Due to the dispersed nature of many pollutants, like NOx, VOCs, or CO, emissions trading programs can have unintended consequences where lower income communities take on a higher share of the pollution burden than more affluent communities. It is important for decision makers to take into consideration these environmental justice concerns along with the emissions reduction benefits and cost effectiveness aspects to trading programs. The balancing of these considerations can be difficult, but prioritization of these elements is critical for more effective policies.
The National Ambient Air Quality Standards (NAAQS) were set by the Environmental Protection Agency (EPA) with the explicit focus on protecting public health (Salzman and Thompson 2019, 119). Direct air pollution is an easily identifiable issue that can impact lower-income or minority communities where industrial, or waste disposal, sites are located. However, additional environmental justice issues like inadequate transportation, healthy and affordable foods, or unsafe homes also impact human health. Environmental justice is ultimately about the fair treatment and health of all citizens.
For these reasons, environmental justice concerns, that include a variety of direct and indirect health indicators, should be prioritized higher than cost effectiveness and other emissions reduction benefits. Focusing on the health-related environmental justice concerns first ensures that any NAAQS implementation methods, like emissions trading, directly support the goal of the NAAQS. Decision makers should ensure they are prioritizing the impacts of trading programs with environmental justice as a top consideration.
Author: Logan Callen
Salzman, James, and Barton H. Jr. Thompson. 2019. Environmental Law and Policy. 5th ed. St. Paul, MN: Foundation Press.