One method for evaluating public health impacts is through a Health Impact Assessment, defined by the Centers for Disease Control as a “process that helps evaluate the potential health effects of a plan, project, or policy before it is built or implemented.” Wallace cited the work of George D. Thurston, a Professor of Environmental Medicine at the New York University School of Medicine, who documented adverse health impacts resulting from exposure to pollutants emitted by fossil-fuel electricity generation. Thurston noted decreased lung function, increased childhood asthma and heart attacks, increased ER visits and hospitalizations, and higher death rates in those exposed to air pollution; that it is “quite feasible for a utility to evaluate public health impacts in an IRP;” and that “DTE should be required to assess public health impacts, and their costs, as part of its planning for fossil generating units.” GLELC executive director Nicholas Leonard included unpublished research conducted by University of Michigan researchers in the testimony, including an HIA of DTE’s current coal-fired power plants.
The findings will inform new rules for filing requirements in utilities’ integrated resource plans. In 2016, Michigan began requiring utilities to file IRPs with the MPSC every five years that project demand and the mix of energy resources to meet demand over the next 5, 10, and 15 years. MPSC opened the docket in August of 2020 as part of an effort to better integrate resource planning with planning for distribution and transmission. But it’s also seeking input on methods for incorporating environmental justice and public health considerations into how utilities plan to meet future energy needs.
In December 2019, Administrative Law Judge Sally Wallace issued a 197-page opinion on DTE Energy’s initial IRP, forcing the utility back to the drawing board. Wallace wrote that “public health impacts, to the extent these impacts can be identified, assigned, and the associated costs quantified, should be recognized as part of the retirement analysis in future IRPs” and that “DTE customers living in proximity to the company’s fossil generating plants are certainly paying healthcare costs associated with exposure to air pollutants emitted by these units.” That’s according to testimony submitted on April 28 to the Michigan Public Service Commission by the Great Lakes Environmental Law Center on behalf of 23 individuals and organizations.
Distribution of particulate matter air pollution (PM2.5) in Metro Detroit. Credit: University of Michigan “There are substantial health impacts of current energy production,” said Dr. Amy Schulz, one of the researchers and professor at the University of Michigan School of Public Health. “And we have opportunities as part of the integrated resource planning process to examine those and to modify decisions in ways that reduce harm, that also allows us to look at equity. We have opportunities to reduce the inequitable distribution of health costs.” Distribution of people of color in Metro Detroit. Credit: University of Michigan
The UM researchers’ HIA found that DTE’s coal-fired power plants are disproportionately located in communities of color. The health burden resulting from the air pollution they generate disproportionately falls on low- to moderate-income neighborhoods primarily inhabited by African Americans, Latinx, and Arab Americans. The analysis also showed that high household energy burdens, low residential energy efficiency, and extreme heat exposure are concentrated in the same census tracts that are more exposed to DTE air pollution. “This is the first time the public service commission is engaging in public health and environmental justice issues in the integrated resource planning process,” Leonard said. “These are things that the Michigan Environmental Justice Coalition and GLELC have been thinking about for a long time. And so we want to lay a strong foundation for building those considerations into the process for future consideration.”
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