Unfinished Business

The Union of Concerned Scientists (UCS) reviewed 107 unique documents from 2,984 public comments regarding the EPA's 2024 Cumulative Impacts (CI) Framework. The analysis identifies five core themes for a robust CI program: legal authority, program execution, community engagement, assessment methodology, and ensuring outcomes. The report notes that the second Trump administration has undermined these efforts by rescinding environmental justice executive orders, disbanding advisory councils, and eliminating the EPA's Office of Environmental Justice and External Civil Rights.

• The second Trump administration has actively dismantled the infrastructure required to finalize and implement the CI Framework, including the rescission of environmental justice executive orders from 1994 and the disbanding of the National Environmental Justice Advisory Council (NEJAC) and the White House Environmental Justice Advisory Council.
• Public commenters are divided on the legal basis for CI assessments; many argue the EPA already possesses sufficient statutory authority under the Clean Air Act and Toxic Substances Control Act, while others believe new or amended laws are necessary to make CI assessments mandatory for major regulatory actions.
• Effective CI programs require clear 'initiation triggers'—such as proximity to other pollution sources or high aggregate CI indicators—and must be integrated into decisionmaking processes like permitting and zoning to avoid becoming a mere 'check-box exercise'.
• Meaningful community engagement is viewed as an interdependent necessity for CI assessments, requiring a shift from process-based metrics (e.g., number of meetings) to outcomes based on health, equity, and the actual influence of communities over scoping and analysis.
• A robust CI assessment must be multidisciplinary, combining quantitative data with qualitative lived experience and Traditional Ecological Knowledge (TEK) to capture non-chemical stressors like food insecurity, discrimination, and excessive heat.
• Commenters emphasize that CI assessments must account for the temporal dimension of impacts, tracking how disadvantages accumulate over a lifespan and across generations to contribute to social and health inequalities.

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_report_8-3.pdf

Chicago

Ellickson, Kristie, Darya Minovi, Robin Morris 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_report_8-3.pdf.

Wikipedia

{{cite report |last1=Ellickson |first1=Kristie |last2=Minovi |first2=Darya |last3=Collin |first3=Robin Morris |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_report_8-3.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{ellickson2026unfinished, author = {Ellickson, Kristie and Minovi, Darya and Collin, Robin Morris 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_report_8-3.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }