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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.
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Document type: Report
Technology Explainer: Europe’s heatwaves are testing nuclear plants. What does it mean for nuclear energy in a warming climate?
Recent European heatwaves have forced nuclear plants in France, Romania, and Hungary to reduce output or shut down due to high river temperatures and low water levels, which trigger environmental protections for aquatic ecosystems. While these disruptions are environmental operating constraints rather than safety failures, they highlight the need for climate-resilient design. Adaptation options include transitioning to indirect or dry cooling systems, utilizing deeper seawater for coastal plants, and deploying advanced reactors or small modular reactors that require less water. The document emphasizes that these challenges are shared by other thermal power plants and that future energy planning must incorporate projected climate conditions into siting and design.
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Document type: Guide
Enduring Federal Obligations to Account for Environmental Justice
The document asserts that the second Trump Administration's efforts to eliminate environmental justice (EJ) analyses do not override existing legal obligations. It highlights that agencies may still be required to consider EJ impacts under specific statutory provisions, the National Environmental Policy Act (NEPA), and the Administrative Procedure Act (APA). Furthermore, it argues that race-neutral EJ analyses, such as those focusing on economically disadvantaged communities, remain legally viable under the Equal Protection Clause, contrary to administration claims following the Loper Bright decision.
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Document type: Fact sheet
The Fraud of “Clean” Natural Gas
The report details a 50-year campaign by the natural gas industry to brand its product as "clean energy" and a "bridge fuel." It argues that this was a strategic fraud designed to protect residential markets from electrification and later to facilitate a massive expansion of infrastructure. The document highlights the role of industry-funded research, specifically the Gas Research Institute (GRI), and a flawed 1996 joint study with the EPA that underestimated methane emissions to legitimize gas as a climate solution. It further describes how the industry used voluntary programs like Natural Gas STAR to fend off mandatory regulations and co-opted environmental organizations to lend credibility to its claims.
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Document type: Report
Hidden Hazards
The Institute for Policy Integrity warns that the EPA is implementing unsupported changes to its toxic chemicals risk evaluation framework and specific assessments, such as for formaldehyde, which may lead to flawed decisions and inadequate safety standards.
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Document type: Briefing
Comments on Hazardous and Solid Waste Management System: Disposal of Coal Combustion Residuals from Electric Utilities; Legacy/CCRMU Amendments, 91 Federal Register 18968, Docket ID No. EPA–HQ– OLEM–2020–0107
The document is a formal comment letter opposing the EPA's proposed Legacy/CCRMU Amendments Rule. The signatories argue that the proposal would exempt hundreds of coal ash dumpsites from oversight, weaken monitoring and cleanup requirements, and allow toxic chemicals to exceed federal safe standards, thereby endangering public health and water resources across the United States.
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Document type: Statement
BRIEF OF AMICI CURIAE UNION OF CONCERNED SCIENTISTS, CENTER FOR OPEN SCIENCE, AND ENVIRONMENTAL PROTECTION NETWORK IN SUPPORT OF PETITIONERS AND REVERSAL
The brief contends that removing Civil Service Reform Act (CSRA) protections for federal employees with policymaking or administrative responsibilities would allow the Trump Administration to fire scientists based on political disagreement rather than merit. It argues that independent science is a statutory requirement for agencies like the EPA, CDC, and HHS to faithfully execute laws related to air quality, chemical safety, and vaccinations. The authors provide case studies on the Clean Air Act, ethylene oxide regulation, mRNA vaccine development, and hepatitis B vaccinations to demonstrate how political interference in science endangers public health and safety.
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Document type: Legal commentary
A Policymaker’s Guide to Implementing Leak Detection and Repair for Methane Mitigation
The document outlines a comprehensive framework for LDAR programs, emphasizing that well-implemented programs can reduce methane leaks by nearly 80%. It details the technical application of OGI cameras, a structured nine-step survey process—from planning to data reporting—and a typology of common leak sources such as valves, flanges, and compressor seals. The guide also provides regulatory benchmarks for survey frequency, repair timelines, and reporting templates to ensure accountability and effectiveness in methane mitigation.
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Document type: Guide
EPA’s New Coal Ash Proposal Is a Gift to Polluters
The document criticizes a proposal by the Trump EPA to roll back protections in the coal combustion residuals (CCR) rule, asserting that these changes—which align with requests from industry groups like the Utility Solid Waste Activities Group (USWAG)—will allow power companies to avoid cleanup obligations and increase toxic contamination risks for nearby communities.
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Document type: Statement
COMMENTS OF UTAH PHYSICIANS FOR A HEALTHY ENVIRONMENT, AIR ALLIANCE HOUSTON, CALIFORNIA COMMUNITIES AGAINST TOXICS, COALITION FOR A SAFE ENVIRONMENT, COMMUNITY IN-POWER AND DEVELOPMENT ASSOCIATION, THE COMING CLEAN NETWORK, ENVIRONMENTAL JUSTICE HEALTH ALLIANCE FOR CHEMICAL POLICY REFORM, MOMS CLEAN AIR FORCE, SIERRA CLUB, TEXAS ENVIRONMENTAL JUSTICE ADVOCACY SERVICES, UNION OF CONCERNED SCIENTISTS, AND EARTHJUSTICE
The document argues that the EPA's 2026 proposed rule to weaken the Risk Management Program (RMP) is unlawful, arbitrary, and contrary to the Clean Air Act's mandate to prevent accidental chemical releases. The commenters contend that the proposal prioritizes industry cost savings and deregulatory executive orders over public health and safety, specifically threatening vulnerable populations and children. They call for the full implementation of the 2024 SCCAP Rule, the restoration of the RMP Public Data Tool, and the retention of critical safety requirements including safer technology analyses, third-party audits, and natural hazard planning.
