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The document argues that environmental pollution disproportionately affects low-income communities and communities of color due to systemic drivers like racism and colonialism. It recommends that the EPA move beyond 'race-neutral' assessments by using direct indices of social adversity—such as segregation and material hardship—rather than simple proxies. Additionally, it calls for the application of an antiracist lens in government science, the recruitment of staff from overburdened communities, and the removal of barriers to laws that repair past environmental injustices.

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  • The document asserts that the concentration of pollution in low-income communities and communities of color is the result of lawful programs and policies driven by colonialism, racism, and economic disinvestment, rather than chance. Consequently, incorporating measures of racism into cumulative impact assessments is essential to reduce these disproportionate outcomes.
  • Cumulative impact assessments should avoid being 'race-neutral' and should move away from using race and ethnicity as mere proxies for marginalization. Instead, the document recommends using direct indices of social adversity, including factors such as tree canopy cover, voter turnout, material hardship, levels of affordable housing, and the degree of segregation.
  • To address power imbalances and historical biases in government science, regulators are encouraged to apply an antiracist lens and improve DEIA (diversity, equity, inclusion, and accessibility) through inclusive hiring, job training, and staff-retention efforts specifically targeting representation from overburdened communities.
  • While environmental regulators as executive agencies cannot advocate for legislation, they should not obstruct laws or policies intended to repair past harms. The NEJAC specifically recommends that the EPA support state and local government efforts to enact laws and rulemaking regarding cumulative impacts and environmental justice.

Cite the original document

APA
Gehred, N., & Ellickson, K. (2025). NEJAC RECOMMENDATIONS SUMMARY. Union of Concerned Scientists. https://www.ucsusa.org/sites/default/files/2025-02/NEJAC%20CI%20reccs_theme%207.pdf
Chicago
Gehred, Natalie, and Kristie Ellickson. NEJAC RECOMMENDATIONS SUMMARY. Union of Concerned Scientists, 2025. https://www.ucsusa.org/sites/default/files/2025-02/NEJAC%20CI%20reccs_theme%207.pdf.
Wikipedia
{{cite report |last1=Gehred |first1=Natalie |last2=Ellickson |first2=Kristie |title=NEJAC RECOMMENDATIONS SUMMARY |publisher=Union of Concerned Scientists |date=February 2025 |url=https://www.ucsusa.org/sites/default/files/2025-02/NEJAC%20CI%20reccs_theme%207.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@techreport{gehred2025nejac, author = {Gehred, Natalie and Ellickson, Kristie}, title = {{NEJAC RECOMMENDATIONS SUMMARY}}, institution = {Union of Concerned Scientists}, year = {2025}, month = feb, url = {https://www.ucsusa.org/sites/default/files/2025-02/NEJAC%20CI%20reccs_theme%207.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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