EDF Health

Petrochemical pollution doesn’t affect communities equally. Better regulations can help.

By Michelle Allen / Published: July 3, 2023

By Michelle Allen, Manager, Community Engagement

Recent high-profile chemical disasters in East Palestine, Ohio, and Deer Park, Texas, have highlighted the risks facing communities where the petrochemical industry operates, but not every spill or toxic pollution release makes headlines. By some counts, there is a chemical fire, explosion or release every other day in this country.

As countries around the world invest in strategies to reduce carbon pollution and rely less on fossil fuels, the oil and gas industry has turned to petrochemicals as an opportunity for growth. Petrochemicals are chemical derivatives refined from petroleum, and they’re found in products we use every day: from water bottles and plastic cases on our phones to paints, fertilizers and carpets.

But images of billowing black clouds of smoke hanging over homes, schools and parks in communities from Appalachia to the Gulf Coast are a reminder that our everyday products—many of which are for the sole purpose of convenience—are not without cost. And too often, these costs are borne by someone else.

Communities are exposed to health risks from petrochemical pollution

Exposure to petrochemical pollution—from acute events like these environmental disasters, but also from prolonged exposure to these air toxics, day in and day out—puts communities at risk. But communities don’t experience these risks equally. Black and brown communities and low-income areas bear the brunt of this unequal and unjust pollution. Children, pregnant people, seniors and people with existing medical conditions are especially at risk of developing a host of health issues from exposure to this toxic pollution, including cancer, respiratory illness, asthma and more.

Communities on the frontlines of petrochemical pollution have long expressed that they have the right to know what’s in the air they’re breathing so they can take action to protect themselves and demand accountability from decisionmakers and industry. A newly proposed update to regulations in the Clean Air Act is a significant step in the right direction.

New EPA proposal would help hold polluters accountable

The Environmental Protection Agency has proposed stronger regulations for some 200 petrochemical facilities throughout the country, more than half of which are concentrated in Texas and Louisiana. These proposed rules include safeguards against petrochemical pollution that advocates have long called for: more air-quality monitoring at the fence line of facilities, stronger protections against flaring, and actions to close loopholes that allow facilities to violate regulations during periods of startup, shutdown and malfunction.

Dedicated community leaders have been leading the fight against this pollution for decades, and it’s great to see the Administration meet these efforts with long overdue protections. We need stronger regulations at the local, state and federal levels to protect the health of residents and require regulators to hold polluters accountable to the communities where they’re operating.

The additional transparency and accountability that will come from these protections are especially critical because many of these facilities have a documented history of breaking the law: our analysis shows that more than half of the facilities expected to be impacted by this proposal are currently violating at least one environmental law, and more than 80 percent have been out of compliance in the last three years.

Strong federal protections are needed to safeguard community health

We urge EPA to adopt a strong final version of this rule that is truly protective of public health. Requiring fence line monitoring to cover a greater number of chemicals and facilities, for example, would help hold polluters accountable and prevent further harm to communities.

EPA’s proposal is a critical step in the right direction—a foundational safeguard that can ground additional layers of protection for communities impacted by petrochemical pollution. Strong federal protections should be part of a comprehensive strategy to help communities achieve a healthy, thriving future for generations to come.

Also posted in Air pollution, Chemical exposure, Environmental justice, Health policy, Health science / Authors: / Comments are closed

Lead pipe survey flaws reveal that states may not be getting their fair share

By Roya Alkafaji / Published: June 29, 2023

An estimated 9.2 million homes and buildings in the nation get their drinking water through a lead pipe, according to EPA’s April 2023 report. The agency estimated the number of lead service lines (LSLs) in each state to arrive at the country’s total.[1]

Based on these estimates, each state was allocated a share of the almost $3 billion in state revolving fund (SRF) resources dedicated to LSL replacement in the current federal fiscal year (FY23). As explained in EDF’s blog about EPA’s announcement, two states had surprisingly high numbers: Florida with 1.2 million LSLs and Texas with 650,000.