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Document type: Statement
Monitoreo de la generación eléctrica mundial en base a carbón (Mayo 2026)
In 2025, global coal capacity grew by 3.5% while generation fell by 0.6%, reflecting a trend where coal is increasingly used as system 'insurance' rather than a primary energy source. While Latin America achieved a 'No New Coal' status in 2025, several countries in the region, including Brazil and Chile, experienced delays or reversals in planned plant retirements. China and India continue to lead global capacity expansions, accounting for 95% of all coal capacity under construction worldwide.
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Document type: Report
EPA’s Disastrous New Proposal Guts Coal Ash Rules – As Coal Plants Nationwide Pollute Water Supplies
Earthjustice criticizes a proposed EPA rule that would dismantle protections established by the 2015 and 2024 coal ash regulations. The organization asserts that the proposal would allow coal power companies to avoid cleaning up contaminated groundwater, exempt hundreds of legacy dump sites from regulation, and permit the use of toxic ash as structural fill in residential areas. According to the text, industry data shows coal ash is already contaminating water above federal safe drinking water standards at 91 percent of U.S. coal plants.
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Document type: Statement
EPA PROPOSES TO GUT COAL ASH SAFEGUARDS AND CLEANUP REQUIREMENTS
Earthjustice reports that the EPA has proposed a rule to gut the 2015 and 2024 coal ash regulations, which would exempt hundreds of dumps from regulation and allow companies to delay or avoid cleaning up toxic contamination. The briefing details specific proposed rollbacks, such as removing safety standards for waste piles and permitting higher levels of heavy metals in contaminated water. Earthjustice intends to challenge these actions in court and urges members of Congress to oppose the proposal.
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Document type: Briefing
The Costs of Embarking on a Manufacturing Pathway
The document outlines the challenges of industrialisation in Africa, including rising income inequality, fiscal strain from upfront capital investments, and environmental degradation. It emphasizes the need for social safety nets, green infrastructure, and strategic navigation of global trade rules to mitigate these costs, arguing that the cost of inaction—continued poverty and import dependence—is higher than the costs of transition.
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Document type: Research paper
BRIEF OF PLAINFIELD TOWNSHIP, PENNSYLVANIA; TOWN OF THURSTON, NEW YORK; AND TOWN OF CAMERON, NEW YORK AS AMICI CURIAE IN SUPPORT OF APPELLANTS AND REVERSAL
The brief supports the reversal of a district court decision that dismissed claims against the EPA for failing to regulate PFAS in sewage sludge. It asserts that PFAS are highly toxic 'forever chemicals' commonly found in sewage sludge used as fertilizer, which contaminates soil, water, and food chains. The authors argue that local governments in Pennsylvania and New York face significant technical, fiscal, and legal hurdles—including state preemption and 'Right to Farm' laws—that prevent them from protecting residents. Legally, the brief contends that CWA Section 405(d)(2)(C) requires the EPA to not only review but also promulgate regulations for newly identified toxic pollutants at least every two years.
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Document type: Legal commentary
Weak by Design: How Agribusiness Organize in Congress to Trap Environmental Reforms in Brazil and Chile
The research examines the 2012 Brazilian New Forest Code and the 2022 Chilean Water Code reform to demonstrate how economic elites intentionally design weak institutions. By analyzing legislative debates and elite interviews, the author argues that environmental degradation can result from regulations that are designed to be ineffective, even when fully enforced, regardless of whether the legislative environment is ideologically cohesive or fragmented.
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Document type: Research paper
Ser complacientes con las empresas no va a salvar a la biodiversidad
The author argues that the IPBES Assessment on Businesses and Biodiversity relies on the flawed assumption that companies lack awareness of their environmental impacts. The text asserts that biodiversity destruction remains profitable, leading companies to lobby against regulations. It highlights the failure of voluntary corporate actions, noting that less than 1% of reporting companies significantly disclose biodiversity impacts. The author rejects market-based instruments like biodiversity credits and certifications as 'false solutions' and 'greenwashing,' calling instead for binding international norms and strict limits on corporate impacts to prevent ecological collapse.
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Document type: Statement
Make Impact Assessments Great Again (MIAGA)
Carbon Market Watch claims the European Commission is routinely ignoring or bypassing required impact assessments and public consultations for major climate policies. The author asserts that this shift toward 'vibe-based' policymaking, driven by deregulation and industry lobbying, undermines transparency and risks significant economic and environmental damage, citing specific examples such as the 2040 climate target and the EU ETS2 Market Stability Reserve.
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Document type: Statement
Comments on Fish and Wildlife Service Proposal to Rescind the Blanket Rule Option
The Institute for Policy Integrity challenges the Fish and Wildlife Service's (FWS) proposal to remove the "blanket rule," which applies endangered species prohibitions to threatened species by default. The Institute asserts that the FWS's rationale is flawed because the D.C. Circuit Court of Appeals previously found the rule consistent with the statute and because recent Supreme Court decisions do not mandate the withdrawal of regulations upheld by prior judicial decisions.
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Document type: Statement
US & Japanese Groups Call for Transparency on Wood Pellet Imports
US and Japanese advocacy groups are calling on Japan's Ministry of Economy, Trade and Industry (METI) to reform the Feed-In Tariff (FIT) system for wood pellets. They argue that Japanese subsidies have fueled an industry in the US characterized by repeated legal violations and pollution. The groups propose prohibiting subsidies for non-compliant mills, mandating full public disclosure of supply chains, and requiring direct due diligence rather than reliance on certification schemes.
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Document type: Statement