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Methodology for Distributional Benefit Analysis of a National Air Quality Rule

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“Environmental Justice” (EJ) has become a pressing social, scientific and political issue over the last decade. The 1994 Executive Order 12898, Federal Action to Address Environmental Justice in Minority Populations and Low-Income Populations, requires agencies to perform EJ reviews of their programs, policies, and activities in order to determine their effects on minority and low income populations. EPA defines “Environmental Justice” as “the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies”.1 EPA further defines “fair treatmentto mean that “no group of people should bear a disproportionate share of the negative environmental consequences resulting from industrial, governmental and commercial operations or policies”. This definition provides very general guidance on the concept of environmental justice, but does not supply specifics and directions for applying this concept to EPA’s programs and activities.

The two most common types of EJ research or distributional analysis are: (1) proximity-tohazards studies and (2) exposure and health risk analysis. The first category of research evaluates how the distribution and proximity of hazards (e.g., Superfund sites, toxic emissions, and existing waste facilities) relate to community demographics. Residential proximity to a waste site or other hazard is often used as a surrogate measure for exposure to contaminants found at those sites. The second category of EJ research, exposure and risk analysis, examines the distributions of exposures and health risks among different socio-demographic groups.

In this document, the authors discuss a method for carrying out the second type of distributional analysis as we analyze the benefits of a national or regional air pollution control regulation. There are several potentially interesting EJ questions that our analysis attempts to answer. These questions address potential inequality in (1) baseline levels of pollutant exposure, (2) reductions in levels of exposure that are expected to result from a pollution rule or regulation, (3) health benefits associated with the reductions in pollution levels, and (4) control scenario pollutant concentrations and associated health risks.

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Date Linked: 05/28/2009

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