To better understand the driving force behind the estimates, we dug into a dataset containing the majority of utility and state responses to the LSL portion of the EPA survey. This data is readily available because of a Freedom of Information Act (FOIA) submission by the Natural Resources Defense Council seeking the survey responses.[2]

First impressions

With some exceptions that we’ll address in a moment, the LSL estimates reported by states and utilities were consistent with our expectations.[3] However, we also came across significant discrepancies in three key states that prompted us to investigate further.

Overall, there are three distinct problems that need untangling and warrant attention more broadly: data entry errors, conflicting state and utility information, and inconsistent directions by the state.

To its credit, EPA recognized these issues as well and plans to offer states and utilities an opportunity to revise their survey responses this fall. Those responses will then be used to allocate the remaining $9 billion dedicated to LSL replacement in FY24, FY25, and FY26. Based on what we found for Florida and Texas alone, we may have roughly 1.6 million fewer LSLs than originally estimated – good news overall.

About EPA’s survey

Every four years, EPA conducts a voluntary survey to estimate the nation’s drinking water infrastructure needs and allocate funding provided by Congress to address these needs. In 2021, EPA conducted the 7th Drinking Water Infrastructure Needs Survey & Assessment (DWINSA), which for the first time ever included information on LSLs.[4]

EPA reports that about 75% of large and medium utilities responded to the LSL portion of the survey. State agencies coordinated collection and submission of the information to the EPA. Because of the FOIA response, we have access to what EPA described as “raw, unadjusted LSL Inventory data uploaded to the [DWINSA] Website as of October 25, 2022.”[5]

As explained in the agency’s FAQs, EPA calculated the estimated number of LSLs in each state based on the sum of two components: the number of reported LSLs and the number of “undiscovered service lines [that] might be lead”.

Texas: Data entry errors

EPA’s report placed Texas and its estimated 647,640 LSLs within the top five states with the most LSLs. Based on this, the agency allocated $146 million in FY23 to assist Texas water utilities in replacing the seemingly large number of LSLs.

However, of the 116 large and medium-sized Texas utilities included in the dataset, only three reported having lead pipes in their system.[6] By far, the City of Houston led the group at 302,359 LSLs, a figure that would have earned the number two spot among all cities across the country. The other two Texas utilities – Fort Worth and Bryan – reported less than 1,000 lead pipes each.

We contacted Houston to verify their number. They promptly explained that there was a data entry error: 302,359 should have been entered as “service lines for which the material makeup of the service line and of the connector are not known”. They added that a recent reevaluation of their data would decrease the number of service lines of an unknown material to 274,098.

With this new information and our understanding of EPA’s calculation, we estimate that Texas most likely has less than 100,000 LSLs.[7] If this is correct, the state’s allocation in FY24-26 should be reduced from $146 million to the baseline of $28 million that is allocated to any state regardless of its number of LSLs. The change would free up $118 million for other states in those fiscal years.

We do not know how many other utilities may have had similar data entry errors, but all utilities should doublecheck their survey responses when EPA provides the opportunity in the fall of 2023. We expect many utilities will have improved their estimates in preparation for the October 2024 deadline to submit service line material inventories to their state under the revised Lead and Copper Rule.

Florida: Conflicting state and utility information

Florida became the state with the most LSLs when EPA estimated it to have 1,159,300 of these pipes replacing Illinois. Based on this, EPA allocated almost $255 million LSL replacement funding to Florida in FY23. Shocked by this news, we had to find out if Florida truly deserved its newfound number one spot.

Pinellas County Utilities appeared at the top of the list of Florida utilities in EPA’s dataset[8] with 40,380 LSLs. When we reached out to the utility, they told us they reported all of their service lines as “unknown” and shared a copy of the spreadsheet they submitted to the state that confirmed this. If the number of LSLs reported in EPA’s dataset for Pinellas County was accurate, that meant almost one-third of their total service lines are lead pipes, a much higher rate than cities with a long history of LSLs.

The question remained whether there was a broader trend at play with Florida’s numbers. This prompted us to reach out to the five other large utilities that reported more than 20,000 LSLs. These utilities serve Jacksonville, Fort Lauderdale, Cocoa, Hillsborough County, and Pasco County.

