With increased attention on economic and racial inequities, environmental justice (EJ) is becoming increasingly considered in the evaluation of human health risks. The White House defines EJ as “the just treatment and meaningful involvement of all people, regardless of income, race, color, national origin, Tribal affiliation, or disability, in agency decision-making and other Federal activities that affect human health and the environment” (from Executive Order 14096 of April 21, 2023, “Revitalizing Our Nation’s Commitment to Environmental Justice for All”). EJ initiatives stem from the observation that low-income, disadvantaged communities may be disproportionately at risk from adverse environmental impacts due to a variety of factors.
Gradient has experience applying EJ principles on proposed infrastructure projects and has advanced the science around the intersection between EJ issues and human health risk assessment. This specific experience in combination with nationally renowned expertise in toxicology, fate and transport, and Geographic Information System (GIS) spatial analysis has allowed Gradient to meet the evolving needs of EJ public health assessments.
Gradient Environmental Justice (EJ) Expertise:
Example Publication:
Environmental Justice: Laws, Programs, and Tools
Gradient provided an overview of environmental justice (EJ) concepts, key federal and state regulations and programs, and tools used to conduct EJ assessments. Notably, the report included a comprehensive survey of EJ programs for each state, including information on agency oversight, key legislation and guidance documents, notable case law, and any state-developed tools or approaches for evaluating EJ issues. This report was used by the utility industry to understand EJ considerations and tools for overall strategic planning (e.g., community concerns for existing and proposed facilities).
Statewide Environmental Hazard Database Development and Mapping
Gradient constructed a comprehensive Geographic Information System (GIS) database of statewide environmental hazards to evaluate potential sources of contamination in proximity to sensitive receptors (e.g., schools, environmental justice [EJ] communities). We developed a WebGIS application based on this database to visualize the data, facilitate spatial analysis, and communicate information about the potential contamination sources to project team members and other interested parties.
Risk Assessment in Evaluating Environmental Justice Concerns
Gradient synthesized available information on approaches for the incorporation of nonchemical stressors into risk assessment. We evaluated recommendations from regulatory agencies, identified and categorized the most significant nonchemical stressors associated with environmental justice (EJ) factors related to vulnerability, and critically analyzed methodologies for incorporating nonchemical stressors into the current risk assessment framework. The analysis was published in the International Journal of Environmental Research and Public Health and was the basis for an invited presentation in US EPA’s Cumulative Risk Assessment Webinar Series.
Regulatory Comments on Toxic Substances Control Act (TSCA) Fenceline Communities Risk Assessments
Gradient developed public comments for US EPA’s “Draft TSCA Screening Level Approach for Assessing Ambient Air and Water Exposures to Fenceline Communities.” We evaluated the proposed methodology for examining risks to fenceline communities under the TSCA priority chemical risk assessment program, with an emphasis on understanding if the proposed screening approach could serve as a scientifically supportable basis for risk management decisions under TSCA. We also identified areas that required clarification from US EPA.
Technical Support and Environmental Justice Analysis for a Natural Gas Infrastructure Project
Gradient compiled and evaluated baseline health statistics (e.g., asthma prevalence, cancer incidence) and public health studies for nearby communities to determine whether there was evidence of the increased vulnerability of potentially affected populations. Gradient also conducted a screening-level analysis to compare predicted air quality impacts in nearby environmental justice (EJ) communities versus in nearby non-EJ communities. A Geographical Information System (GIS) was used to combine information on community EJ status with modeled air concentrations, and statistical analyses were conducted to compare modeled concentrations for several different air pollutants in EJ versus non-EJ communities.