EPA Mandate Fuels Environmental Crisis for America’s Poor

By Keith W. Cooley, CEO, Principia, LLC


“If there is neither excessive wealth nor immoderate poverty in a nation, then justice may be said to prevail.” – Thales

Executive Summary: Once believed to be a powerful tool to slow the pace of climate change, the Environmental Protection Agency’s (EPA) unrelenting focus on alternative fuels made from corn has spawned an environmental crisis… especially for the poor and the disadvantaged. When it comes to community health concerns, production of corn based alternative fuels (principally corn ethanol) and the toxic algae growth it promotes, is a growing environmental crisis that we must confront as soon as possible. Here’s why.

Toxic Algal Bloom Process

History: The EPA promulgated regulation known as the Renewable Fuel Standard (RFS) and signed it into law in 2007 to reduce greenhouse gas emissions and expand the nation’s renewable fuels sector while reducing reliance on imported oil1.

The idea was to produce increasing amounts of alternative fuels to be blended into petroleum gasoline supplies. 11 billion gallons of these fuels would be produced in 2009 and that level would eventually be increased to 36 billion gallons in 2022. A major part of the strategy focused on plant based conventional biofuels… especially ethanol produced from corn. These production levels would increase from 10 billion gallons to 15 billion in the same time frame2.  As an aside, proposed corn ethanol increases have now grown beyond those original numbers to 18+ billion gallons3 with blends of gasoline ranging from 10% to 85% ethanol4.

Planning for these production levels convinced many farmers to grow corn because of government subsidies in place from 1978 through 2011, indirect subsidies in the form of billions of dollars per year in federal crop insurance, and a later federal mandate (a subsidy of sorts) requiring that the 36 billion gallons of renewable fuel scheduled for 2022 be produced mainly from corn5, 6.

That led to two considerably negative unintended consequences:

  • Expansion of corn crops onto land not fit for such use… especially edge tillage or planting right up to the edge of the field which removes protective border lands and increases soil erosion, chemical runoff, etc. 7
  • Discontinued crop rotation (varying crops each cycle on the same ground to avoid soil depletion as well as to control weeds, diseases, and pests) in favor of growing only corn supplemented by increased use of nitrogen and phosphorus rich fertilizers8

Outcomes From Such Behaviors: Both the expansion of croplands and crop rotation discontinuance call for increased fertilizer usage that drives huge amounts of nitrogen or phosphorus rich material to runoff into nearby lakes, rivers, and stream. In many cases sewers, septic systems, and wastewater treatment facilities are overwhelmed by this runoff, allowing toxin producing algae to grow excessively into something called harmful algal blooms (HABs). They enter our drinking water and recreational water systems causing people and animals to get sick and sometimes die9.

Practices like these that cause HABs make agriculture one of the largest sources of nitrogen and phosphorus pollution in the country10.

HABs can11:

  • Produce extremely dangerous toxins that sicken or kill people and animals
  • Create dead zones in the water
  • Raise treatment costs for drinking water
  • Hurt industries that depend on clean water

Drinking, accidentally swallowing or swimming in water affected by HABs can cause serious health problems including12:

  • RashesAlgal Bloom Impacts Body
  • Stomach or liver illness
  • Respiratory problems
  • Neurological affects

HABs that occur in freshwater, like the Great Lakes and other drinking water sources, are dominated by the cyano-bacteria Microcystis. This organism produces a liver toxin that can cause gastrointestinal illness as well as liver damage.

Experts see the threat growing: As a point of reference, all 50 states are impacted by cyanobacteria HABs13… and, as the causes of HABs increase (viz. higher ambient temperatures, water pH levels, and nutrient levels), it stands to reason that the blooms themselves will become more prevalent14.

Anyone can be harmed by contaminated water, but some people—especially children, the elderly, people with weakened immune systems, people in remote or low-income communities with inadequate water systems, and people in communities that are dependent on fish and shellfish—are at higher risk15.

Health Cost Impact: While there are few studies that speak directly to this issue, those that do estimate human health costs to be substantial. The National Oceanographic and Atmospheric Administration (NOAA) conservatively estimates that these HABs have an average annual cost to the U.S. of $82 million based on public health, tourism, and seafood industry impacts16.