We heard back from all but one and the sentiment was the same – confusion as to where the numbers in EPA’s dataset came from. Some stated that they are just now starting to inventory their service lines ahead of the October 2024 deadline, and others don’t remember responding to any survey at all. We contacted Florida DEP, the agency that oversees drinking water programs, but have not heard back.

At this stage, it is still unclear as to where the numbers for individual utilities in Florida originated, but we suspect that the state provided them. As such, we estimate that there are less than 100,000 LSLs in Florida.[9] If this is correct, its allocation for LSL replacement should be reduced from $255 million to the $28 million baseline allocation.

Ultimately, what the utilities reported to the state conflicts with what showed up in EPA’s dataset. EPA and the state should work together to figure it out. Based on the lesson learned, EPA should identify states where similar problems may have occurred.

New York: Inconsistent directions

EPA estimated that New York State has 494,007 LSLs, bringing in almost $114 million for LSL replacement in FY23.

Out of the 59 medium and large utilities[10] in New York listed in EPA’s dataset, 19 reported LSLs in their distribution area.[11] We were surprised to find that New York City was listed as “no lines reported” even though their service line material data was publicly available at the time of the survey.[12]

When asked about why they didn’t report LSLs to EPA, New York City’s water utility staff responded that they were told by the state not to provide it. The state’s SRF program manager confirmed that New York City’s LSL data was not requested so New York City could focus its efforts on getting several large infrastructure projects included in the base survey, explaining that these efforts resulted in the second largest DWINSA need increase nationally. He also noted that New York City was the only public utility they did not engage with on the LSL portion of the survey.

Based on our understanding of how EPA calculated a state’s number of LSLs and how large New York City is compared to other cities in the state, we think that EPA’s estimate for New York State may be low.[13] However, in our follow-up communications with the state, we were told that EPA’s calculations includes estimates for New York City because it is based on data for other medium and large utilities in the state. The city provided a similar message. Until we see EPA’s formula in more detail, we cannot know for sure.

Nonetheless, we encourage the state and New York City to update their reporting and to provide an opportunity for other utilities to update their DWINSA responses.

Summary

We thank NRDC for submitting the FOIA request and EPA for making it publicly available. The information allowed us to look more closely at the surprises in EPA’s LSL estimates.

We also applaud EPA for its willingness to give states and utilities the opportunity to update the LSL information. We anticipate that this will enable a fairer allocation of the funding dedicated to LSL replacement to states based on their need.

We recognize that the problems found here may not be unusual for any survey seeking previously undisclosed information, especially since some of the parties did not understand that the information would affect each state’s share of the $15 billion in funding dedicated to LSL replacement.

 

 

[1] EPA’s estimate of 9.2 million LSLs includes service lines that are classified as “galvanized requiring replacement” but excludes 2.8 million standalone galvanized pipes. See page 6 of the EPA’s 7th DWINSA Fact Sheet for service line category definitions.

[2] We focused on the last file uploaded by EPA on November 7, 2022 named “EPA-2022-003617 Responsive Document Batch 6” and tab labelled “State Med-Large Data”.

[3] Based on a 2016 American Water Works Association (AWWA) Survey of LSL estimates.

[4] In 2017, Congress directed EPA to collect information on LSLs as part of the DWINSA in America’s Water Infrastructure Act (AWIA) of 2018 (P.L. 115-270).

[5] See file from FOIA response named “EPA-2022-003617 Responsive Document Batch 6” and tab labelled “Data Caveats”.

[6] EPA assigned each utility’s response (see Column E: Status) to one of four categories. Out of the 116 large and medium sized Texas utilities in the dataset, 59 utilities reported 0 lines. The remaining reported at least 1 line under the following categories: 4 all unknown, 37 no unknown, 16 some unknown.

[7] EPA’s estimate of 647,620 LSLs in Texas means that 5% of all of the service lines in the state are lead. If the number drops to less than 100,000, that translates to only 0.7% of all service lines in the state being made of lead.

[8] EPA assigned each utility’s response (see Column E: Status) to one of four categories. Out of the 85 large and medium Florida utilities in the dataset, 18 utilities reported 0 lines. The remaining reported at least 1 line under the following categories: 1 all unknown, 4 no unknown, 63 some unknown.

