Accounting for Health Risk Inequality in Regulatory Impact Analysis: Barriers and Opportunities

Abstract

There has been increasing interest in accounting for inequality in health risks and benefits within regulatory impact analyses, both given more general interest in the distributions of benefits and growing concerns about inequity (defined as those inequalities deemed unjust or unfair) and environmental injustice (in this context, those health risk inequalities that are correlated with race/ethnicity and certain other sociodemographic factors). Although there has been growing literature on this topic, there has been limited progress in practice, and the lack of quantification limits consideration of inequality in the policy process. Controversy remains regarding the best approaches to formally incorporate inequality, when these approaches should be used, and even whether it makes sense to quantify inequality in this context. The objective of this article is to review the literature on approaches for incorporating estimates of, and concerns for, inequality into regulatory impact analyses, especially those where environmental justice considerations are relevant, and consider the interpretation of these approaches and the implications for decision making. Using the case example of the Transportation and Climate Initiative, a collaboration among Northeast and Mid‐Atlantic states to reduce carbon emissions from the transportation sector, multiple strategies are described that could be used to shed light on health risk inequality and inequity, consider them in pending policy decisions, and evaluate their implications for the policy or instrument choice. Given appropriate contextualization and acknowledgment of the multidimensionality of equity, quantitative inequality indicators can provide meaningful insight about both inequality and inequity in health risks.

Equity and modeling in sustainability science: Examples and opportunities throughout the process

“…The use of wealth or income metrics lead to especially common unintended consequences in cost optimization settings, which may structurally prioritize those with more resources in efforts to protect the greatest “value” as proxied by financial metrics (e.g., in flood prevention and recovery assistance) ( 21 ). Similarly, efforts to make models tractable by focusing on areas within the immediate control of a decision maker (e.g., a narrow evaluation of direct impact) can overlook contexts of existing, structural, and interconnected injustices: for example, not considering cumulative burdens when modeling distributive impacts of pollution ( 143 ). Instead of focusing solely on harms, we ask how can models both better represent and be better applied to support, the capabilities, agency ( 127 , 144 ), and desires ( 145 ) of communities?…”

Benefit-Cost Analysis of Air Pollution, Energy, and Climate Regulations

“…48 It is hard to empirically sort out these effects, and differences in marginal valuations are ignored in RIA. 49 One concentration-response (C-R) coefficient is used to represent a specific health effect of a particular pollutantfor example, the effect of PM2.5 on all-cause mortalitywithout differentiation for population characteristics (Levy, 2021). Population-averaged unit values, such as the VSL, are taken to represent marginal values.…”

Odor, air quality, and well-being: understanding the urban smellscape using crowd-sourced science

“…Further, these compounds may not affect health in isolation; instead, people are often co-exposed to multiple compounds in chemical mixtures that can result in enhanced toxicity, which requires more study [30]. Thus, instead of individual chemical measurements, odors could serve as air pollution markers for complex exposures, which have been identified as particularly important for environmental injustice [31,32]. While studies have begun to link odorous compounds to air quality and health and well-being impacts, further work is needed, particularly concerning the role of odor mediation [18,23,29,30,33].…”