Cumulative Risk Assessment and Environmental Equity in Air Permitting: Interpretation, Methods, Community Participation and Implementation of a Unique Statute
The agency may not issue a permit to a facility without analyzing and considering the cumulative levels and effects of past and current environmental pollution from all sources on the environment and residents of the geographic area within which the facility’s emissions are likely to be deposited, provided that the facility is located in a community in a city of the first class in Hennepin County that meets all of the following conditions:
- is within a half mile of a site designated by the federal government as an EPA superfund site due to residential arsenic contamination;
- a majority of the population are low-income persons of color and American Indians;
- a disproportionate percent of the children have childhood lead poisoning, asthma, or other environmentally related health problems;
- is located in a city that has experienced numerous air quality alert days of dangerous air quality for sensitive populations between February 2007 and February 2008; and
- is located near the junctions of several heavily trafficked state and county highways and two one-way streets which carry both truck and auto traffic. (Minn. Stat. § 116.07 subd. 4a) 
2.1. Interpreting and Defining the Area Described by the Statute
2.2. Determining the “Geographic Area Within Which the Facility’s Emissions Are Likely to be Deposited”
2.3. Scoping the “Effects of Past and Current Environmental Pollution…on the Environment and Residents of the Geographic Area…”
2.4. Reporting and Context for “Effects of Past and Current Environmental Pollution…on the Environment and Residents of the Geographic Area…”
2.5. Hazard Indicators
2.6. Exposure Indicators
2.7. Health Indicators
2.8. Facility Specific Information
2.9. Stakeholder Participation in the Method Development Process
- How can we notify you about future public meetings related to specific permit applications in this area? (e-mails, newspaper, posters/flyers, PCA website update, etc.)
- What do you want to know about permit applications for proposed projects in this area (types of pollutants, estimated health risks, location of the project, who the company is, etc.)?
- What community information should be included in a cumulative levels and effects analysis?
- What concerns you about the environment or pollution in your neighborhood?
- What was the most interesting, or surprising thing that you learned at this meeting?
2.10. Limitations to the Methodology and the Public Participation Process
3. Results and Implementation
3.1. Public Participation Plan for the Permitting Process
3.2. Case Study of the First Permit Application
- traffic densities,
- acute respiratory air toxics modeling results,
- acute estimates for ambient air monitoring,
- asthma related hospitalizations,
- asthma related emergency room visits,
- results from the Asthma Capitals Study ,
- smoking status rates ,
- percent population uninsured ,
- median income 
- percent of the population under the statewide average income , and
- the percent of the population that is non-white .
- Is the analysis adequate? (was all available data included, was this a reasonable “hard look” at potential facility impacts to existing cardiovascular and respiratory events, etc.)
- Considering all of the information presented, would you recommend moving forward with a draft permit?
- Are the limits incorporated into this analysis adequate to limit potential facility impacts to the community?
- Are there any further voluntary efforts that the agency would suggest?
4. Conclusions and Lessons Learned
- Conflict of InterestThe authors declare no conflict of interest.
References and Notes
- United States Environmental Protection Agency, Office of Research and Development, National Center for Environmental Assessment, Framework for Cumulative Risk Assessment, 630P02001F; United States Environmental Protection Agency, Office of Research and Development, National Center for Environmental Assessment: Washington, DC, USA, 2003.
- Minnesota Environmental Policy Act. Minnesota Statutes 1973, Sections 116D.01–116D.11.
- Citizens Advocating Responsible Development vs. Kandiyohi County Board of Commissioners. A04 886 A04 890, MN Supreme Court 2006; MN, USA.
- Minnesota Pollution Control Agency. Cumulative Air Emissions Risk Analysis. Available online: http://www.pca.state.mn.us/lupg42d accessed on 3 February 2010.
- Permits. Minnesota Statutes 2008, Section 116.07, Subdivision 4a.
- Minnesota State Legislature. House Actions, Bill Name: HF3293. Available online: https://www.revisor.mn.gov/bin/getbill.php?number=HF3293&session=ls85&version=list&session_number=0&session_year=2008 accessed on 26 October 2011.