[9] EPA’s estimate of 1,159,300 LSLs in Florida means that 17% of all of the service lines in the state are lead. If the number drops to less than 100,000, that translates to only 1.5% of all service lines in the state being made of lead.

[10] New York State told us that 5 of the 59 utilities were removed from the state’s sample after the DWINSA data collection began.

[11] EPA assigned each utility’s response (see Column E: Status) to one of four categories. Out of the 59 large and medium-sized New York utilities in the dataset, 15 utilities reported 0 lines. The remaining reported at least 1 line under the following categories: 11 all unknown, 18 no unknown, 17 some unknown.

[12] In 2021, EDF downloaded New York City’s service line inventory from their OpenData website, showing 62,770 potential lead service lines and 126,395 service lines of unknown material. New York City told us in a June 2023 email that it reported 137,542 potential LSLs and 230,870 service lines of unknown material in 2021.

[13] EPA’s estimate of 494,007 LSLs in New York means that 14% of all of the service lines in the state are lead. If the number increases by at least 100,000 to include New York City, that translates to 17% of all service lines in the state being made of lead.

Also posted in Lead / Authors: / Comments are closed

Flaws found in EPA’s lead pipe survey of states and water utilities

By Roya Alkafaji and Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: June 29, 2023

Deep Dive: Read our Deep Dives blog for an in-depth analysis on the data that drove the 2023 allocation of federal funding for lead service line replacements.

What’s New: EPA recently estimated there are 9.2 million lead service lines (LSLs) in the nation’s drinking water infrastructure based on information reported by states and water utilities. This was collected as part of a survey conducted every four years to understand drinking water infrastructure needs.

The agency estimated the number of LSLs for each state. Two had surprisingly high numbers: Florida with 1.2 million LSLs and Texas with 650,000.

After reviewing data EPA used to estimate each state’s totals[1], we believe that these two may have less than 100,000 LSLs each. If true, this means the country may actually have about 1.6 million fewer LSLs than originally thought – good news overall.

Read More »

Also posted in Drinking water, Lead / Tagged , , , , | Authors: , / Comments are closed

Broken GRAS: Secret GRAS determinations may outnumber those reviewed by FDA

By Maricel Maffini, PhD, Consultant and Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: April 13, 2023

What Happened?

FDA estimates that, each year, food companies designate 82 new food chemicals as “GRAS” (Generally Recognized as Safe) for use in food. On average, FDA reviews only 64 of those new chemicals for safety. For the remaining 18 chemicals in FDA’s estimate, the companies making and marketing them for use in food or in the food-production process choose not to seek a voluntary review by FDA.

In comments to the agency, we said we think FDA’s estimate may be too low – and the number of new chemicals added to food that bypass FDA review may be as high as 130 new food chemicals a year (significantly higher than 18). This is based on searches of company marketing claims. In an 8-week period, we identified 10 chemicals claimed as GRAS without a submitted notice to FDA seeking voluntary review. (Please see our comments for a full explanation of our estimate.)

Why It Matters

I want to throw in chemical safety as another really, really important area for the future – for humankind, really – and where science is evolving rapidly.—Robert Califf, MD, FDA Commissioner

FDA’s review of GRAS safety determinations is critical to ensure food chemicals are safe. When agency scientists receive GRAS notices, they closely review them and ask notifiers tough questions about the safety of the chemical alone—and the potential consequences when that chemical is combined with other chemicals on the market.

But FDA allows companies to withdraw their notices – which they do in about 17% of cases. Sometimes companies fix the problems and resubmit the notice. FDA does not require companies to do this, however. Too many simply continue to market the chemical for food uses as GRAS without seeking further FDA review. That is in addition to the GRAS safety determinations companies choose never to file, which leads to chemicals entering our food system without any FDA notice or review at all.

Our Take

While the GRAS system is clearly broken (something we’ve blogged about at length and the Washington Post covered in-depth back in 2014), FDA does retain the ability and the duty to monitor the marketplace to ensure unsafe chemicals that food companies claim as GRAS are kept off the market. Unfortunately, the agency appears to lack any system to ensure that monitoring takes place. The only examples of agency action to pull industry-certified GRAS products off the market have been caffeinated alcoholic beverages and partially hydrogenated oils (aka artificial trans fat). Both were prompted, in part, by state and media calls for action.

