UCS Report Lays Out Steps Needed to Turn Cumulative Impacts Assessments into Action

WASHINGTON-A new report from the Union of Concerned Scientists (UCS) analyzes public comments on the U.S. Environmental Protection Agency's (EPA) Interim Framework for Advancing Consideration of Cumulative Impacts. The UCS analysis finds most commenters agree it is necessary to consider the combined effects of multiple environmental and socioeconomic burdens on communities, such as exposure to air pollution, extreme heat and living with material hardship, and identifies key steps needed to ensure cumulative impacts assessments are used to improve conditions in overburdened communities.

The report: "Unfinished Business: A Review of Public Comments on the Environmental Protection Agency's Cumulative Impacts Framework," analyzes public and Tribal community comments submitted to the EPA on the framework and incorporates insights from four convenings of commenters and experts.

The analysis identifies several key recommendations for turning cumulative impacts assessments into meaningful action. Commenters and convening participants urged decision makers to use cumulative impacts assessments to inform decisions and actions that improve conditions in overburdened communities. They emphasized the need for clear legal authority, defined roles and responsibilities, and coordination across federal, state, Tribal and local governments to ensure assessments are incorporated into decision-making. They also called for meaningful community engagement throughout the assessment and decision-making process, including incorporating the experiences of affected communities. Additionally, they recommended tracking cumulative impacts and other metrics over time to evaluate whether programs are achieving their goals and adapting programs when they are not.

The EPA published its Interim Framework for Advancing Consideration of Cumulative Impacts in November 2024 and opened a 90-day public comment period. The agency received 92 unique public comments on the framework including nearly 3,000 similar comments submitted as part of a mass comment campaign. UCS and independent researchers reviewed the comments-after not being assessed and considered by the government-and identified themes in 101 documents directly pertaining to the framework.

Ultimately, the report finds that advancing cumulative impacts policies requires collaborating among people with diverse expertise to implement programs that produce measurable improvements in overburdened communities.