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|Acute (hourly exposure)||Chronic (lifetime exposure)|
|Respiratory/Olfactory||Traffic, Environmental Tobacco Smoke (ETS), criteria pollutants, Air Toxics, AQI, asthma data||Traffic, ETS, criteria pollutants, Air Toxics, AQI, asthma hospitalization data|
|Developmental/Reproductive/Endocrine/Fetotoxicity||Air Toxics, SMRSC site*||Air Toxics, drinking water, SMRSC site|
|Hematological||Air Toxics||Air Toxics|
|Neurological||Air Toxics||Air Toxics, mercury in fish, drinking water, SMRSE site, blood lead|
|Eyes (irritant)||Traffic, Air Toxics, AQI||Traffic, Air Toxics, AQI|
|Alimentary||Air Toxics, drinking water||Air Toxics, drinking water|
|Bone & teeth||Air Toxics||Air Toxics, drinking water, blood lead|
|Cardiovascular||Traffic, Air Toxics, AQI, ETS, criteria pollutants||Traffic, Air Toxics, AQI, SMRSE site, ETS, criteria pollutants|
|Kidney||Air Toxics||Air Toxics, drinking water|
|Hepatic||Air Toxics||Air Toxics, drinking water|
|Cancer||Not Applicable||ETS, traffic, criteria pollutants, Air Toxics, AQI, drinking water, SMRSC site, blood lead|
|Ozone||See respiratory endpoint above||See respiratory endpoint above|
|Lead||See neurological and carcinogenic endpoints above.|
|Particulate Matter||See respiratory endpoint above, and include cardiovascular data.||See respiratory endpoint above, and include cardiovascular data.|
|CO||See cardiovascular and neurological endpoints above.||Not Applicable|
|NO2||See respiratory endpoint above||See respiratory endpoint above, and include cardiovascular data.|
|SO2||See respiratory endpoint above||See respiratory endpoint above, and include cardiovascular data.|
|Specific Descriptors||General Discussion|
|Existing Stressors||• Ambient air toxics measurements||• Similar to other urban areas in St. Paul/Minneapolis|
|• Ambient PM2.5 measurements||• Lower than National Standard, similar to other urban areas in St. Paul/Minneapolis|
|• Traffic densities||• Similar to 10× statewide averages|
|• Exposure to tobacco smoke||• Tied for highest smoking rates in metropolitan area|
|• Potential exposures from nearby facilities (point sources)||• ~8 nearby facilities with potential exposures|
|Descriptions of Vulnerabilities||• Asthma hospitalizations and emergency room visits||• ~1.5–2 times higher than Minneapolis city-wide average|
|• Cardiovascular hospitalizations||• High variability, uncertain|
|• Socioeconomic status and minority populations||• Potential environmental equity area|
|• Percent of Population without health insurance||• One of the higher in Hennepin County|
|• Ranking in AAFA 100 Cities Asthma ranking||• Ranked best place in nation to live with asthma|
|• Comparisons with Healthy People 2020 Objectives||• Asthma hospitalizations and ED visits in Study Area do not meet 2020 Healthy People objectives|
|Pathways/media||• Outdoor air, indoor air (ETS surrogate), ingestion of homegrown produce, incidental ingestion of soil|
|Routes||• Inhalation, ingestion|
|Subpopulations||• General population in the Study Area||• Consideration for children included (early lifestage exposure)|
|Endpoints||• Short-term respiratory and cardiovascular effects|
|Proposer Risk Reduction Activities||• Geothermal heating||• Reduced NO2 emissions|
|• Permit limits on daily and annual paint use||• Reduced particulate and VOC emissions|
|• Permit limits on annual natural gas use||• Reduced NO2 emissions|
|• Biofiltration gardens||• Reduced run-off from the site|
|• Double panel filters on paint spray booth exhaust||• Reduced particulate emissions|
|• Permit limits on specific metals in paints||• Reduced metallic emissions: chromium, lead, manganese, nickel or cadmium|
|• Public transit is a lower impact activity than individual vehicles||• Reduced vehicle emissions (NO2, particulate)|
© 2011 by the authors; licensee MDPI, Basel, Switzerland This article is an open-access article distributed under the terms and conditions of the Creative Commons Attribution license (http://creativecommons.org/licenses/by/3.0/).
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Ellickson, K.M.; Sevcik, S.M.; Burman, S.; Pak, S.; Kohlasch, F.; Pratt, G.C. Cumulative Risk Assessment and Environmental Equity in Air Permitting: Interpretation, Methods, Community Participation and Implementation of a Unique Statute. Int. J. Environ. Res. Public Health 2011, 8, 4140-4159. https://doi.org/10.3390/ijerph8114140
Ellickson KM, Sevcik SM, Burman S, Pak S, Kohlasch F, Pratt GC. Cumulative Risk Assessment and Environmental Equity in Air Permitting: Interpretation, Methods, Community Participation and Implementation of a Unique Statute. International Journal of Environmental Research and Public Health. 2011; 8(11):4140-4159. https://doi.org/10.3390/ijerph8114140Chicago/Turabian Style
Ellickson, Kristie M., Sarah M. Sevcik, Shelley Burman, Steven Pak, Frank Kohlasch, and Gregory C. Pratt. 2011. "Cumulative Risk Assessment and Environmental Equity in Air Permitting: Interpretation, Methods, Community Participation and Implementation of a Unique Statute" International Journal of Environmental Research and Public Health 8, no. 11: 4140-4159. https://doi.org/10.3390/ijerph8114140