Examples of inaction, however, are numerous and include: tara flour, COZ corn oil, Apocynun ventron, gamma aminobutyric acid (GABA), aquaequorin/Prevagen, and many more.

One of the key breakdowns that contributes to FDA’s failure to monitor is the lack of coordination between the regulatory programs in the Center for Food Safety and Applied Nutrition (CFSAN) and the inspection/enforcement programs in the Office of Regulatory Affairs (ORA).

Next Steps

In January 2023, FDA Commissioner Califf announced a proposal to reorganize the food safety program in response to stakeholder calls for action after the infant formula debacle and to a recent review of the agency by the Reagan-Udall Foundation. This review noted that one key step is to appoint a new Deputy Commissioner for Human Food. This person would have greater responsibility to coordinate efforts between CFSAN and ORA. The Commissioner’s proposal has been strongly criticized since there would be no clear line of authority between the new Deputy Commissioner and ORA.

But Commissioner Califf has stated that chemical safety is a priority, telling a reporter that “I want to throw in chemical safety as another really, really important area for the future – for humankind, really – and where science is evolving rapidly.”[1]

Fixing GRAS is an important step to rebuild consumer confidence and reduce the ongoing risk to public health. Until the broken GRAS system is fixed, FDA will continue to be hamstrung in preventing health risks posed by chemicals of unknown safety. Until the system is fully fixed—which includes ensuring that no chemicals enter our food system without notice to, and review by, the agency—FDA needs to be coordinating with ORA and CFSAN to proactively monitor and enforce GRAS evaluations on chemicals entering the market to ensure they are actually safe.

Go deeper: You can learn more from these resources:

 

NOTES

[1] FoodFix, January 31, 2023, edition.

Posted in Deep Dives / Authors: , / Comments are closed

Alternative Figures: FDA’s food chemical reports to Congress don’t add up

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: April 10, 2023

In its annual justification of budget estimates to Congress, FDA describes its activities and tracks its performance. One of those performance measures is the percentage of food- and color-additive petitions (FAPs/CAPs) the agency has reviewed and completed within 360 days of receipt.[1]

We analyzed FDA’s reports to Congress published from 2016 to 2023 and found that FDA told Congress it had completed 100% of its reviews within 360 days in every year but one. The exception was FY2020, when the rate dropped to 89%. During that 7-year period, the agency reported that it had filed a total of 51 petitions. (See Table 1.)

Why It Matters

FDA’s impressive claims about the percentage of FAP/CAP reviews it completed run contrary to our experience and the available evidence:

  • FDA’s own webpage describes seven petitions that have been under review for over 360 days. (See Table 2.) Five of those overdue petitions were filed in FY2021, when the agency claimed it had reviewed and completed 89% of them. The agency reports filing and reviewing only two petitions in that year.
  • Four of five petitions submitted by food safety advocates for which the agency has made a decision were in FDA’s review pipeline for over 360 days.[2] For three of those overdue petitions, FDA acted only after petitioners sued in court for unreasonable delay. (See Table 3.)
  • FDA’s guidance for industry on these petitions says, “the average time between submission until a final rule is published for a direct food additive petition is 24 months and for color additive petitions, the approval process varies significantly.”

Our Take

Accurate and transparent reporting empowers Congress to:

  • See that the agency is having difficulty meeting its deadline for reviewing FAPs/CAPs; and
  • Set priorities and evaluate FDA’s funding requests more effectively.

