Unfinished Business

The Union of Concerned Scientists (UCS) conducted a qualitative thematic analysis of 92 public comments submitted to the US EPA regarding its November 2024 Cumulative Impacts Framework. This process involved five coders who identified five primary themes and subthemes, utilizing NVivo software and Gwet’s AC1 scores to ensure inter-rater reliability. To validate these findings, UCS held four virtual 'ground-truthing' convenings between February and May 2026 with 18 experts and community members. The analysis was prompted by the second Trump administration's actions since January 2025, which the report states have undermined the EPA's ability to use the Framework and ignored public comments.

• The US Environmental Protection Agency (EPA) released a framework in November 2024 to integrate cumulative impacts—including social, environmental, health, historical, cultural, and economic stressors—into policymaking, but the second Trump administration has since undermined its application.
• The Union of Concerned Scientists (UCS) analyzed a dataset of 101 documents derived from 92 public comments submitted to the EPA between November 21, 2024, and February 19, 2025, while excluding 2,890 comments identified as a mass comment campaign.
• The thematic analysis process reduced an initial set of 10 themes down to 5, achieving a Gwet’s AC1 score of greater than 0.6 for the majority of themes, indicating fair to good agreement among coders.
• UCS conducted four virtual 'ground-truthing' convenings between February 18 and May 6, 2026, involving 18 participants to verify the qualitative analysis and integrate community and expert expertise.
• The study identifies three primary limitations: the lack of representation from regulated parties in the convenings, the exclusion of 2,890 duplicative comment letters from individual coding, and lower inter-reliability scores for specific subthemes such as rationale and goals.

APA

Ellickson, K., Minovi, D., Collin, R. M., Walts, A., Gross-Davis, C. A., & Kay, S. (2026). Unfinished Business. Union of Concerned Scientists. https://www.ucs.org/sites/default/files/2026-08/Unfinished%20Business_appendix_8-3.pdf

Chicago

Ellickson, Kristie, Darya Minovi, Robin M. Collin, Alan Walts, Carol Ann Gross-Davis, and Samuel Kay. Unfinished Business. Union of Concerned Scientists, 2026. https://www.ucs.org/sites/default/files/2026-08/Unfinished%20Business_appendix_8-3.pdf.

Wikipedia

{{cite report |last1=Ellickson |first1=Kristie |last2=Minovi |first2=Darya |last3=Collin |first3=Robin M. |last4=Walts |first4=Alan |last5=Gross-Davis |first5=Carol Ann |last6=Kay |first6=Samuel |title=Unfinished Business |publisher=Union of Concerned Scientists |date=September 2026 |url=https://www.ucs.org/sites/default/files/2026-08/Unfinished%20Business_appendix_8-3.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{ellickson2026unfinished, author = {Ellickson, Kristie and Minovi, Darya and Collin, Robin M. and Walts, Alan and Gross-Davis, Carol Ann and Kay, Samuel}, title = {{Unfinished Business}}, institution = {Union of Concerned Scientists}, year = {2026}, month = sep, url = {https://www.ucs.org/sites/default/files/2026-08/Unfinished%20Business_appendix_8-3.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }