Coronavirus Pandemic Reinforces the Need for Cumulative Impacts Analysis

Darya Minovi

March 24, 2020


UPDATE: The Center for Progressive Reform signed a March 31, 2020 letter in support of federal funding for programs aligned with the Equitable and Just National Climate Platform in the COVID-19 stimulus legislation. Among a variety of environmental justice priorities, the request includes cumulative impacts analysis.


As the coronavirus (COVID-19) continues to spread around the globe, the inequalities in American society have come into even sharper relief. People with low incomes who are unable to work from home risk being exposed to the virus at work or losing their jobs altogether. Their children may no longer have access to free or reduced-price meals at school. They are also less likely to have health insurance, receive new drugs, or have access to primary or specialty care, putting them at a greater risk of succumbing to the illness. As with any shock to the system – natural disaster, conflict, and now a pandemic – vulnerable populations are hit hardest and have a harder time bouncing back.                                                

In addition to socioeconomic risk factors, a less obvious but often inescapable hazard puts poor people in a literal and figurative chokehold: pollution. People with underlying health conditions, such as heart disease, diabetes, and lung disease, face a higher risk of severe illness from coronavirus. One study of the 2003 SARS outbreak (a virus similar to COVID-19) found that Chinese patients in areas with moderate air pollution had an 84 percent greater risk of dying than patients in areas with less air pollution. Many studies have also identified a strong link between air pollution and cardiovascular disease and unfortunately, people with low incomes and communities of color face a greater risk of being exposed to air pollution from tailpipe emissions, poor housing, and hazardous facilities, to name a few sources. The combined effect of these exposures is in the least a public health concern, and at worst, kills people.

In the context of COVID-19, this creates a pandemic-inequality feedback loop. Disproportionate exposure to pollution, limited resources, existing health disparities, and less access to policymakers combine to increase a community’s vulnerability to a pandemic. The resulting health consequences and economic dislocation further reduce a community’s capacity to bounce back and effect policy change that might better protect them in the future.

The inequitable impacts of COVID-19 are already clear from an economic standpoint, and it won’t be long before the public health disparities reveal themselves. Upstream legal and policy interventions to protect overburdened communities could build resilience and eventually help break the pandemic-inequality feedback loop.

Experts have begun to evaluate the combined burden of environmental pollutants and social vulnerabilities through a method known as cumulative impacts analysis. In such analysis, environmental stressors (e.g. PM2.5 levels, proximity to hazardous facilities, and traffic volume) and social vulnerabilities (e.g. percent low-income, percent over age 64, and linguistic isolation) are combined to identify communities facing the greatest burden. While government officials and advocates in Chicago, California, and Michigan, for example, have begun conducting these assessments, there is no standardized methodology, and translation to regulatory action has been slow. In 2008, Minnesota passed a law requiring the state Pollution Control Agency to consider “cumulative levels and effects of past and current pollution” before issuing permits for facilities in a section of South Minneapolis burdened by environmental health issues. The agency also developed a new approach for community outreach to garner greater input during the application review process.

In addition, in 2015, after years of tireless work from environmental justice advocates, California passed S.B. 673, which requires the state Department of Toxic Substances Control to consider “indicators of community vulnerability, cumulative impact, and potential risks to health and well-being” when issuing or renewing permits. While cumulative impacts may be broadly interpreted, requiring regulatory agencies to honestly examine the true burden of additional pollution on a community is a necessary step to prompt targeted action, whether through monitoring, permitting, enforcement, or site clean-up.

At the same time, existing legal requirements for cumulative risks analysis are under threat from conservative policymakers and their corporate interest allies. As part of it broader campaign to gut the National Environmental Policy Act (NEPA), the Trump administration is seeking to end the long-term requirement that agencies consider cumulative impacts as part of their required analyses under the statute. Among other things, the change would significantly undermine the power the statute offers to vulnerable communities in fighting efforts to site new polluting projects in their neighborhoods.

Despite this assault at the federal level, frontline communities have long advocated for protective measures, including cumulative impacts. In addition, last month, Reps. Donald McEachin (D-VA) and Raúl Grijalva (D-AZ) introduced the Environmental Justice for All Act, which would require cumulative impacts analysis in certain permitting decisions.

While cumulative impacts analysis is by no means a silver bullet, it is an underutilized and highly valuable tool that recognizes that the whole of environmental and social stressors is greater than the sum of the parts. Failing to assess these risks only serves to ensure resources are directed away from those who need them most, and ultimately harms low-income families and communities of color.

We still don’t know how long this pandemic will last, but in the meantime, we can take steps to protect and empower communities that have been systemically excluded from regulatory protections for decades.

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