Our Research Findings

Table 1 summarizes those findings. We excluded years where we did not have data for both petitions filed/reviewed in the fiscal year and the percent of petitions reviewed within 360 days.[3]

Table 1: FDA’s Reporting of Office of Food Additive Safety Activity

(Year of Budget Justification Reports)
Fiscal Year FAPs/CAPs

Filed/ Reviewed*

 FAPs/CAPs Percent Reviewed within 360 days
FY2015

10 / 11
(2016 report, p. 61)

100%

(2017 report p. 57 &

2016 report p. 59)
FY2016 7 / 7

(2017 report, p. 60)

100%

(2018 report p. 54 &

2017 report p. 57)
FY2017 10 / 10

(2018 report p. 57)

100%

(2019 report p. 67 &

2018 report p. 54)
FY2018 10 / 10

(2018 report p. 57)

100%

(2021 report p. 80 &

2020 report p. 68 &

2019 report p. 67)
FY2019 5 / 5

(2021 report p. 82 &

2020 report p. 70)

100%

(2022 report p. 96 &

2021 report p. 80 &

2020 report p. 67)

FY2020

 7 / 7

(2021 report p. 82)

89%

(2023 report p. 66)
FY2021

 

 2 / 2

(2022 report p. 98)

100%

(2023 report p. 64 &

2022 report p. 96)

* Reviewed includes approved, withdrawn, or placed in abeyance due to deficiencies during the fiscal year.

 

Table 2 identifies all food and color additive petitions that FDA’s website reported as under review (and not in abeyance or decided) as of April 7, 2023. “Days Under Review” is calculated as of that date.

Table 2: Status of Food and Color Additive Petitions
Under Review as of April 7, 2023
Substance and Requested Action Petition No. Filing Date Days Under Review
Revoke BHA FAP 0A4216 6/22/90 11,977
Allow jagua (genipin-glycine) blue CAP 0C0317 7/31/20 980
Allow Vitamin D3 FAP 1A4827 2/3/21 793
Allow Gardenia Blue Powder CAP 1C0319 4/20/21 717
Allow vitamin D2 mushroom powder FAP 1A4828 6/8/21 668
Allow blue Galdieria (Galdieria sulphuraria) extract CAP 1C0320 7/27/21 619
Allow vitamin D2 heat-killed (“inactive”) baker’s yeast FAP 1A4829 9/28/21 556
Allow myoglobin CAP 2C0322 12/13/21 480
Revoke bisphenol A (BPA) FAP 2B4831 5/2/22 340
Revoke Red Dye No. 3 CAP 3C0323 11/15/22 143

 

Table 3 reviews the timing of FAPs/CAPs submitted by food safety advocates since 2014. Where available, FDA’s decision on the petition is noted, as well as whether petitioners went to court asking a judge to issue a writ of mandamus to order the agency to act. For each of those lawsuits, FDA agreed relatively quickly to a schedule to make a final decision on the petition.

Table 3: Timing of Review for Advocates’ Petitions
Seeking Revocation of Food and Color Additive Approvals (as of April 7, 2023)
Substance and Requested Action Filing Date Decision Date Days Under Review Decision Lawsuit Filing Date
Perchlorate as FCS 12/31/14 4/28/17 849 Denied 3/31/16
Long-chain PFAS (non-sulfonated) as a food contact substance (FCS) 1/7/15 12/29/15 356 Accepted None
Carcinogenic flavors as food ingredient 8/17/15* 10/2/18 963 Accepted for 6 of 7 5/17/18
Ortho-phthalates as FCS 4/12/16** 5/20/22 1516 Denied 2/7/21
Lead acetate as cosmetic color additive 2/24/17 10/25/18 618 Accepted None
Bisphenol A as FCS 5/2/22 Pending
Red Dye No. 3 11/15/22 Pending
* Revised to 2/12/16 due to substantive amendments provided by petitioner.

** Revised to 3/26/18 due to substantive amendments provided by petitioner.

 

Next Steps

The agency should explain to Congress and stakeholders how it came up with its numbers and ensure accurate and transparent reporting.

NOTES

[1] The statutory deadline for a final decision on a food or color additive petition is 90 days, with an option to extend for an additional 90 days for a total of 180 days. See 21 U.S.C. §§ 348(c)(2) and 379e(d)(1). We do not know why FDA’s performance measure gives the agency twice as much time to complete a review than is allowed by the law.

[2] Long-chain PFAS food additive petition was processed in 356 days. See Table 3.

[3] FDA reported 100% for FY2014 in the 2016 report(p. 59) but did not include the number of FAPs/CAPs reviewed. In its 2023 report, the agency reported reviewing five FAPs/CAPs (p. 61) but did not provide the percentage of reviews that had been approved, withdrawn, or placed in abeyance in 360 days.

