Abstract
In 2008, the statute authorizing the Minnesota Pollution Control Agency (MPCA) to issue air permits was amended to include a unique requirement to analyze and consider “cumulative levels and effects of past and current environmental pollution from all sources on the environment and residents of the geographic area within which the facility’s emissions are likely to be deposited.” Data describing the Statute Area suggest it is challenged by environmental and socioeconomic concerns, i.e., concerns which are often described by the phrase ‘environmental equity’. With input from diverse stakeholders, the MPCA developed a methodology for implementing a cumulative levels and effects analysis when issuing air permits in the designated geographic area. A Process Document was created defining explicit steps a project proposer must complete in the analysis. An accompanying Reference Document compiles all available environmental health data relevant to the Statute Area that could be identified. The final cumulative levels and effects methodology is organized by health endpoint and identifies hazard, exposure and health indices that require further evaluation. The resulting assessment is summarized and presented to decision makers for consideration in the regulatory permitting process. We present a description of the methodology followed by a case study summary of the first air permit processed through the “cumulative levels and effects analysis”.
Highlights
Cumulative risk assessment is growing and evolving, driven by scientific findings, public concern, expanded data availability, and practical experience
The screening factors identified above are used to identify human health endpoints for inclusion in a Cumulative Levels and Effects (CL&E) analysis
The question and answer period lasted longer than originally envisioned, and included complex and far-ranging questions. Some of these questions were: Are there other countries doing this?; Could we focus on avoiding hazards, rather than assessing risk?; Do environmental laws include background pollutant levels in the populations?; Who makes permitting decisions and how does that process work?; What is your educational background?; Does your agency require ethics courses?; and If Minnesota Pollution Control Agency (MPCA) can’t do the analysis described in law, how can you issue any permit for this area?
Summary
Cumulative risk assessment is growing and evolving, driven by scientific findings, public concern, expanded data availability, and practical experience. Environmental health-related agencies are under pressure to be responsive to public comments, concerns, and requests based on this growing awareness. At the same time scientific investigations of cumulative risks have become increasingly complex; progressing from investigations of aggregate exposures (phthalates); exposures to multiple yet similar chemicals (organophosphate pesticides) or more complex substances (e.g., particulate matter); to, more recently, the interaction between chemical exposures and non-chemical stressors. The term “stressors” in this definition is a physical, chemical, biological, or other effect that can cause an adverse response in a human or other organism or ecosystem (e.g., socioeconomic status, existing exposures, existing health outcomes, etc.). The word “agents” describes chemical, biological or physical exposure entities (e.g., radon, nitrogen dioxide, a virus, etc.). The MPCA used the EPA’s definition described above as the appropriate starting point for development of a cumulative risk assessment method due to the broad language in the statute
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