However, a 2011 study by the International Water Association estimated the total annual cost of acute health effects from food and water borne marine pathogens/toxins at ~$900 million or more than 10 times the NOAA figure17. The true number is, no doubt, somewhere in between but one wonders if any of these numbers include the cost of issues like pain, suffering, or longer term respiratory distress18.

BalanceEnvironmental Justice Concerns: Of particular interest is the issue of our poorest, our weakest, and our most vulnerable being especially harmed as this crisis grows and spreads. It is this uneven risk of harm that the concept of environmental justice is meant to address… because while Americans of every social/demographic strata are exposed to these hazards, the laws, regulations, and policies that affect how we confront them are too often unevenly applied based on racial, ethnic, age related, and economic circumstance.

Majority citizens, defined as those with the most power in terms of media, business and political representation (typically white and well to do), reap the benefits of the latest scientific, medical and economic solutions; Minority citizens (i.e. all others) are left to manage the burden of environmental neglect and we see its results at every turn.

Flint, Michigan with its lead contaminated water system is our best current example of environmental injustice19 at work but many others abound. Low income communities (urban and rural) and communities of color across the nation are the victims of environmental discrimination because, when compared to their majority counterparts20:

Increasing1) They have higher exposure rates to air pollution

2) They are most often located near landfills, hazardous waste, and other industrial sites

3) Lead poisoning disproportionately affects their children

4) They are disproportionately affected by climate change

5) Most importantly, for this study, victims of environmental discrimination have limited access to clean water and are plagued with water contamination…

o  Studies document limited access to clean water in low‐income communities of color.

o  Water contamination has largely affected children of color who live in rural areas, indigenous communities, and migrant farmworker communities.

o  Contaminated water can cause an abundance of health‐related issues, particularly for young children.

o  Depending on the contaminant, possible health problems can include waterborne diseases, blood disorders, and cancer.

Incidences of HABs are on the rise. Increasing greenhouse gas emissions, rising temperatures due to climate change, and excess nutrients in our groundwater systems essentially guarantee it. And communities of color across the nation, like those around the Chesapeake Bay and the western end of Lake Erie, will be exposed to greater public health threats as that happens. Couple this with President Trump’s stated goal of a 25% slash to EPA funding that combats issues like these and it’s clear we face an uphill fight for our collective health, welfare, and safety21.

More importantly, if the pace of the RFS mandate continues unchecked, it will only add “fuel to the fire” of this environmental catastrophe transforming thousands more citizens across the country into victims of a growing water health crisis. And these demographics, (the poor, disadvantaged, and other underserved communities) by definition, are victims of environmental injustice because they are at higher risk AND typically are affected first… and hardest.

In the context of the argument(s) just presented, what should we be doing to combat the growing problems corn based alternative fuels represent?

Clearly with environmental justice so fragile a concept in America… business, government, public health, and Non Governmental Organizations (NGOs) should focus on preventing injustice as opposed to simply reacting to it. In fact, preventing or at least significantly reducing nutrient runoff from alternative fuel production is the best approach we can take. How might that look?

Suggested Solutions: Sensible RFS reform should include:

1.     A cap on future ethanol blend ratios (limit fuel blends to 10% maximum)

2.     Elimination of the mandate for corn so as to allow for other forms of ethanol to be produced (e.g. cellulosic ethanol made from wood pulp, grasses, straw, etc.)

3.     Significant reduction of subsidies for corn ethanol; provide incentives for cellulosic and/or other advanced biofuel production instead

4.     A prohibition on conversion of land not fit for planting, especially edge tillage, as well as a ban on any future fuels produced in such fashion

5.     An HAB mitigation fund to support environmental cleanup efforts in low-income communities (both urban and rural), communities of color, and other areas of historical environmental neglect.

Advocacy6.     Other progressive alternative fuels legislation written in the spirit of this study. An example would be H.R. 1315 authored by Reps. Bob Goodlatte (R-Va.), Jim Costa (D-Calif.), Steve Womack (R-Ark.), and Peter Welch (D-Vt.)

