The EPA's Silent Surrender -- Who Bears the Cost?
The EPA’s Silent Surrender—Who Bears the Cost?
A recent Urban Lens post detailed the Trump administration’s systemic assault on science, arguing that it undermines evidence-based policymaking and threatens democratic governance—and, by extension, the long-term sustainability of American cities. This essay examines a specific casualty of that campaign: the likely termination of the Environmental Protection Agency’s (EPA) research into cumulative exposure, the study of how simultaneous or prolonged contact with multiple environmental toxins affects human health. The consequences for public policy and urban resilience would be severe.
The Science at Stake
Cumulative exposure research investigates how pollutants—airborne particles, industrial chemicals, pesticides—interact with climate-related stressors like extreme heat and wildfire smoke to amplify harm, particularly among vulnerable groups: children, the elderly, low-income communities, and residents of urban or industrial zones. It also accounts for industrial practices, urbanization, and socioeconomic conditions that compound health risks over time. Unlike single-substance studies, it reveals synergistic effects, such as how lead exposure exacerbates heat-related illnesses.
For example, in Baltimore’s Curtis Bay—a majority-Black, low-income neighborhood—cumulative exposure research demonstrated how industrial carcinogens, lead paint, and diesel particulate matter combined to elevate cancer risks far beyond EPA thresholds. This evidence forced stricter oversight of a nearby medical-waste incinerator. Without such science, communities like Curtis Bay lose the leverage to challenge polluters, leaving them to endure silent epidemics.
The field is neither speculative nor methodologically weak. It relies on probabilistic risk modeling, biomonitoring, and cohort studies endorsed by the National Academies of Sciences, Engineering, and Medicine. Its findings underpin regulations that prevent costly health crises, from asthma epidemics to neurodevelopmental disorders, in pollution-burdened areas. Dismantling this research would strip protections from millions while serving the interests of polluters and anti-regulatory ideologues.[1]
Why Target This Research?
The motive is political for some, financial for others.
Project 2025, a policy blueprint led by the Heritage Foundation and backed by Trump allies, aims to dismantle the “administrative state,” depicting agencies like the EPA as bureaucratic overreach. Cumulative exposure research is a target because it justifies stricter emissions rules by demonstrating that combined pollutants pose greater risks than individual analyses suggest. Critics dismiss it as a barrier to deregulation and scorn environmental justice as activism.
The beneficiaries of its termination are clear:[2]
Deregulatory advocates (e.g., the Heritage Foundation) would advance their vision of a shrunken federal government.
Polluting industries (petrochemicals, plastics, fossil fuels) would face fewer restrictions if toxins were assessed only in isolation. (In 2024, these sectors spent over $300 million on federal lobbying.)
Real-estate developers would evade costly environmental reviews accounting for compound risks.
Opponents argue the science is “too uncertain” to justify “burdensome” rules—a framing that prioritizes short-term corporate savings over long-term public health. Such claims serve polluters, not scientific rigor or sound policy.
Consequences for Policy and Urban Areas
Cumulative exposure research underpins tools that address what economists call externalities—hidden costs imposed on third parties by market transactions. Throughout industrial history, profitable factories have discharged harmful byproducts, leaving nearby communities to bear the health consequences.
· In Hinkley, California, Pacific Gas and Electric contaminated groundwater with hexavalent chromium, leading to illnesses exposed by Erin Brockovich.
· In Appalachia, coal companies dumped mining waste into streams, contributing to chronic respiratory diseases.
· In Louisiana’s "Cancer Alley", chemical plants have been linked to elevated cancer rates in low-income communities.
In each case, along with many more such cases, companies profited while offloading health burdens onto marginalized neighbors. Without regulation—and without scientific evidence linking pollution to harm—victims rarely wield bargaining power.
Eliminating cumulative exposure research doesn’t erase harm; it deprives victims of the data needed to demand redress.
Threatened Tools
The Trump administration’s proposed 65% cut to the EPA’s Office of Research and Development (ORD) endangers critical tools:
· EJSCREEN: A mapping tool that overlays pollution data with demographic indicators (race, income), guiding civil-rights enforcement.
· NAAQS: National air-quality standards, informed by ORD research, which account for effects on vulnerable groups. Weaker science means laxer limits—especially in cities.
· IRIS: ORD’s chemical-risk database, essential for pollution cleanup and pesticide regulation. Its elimination would cripple the EPA’s ability to quantify cumulative risks.
Without these, cities would lose capacity to address converging threats like air pollution and extreme heat. Local governments would struggle to enforce protections, secure funding, or litigate against polluters.
The erosion of this research also imperils litigation. In 2022, a Louisiana court blocked a Formosa plastics plant permit partly due to EPA data showing synergistic risks to nearby Black communities. Without ORD’s assessments, such victories become improbable. Polluters could revert to pre-1990s arguments that plaintiffs cannot prove causation, leaving victims without recourse.
Broader Implications
This is one of many scientific fields whose abandonment would damage America’s leadership in environmental science—and, more gravely, signal a philosophy that deprioritizes public health.
The financial fallout will disproportionately hit vulnerable households. A 2023 study in Environmental Health Perspectives estimated that cumulative exposure to just five pollutants (lead, PM2.5, etc.) costs the U.S. $5.7 billion annually in pediatric asthma and ADHD cases—expenses borne largely by Medicaid and families. Defunding this research doesn’t eliminate costs; it shifts them from polluters to taxpayers and emergency rooms.
Cumulative exposure science is not just academic; it is a pillar of public health, civil rights, and urban sustainability. Its termination would erase decades of progress, leaving millions unprotected. Cities may attempt to compensate, but they lack the EPA’s resources or authority. If urban centers are the front lines of American life, abandoning this science risks making them the front lines of environmental collapse.
Bill Bowen
[1] https://www.americanprogress.org/article/project-2025-would-make-it-easier-for-big-corporations-to-dump-dangerous-toxins-that-poison-americans/
[2] https://www.earthday.org/the-gaslight-effect-lobbying-in-the-fossil-fuel-industry/