It’s time to change the way we measure pollution

For decades, Democrats and Republicans have disagreed on the role and size of government. No federal agency captures this fissure more than the Environmental Protection Agency (EPA) and the changing scope of environmental regulations. 

However, as much as political parties have disagreed, President Donald Trump’s actions are without parallel since the EPA was created 50 years ago by Richard Nixon, a Republican. Gutting more than 100 clean air, clean water and toxic chemical environmental protections, the Trump administration has taken a dangerous approach.  

Many Americans are paying more for health care, experiencing decreased quality of life and are dying from COVID-19 at higher rates because of harmful pollution. Vulnerable communities in particular, continue to be disproportionately exposed to this pollution. Given this, as we honor and reflect on the EPA’s 50th anniversary, we must envision a world in which the EPA not only protects our environment, but also our health and our neighborhoods. This will require new tools and new approaches. President-elect Joe Biden, will have the monumental task of not only reinstating many of the crucial environmental protections that have been cut and rebuilding the morale of the EPA and White House Council for Environmental Quality, but he will also have the task of furthering the cause of environmental justice in an unprecedented manner. In order to truly clean up our air and protect all communities from toxic pollution, regulators will need to fundamentally shift the way pollution is measured. 

Years of redlining, residential segregation and other forms of injustice have disproportionately placed environmental burdens on minority communities. In Michigan, for example, these communities make up 25 percent of the state’s population but two-thirds of those living next to hazardous waste facilities. Despite the fact that the EPA civil rights regulations prohibit environmental permit decisions that have a discriminatory effect, the agency has been slow to investigate complaints of racial discrimination. While addressing the legacy of environmental injustice will certainly require greater funding and increased capacity, root causes can be addressed if the EPA works to fundamentally shift the way pollution is measured and regulated. Adjusting the facility permitting process to be more community centered and to account for cumulative impacts of air pollution is a great way to address these long standing disparities. 

When polluting facilities apply for state and federal permits, their permits are evaluated on an individual, facility by facility basis, despite the fact that neighboring communities experience pollution from multiple sources. That is, if Company A submits a permit to emit pollution under emissions standards, their permit is evaluated with limited to zero consideration for the fact that company A, B and C are all located right next to each other, also emitting pollution, with a community stuck in between. In this sense, air quality regulations are enforced to keep companies compliant, not to keep communities safe. This is misguided. Communities like Detroit’s 48217 zip code, “Cancer Alley” in Louisiana and Houston’s East End have been deemed “sacrifice zones” by researchers, scientists and advocates because they illustrate the shortcomings of measuring pollution facility by facility. Measuring cumulative impacts could help turn this tide and New Jersey, which recently passed landmark legislation to permit individual facilities by accounting for cumulative pollution and health impacts in overburdened areas, could provide a valuable roadmap at the federal level. Some may cry foul, but this is not a novel concept. It’s harder to go to restaurants, nightclubs, and the movies when the building is already packed. If fire marshals can limit the number of attendees in a crowded building to prevent injury, environmental regulators should be empowered to limit industrial facility expansions when it places communities in harm’s way. 

EPA regulations that work to ensure that all communities have clean, healthy air to breath also need to be dramatically improved. Currently, guided by National Ambient Air Quality Standards, the EPA measures six chemicals that are said to impact health. These chemicals include particulate matter (PM), lead, sulfur dioxide, ozone, carbon monoxide, nitrogen dioxide and are associated with higher rates of asthma, cancer and other health conditions. Current standards dictate what the EPA considers safe concentrations of each pollutant to protect public health. One glaring gap is that these pollutants are regulated individually, despite causing common health impacts. For instance, a city could have near limit concentrations of sulfur dioxide and near limit concentrations of PM and still be compliant with EPA regulations even if these concentrations cause adverse health impacts when experienced together. 

Imagine if dietary guidelines, which currently recommend 2,000 calories per day, allowed you to eat 1,999 calories worth of ice cream, 1,999 calories worth of apples and 1,999 calories worth of bacon all in one day. That is the current state of National Air Quality Standards. A good diet requires a full accounting of the calories a person eats in the day, even when it comes from multiple sources. Moving forward, rather than simply setting one standard for safe particulate matter exposure and another standard for safe levels of ozone or sulfur dioxide exposure, the EPA should set a health standard that accounts for exposure to several of these chemicals together, since they all can cause respiratory health effects. Much like dietary intake guidelines account for the fact that someone may eat several types of food to reach the recommended 2000 calories per day, the EPA should develop health standards that dictate safe maximum pollution exposure that accounts for exposure from several individual pollutants that cause similar health impacts. 

No community should have to suffer increased asthma rates, cancer rates and other health burdens associated with pollution. To this end, the Biden administration’s EPA regulators will have the task of better protecting public health and addressing deeply rooted disparities in every aspect of environmental and climate policymaking. While making these changes will require fundamental shifts in the way the EPA measures and regulates pollution, to address long standing environmental injustice and to secure clean air for all Americans, these are reforms worth making. 

Justin Onwenu is an organizer for The Sierra Club in Detroit. He is also a Public Voices fellow of the OpEd Project and the Yale Program on Climate Change Communication. You can connect with him on Twitter at @JustinOnwenu.

Nicholas Leonard is the executive director of the Great Lakes Environmental Law Center, a Detroit-based environmental law nonprofit. GLELC regularly represents Michigan residents and organizations confronting environmental injustice.