An approach to research of regulations in order to increase “environmental justice” within disadvantaged communities has to consider all the potential health risks that could be embedded in the water supply as new regulations are developed, a member of the Environmental Protection Agency’s (EPA) Science Advisory Board (SAB) told The Driller. 

Research on the cumulative impacts of federal regulations—commonly known as “cumulative impacts research”—has to be considered when developing new rules, including the impact of existing rules, otherwise a contaminant in the water might be overlooked and the expected health benefits to the residents of such communities might be negated, according to Mark LeChevallier, a member of SAB who is the principal for Dr. Water Consulting, LLC, which consults on water quality.

A lack of cumulative impacts research could affect disadvantaged communities if a community’s water supply is contaminated and some contaminants are missed because a regulation was not considered, according to LeChevallier, who provided arsenic, chromium, and lead as examples of the cocktail of contaminants in water. With often the immediate focus being the mitigation of the lead, the other contaminants go to the backburner, he said. 

“Without doing a holistic approach, the benefits (to the community of EPA action) may not be there, because while you may solve a lead problem, arsenic or chromium still exists there,” LeChevallier said.

Charles Lee, EPA’s senior policy advisor for environmental justice, conducted a presentation on cumulative impacts research to a meeting of the SAB held on Oct. 15, 2024. 

“In 2023, the Office of Inspector General directed EPA to develop performance metrics to monitor progress in identifying and addressing cumulative impact and disproportionate health effects,” Lee said.

Cumulative impacts research provides a particularly powerful lens that is critical not just for advancing the cumulative impact assessment, but also Earth justice analysis overall, Lee said. 

Furthermore, researchers need to “go beyond merely demonstrating the existence of disproportionality, but to better understand the contours of such disproportionate impacts in a way that compels where there’s the greatest need and compels action,” Lee said.

In examining the cumulative impact issue, EPA developed a logic model that “has three prongs,” including “a framework”; “performance metrics”; and “program commitments” to cumulative impacts research, Lee said.

“There is an alignment between the development of this framework, the performance measures, and the actual program commitments and ongoing work,” Lee added. 

Such an alignment is needed for integrating the consideration of cumulative impacts in EPA’s program, he said.

“EPA recognizes this as the totality of exposures to combinations of chemical and non-chemical stressors and their effects on health and quality of life,” as well as the “disproportionate impacts,” said Lee.

Furthermore, “there is “substantial scientific evidence, particularly on the patterns of concentrated environmental burdens,” Lee said, adding there is at least “one study around the relationship between redlining and elevated air pollution,” he said. “Redlining” is a practice employed by mortgage-lenders in which they draw red lines on a map of a community to indicate areas or neighborhoods in which they will not make loans.

Because of such discriminatory practices, EPA has inventoried its activities and translated the finding of those reviews into commitments. In addition, EPA found that every program and region has made similar commitments, starting with the National Academy of Science Panel (NASP) on the state of the science and future cumulative impact assessment, according to Lee. As a result, NASP has committed to ensuring the scientific methods used are “really grounded in engaging authentically with communities and tribes” and take into account the lived experiences of the residents of those communities, he said.

In addition, EPA “is moving beyond just looking at cumulative impact assessment,” and there are more than 90 strategic research action plan projects that touch on cumulative impacts that total $49 million, Lee said.

Cumulative impacts research “is a complex issue,” LeChevallier said. He added that while EPA’s cumulative impacts research effort is complex, such a complex approach is needed because “unless we consider all of these impacts, the rules that we have now probably don’t have the benefits sought without having a cumulative approach,” said LeChevallier.

“There’s probably more risks out there that we’re not adjusting in disadvantaged communities,” according to LeChevallier, who added it is important to remember that the goal of that research is to provide the most health benefits to a community as possible.