Also posted in FDA / Authors: / Comments are closed

Health data needs to inform targeted environmental justice initiatives

By Ananya Roy and Veronica Southerland / Published: April 4, 2023

Key Findings and Recommendations 

  • Air pollution results in a large burden of childhood asthma across the country, and this burden is disproportionately borne by people of color.
  • More than $100 million in grants from the Environmental Protection Agency is available for environmental justice initiatives, but targeting programs to alleviate the health impacts of air pollution to overburdened communities requires local-level health information that is often not readily available.  
  • We recommend health advocates and researchers work with local and state public health departments and impacted communities to access existing fine-scale data where available.

In the past, the lack of neighborhood-scale data on baseline disease rates, pollutant concentrations and children’s asthma has made it difficult to determine which U.S. communities bear the highest health burden from air pollution. Disparities in pollution exposures have been routinely underestimated. Generating more fine-scale data, together with advances in hyperlocal air monitoring, will make visible the disparities in exposure to air pollution across and within neighborhoods, allowing us to target mitigation and prevention efforts for maximum benefit. 

We now have an opportunity to make significant progress towards identifying, prioritizing and addressing the harms faced by the most burdened communities. EPA has made available over $100 million dollars for grants to advance environmental justice, including health impact assessments. Grant recipients can use the funds to obtain health information at the neighborhood level, data essential for identifying communities with the highest burden of air pollution health impacts. The application deadline is April 14, 2023. 

Pollution and racism 

Using new air monitoring techniques, advances in modeling, and community-based participatory research, studies confirm that neighborhoods which have experienced historical racism also experience higher levels of air pollution.

Decades of discriminatory and racist policies, practices and disenfranchisement have resulted in the disproportionate exposure to pollution sources in communities of color, along with disinvestment in housing and economic opportunities in these communities. Communities of color and areas of low wealth therefore face exposure to higher levels of air pollution and are more vulnerable to that air pollution, resulting in heavier health burdens borne by families.  

Air pollution data is only half of the story 

While air pollutant exposure is important in determining the effect of that pollutant on the health of a community, social factors and existing disease burden and risk play a large role in the impact that pollutant will have on the total health burden attributable to a pollutant in a community.  

Existing disease burdens and risks in populations are reflected in “baseline disease rates,” a key public health metric documented by public health agencies. Baseline disease rates vary within cities, but those rates are rarely made publicly available for use in risk assessment. 

Gaps in baseline disease data availability limit the ability of health impact assessments to determine which communities have existing vulnerabilities to the harmful effects of air pollution. For example, while studies of pediatric asthma attributable to nitrogen dioxide, a traffic-related air pollutant, have estimated there are 200,000 affected children living in American cities, these studies have relied on national-level estimates of asthma incidence. These national-level estimates hinder the ability of researchers to determine which areas within cities are experiencing the highest burden of asthma attributable to asthma. 

Local-level health data is needed to identify risks to overburdened communities  

The public health information available from city to city and within cities is a mix of fine-scale data (ZIP code level) and coarse-scale data (ZIP3 – aggregated data based on ZIP code information, roughly the size of counties.) The assessment of health risks, factors and outcomes can vary greatly depending on which level of data is used. 

Studies have repeatedly shown that using fine-scale baseline disease rates can make a profound difference when mapping the spatial distribution of health burdens attributable to air pollutants and on the ability to quantify disproportionate impacts in disadvantaged populations. For example, in an analysis of within-city air pollution risks in the San Francisco Bay Area of California, we found the highest census block group baseline mortality rate was 12 times higher than the rates in the census block group with the lowest rates, while the highest county rate was only four times greater than the lowest county mortality rate.

Lack of fine scale data leads to unreliable analysis 

Our work in New Jersey highlights the pitfalls of using only coarsely-resolved spatial data in identifying those communities that are at highest risk of the health burdens of air pollution. An analysis of the impact of pollution in that state found that 18,000 asthma emergency room visits by children could be attributed to fine particle pollution and 70% of those impacts were among communities of color (Asian, Black and Native American) and Hispanic populations.

