.
Threshold Calculations:
Methodologies differ in the degree to which they require quantitative or
qualitative data, as well as the degree of community engagement they
include. Some quantitative approaches discussed in paper include:
Environmental Justice Screening Method (EJSM): calculates the total score and enables review of each of the five categories separately, which facilitates uses tailored to various decision contexts
EJSM included a process of ground-truthing results in which community partners, supported by researchers, gathered data about pollution sources and their proximity to concentrations of people, such as the elderly, young children, and people with chronic health conditions, who are most vulnerable to pollution (p. 90).
Burden of Disease: the original Global Burden of Disease (GBD) study was published in 1993 and included quantitative estimates for 107 diseases and 483 nonfatal health consequences (73). A 2013 update presents estimates of all-cause mortality, deaths by cause, years of life lost, years lived with disability, and disability-adjusted life years by country, age, and sex for 323 diseases and injuries, 67 risk factors, and 1,500 sequelae for 188 countries (24,30).
Disability-Adjusted Life Year (DALY): is a time-based measure that combines years of life lost due to premature mortality and years of healthy life lost due to disability which can address the need to capture a composite metric of both premature mortality and the prevalence and severity of ill health. Advantages to the DALY approach: composite metric that captures both premature mortality and the prevalence and severity of ill health.
Description of Graphic:
This figure shows the different approaches to cumulative impacts
analysis, which are illustrated by six widely used approaches:
biomonitoring, health risk assessment, ecological risk assessment,
health impact assessment, burden of disease, and mapping of cumulative
impacts.
M. Payne-Sturges, D. C., Sangaramoorthy, T., & Mittmann, H. (2021). Framing Environmental Health Decision-Making: The Struggle over Cumulative Impacts Policy. International journal of environmental research and public health, 18(8), 3947.
Authority: Journal Article
State: Maryland
Type: Academic Publication
Year: 2021
Definition:
Research concerning the CI policy impasse in Maryland shows that the
lack of a common definition as well as its conceptual complexity further
complicated how it became understood and interpreted as a health issue
in the policy arena. Study also found that policy-relevant actors’
framings of “affected” communities—-largely low-income and racial
minority populations—-and racial disparities in health also hindered
policy progress on cumulative risks. Bill opponents contested bill
proponents’ claims of disproportionate pollution impacts and
discriminatory regulatory enforcement by framing cumulative impacts as
also stemming from inherent individual behaviors, lifestyle factors, and
economic inequalities of communities themselves.
Social/Environmental Indicators:
No specific CI indicators mentioned. However, indicators and tools to
measure CI were referenced as a key finding: “A number of screening or
surveillance tools to identify “overburdened” communities exist, and
such mapping may help guide prioritization of local level environmental
health interventions and investments to protect disproportionately
exposed or vulnerable populations. Yet, the almost exclusive
institutional focus on developing mapping algorithms and other risk
assessment methods as solutions to “cumulative” contributes to
disagreements over how to define “overburdened communities,” what forms
of evidence and expertise are considered valuable, trustworthy and
credible in policy deliberations that attempt to frame environmental
issues as public health challenge, inducing a type of “paralysis by
analysis,” where the process of attempting to assess risk significantly
slows down or even prevents government interventions.”
Thresholds:
No specific thresholds mentioned.
Threshold Calculations:
No specific threshold calculations mentioned.
Description of Graphic:
Detailed comparison of language and requirements from three cumulative
impacts bills considered by Maryland State Legislators between 2014 and
2016
Evolution of proposed cumulative impacts legislation in Maryland 2014–2016.