Whatever the case, it is vital that regulations, standards, education, and proactive diplomacy get out in front of the issues before they worsen. It’s up to each of us, working together, to move this country beyond a growing crisis of environmental injustice. So what can you do?

If you are a concerned citizen, please consider:

·      Educating your family, friends and associates about the impact corn ethanol production has on water pollution and the risks for those impacted by environmental injustice

·      Calling or writing your congressional representatives to express your concern

·      Working with local nonprofits who are pushing for corrective action (e.g. League of Conservation Voters, National Wildlife Federation, and state Environmental Councils

If you are a doctor/public health official, please consider:

·      Educating the public and policy makers about the risks water pollution from corn ethanol production poses to public health and the importance of action on their part

·      Urging those in the field of medical education at all levels to incorporate issues of nutrient runoff and environmental injustice into educational programming/curricula.

·      Stressing the importance of monitoring, prevention, preparedness, and public education on health issues associated with nutrient runoff, especially for those most likely to become victims of environmental injustice

If you are a business leader, please consider:

·      Planning for a smart energy future that intentionally limits the use of products whose processing drives nutrient runoff, water pollution and issues of environmental injustice

·      Sharing your concern with state, federal and local officials and advocating for their support in lowering health and welfare risks, especially for poor and the disadvantaged

If you are a government leader, please consider:

·      Speaking with your constituents, urging them to get educated and take action

·      Partnering with other governmental representatives at the federal, state and municipal levels to sponsor or support bills that reform today’s RFS standards and its impact on environmental injustice

On a broader scale, as a group of community, business, governmental, and public health leaders committed to ending centuries of institutionalized and systemic injustice, let’s work together to:

·      Build policy agendas with constituents of all types at municipal, state and federal levels to ensure that all Americans have access to a clean and healthy environment22.

·      Reimagine how we gain unfettered access to robust wastewater infrastructure that protects in the way environmental justice on a national scale demands.

End Notes:

1.      https://www.epa.gov/renewable-fuel-standard-program
2.      https://www.epa.gov/renewable-fuel-standard-program/program-overview-renewable-fuel-standard-program
3.      https://www.epa.gov/renewable-fuel-standard-program/proposed-renewable-fuel-standards-2017-and-biomass-based-diesel
4.      https://www.epa.gov/renewable-fuel-standard-program/e85-fuel
5.      https://www.manhattan-institute.org/pdf/ib_32.pdf
6.      https://fee.org/articles/ethanol-is-bad-for-cars-the-environment-and-america/
7.      https://www.forbes.com/sites/jamesconca/2014/04/20/its-final-corn-ethanol-is-of-no-use/#3b88e10067d3
8.      https://www.nwf.org/News-and-Magazines/Media-Center/Reports/Archive/2016/12-15-2016-Fueling-Destruction.aspx
9.      https://medsocietiesforclimatehealth.org/reports/medical-alert/
10.   https://www.epa.gov/nutrientpollution/sources-and-solutions
11.   https://www.epa.gov/nutrientpollution/harmful-algal-blooms
12.   https://www.epa.gov/nutrientpollution/effects-human-health
13.   https://www.niehs.nih.gov/health/topics/agents/algal-blooms/index.cfm
14.   http://www.cnbc.com/2016/07/26/why-are-there-so-many-toxic-algae-blooms-this-year.html
15.   https://medsocietiesforclimatehealth.org/reports/medical-alert/
16.   https://coastalscience.noaa.gov/research/habs/
17.   http://publications.jrc.ec.europa.eu/repository/bitstream/JRC101253/lbna27905enn.pdf
18.   https://www.epa.gov/sites/production/files/2015-04/documents/nutrient-economics-report-2015.pdf
19.   http://www.ejolt.org/2013/02/environmental-injustice/
20.   https://www.americanprogress.org/issues/race/news/2016/04/25/136361/5-things-to-know-about-communities-of-color-and-environmental-justice/
21.   http://www.huffingtonpost.com/entry/epa-great-lakes-restoration-initiative_us_58bdbc03e4b0d8c45f457055
22.   https://cbc.house.gov/uploadedfiles/2017.03.22_cbc_we_have_a_lot_to_lose_v5.pdf

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