An Evaluation of Efforts to Raise Human Health Assessment in the Environmental Impact Assessment Process

Background: The National Environmental Protection Act (NEPA) mandates federal agencies evaluate the effects of land-use proposals on human health and the environment through the environmental impact assessment (EIA) process. Environmental impacts of proposals, such as air quality, are routinely examined in EIA processes. Environmental health impacts of every federal proposal have the potential for being improved through the NEPA process. As a commenting agency under NEPA, CDC's National Center for Environmental Health (NCEH) can provide comments to other federal agencies on health analysis and mitigation; however engagement has historically been limited. Data regarding the effectiveness of engagement has not been collected.

Methods: A preliminary retrospective evaluation was conducted. Based on comment letters generated in 2002, 2004, 2006, and 2008, a convenience sample of 10 EIAs were identified in which the initial EIA document, the comment letter, and the post-comment document(s) were available. Health references in documents were assessed based on context, frequency, and use of human population-based data to conduct health analysis, and NCEH's commenting activities were evaluated based on the specificity, early engagement and timeliness of comments.

Results: Frequency of health references increased slightly after comments were issued, but the rise did not result in the inclusion of human population-based data. Consideration of health impacts was not a core element of any post-comment documents.

Conclusion: Historical engagement in NEPA processes did not appear to effectively integrate health into impact assessments. Future evaluation will test whether recent changes to target comments and standardizing a tracking process leads to improvements.