Cumulative Impacts of Pollution:  The Need for Government Decision-Making to Consider the Combined Impact of Pollution From Multiple Sources on Public Health of At-Risk Populations

Many low-income, working class and communities of color are impacted by multiple pollution sources that combine to have cumulative, harmful impacts on public health and air and water quality. Current regulation of public health risk ignores the overall impact of the cumulative effect of exposure to multiple pollutants from numerous sources over time.

Cumulative impacts are the impacts on a community of the sum of all stressors experienced including multiple toxic pollution sources (mobile and stationary); unhealthy and unsafe housing; lack of jobs; gentrification; poverty, widespread health problems, and other similar stressors on people’s health and well-being.

Unfortunately, government regulatory agencies and the laws governing pollution do not truly consider these cumulative impacts in their decision-making on permit decisions or regulations about how much pollution is actually “acceptable” or “safe.”  Government environmental and health assessments typically evaluate a specific pollution source in a vacuum without considering the scientific reality that other pollution sources and environmental stressors in an area can combine to create a new, elevated and unsafe health risk.

Greenaction works on regional, state and federal levels to encourage government agencies to adopt enforceable measures to reduce cumulative impacts of pollution and to adopt rules that require cumulative impacts to be considered in permit and other regulatory decisions.

Greenaction is a leader in the Bay Area Environmental Health Collaborative and the San Joaquin Valley Cumulative Health Impacts Project, two regional coalitions focused specifically around advocacy to encourage government agencies to evaluate and reduce cumulative impacts on public health of our most vulnerable and at-risk communities.

Greenaction and our allies are calling on regulatory agencies to:

1.       Adopt Cumulative Impact Criteria & Precautionary Approach:

Adopt enforceable measures to evaluate, limit and reduce cumulative health risks. Revise risk evaluation procedures to assess whether exposures may cause, contribute to, or exacerbate adverse cumulative health impacts for affected residents. Re?define what is considered a “significant” risk to incorporate cumulative exposures. Acknowledge the flaws of regulatory review when cumulative impacts are not considered.

2.       Establish Pollution Caps/Limits:

Limit air pollution levels by establishing caps in highly impacted areas, prioritizing communities with high risks or exposure levels, and areas where residents may be particularly vulnerable to the adverse health effects of pollution. Adopt enforceable regulations to ensure caps are achieved. Regulate and limit pollution from substantial indirect (“magnet”) sources.

3.       Promote Pollution Reduction & Prevention:

Target high?risk sources for pollution reductions. Encourage and support investment in less toxic alternatives. Partner with industry to develop reduction plans. Provide incentives to companies that transition to safer technologies and practices.

4.       Prioritize High Impact Areas & Vulnerable Populations:

Focus regulatory efforts on areas with high health risks and disparities, where residents are particularly vulnerable to the harmful effects of pollution due to social, economic or other factors. Invoke authority to establish special zones in areas impacted by heavy pollution. Target enforcement in high?risk areas, and at problematic facilities.

5.       Meaningful Public Participation:

Community Outreach & Involvement. Engage communities at every stage of decision?making and ensure that residents’ views are incorporated. Conduct comprehensive outreach in accessible, understandable languages and formats. Be responsive to community concerns and interests. Provide residents a real opportunity to influence outcomes.

6.       Government Should Assert Leadership; Initiate Collaboration, Innovation:

Invoke authority to protect residents from the adverse impacts of accumulated exposures to pollutants, even where no model may exist. Assert leadership and collaborate with local, regional and state regulatory agencies to safeguard community health and ensure that incompatible land uses are addressed and avoided. Develop new strategies and adopt strong measures to reduce disparities and ensure strong health protections for all residents