Comparing the results using coarse-scale and fine-scale data, we found that:

  • Analysis using coarse-resolution emergency room visit information overestimated the burden to white populations. It underestimated the burden to people of color by as much as 90%. 
  • Using fine-scale data, we found emergency room visits for the ZIP code with the highest burden to be 1.5 times higher than the highest burden estimated using coarse-resolution data. 
  • We also found that using fine-scale data revealed double the variation between the ZIP code with the highest risk of PM-attributable visits and ZIP codes with the least risk of PM-attributable visits. Variation allows us to observe the relative disparities in risk within a community that are not otherwise observable with coarse-scale baseline disease data. 

The use of coarse-resolution (ZIP3) asthma emergency department visit data may underestimate PM-attributable asthma burdens (number of cases per 10,000) among non-white populations when compared to fine-scale (ZIP) data. Red shows communities where coarse-resolution health data underestimates risks.

Local-level health information can help EPA and other funders to identify and direct resources to the communities that need it most, which are too often communities of color facing legacy injustices. 

Our work in the Bay Area of California highlights the need for fine-resolution data on baseline disease rates, as pollutant concentrations alone were unable to capture the variation of air pollution health risks within Oakland.  

The maps shown in Figure 2 are of the neighborhoods of West Oakland. Looking only at the spatial distribution of the highest pollutant concentrations (A), the area of highest risk appears to be the truck traffic corridor of I-880. However, when we incorporated census block group baseline disease rates (B), provided by the Alameda County Public Health Department, we found that the area of highest risk, and therefore where the largest emission reductions could result in the largest reduction in health burden, was another area of West Oakland where both baseline mortality rates and pollution levels were elevated.  

Pollutant concentrations and county baseline disease rates alone would not have revealed this vulnerable neighborhood. A better understanding of pollution hotspots can help direct federal funds intended to address long legacies of pollution burdens to communities where they’re most needed. 

West and Downtown Oakland. The map on the left (A) shows the spatial distribution of pollutant concentrations, with high concentrations highlighted in the blue circle near major roadways. The map on the right (B) shows the spatial distribution of air pollutant attributable health burdens when the spatial distribution of underlying disease patterns are taken into consideration. The area of highest air pollutant attributable health burdens in map (B) is highlighted in the blue circle.

Ways to expand and improve local-level health data 

Past investment in satellite-derived estimates and local air pollution monitoring has resulted in making exposure disparities visible. Similar investment is required now for developing fine-scale data on baseline disease rates, which will enable identification of communities with the highest air pollution-attributable health burdens.  

Mechanisms currently exist for developing more fine-resolution data on baseline asthma emergency department visits. As part of the analysis in New Jersey described above, we purchased discharge-level emergency department visit data for New Jersey from 2016 to 2019 from the Healthcare Cost and Utilization Project’s State Emergency Department Database (HCUP SEDD). We urge the Agency for Healthcare Research and Quality, which manages the HCUP SEDD, to develop baseline asthma emergency department visit datasets and that the Agency update these datasets annually and make them publicly available. 

We recommend that health advocates and researchers work with local and state public health departments to access existing fine-scale data where available. We have found that local health departments often have the data needed but lack the resources to dedicate staff and expertise to process and analyze the information. As an example, EDF has had success working with the Alameda County Public Health Department to develop mortality rates at the census block group level. Other impediments to developing baseline disease rates include lack of funding and concerns about privacy. 

Deadlines approaching for funding opportunities to develop local-level health data 

EPA is accepting environmental justice grant applications through April 14, 2023 through two avenues: the EJ Collaborative Problem-Solving Cooperative Agreement Program (EJCPS) and the Environmental Justice Government-to-Government (EJG2G) program. 

While both grant programs are relevant to the use of local-level health data, the Government-to-Government grants allow community-based organizations to partner with their local health department on use of local-level data in health impact assessments. This can help alleviate the problem discussed above regarding inadequate staffing and expertise at local health departments.  

Of the five broad categories listed in the funding announcement, use of local-level health data fits under the category “community-led air and other pollution monitoring, prevention, and remediation, and investments in low- and zero-emission and resilient technologies and related infrastructure and workforce development that help reduce greenhouse gas emissions and other air pollutants.” 

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