We (Still) Have the Science on Cumulative Impacts

Advocates for environmental policies aim to enhance the health and quality of life for themselves and their communities. These policies are crucial, as their effectiveness relies heavily on the quality of information considered during their formulation.

While using limited data might be sufficient for addressing small-scale issues, the health of both humans and the environment is influenced by a complex web of interconnected factors. Ignoring these connections results in policy decisions made without full insight.

Lacking comprehensive information and a wide-ranging perspective, it becomes easy to overlook the significance of individual reductions in public health protections or assume that a single facility emitting additional pollution won’t significantly impact nearby residents. The Trump administration’s scientific policies have focused on restricting the data considered, concealing the potential harm of weak or absent regulations.

This underscores the need for cumulative impacts policies. These require an assessment of multiple stressors and burdens to ensure decisions are thorough, effective, and fair.

A cumulative impacts policy holds up in court

New Jersey pioneered the implementation of a cumulative impacts policy for environmental permitting. The law empowers the New Jersey Department of Environmental Protection (NJ DEP) to impose conditions, restrict, or even refuse permits for construction or expansion of facilities, such as factories or power plants, if they exacerbate existing stressors above those in other areas. These stressors include air pollution, soil and water contamination, and access to environmental resources like green spaces and open recreation areas.

Advocates for robust environmental health protections focus on two key questions: does a policy reduce pollution levels, and does it address inequities in pollution exposure between communities? This latter point is vital, as low-income communities and communities of color have historically faced greater pollution burdens.

Recently, a scrap metal industry and a labor union challenged New Jersey’s Environmental Justice (EJ) law in appellate court. However, the court unanimously affirmed that the agency acted within its regulatory authority and legal intent when developing the regulations. This ruling, along with the policy’s development process, is expected to encourage cumulative impacts policies in other areas.

An ever-growing body of science

Legal mandates and court rulings like New Jersey’s influence the progress of cumulative impacts policies, as does ongoing scientific advancement. I have been engaged in research and discussions on cumulative impacts since working on Minnesota’s first cumulative impacts law in 2009. Initially, critics dismissed these policies as unscientific or overly complex. Until recently, my discussions often countered these misconceptions by highlighting validated methods, existing policies, and supporting scientific evidence.

Since then, researchers and environmental advocates nationwide have contributed to a deeper scientific understanding of cumulative impacts. This field has grown so substantially that the National Academies of Science, Engineering, and Medicine (NASEM) published a report titled “State of the Science and the Future of Cumulative Impact Assessment,” requested by the US Environmental Protection Agency (EPA) under President Biden. However, the Trump administration halted the project before its final editing, reflecting a broader pattern of undermining federal science.

What is the state of the science of cumulative impacts?

NASEM issues state-of-the-science reports at the request of federal agencies, covering topics such as U.S. health research, education statistics, and infrastructure. These reports answer “charge questions” posed by these agencies. Authored and reviewed by expert panels, these reports are disseminated online, in print, and through public webinars. The foundational questions for the CI State of the Science explored how past EPA efforts on cumulative impacts inform current practices, what data types should be used in assessments, how communities react to stressors, and how to integrate local and Tribal knowledge. Additional questions examined uncertainty characterization and scaling assessments from local to national levels.

Notably, the NASEM committee emulated its recommendations for conducting CIAs in its report preparation. Before drafting, the committee held sessions to gather input from individuals affected by multiple pollution sources and those studying or formulating cumulative impacts policies. Demonstrating transparent engagement, the NASEM report includes workshop proceedings. Unfortunately, the Trump administration canceled the project before a planned Tribal engagement session.

Cumulative impacts assessments involve integrating qualitative data, such as personal experiences, with quantitative data like pollution levels or population proximity to contamination sites. This mixed methods approach aims to provide comprehensive research answers. The report’s authors applied this approach, incorporating participant quotes to elucidate concepts. The report, exemplifying transparency, details:

• The evolution of cumulative impacts practice, including the diverse information types used in creating CIAs, such as environmental, regulatory, and health assessments, risk assessments, and community assessments.
• Exploration of qualitative and quantitative data from urban, rural, and Tribal communities needed for cumulative impact assessments.
• Methodologies and frameworks for synthesizing and analyzing these data types to reflect community stressor and burden interactions.
• Discussions on factors affecting health, emphasizing the inclusion of both stressors and resources.

A real-world understanding of complex problems

The primary aim of cumulative impacts policies is to connect people’s real-life experiences with the decisions impacting their health and environment. In its final chapter, the NASEM report showcases CIA examples:

• It explores Louisiana’s region known as “Cancer Alley,” where numerous pollution sources impact a community already facing economic, health, and social challenges.
• It presents a CIA approach using varied data types to evaluate the adequacy of resources like housing in diverse communities, including urban and rural tribal areas.
• It discusses potential CIA applications in chemical disaster scenarios, such as the East Palestine, Ohio train derailment, and suggests a cumulative impacts strategy for enhancing community resilience against frequent wildfires.
• These case studies illustrate how CIAs can mitigate environmental hazards and injustices.

Throughout the report, the authors encourage the EPA to advance cumulative impacts research, develop its framework document, and utilize existing CIAs to advocate for pollution reduction. Despite the Trump administration’s apparent deprioritization of healthier communities and environments, state and local governments can adopt cumulative impacts strategies. Individuals can contribute by sharing the NASEM report with local environmental agencies. The National Caucus of Environmental Legislators and the Tishman Center at the New School actively monitor state and local cumulative impacts policies. Explore your area’s progress and inform them about the NASEM report!